Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Brown v. ResortStay International, LLC

United States District Court, D. Nevada

December 12, 2017

ROSALIND BROWN, Plaintiff,
v.
RESORTSTAY INTERNATIONAL, LLC, a Nevada Limited Liability Company; STARPOINT RESORT GROUP, INC., a Nevada Corporation, Defendant.

          Law Offices of Michael P. Balaban Michael P. Balaban Attorneys for Plaintiff

          Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Anthony L. Martin Nevada Bar No. 8177 Erica J. Chee Nevada Bar No. 12238 Attorneys for Defendants

          STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION

         Plaintiff Rosalind Brown (“Plaintiff”) and Defendants ResortStay International, LLC and Starpoint Resort Group, Inc. (collectively, “Defendants”) (collectively, the “Parties”), by and through their respective counsel of record, hereby request the Court enter the following Stipulated Protective Order Concerning Confidential Information. This Stipulation is brought pursuant to and in compliance with Local Rule 7-1.

         Plaintiff has requested confidential, non-public information and documents from Defendants, including, but not limited to, documents protected by a confidential settlement agreement with an individual that is not a party to this action, non-public business records, personnel files, and other information and documents regarding certain individuals, who are not, and are not expected to be, individual parties to this action. Plaintiff has also requested documents related to Defendants' business operations. Defendants consider this information and those documents to be private and confidential.

         Discovery in this case requires the production of documents, the answering of Interrogatories, and the taking of oral and/or written depositions, during which the aforementioned proprietary, trade secret, confidential and/or private information and documents of the parties will be exchanged and disclosed. To facilitate the prompt resolution of disputes over confidentiality and to adequately protect material entitled to be kept confidential, the Parties agree to limit the disclosure and use of proprietary, confidential, and private information and documents, 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 filed in the United States District Court for the District of Nevada 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 Defendants 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.

         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 ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.