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Porteous v. Capital One Services II, LLC

United States District Court, D. Nevada

April 20, 2018

NATASHA PORTEOUS on behalf of herself and all others similarly situated, Plaintiffs,
v.
CAPITAL ONE SERVICES II, LLC and DOES 1 through 50, inclusive, Defendants.

          Anthony L. Martin Nevada Bar No. 8177 Tullio J. Marchionne Nevada Bar No. 4684 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Attorneys for Defendant Capital One Services II, LLC

          THIERMAN BUCK LLP Joshua D. Buck, Esq. Nevada Bar No. 12187 Leah L. Jones, Esq. Nevada Bar No. 13161 Attorneys for Plaintiff

          STIPULATED [REVISED] PROTECTIVE ORDER GOVERNING THE CONFIDENTIALITY OF INFORMATION AND DOCUMENTS

         Plaintiff Natasha Porteous (“Plaintiff”) has filed an action individually and on behalf of others similarly situated in the above-captioned Court against Capital One Services II, LLC (“Defendant”), alleging violations of the Fair Labor Standards Act (“FLSA”) and Nevada state law. Defendant denies Plaintiff's allegations and that she or others similarly situated are entitled to any relief.

         Plaintiff and any potential Opt-In Plaintiffs (collectively, “Plaintiffs”) are expected to and have requested confidential, non-public information and documents from Defendant, including, but not limited to, personnel files and other employee information. Plaintiffs are also expected to request documents related to Defendant's business operations. Defendant considers this information and these documents to be private and confidential. Defendant is expected to request documents and information regarding the Plaintiffs' compensation and personal finances, employment history, general background, and education, which Plaintiffs may consider to be private and confidential.

         Discovery in this case will require the production of documents, inspection of tangible things, the answering of interrogatories and requests to admit, and the taking of oral and/or written depositions, during which the aforementioned proprietary, trade secret, confidential and/or private information and documents of the parties will be exchanged and disclosed. To expedite the flow of discovery without risk of automatic waiver of confidentiality, to facilitate the prompt resolution of disputes over confidentiality, and to protect adequately material entitled to be kept confidential, the Parties agree to limit the disclosure and use of proprietary, trade secret, confidential and private information and documents as stipulated, pursuant to this Protective Order, on the following terms:

         I. DEFINITIONS

         The following definitions shall apply to this Protective Order:

A. This “Action” shall refer to the above-captioned proceeding in the United States District Court for the District of Nevada and any appeal thereof through final judgment.
B. “Producing Party” shall mean any person or entity producing documents, information or other materials in this Action, including any party to this Action or any third parties.
C. “Party” shall mean the named Plaintiff and any opt-in Plaintiffs and Defendant in this Action, and any other person that may become a named party to this Action.
D. “Confidential” information shall be defined as such documents, deposition testimony or other information disclosed during discovery in this Action which the Producing Party or another Party reasonably and in good faith contends contains information that should be protected from disclosure pursuant to this Protective Order. Any Party may designate any information or documents as Confidential in the reasonable exercise of such Party's sole discretion; provided, however, by agreeing to this Protective Order, no Party waives the right to challenge any other Party's designation of any information or document as Confidential.
E. “Attorneys' Eyes Only” shall mean only to be reviewed by the Parties' counsel of record.
F. “Legend” as used herein shall mean a stamp or similar insignia stating “Confidential” or “Confidential - Attorneys' Eyes Only”.
G. When reference is made in this Protective Order to any document or Party, the singular shall include the plural, and plural shall include the singular.

         II. DESIGNATION OF INFORMATION AND DOCUMENTS

         A. When any document or things produced under this Protective Order are designated Confidential or Confidential - Attorneys' Eyes Only, a Legend shall be affixed to the first page and all pages containing information for which the Producing Party seeks protection. When information produced in answer to an Interrogatory, or response to a Request for Production or Request for Admission is designated as Confidential ...


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