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Lindsey-Espaniola v. Government Employees Insurance Co.

United States District Court, D. Nevada

May 28, 2019

BETSY LINDSEY-ESPANIOLA, individually, Plaintiffs,
v.
GEICO ADVANTAGE INSURANCE COMPANY; DOE INDIVIDUALS 1-20, inclusive; and ROE CORPORATIONS 1-20, inclusive, Defendants.

          ATKIN WINNER & SHERROD THOMAS E. WINNER Nevada Bar No. 5168 Attorneys for GEICO ADVANTAGE INSURANCE COMPANY

          DIMOPOULOS IN.IURY.LAW GARNET E. BEAL Nevada Bar No. 12693 Attorneys for Plaintiff

          STIPULATION AND CONFIDENTIAL ORDER

         IT IS HEREBY STIPULATED by and between all parties: Plaintiff BETSY LINDSEY-ESPANIOLA, by and through her counsel of record, DIMOPOULOS INJURY LAW, and Defendant GEICO ADVANTAGE INSURANCE COMPANY, by and through its counsel of record, ATKIN WINNER & SHERROD, as follows:

1. The parties agree that certain documents and data produced in this litigation contain confidential information. A document containing confidential information shall be designated by marking the document with a watermark indicating "Proprietary or Confidential Information - Subject to Protective Order, No. 2:18-cv-01850-MMD-PAL."
2. Except as otherwise provided in this stipulation or by further order of the court, all documents designated confidential shall be used only for purposes of this litigation and shall be disclosed only to the parties and their attorneys (including secretarial and legal staff); and to any consultant retained by the parties as a potential or actual expert witness in this litigations. All such individuals who are given access to the Confidential Information must first agree to be bound by the terms of this Stipulation and Protective Order by signing the "Acknowledgement of Stipulation and Protective Order," attached as Exhibit A to that Order.
3. For any deposition transcript that contains testimony concerning Confidential Information, or which includes any document containing Confidential Information that is marked as an exhibit, each such deposition shall be designated as "Subject to Protective Order, No. 2:18-cv-01850-MMD-PAL" on the record during said deposition, placed under seal, and shall be subject to the terms of the Stipulated Protective Order.
4. When this litigation is concluded by judgment, settlement, dismissal or otherwise, the provisions of this protective order shall remain in effect and each such confidential document (and all copies thereof) shall be returned within forty-five (45) days of conclusion of the case to counsel for the party that produced the confidential document.
5. All documents so marked confidential may be referred to or incorporated in briefs, affidavits, or other documents filed with the court provided that such documents are either: (1) filed with the Clerk of Court under seal and prominently marked "Proprietary or Confidential Information - Subject to Protective Order Case, No. 2:18-cv-01850-MMD-PAL"; and (2) in a manner pursuant to United Stated District Court Nevada Local Rule lO-S(b).[1]
6. The stipulation/protective order shall remain in effect until further order of the court.

         STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIAL DOCUMENTS UNITED STATE FEDERAL DISTRICT COURT, DISTRICT OF NEVADA CASE NO. 2:18-CV-01850-MMD-PAL

         The parties, Plaintiff BETSY LINDSEY-ESPANIOLA; and Defendant GEICO ADVANTAGE INSURANCE COMPANY; by and through their respective counsel of record, acknowledge that certain documents produced in the subject consolidated action contain confidential information including, but not limited to. trade secrets; confidential research, development or commercial information; financial information; process and training materials; and other sensitive, non-public information (collectively. ■"Confidential Information").

         The Court, being advised of the agreement of the parties to the entry of this Stipulated Protective Order, HEREBY ORDERS AS FOLLOWS:

         1. This Stipulated Protective Order shall apply to all confidential information, properly designated as described in Paragraph 4, which is produced in this litigation.

         2. In connection with discovery proceedings in the Litigation, any party to the Litigation (the "Designating Party") shall have the right to designate as "Confidentiar* any testimony, documents, and other material containing Confidential Information, the disclosure of which in a manner other than that specified herein the Designating Party in good faith believes would present a significant risk of injury to the legitimate business interests of the disclosing party or a significant risk of injury to any other legitimate interest. Such Confidential Information includes, but is not limited to, proprietary trade secrets; all materials reflecting, referring to or evidencing any information deemed confidential by local, state, or federal statute, ordinance, regulation, or other law; confidential non-public business plans or forecasts; confidential non-public financial plans and forecasts; all private or sensitive commercial, financial, personal or personnel information; confidential non-public underwriting and rating information; training manuals, guidelines and other proprietary process documentation; and confidential research and development information. Confidential Information also includes, but is not limited to, personal information such as a person's social security number, medical records, personnel file, bank records, tax records and other sensitive non-public information. Confidential Information may ...


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