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Isbell v. Party City Corp.

United States District Court, D. Nevada

April 17, 2018

DEVON ISBELL, an individual, Plaintiff,
v.
PARTY CITY CORPORATION, a foreign corporation; MIKEZAMECNIK, an individual; MIKE FRANCO, an indvidual; DOE BUSINESS ENTITIES 1-10; and DOE INDIVIDUALS 1-50. Defendants

          THE GEDDES LAW FIRM, P.C. WILLIAM J GEDDES ATTORNEY FOR PLAINTIFF DEVON I SHELL

          FOX ROTHSCHILD LLP DAVID F. FAUSTMAN ATTORNEYS FOR DEFENDANTS PARTY CITY AND SCOTT SNICK

          [PROPOSED] STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIALITY OF DOCUMENTS PRODUCED IN LITIGATION

         I. RECITALS

         WHEREAS: the parties to the above-captioned litigation anticipate that discovery will require the parties to disclose records and information that are confidential and sensitive, including because such records are anticipated to include the parties' private employment records and private medical records; and

         WHEREAS: the parties seek to protect and prevent the improper dissemination of such confidential and private records and information to third parties, during the course of litigation and after the litigation has ended;

         II. STIPLUATION

         THEREFORE: the parties, by and through their respective counsel of record, hereby stipulate and request the Court issue an Order ("Stipulated Protective Order"), protecting the confidential nature of certain records and information as may be produced during the course of the above-captioned matters, as follows:

         1. If any person or entity, whether or not a party to the instant action, produces or receives answers to interrogatories, or documents or other things, which the producing or receiving person or entity considers to be "Confidential Information, " as defined in § II(3)(A)(I) infra; or

         2. If there is deposition testimony which any person or entity, whether or not a party to the instant action, believes contains "Confidential Information, " as defined in § II(3)(A)(I) infra; or

         3. Third parties produce information which the third-parties assert is confidential, the fol lowing procedure shall I govern pursuant to Federal Rule of Civil Procedure (" Fed. R. Civ. P.") 26 (c) et. seq.:

         A. Any documents (and the contents thereof), things or information falling within the definition of "Confidential Information, " set forth in § II(3)(A)(I) infra, that are produced may be designated and marked, in whole or in part, without regard to whether redactions are made, "Confidential" by the party producing the documents or information, at the time the documents are delivered to or made available for inspection by any party;

         I. "Confidential Information" is defined herein as: (a) employment records of any employees or former employees of any party; (b) confidential notes, memoranda, and statements regarding non-party employees; (c) confidential information concerning the discipline and/or termination of non-party employees and former employees; (d) the production of information or documents proprietary to any party, including by way of example and not limitation, tax records, financial statements; (e) other private information of any party or non-party to the present litigation, including consumer records, eg., phone bills; (f) financial records and business records of any person or entity, whether a party or non-party to the present litigation; and (g) medical records including medical bills and psychological records and medical information of any person, whether a party or non-party to the present litigation.

         B. If a party produces to another party items that contain Confidential Information as defined above, that party may designate one or more documents, or a portion of a document, as " Confidential" before producing that document to the other party. Such designation shall be made by marking, stamping or typing the word "Confidential" on each page of the document at the time it is produced to the receiving party's counsel;

         C. Any party may designate deposition testimony as "Confidential" by orally making such a designation on the record either at the commencement of the deposition, at the time the testimony is given, and/or before the end of that day's questioning. Following such a designation, the court reporter shall mark "Confidential" on the ...


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