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Garcia v. Service Employees International Union

United States District Court, D. Nevada

March 15, 2018

RAYMOND GARCIA, et al., Plaintiffs


         The Court enters the following protective order to govern the designation and production of confidential information or documents so designated by Plaintiffs and Defendants.

         1. Purposes and Limitations

         Discovery activity in this action is likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation would be warranted. Accordingly, the parties have stipulated to and petitioned the Court to enter the following Protective Order.

         The parties acknowledge that this Protective Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that are entitled under the applicable legal principles to treatment as confidential. The parties further acknowledge, as set forth below, that this Protective Order creates no entitlement to file confidential information under seal. Local Rule IA 10-5 sets forth the procedures that must be followed and reflects the standards that will be applied when a party seeks permission from the Court to file material under seal.

         2. Definitions

         2.1. Party: Any party to this action, including all of its officers, directors, employees, consultants, retained experts, and outside counsel (and their support staff).

         2.2. Disclosure or Discovery Material: All items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

         2.3. "Confidential" Information or Items: Information (regardless of how generated, stored or maintained) or tangible things that qualify for protection under standards developed under Federal Rule of Civil Procedure 26(c).

         2.4. "Highly Confidential - Attorneys' Eyes Only" Information or Items: Extremely sensitive "Confidential Information or Items" whose disclosure to another Party or nonparty would create a substantial risk of serious injury that could not be avoided by less restrictive means.

         2.5. Receiving Party: A Party that receives Disclosure or Discovery Material from a Producing Party.

         2.6. Producing Party: A Party or nonparty that produces Disclosure or Discovery Material in this action.

         2.7. Designating Party: A Party or nonparty that designates information or items that it produces in disclosures or in responses to discovery as "Confidential" or "Highly Confidential -Attorneys' Eyes Only." 2.8. Protected Material: Any Disclosure or Discovery Material that is designated as "Confidential" or as "Highly Confidential - Attorneys' Eyes Only." 2.9. Outside Counsel: Attorneys who are not employees of a Party but who are retained to represent or advise a Party in this action.

         2.10. House Counsel: Attorneys who are employees of a Party.

         2.11. Counsel (without qualifier): Outside Counsel and House Counsel (as well as their support staffs).

         2.12. Expert: A person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action and who is not a past or a current employee of a Party or of a competitor of a Party and who, at the time of retention, is not anticipated to become an employee of a Party or a competitor of a Party. This definition includes a professional jury or trial consultant retained in connection with this litigation.

         2.13. Professional Vendors: Persons or entities that provide litigation support services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations; organizing, storing, retrieving data in any form or medium; etc.) and their employees and subcontractors.

         3. Scope

         The protections conferred by this Protective Order cover not only Protected Material (as defined above), but also any information copied or extracted therefrom, as well as all copies, excerpts, summaries, or compilations thereof, plus testimony, conversations, or presentations by parties or counsel to or in Court or in other settings that might reveal Protected Material. The protections conferred by this Stipulation and Order do not waive the right of Plaintiffs or Defendants to challenge the propriety of any discovery. This Protective Order does not decide the validity of any such challenge.

         4. Duration

         Even after the termination of this litigation, the confidentiality obligations imposed by this Protective Order shall remain in effect until a Designating Party agrees otherwise in writing or a Court order otherwise directs.

         5. Designating Protected Material

         5.1. Exercise of Restraint and Care in Designating ...

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