United States District Court, D. Nevada
MATTHEW L. SHARP, LTD. MATTHEW L. SHARP, ESQ. Attorney for
PRINCE DENNIS M. PRINCE, ESQ. Nevada Bar No. 5092 TRACY A.
EGLET, ESQ. Nevada Bar No. 6419 Attorney for Plaintiff
SILVESTRI JAMES P. C. SILVESTRI, ESQ., WALTER F. FICK, ESQ.
Attorneys for Defendant, Allstate Property and Casualty
STIPULATION AND ORDER FOR PROTECTIVE ORDER REGARDING
DOCUMENTS AND TESTIMONY PERTAINING TO PROPRIETARY
FERENBACH UNITED STATES MAGISTRATE JUDGE
the following, collectively referred to as "the Parties,
• Plaintiff, Brenda Thompson ("Plaintiff), and
• Allstate Insurance Company ("Allstate"), by
and through their respective counsel, enter into this
Stipulation and Protective Order Regarding Confidential
Information as set forth below.
order to protect the confidentiality of Confidential
Information obtained by the parties in connection with this
case, the parties hereby agree as follows:
party or non-party may designate as "confidential"
(by stamping the relevant page or other otherwise set forth
herein) any document or response to discovery which that
party or non-party considers in good faith to contain
information involving trade secrets, or confidential business
or financial information, subject to protection under the
Federal Rules of Civil Procedure or Nevada law
("Confidential Information"). Where a document or
response consists of more than one page, the first page and
each page on which confidential information appears shall be
party or non-party may designate information disclosed during
a deposition or in response to written discovery as
"confidential" by so indicating in said response or
on the record at the deposition and requesting the
preparation of a separate transcript of such material.
Additionally a party or non-party may designate in writing,
within twenty (20) days after receipt of said responses or of
the deposition transcript for which the designation is
proposed, that specific pages of the transcript and/or
specific responses be treated as "confidential"
information. Any other party may object to such proposal, in
writing or on the record. Upon such objection, the parties
shall follow the procedures described in paragraph 8 below.
After any designation made according to the procedure set
forth in this paragraph, the designated documents or
information shall be treated according to the designation
until the matter is resolved according to the procedures
described in paragraph 8 below, and counsel for all parties
shall be responsible for making all previously unmarked
copies of the designated material in their possession or
control with the specified designation.
information produced or exchanged in the course of this case
(other than information that is publicly available) shall be
used by the party or parties to whom the information is
produced solely for the purpose of this case.
Except with the prior written consent of other parties, or
upon prior order of this Court obtained upon notice to
opposing counsel, Confidential Information shall not be
disclosed to any person other than:
(a) counsel for the respective parties to this litigation,
including in-house counsel and co-counsel retained ...