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Farrell v. Neiman Marcus Group, Inc.

United States District Court, D. Nevada

April 16, 2018

SUSAN FARRELL, an Individual, Plaintiff,
v.
NEIMAN MARCUS GROUP, INC., a Foreign Corporation, d/b/a NEIMAN MARCUS, DOE EMPLOYEES I through X, and ROE BUSINESS ENTITIES, inclusive, Defendants.

          MICHAEL C. HETEY, ESQ. Nevada Bar No. 5668 HAROLD J. ROSENTHAL, ESQ. Nevada Bar No. 10208 THORNDAL ARMSTRONG DELK BALKENBUSH & EISINGER Attorneys for Defendant, NEIMAN MARCUS GROUP, INC., d/b/a NEIMAN MARCUS

          LAW OFFICES OF KEVIN R. HANSEN KEVIN R. HANSEN, ESQ. AMY M. WILSON, ESQ. Attorneys for Plaintiff

          THORNDAL ARMSTRONG DELK BALKENBUSH & EISINGER MICHAEL C. HETEY, ESQ. HAROLD J. ROSENTHAL, ESQ.Attorneys for Defendant, NEIMAN MARCUS GROUP, INC., d/b/a NEIMAN MARCUS

          STIPULATED PROTECTIVE ORDER AND CONFIDENTIALITY AGREEMENT

         Plaintiff, SUSAN FARRELL (“Plaintiff”), by her attorneys, Defendant NEIMAN MARCUS GROUP, INC dba NEIMAN MARCUS (“Defendant”) by its attorneys, hereby agree and stipulate to a Protective Order and Confidentiality Agreement governing certain corporate documents to company policies and procedures of NEIMAN MARCUS proprietary information and methods, including but not limited to business method materials of NEIMAN MARCUS, which maybe disclosure during the course of this above captioned Civil Action as follows:

         1. That good cause exists for the parties to enter into a Protective Order and Confidentiality Agreement concerning confidential corporate documents as may be requested by Plaintiff, which may be provided to the Plaintiff through discovery efforts in this matter.

         2. A Protective Order and Confidentiality Agreement is necessary because NEIMAN MARCUS is of the good faith belief that these corporate documents constitute trade secrets and consist of proprietary information, in accordance with FRCP 26(c)(1)(a)-(g).

         3. As such, the parties hereby stipulate that the below measures be implemented in connection with the confidential corporate documents.

         4. Corporate documents, information, or materials which are deemed confidential by NEIMAN MARCUS and are produced in the Action must be designated by marking each page of the document(s) with a label stating “CONFIDENTIAL” and/or “Subject to Stipulated Protective Order and Confidentiality Agreement, Case No. 2:17-cv-2912”. In lieu of marking the original of a document, if the original is not produced, NEIMAN MARCUS may mark the copies that are produced or exchanged.

         5. Documents, information, or materials designated as “CONFIDENTIAL” and/or “Subject to Stipulated Protective Order and Confidentiality Agreement, Case No. 2:17-cv-2912” shall not be furnished, shown, disclosed or divulged to any person except “Qualified Persons”, who are defined as:

a. The Parties;
b. Any Defendant's insurers, if any;
c. Counsel for the Parties including counsel's paralegals and non-professional personnel;
d. Mediators agreed upon by the Parties;
e. Experts retained and/or consulted with by the Parties in connection ...

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