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Small v. University Medical Center of Southern Nevada

United States District Court, D. Nevada

June 22, 2018

DANIEL SMALL, CAROLYN SMALL. WILLIAM CURTIN, DAVID COHEN, LANETTE LAWRENCE, and LOUISE COLLARD, Individually, and on Behalf of All Other Persons Similarly Situated, Plaintiffs,
v.
UNIVERSITY MEDICAL CENTER OF SOUTHERN NEVADA; a political subdivision of Clark County, State of Nevada, CLARK COUNTY, a political subdivision of the State of Nevada, and JOHN ESPINOZA, an individual.

          LEWIS BRISBOIS BISGAARD & SMITH LLP Robert W. Freeman, Esq. Nevada Bar No. 003062 Danielle C. Miller, Esq. Nevada Bar No. 009127 6385 S. Rainbow Boulevard, Suite 600 Attorneys for Defendants University Medical Center of Southern Nevada and John Espinoza

          THE O'MARA LAW FIRM, P.C. David C. O'Mara, Esq. Nevada Bar No. 8599 William M. O'Mara, Esq. Co-Counsel for Plaintiffs

          LAW OFFICES OF RAYMOND B. WALTON Raymond B. Walton, Esq., (Pro Hac) 3381 Violet Lantern Dana Point, California 92629 Co-Counsel for Plaintiffs

          GLANCY PRONGAY & MURRAY LLP Marc L. Godino, Esq. (Pro Hac Admission) Kevin F. Ruf, Esq. (Pro Hac Admission) Kara Wolke, Esq. (Pro Hac Admission) 1925 Century Park East, Suite 2100 Co-Counsel for Plaintiffs TOSTRUD LAW GROUP, P.C. Jon A. Tostrud, Esq. (Pro Hac Admission) Anthony Carter, Esq. (Pro Hac Admission) 1925 Century Parke East, Suite 2125 Los Angeles, CA 90067 Co-Counsel for Plaintiffs

          REMPFER MOTT LUNDY, PLLC Joseph Mott, Esq. 10091 Park Run Drive, Suite 200 Co-Counsel for Plaintiffs

          AMENDED STIPULATED PROTECTIVE ORDER

         In order to protect the confidentiality of confidential information obtained by the parties in connection with this case, the parties hereby agree as follows:

         1. Any party or non-party may designate as “confidential” (by stamping the relevant page or other otherwise set forth herein) any document or response to discovery which that party or non-party considers in good faith to contain information involving trade secrets, confidential business or financial information, or private information, including protected health information (“PHI”) as defined by the Health Insurance Portability and Accountability Act (“HIPAA”), that is subject to protection under the Federal Rules of Civil Procedure and/or other federal and Nevada laws (“Confidential Information”). Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be so designated.

         2. With regard to “PHI” as defined in HIPAA and it regulations (the definitions for which are found in 45 C.F.R. 160.103), the parties agree that such PHI is not relevant to the legal claims being pursued by Plaintiffs and, as such, may be redacted from any production of documents, including electronically stored information (“ESI”) subject to any discovery orders on record in this action.

         3 A party or non-party may designate information disclosed during a deposition or in response to written discovery as “confidential” by so indicating in said response or on the record at the deposition and requesting the preparation of a separate transcript of such material. Additionally a party or non-party may designate in writing, within twenty (20) days after receipt of said responses or of the deposition transcript for which the designation is proposed, that specific pages of the transcript and/or specific responses be treated as “confidential” information. Any other party may object to such proposal, in writing or on the record. Upon such objection, the parties shall follow the procedures described in paragraph 8 below. After any designation made according to the procedure set forth in this paragraph, the designated documents or information shall be treated according to the designation until the matter is resolved according to the procedures described in paragraph 8 below, and counsel for all parties shall be responsible for making all previously unmarked copies of the designated material in their possession or control with the specified designation.

         4. All information produced or exchanged in the course of this case (other than information that is publicly available) shall be used by the party or parties to whom the information is produced solely for the purpose of this case.

         5. Except with the prior written consent of other parties, or upon prior order of this Court obtained upon notice to opposing counsel, Confidential Information shall not be disclosed to any person other than:

a. counsel for the respective parties to this litigation, including in-house counsel and co-counsel retained for this litigation;
b. employees of such counsel;
c. individual defendants, class representatives, any officer or employee of a party, to the extent deemed necessary by Counsel for the ...

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