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YWS Architects, LLC v. Alon Las Vegas Resort, LLC

United States District Court, D. Nevada

January 24, 2018

YWS Architects, LLC, d/b/a YWS Design & Architecture, a Nevada limited liability company, Plaintiff,
v.
ALON LAS VEGAS RESORT, LLC, a Delaware limited liability company, ALON LAS VEGAS LANDCO, LLC, a Delaware limited liability company; TISHMAR, LLC, a Nevada limited liability company; Defendants. AND RELATED COUNTERCLAIMS

          GREENBERG TRAURIG, LLP, MARK G. TRATOS, ESQ., DONALD L. PRUNTY, ESQ., SHAUNA L. NORTON, ESQ. ROBERT D. ROURKE, ESQ Counsel for YWS Architects, LLC and Tom Wucherer

          MEAD LAW GROUP, LEON F. MEAD, II, ESQ, SARAH A. MEAD, ESQ, Counsel for the Alon Parties

          PATRICK G. BYRNE, ESQ., SNELL & WILMER, LLP, Counsel for Alon Las Vegas Resort, LLC, Alon Las Vegas Landco, LLC and Alon Leisure Management, LLC

          JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER REGARDING THE CONFIDENTIALITY OF DISCOVERY DOCUMENTS AND INFORMATION

          THE HONORABLE CAM FERENBACH UNITED STATES MAGISTRATE JUDGE.

         Plaintiff/Counter-Defendant YWS Architects, LLC and Tom Wucherer (collectively, “YWS”) and Defendant/Counter-Claimants Alon Las Vegas Resort, LLC and Alon Leisure Management, LLC (collectively, “Alon”), by and through their respective counsel, and subject to approval of the Court, hereby stipulate to the following proposed stipulated protective order relating to confidential information. YWS and Alon are referred to collectively as the “Parties.”

         1.Purpose.

         The Parties recognize that preparation and trial of this action may require the discovery of certain records and other materials claimed by one or more of the parties to contain confidential business, commercial, financial, or personal information. Specifically, preparation and trial of this action may require the production or disclosure of:

(a) Agreements, drafts, term sheets, contracts, and other documents that contain commercially-sensitive information or other confidential terms, including agreements with third parties;
(b) Financial information about the parties or third parties that is not publicly disclosed, including compensation terms and revenue figures;
(c) Documents constituting or referring to business planning and strategy that, if disclosed, would competitively prejudice one or more of the parties or third parties;
(d) Other private or commercially-sensitive documents that would prejudice the parties' or third parties' legitimate business interests if publicly disclosed; and
(e) Individuals' personal, private information, including telephone numbers, e-mail addresses, home addresses, and other medical and/or financial information.

         The parties desire to litigate this action without jeopardizing their business and commercial interests, any individuals' legitimate privacy interests, or any third party interests in the confidentiality of this information, and so enter this proposed stipulated protective order (“Order”).

         2.Designation of Confidentiality.

         Designation of any materials as “Confidential” or “Highly Confidential -Attorneys Eyes Only” shall be a representation that the designating party's counsel, in good faith, believes that the designated material comprises or contains information falling into one of the categories described above. The protection of this Order may be invoked with respect to any testimony, deposition, court filing, or discovery request (or response thereto), documents, records, or tangible things - and any copies, abstracts, excerpts, or analyses thereof - used, served, or produced by any party in this action which contain information falling into any of the categories described above.

         Documents.

         With respect to documents, the copy of the document when produced shall bear the clear and legible designation “Confidential” or “Highly Confidential - Attorneys Eyes Only, ” as the case may be.

         Interrogatories or Request for Admissions.

         With respect to responses to interrogatories or requests for admission, the specific pages of the responses containing “Confidential” or “Highly Confidential - Attorneys Eyes Only” information shall be so marked.

         Depositions.

         In order to obtain confidential or highly confidential treatment of a deposition, the designating party must designate the specific testimony to be maintained as “Confidential” or “Highly Confidential - Attorneys Eyes Only” within seven (7) business days of receipt of the deposition transcript. All deposition testimony shall be treated as “Highly Confidential - Attorneys Eyes Only” until such time as the designation deadline has passed.

         Documents Produced ...


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