United States District Court, D. Nevada
DANIEL SMALL, CAROLYN SMALL. WILLIAM CURTIN, DAVID COHEN, LANETTE LAWRENCE, and LOUISE COLLARD, Individually, and on Behalf of All Other Persons Similarly Situated, Plaintiffs,
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.
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
O'MARA LAW FIRM, P.C. David C. O'Mara, Esq. Nevada
Bar No. 8599 William M. O'Mara, Esq. Co-Counsel for
OFFICES OF RAYMOND B. WALTON Raymond B. Walton, Esq., (Pro
Hac) 3381 Violet Lantern Dana Point, California 92629
Co-Counsel for Plaintiffs
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
order to protect the confidentiality of confidential
information obtained by the parties in connection with this
case, the parties hereby agree as follows:
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
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.
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.
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.
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
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 ...