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Patel v. Phc-Elko, Inc.

United States District Court, D. Nevada

March 19, 2018

DEVENDRA PATEL, M.D., an individual, Plaintiff,
v.
PHC-ELKO, INC., a Nevada Corporation d/b/a NORTHEASTERN NEVADA REGIONAL HOSPITAL, Defendants.

          MARQUIS AURBACH COFFING, Liane K. Wakayama, Adele V. Karoum, Attorneys for Plaintiff

          BASS, BERRY & SIMS PLC, Robert W. Horton,

          LEWIS ROCA ROTHGERBER CHRISTIE LLP, David C. McElhinney, Esq., Attorneys for Defendant

          AGREED PROTECTIVE ORDER

         It appearing to the Court, as evidenced by the signatures of counsel for the parties, that the parties have agreed to the following Order Protecting the Confidentiality of Certain Documents, IT IS HEREBY ORDERED:

         1. For the purpose of this Protective Order (the "Order"), "CONFIDENTIAL INFORMATION" shall mean documents and information in whatever form which contain or constitute trade secrets, other confidential, proprietary, or financial information, and/or personnel information related to Defendant's employees, as well as any patient information belonging to Defendant. Additionally, all summaries, notes, extracts, compilations or any other direct or indirect reproduction from or of any protected material shall be entitled to protection under this Order. Documents containing CONFIDENTIAL INFORMATION shall be designated CONFIDENTIAL by the producing party by stamping or writing the legend: "CONFIDENTIAL" or "NOTICE: DO NOT DISCLOSE" or words to this effect, on the face of each such document or page of the document or, alternatively, on the portion of the document containing the CONFIDENTIAL INFORMATION. Any document so designated shall be handled in accordance with this Order.

         2. CONFIDENTIAL INFORMATION, whether in the form of documents or otherwise, shall be used solely for the prosecution and defense of this case and shall be disclosed only to the following:

(a) The Court in this action or the court hearing an appeal from a judgment or order rendered by the Court in this action;
(b) Counsel of record for the parties in this action and associates, secretaries, and paralegals actively engaged in assisting counsel of record;
(c) The parties, but solely for the purpose of assisting counsel;
(d) Outside consultants and expert witnesses employed or retained by the parties or their counsel, who have access to CONFIDENTIAL INFORMATION solely for evaluation, testing, testimony, preparation for trial or other services related to this litigation.

         3. Each party may further have the right to designate as “HIGHLY CONFIDENTIAL/ATTORNEYS' EYES ONLY” and subject to this Order any and all documents, information or other materials which a designating party reasonably believes to contain, reflect, or otherwise disclose (1) trade secrets, (2) highly sensitive medical or patient information, (3) highly sensitive business or financial information, or (4) any other confidential information that the producing party believes to be competitive business information or that relate to competitive decision making to which the other party would not have access but for this litigation (collectively, “Highly Confidential Material”). As to documents produced to the opposing party in the course of this case, this designation shall be made by stamping or otherwise labeling each page or thing containing highly confidential material with the legend “HIGHLY CONFIDENTIAL/AEO” prior to its production or, if inadvertently produced without such legend, by furnishing written notice to the receiving party that the information shall be considered Highly Confidential under this Order.

         4. To the extent that Material is so marked “Highly Confidential/AEO, ” such material shall only be revealed to or used by Qualified Persons as provided for in paragraph 5 hereof and shall not be communicated in any manner, either directly or indirectly, to any person or entity not permitted disclosure pursuant to this Order. Any materials created by the receiving party which include Highly Confidential/AEO Materials, including copies, abstracts, summaries or information derived therefrom, or notes or other records, shall also be deemed Highly Confidential and the same terms regarding confidentiality of these materials shall apply as apply to the originals, and shall hereinafter be referred to as Highly Confidential Material. Such Highly Confidential Material shall be used only for purposes directly related to this proceeding, and for no other purpose whatsoever.

         5. As used herein, the term ...


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