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.

Moncada-Gil v. Honda Motor Company, Ltd.

United States District Court, D. Nevada

January 4, 2018

MARIA ELSA MONCADA-GIL, Plaintiff,
v.
HONDA MOTOR COMPANY, LTD., AMERICAN HONDA MOTOR CO., INC., HONDA R&D CO., LTD., HONDA OF AMERICA MFG., INC., TAKATA CORPORATION, TK HOLDINGS, INC., HIGHLAND INDUSTRIES, INC., CATHEL1NA VELASQUEZ, ROE CORPORATIONS I through X, inclusive; AND DOES I through X, inclusive, Defendants.

          Roger M. Cram Daniel Dastup CRAM VALDEZ BRIGMAN & NELSON Attorneys for Plaintiff.

          Paul G. Cereghini Curtis J. Busby BOWMAN AND BROOKE LLP Attorneys for Defendants American Honda Motor Co., Inc. and Honda of America Mfg., Inc.

          Greg W. Mash LAW OFFICES OF GREG W. MARSH Co-Counsel for Defendants American Honda Motor Co., Inc. and Honda of America Mfg., Inc.

          STIPULATED CONFIDENTIALITY AND PROTECTIVE ORDER

          Peggy A. Leen United States Magistrate Judge.

         Pursuant to the Federal Rules of Civil Procedure, and with the consent of the parties in the above-captioned litigation ("the Litigation"), and good cause appearing, IT IS HEREBY ORDERED that:

         1. "Party" shall mean all named Parties to any action in this Litigation, including any named Party added or joined to this Litigation. This Order governs the handling of documents, depositions, deposition exhibits, interrogatory responses, responses to requests for disclosure, responses to requests for admissions, responses to requests for production of Documents, and all other discovery obtained in this Litigation (hereinafter "Discovery Material") to the extent they contain CONFIDENTIAL or HIGHLY CONFIDENTIAL information as defined in this ORDER. "Producing Party" shall refer to the Party that gives testimony or produces Discovery Material; the "Designating Party" is the Party who designates information under this Order (who can be the Producing Party or another Party or Third Party); and "Receiving Party" shall refer to the Parties that receive the Discovery Material. This Order shall also apply to production of Discoveiy Material from Third Parties, if so elected by the Third Parties as provided in Paragraph 10 and to the extent documents produced by Third Parties include COVERED INFORMATION of any Party hereto.

         CATEGORIES OF PROTECTED MATERIAL

         2. Designation of Material as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL: Any Producing Party may designate its Discovery Material (or its confidential information contained in another party's Discovery Material) as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL" if the Producing Party in good faith believes it contains COVERED INFORMATION as defined below.

         3. "CONFIDENTIAL Material" means any Discovery Material that contains confidential or sensitive non-public information, including business, commercial, technical, marketing, planning, personal, research, or financial information of any Party or Third Party, and which has been designated CONFIDENTIAL for purposes of this Litigation.

         4. "HIGHLY CONFIDENTIAL Material" means any Discovery Material that a Party or Third Party reasonably believes to be economically or competitively sensitive and that warrants the extra layer of protection described below. By way of example, and not limitation, "HIGHLY CONFIDENTIAL Material" includes strategic planning information; negotiation strategies; proprietary software or systems; proprietary edits or customizations to software; pricing information; non-public product design or testing information or extremely sensitive, highly confidential, non-public information, consisting either of trade secrets or proprietary or other highly confidential business, financial, regulatory, or strategic information, the disclosure of which would create a substantial risk of competitive or business injury to the Designating Party.

         5. "CONFIDENTIAL Material" and "HIGHLY CONFIDENTIAL Material" shall not include information that has been intentionally publicly disclosed by the Designating Party, and shall not include documents, data or materials that have been submitted to any government agency intentionally and ultimately without any request for confidential treatment.

         6. "CONFIDENTIAL Material" and "HIGHLY CONFIDENTIAL Material" are collectively defined as "COVERED INFORMATION."

         GENERAL PROVISIONS

         7. A Party or Third Party may designate Discovery Material as COVERED INFORMATION in the following manner:

a. TIFF Documents: In the case of documents or other materials (apart from depositions or other pre-trial testimony), by affixing the appropriate legend to each page of the document.
b. Native Documents: With respect to documents produced in native format, by including the designation in the file name.
c. Depositions: In the case of depositions or other pre-trial testimony, by designating the portion of the transcript on the record during the deposition or by written notice served on counsel of record in this Litigation within thirty days after the receipt of the transcript ("transcript" does not include an ASCII or rough transcript). Before the thirty-day period expires, the testimony shall be treated as HIGHLY CONFIDENTIAL Material.
d. Non-Written Materials. In the case of non-text COVERED INFORMATION (e.g., videotape, audio tape, computer disk), by labeling the outside of the material with the designation.

         8. Production of COVERED INFORMATION Without Designations: The failure to designate Discovery Material as CONFIDENTIAL Material or HIGHLY CONFIDENTIAL Material does not constitute a waiver and may be remedied by prompt written notice upon discovery of the failure.

         9. Counter Designations of COVERED INFORMATION: Any Party may designate, or counter-designate with a higher designation, Discovery Material produced by any Party or Third Party if the materials contain or are derived from that Party's own COVERED INFORMATION. If a Party counter-designates, the Party shall notify the Producing Party in writing of the counter-designation, and the Producing Party will then re-produce the COVERED INFORMATION with the requested confidentiality designation to all Parties who received the original production.

         10. Notice to Non-Parties: Any Party issuing a subpoena to a non-party shall enclose a copy of this Protective Order with a request that, within fourteen (14) days of receipt, the nonparty either agree to the terms of this Protective Order or notify the issuing ...


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.