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Harari v. Core-Mark International, Inc.

United States District Court, D. Nevada

May 31, 2018

AUNI HARARI, an Individual, Plaintiff,
v.
CORE-MARK INTERNATIONAL, INC., a Foreign Corporation, DOES I-X; ROE CORPORATIONS I-X, Defendants.

          Jenny L. Foley, PH.D., Esq., HKM EMPLOYMENT ATTORNEYS LLP JENNY L. FOLEY, PH.D., ESQ.,

          FISHER & PHILLIPS LLP SCOTT M. MAHONEY, ESQ. Nevada Bar No. 1099 ALLISON L. KHEEL, ESQ., JOELW. RICE (PRO HAC VICE) FISHER & PHILLIPS LLP, Attorneys for Defendant

          STIPULATED PROTECTIVE ORDER

         Upon the stipulation of Defendant, Core-Mark International, Inc. (hereinafter “Defendant”), by and through its counsel, Joel W. Rice, Esq. and Allison L. Kheel, Esq., Fisher & Phillips LLP, and Counsel for Plaintiff (hereinafter “Plaintiff”), Jennifer Foley, Esq., of Law Offices of HKM Employment Attorneys LLP (collectively the “Parties”), and pursuant to the Federal Rules of Civil Procedure, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED AS FOLLOWS:

         This Agreed Protective Order and Confidentiality Agreement (“Order”) is necessary to protect proprietary, confidential, competitive, trade secrets, and/or private documents and information (“Confidential Information”) that may be or have been produced and/or otherwise disclosed during the course of discovery and other proceedings in Civil Action No. 2:18-cv-00121-GMN-VCF, styled Auni Harari v. Core-Mark International Inc., filed in the United States District Court, District of Nevada, (the “Action”), whether such information is produced and/or disclosed prospectively or retroactively. Such Confidential Information shall only be used for purposes of this Action and any appeal, and shall not be disclosed, exhibited, delivered, or the existence be made known to any person except in accordance with this Order.

         The Parties may retroactively designate documents or information that has previously been produced and/or disclosed during the course of discovery and other proceedings in this Action as Confidential Information subject to this Order.

         To assure that unfair advantage is not gained by any party (or any non-party) as a result of discovery or other disclosure in this Action; to avoid any potentially harmful disclosure of Confidential Information; and to facilitate discovery and other pre-trial proceedings without unnecessary motions and hearings, the Parties have stipulated that discovery and disclosure of Confidential Information should proceed only upon the terms and conditions set forth herein.

         ACCORDINGLY, IT IS HEREBY ORDERED that:

         1. Applicability.

         This Order shall apply to all information and materials (including, without limitation, documents, deposition testimony and interrogatory answers) produced or disclosed through discovery or any other activity in this Action (i) by any Plaintiff or any Defendant (individually referred to herein as a “Party” and collectively referred to herein as the “Parties”) or (ii) by any person, entity, or witness not a party to this Order (“non-party”), which is designated to be "Confidential Information" under this Order.

         2. Designation of Confidential Information.

         Any Party or non-party may at any time and in the manner described below, designate any document or thing as “Confidential Information, ” including without limitation, answers to interrogatories, deposition testimony, or any other information or materials produced or disclosed by the Party or a non-party during discovery or in any other pretrial proceedings in this Action, thereby giving notice that such materials (i) contain confidential information, and (ii) shall be subject to this Order. All materials so designated, including copies, summaries, or abstracts, or other recognizable artifacts shall be treated as “Confidential Information.” The parties shall have thirty (30) days from the date that this Protective Order is entered by the Court to designate previously-produced materials as “Confidential Information.”

         3. Method of Designation.

         Each page of documents disclosed or produced, along with all answers to interrogatories, responses to requests for admission, or other such discovery materials that are designated as Confidential Information, shall be accompanied by a cover letter or a conspicuously hand-written inscription, in ink, with the following:

         “CONFIDENTIAL”

         or

         “CONFIDENTIAL ...


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