Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Premo v. Optimum CX, LLC

United States District Court, D. Nevada

April 18, 2019

MARK PREMO, Plaintiff,
v.
OPTIMUM CX, LLC, an Arizona limited liability company fka FUSION CONTACT CENTERS, LLC; DOES 1 through 10, inclusive, Defendants.

          MOORE LAW GROUP, P.C. John D. Moore, Esq. Attorney for Plaintiff Mark Premo

          LEWIS BRISBOIS BISGAARD & SMITH LLP Bruce C. Young, Esq. Paige S. Shreve, Esq. Attorneys for Defendant Spring Valley Health Care LLC d/b/a Spanish Hills Wellness Suites

          STIPULATED CONFIDENTIALITY AND 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 ("H PAA"), 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 PHI that is not relevant to the legal claims being pursued by Plaintiffs may be redacted from any production of documents, including electronically stored information ("ESI") subject to any discovery orders on record in this action. To the extent that there is a dispute regarding whether any such PHI is relevant to Plaintiffs' claims, the Parties agree to meet and confer regarding the relevance of such PHI. If the Parties are unable to agree regarding the relevance of such PHI, the Parties shall follow the procedures described in Paragraph 9, below.

         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, including deposition testimony or video (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 prosecution or defense of this litigation;
d. consultants or expert witnesses retained for the prosecution or defense of this litigation, provided that each such person shall execute a copy of the Certification annexed to this Order as Exhibit "A" (which shall be retained by counsel to the party so disclosing the Confidential Information and made available for inspection by opposing counsel during the pendency or after the termination of the action only upon good cause shown and upon order of the Court) before being shown or given any Confidential Information;
e. any authors or recipients of the Confidential ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.