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Bracco v. Findlay Automotive of Nevada, LLC

United States District Court, D. Nevada

November 21, 2017

MARIA BRACCO, an individual, Plaintiff,
v.
FINDLAY AUTOMOTIVE OF NEVADA, LLC dba FINDLAY TOYOTA, a Nevada corporation; and DOES 1-50, inclusive, Defendants.

          Anthony L. Martin Nevada Bar No. 8177, Amy L. Howard Nevada Bar No. 13946 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Attorneys for Defendant Findlay Automotive of Nevada, LLC dba Findlay Toyota.

          WATKINS & LETOFSKY, LLP Daniel R. Watkins Theresa M. Santos Attorneys for Plaintiff Maria Bracco.

          STIPULATED PROTECTIVE ORDER GOVERNING THE CONFIDENTIALITY OF INFORMATION AND DOCUMENTS

         Defendant Findlay Automotive of Nevada, LLC dba Findlay Toyota (“Defendant”) and Plaintiff Maria Bracco (“Plaintiff”) (collectively referred to as “Parties”), by and through their respective counsel of record, hereby request the Court enter the following Stipulated Protective Order Governing the Confidentiality of Information and Documents. This Stipulation is brought pursuant to and in compliance with Local Rule 7-1.

         Plaintiff is expected to request confidential, non-public information and documents from Defendant, including but not limited to, sales reports, information that may contain customer information, including customer names, addresses, and financial information, non-public business records, personnel files, and other information and documents regarding certain individuals, including employees who are not, and are not expected to be, parties to this matter. Plaintiff may also request documents related to Defendant's business operations. Defendant considers this information and these documents to be private and confidential. In addition, Defendant may request confidential, non-public information and documents from Plaintiff, including financial records, and other information and documents regarding certain individuals, who are not, and are not expected to be, individual parties to this action.

         Discovery in this case will require the production of documents, inspection of tangible things, the answering of Interrogatories and Requests to Admit, and the taking of oral and/or written depositions, during which the aforementioned proprietary, trade secret, financial, medical, confidential and/or private information and documents of the Parties will be exchanged and disclosed. To expedite the flow of discovery, facilitate the prompt resolution of disputes over confidentiality, and to protect adequately material entitled to be kept confidential, the Parties agree to limit the disclosure and use of proprietary, confidential, and private information and documents as stipulated, pursuant to this Stipulated Protective Order on the following terms:

         I. DEFINITIONS

         The following definitions shall apply to this Stipulated Protective Order:

A. The “Action” shall refer to in the instant litigation originally filed in the United States District Court for the District of Columbia, and transferred to the United States District Court for the District of Nevada, No. 2:17-cv-01222-APG-VCF, and any appeal thereof through final determination.
B. “Producing Party” shall mean any person or entity producing documents, information or other materials in the Action, including any Party to the Action or any third parties.
C. “Party” shall mean the Plaintiff and Defendant in this Action, and any other person that may become a named Party to the Action.
D. “Confidential” information shall be defined as such documents, deposition testimony or other information disclosed during discovery in the Action which the Producing Party or another Party reasonably and in good faith contends contains information that should be protected from disclosure pursuant to this Stipulated Protective Order. Any Party may designate any information or documents as Confidential in the reasonable exercise of such Party's sole discretion; provided, however, by agreeing to this Stipulated Protective Order, no Party waives the right to challenge any other Party's designation of any information or document as Confidential.
E. “Legend” as used herein shall mean a stamp or similar insignia stating Confidential.
F. When reference is made in this Stipulated Protective Order to any document or Party, the singular shall include the plural, and plural shall include the singular.
G. “Attorneys' Eyes Only” shall mean only to be reviewed by counsel of record.

         II. DESIGNATION OF INFORMATION AND DOCUMENTS

         A. When any document or things produced under this Stipulated Protective Order are designated Confidential, a Legend shall be affixed to the first page and all pages containing information for which the Producing Party seeks protection. When information produced in answer to an Interrogatory, or response to a Request for Production or Request for Admission is designated as Confidential, the response or answer shall be preceded with the appropriate designation.

         B. Some documents being produced by both Plaintiff and Defendants may contain social security numbers. Without need of any designation, social security numbers will be deemed to be Confidential. In the event a document is produced without the redaction of a social security number, any Party seeking to use the document will make every effort to ...


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