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Jaragoski v. Ford Motor Co.

United States District Court, D. Nevada

February 5, 2018

RONALD R. JARAGOSKI, a single man, Plaintiff,
v.
FORD MOTOR COMPANY, a Delaware corporation; and JOHN DOE ENTITIES I-X, inclusive, Defendants.

          Joshua D. Cools SNELL & WILMER L.L.P. Attorneys for Defendant FORD MOTOR COMPANY.

          STIPULATED PROTECTIVE ORDER

         In order to preserve and maintain the confidentiality of certain confidential, commercial and/or proprietary documents and information produced or to be produced by FORD MOTOR COMPANY (“Ford”) or by any party in this action, it is ordered that:

         1. Documents or information to be produced or provided by Ford or any party in this litigation that contain confidential, commercially sensitive, private personal information and/or proprietary information may be designated as confidential by marking or placing the applicable notice “Subject to Non-Sharing Protective Order, ” “Subject to Protective Order, ” or “Confidential, ” or substantially similar language on media containing the documents, on the document itself, or on a copy of the document, in such a way that it does not obscure the text or other content of the document. The burden is on the producing party to establish that the information or document is entitled to such protection.

         2. As used in this Order, the terms “documents” or “information” mean all written material, electronic data, videotapes and all other tangible items, produced in whatever format (e.g., hard copy, electronic, digital, etc.) and on whatever media (e.g., hard copy, videotape, computer diskette, CD-ROM, DVD, by secure electronic transmission, hard drive or otherwise).

         3. Documents or information designated as “Subject to Non-Sharing Protective Order, ” “Subject to Protective Order, ” or “Confidential” or substantially similar language in accordance with the provisions of this Order (“Protected Documents” or “Protected Information”) shall only be used, shown or disclosed as provided in this Order. However, nothing in this Order shall limit a party's use or disclosure of his or her own information designated as a Protected Document or Protected Information.

         4. If a receiving party disagrees with the “Protected” designation of any document or information, the party will notify the producing party in a written letter and identify the challenged document(s) with specificity, including Bates-number(s) where available, and the specific grounds for the objection to the designation. After attempting to resolve the issue dispute in good faith pursuant to Local Rule 26-7, if the parties are unable to resolve the issue of confidentiality regarding the challenged document(s), Ford will thereafter timely apply to the Court to set a hearing for the purpose of establishing that the challenged document(s) or information is/are confidential. Protected Documents will continue to be treated as such pending determination by the Court as to the confidential status.

         5. Protected Documents and any copies thereof shall be maintained confidential by the persons authorized to receive the documents pursuant to paragraph 6 and shall be used only for prosecuting, defending, or attempting to settle this litigation, subject to the limitations set forth herein.

         6. Protected Documents shall be disclosed only to “Qualified Persons.” Qualified Persons are limited to:

a. Counsel of Record for the parties, and the parties;
b. Paralegals and staff employed by Counsel of Record and involved in the preparation and trial of this action;
c. A vendor hired by a party to host data and maintain a database of electronic data or perform other work related to the collection, review or production of documents in the case;
d. Experts and non-attorney consultants retained by the parties for the preparation and/or trial of this case, provided that no disclosure shall be made to any expert or consultant who is employed by a competitor of Ford;
e. The Court, the Court's staff, witnesses, and the jury in this case; and
f. With respect to documents designated as “Sharing” or “Subject to Protective Order, ” attorneys representing Plaintiff(s) and the experts and non-attorney consultants retained by such attorneys, in other cases pending against Ford involving a 1999-2001 model year Ford Explorer/Mercury Mountaineer with claims of airbag system non-deployment, provided no ...

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