United States District Court, D. Nevada
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
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.
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.
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:
following definitions shall apply to this Stipulated
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
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
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
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.
DESIGNATION OF INFORMATION AND DOCUMENTS
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.
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 ...