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Nester v. Recreational Equipment, Inc.

United States District Court, D. Nevada

August 1, 2018

LEANNE NESTOR, an individual, Plaintiff,
v.
RECREATIONAL EQUIPMENT, INC., a Washington corporation Defendant.

          GARG GOLDEN LAW FIRM, ANTHONY GOLDEN ANTHONY B. GOLDEN, ESQ. PUNEET K. GARG, ESQ. GARG GOLDEN LAW FIRM, ATTORNEYS FOR PLAINTIFF LEANNE NESTOR

          ALVERSON, TAYLOR, MORTENSEN & SANDERS, SHIRLEY BLAZICH, ESQ. NEVADA BAR NO. 08378 MICHAEL McLOUGHLIN, ESQ. NEVADA BAR NO. 12820 ATTORNEYS FOR DEFENDANT RECREATIONAL EQUIPMENT, INC

          STIPULATED PROTECTIVE ORDER AND CONFIDENTIALITY AGREEMENT

         WHEREAS, Plaintiff, Leanne Nestor, by and through its attorneys of record, Anthony B. Golden, Esq. and Puneet K. Garg, Esq. with the law firm of GARG GOLDEN LAW FIRM and Defendant, Recreational Equipment, Inc., by and through its attorneys of record, Shirley Blazich, Esq. and Michael T. McLoughlin, Esq. with the law firm of Alverson, Taylor, Mortensen & Sanders (collectively referred to as the “Parties”) each seek production of records and documents (“documents”) pertaining to the other Parties or to other persons who are not parties to this litigation, or which are considered personal, confidential and/or proprietary;

         WHEREAS, one or more of the Parties may contend that certain documents to be produced may contain privileged, confidential, proprietary, or other sensitive information, the public disclosure of which could cause irreparable harm;

         WHEREAS, the protection of the documents that are produced and which contain privileged, confidential, proprietary, or sensitive information is in the public interest;

         THEREFORE, IT IS HEREBY STIPULATED AND AGREED between the Parties, by and through their respective attorneys of record, as follows:

         1. All Classified Information produced or exchanged during the course of this litigation shall be used solely for the purpose of preparation for and the trial of this litigation proceeding and for no other purpose whatsoever, and shall not be disclosed to any person except in accordance with the terms hereof.

         2. “Classified Information, ” as used herein, means any information of any type, kind or character which is designated a “Confidential” or “For Counsel Only” (or “Attorneys' Eyes Only”) by any of the supplying or receiving parties, whether it be a document, information contained in a document, information revealed during a deposition, information revealed in an interrogatory answer, or otherwise. If designated as “Confidential” or “For Counsel Only” (or “Attorneys' Eyes Only”), a party will make such designation only as to that information that it in good faith believes contains confidential information. Information or material that is already available to the public shall not be classified.

         3. “Qualified Persons, ” as used herein, means:

(a) Attorneys of record for the parties in this litigation and employees of such attorneys to whom it is necessary that the material be shown for purposes of this litigation;
(b) Actual or potential independent experts or consultants, who have signed a document in the form of Exhibit “A”, attached hereto and incorporated by reference;
(c) One “in-house” corporate officer or employee of a corporate party who shall be designated in writing by the corporate party prior to any disclosure of “Confidential” information to such person and who shall sign a document in the form of Exhibit A, attached hereto (such signed document to be filed with the Clerk of this Court by the party designated such person);
(d) If this Court so elects, any other person may be designated as a Qualified Person by order of this Court, after notice and hearing to all parties.

         4. Documents produced in this action may be designated by any party or parties as “Confidential” or “For Counsel Only” (or “Attorneys' Eyes Only”) information by marking each page of the document(s) so designated with a stamp stating ...


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