United States District Court, D. Nevada
HATFIELD & ASSOCIATES, LTD. Trevor J. Hatfield, Esq.
Attorney for Plaintiff.
DRIGGS, WALCH F. Thomas Edwards, Esq. Attorneys for Defendant
L.L.O. Inc. d/b/a/ Acme Electric.
URBAN LAW FIRM Nathan R. Ring, Esq. S. Decatur Blvd.
Attorneys for Defendant Local 357.
STIPULATED CONFIDENTIALITY AND PROTECTIVE
to the Stipulation contained herein by and among counsel for
Plaintiff MALINDA SLATON, (“Plaintiff”) and
counsel for Defendant L.L.O. INC., d/b/a ACME ELECTRIC, a
domestic corporation and Defendant INTERNATIONAL BROTHERHOOD
OF ELECTRICAL WORKERS LOCAL UNION 357,
(“Defendants”), the Court hereby finds as
and discovery activity in this action are likely to involve
production of confidential, proprietary, or private
information for which special protection from public
disclosure and from use for any purpose other than
prosecuting and defending this litigation may be warranted.
Accordingly, the parties hereby stipulate to and petition the
court to enter the following Stipulated Protective Order. The
Parties acknowledge that this Order does not confer blanket
protections on all disclosures or responses to discovery, or
any categories of information not specifically addressed
herein, and that the protection it affords from public
disclosure and use extends only to the limited information or
items that are entitled to confidential treatment under the
applicable legal principles, and designated
“confidential” as described herein. The parties
further acknowledge, as set forth further below, that this
Stipulated Protective Order does not entitle them to file
confidential information under seal or otherwise change
Federal or Local rules, procedures, and standards to be
applied when a party seeks permission from the court to file
material under seal.
“Litigation” shall mean the above-captioned case,
pending in the United States District Court, District of
Nevada Case No. 2:17-cv-01561.
“Documents” or “Information” shall
mean and include any documents or portions thereof, or
information extracted therefrom, (whether in hard copy or
electronic form), records, correspondence, analyses,
assessments, statements (financial or otherwise), responses
to discovery, tangible articles or things, whether
documentary or oral, and other information provided, served,
disclosed, filed, or produced, whether voluntarily or through
discovery or other means, in connection with this Litigation.
A draft or non-identical copy is a separate document within
the meaning of these terms.
“Party” (or “Parties”) shall mean one
party (or all parties) in this Litigation and their in-house
and outside counsel. “Non-Party” shall mean any
entity or individual that is not a party to this Litigation.
“Producing Party” shall mean any person or entity
who provides, serves, discloses, files, or produces any
Documents or Information. “Receiving Party” shall
mean any person or entity who receives any such Documents or
Party may designate any document, object, file, photograph,
video, tangible thing, interrogatory answers, answers to
requests for admissions, testimony, or other material or
copies thereof (collectively, the “Discovery
Material”) as “Confidential Information”
following a good faith determination that the information so
designated is or may reveal confidential or proprietary
OF RESTRAINT AND CARE IN DESIGNATING MATERIAL FOR
Party or Non-Party that designates information or items for
protection under this Order must take care to limit any such
designation to specific material that qualifies under the
appropriate standards. Indiscriminate or routinized
designations are prohibited.
AND TIMING OF DESIGNATIONS
CONFIDENTIAL Documents shall be so designated prior to or
simultaneous with their production by labeling each page of
the CONFIDENTIAL document with the legend
“CONFIDENTIAL.” If only a portion or portions of
the material on a page qualifies for protection, the
Producing Party also must clearly identify the protected
Testimony taken at a deposition, or in other pretrial or
trial proceedings, may be designated as CONFIDENTIAL by any
Party making a statement to that effect on the record at the
deposition. Arrangements shall be made with the court
reporter taking and transcribing such deposition to
separately bind such portions of the transcript and
deposition exhibits containing Information designated as
CONFIDENTIAL, and to label such portions appropriately.
Counsel for the Parties may also designate an entire
deposition transcript as CONFIDENTIAL at the time of the
deposition. A party's failure to designate testimony
confidential at the time of deposition shall not constitute
the party's waiver of its right to correct its failure
within ten ...