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Razaghi v. Razaghi

United States District Court, D. Nevada

May 30, 2019

KORY RAZAGHI, Plaintiff,
v.
AHMAD RAZAGHI; MANUEL MORGAN; MORGAN & RAZAGHI HEALTHCARE, LLC; RAZAGHI HEALTHCARE, LLC; RAZAGHI DEVELOPMENT COMPANY, LLC; and DOES I through X, ROE CORPORATIONS I through X, inclusive, Defendants.

          MARQUIS AURBACH COFFING Phillip S. Aurbach, Esq., Jonathan B. Lee, Esq. Attorney for Plaintiff Kory Razaghi

          BAILEY KENNEDY PAUL C.WILLIAMS ROTHSTEIN DONATELLI LLP RICHARDW. HUGHES DONNA M. CONNOLLY REED C. BIENVENU Attorneys for Defendants Ahmad Razaghi; Razaghi Development Company, LLC, Razaghi Healthcare (AZ), and Razaghi Healthcare (NV)

          STIPULATED PROTECTION ORDER

         Plaintiff Kory Razaghi, through his attorney of record, Marquis Aurbach Coffing; and Defendants, Ahmad Razaghi, Razaghi Healthcare, LLC (NV), Razaghi Healthcare, LLC (AZ), and Razaghi Development Company, LLC, through their attorneys of record, Rothstein Donatelli (Pro Hac Vice) and Bailey Kennedy, hereby enter into this Stipulation for a Protection Order (“Order”) pursuant to the provisions of FRCP 26(c). The Parties have agreed and stipulated to the entry of this Order for the protection of confidential and sensitive documents, records, and information produced or otherwise disclosed by the parties in this action.

         IT IS HEREBY STIPULATED AND AGREED, by and between the Parties, through their respective counsel of record, that the following terms and conditions shall govern the disclosure, production, and use of documents and information in this action:

         I. DEFIN ITIONS

         1. “Material” refers to any document, data compilation, testimony, report, interrogatory response, response to a request for admission, response to a request for production, or other information in any form produced or disclosed in this action (including copies), whether voluntarily or through any means of discovery authorized by law, and whether by a party or non-party.

         2. Material may be designated “Confidential” if the Designating Party in good faith believes that disclosure of such Material in this action without the designation presents a risk of injury to the legitimate business or personal interests of the Designating Party, or any other legitimate interest of the Designating Party. Confidential information includes, but is not limited to, all Material reflecting, referring to, or evidencing any information deemed confidential by any local, state, or federal statute, ordinance, regulation, or other law, confidentiality agreement, business plans or forecasts, financial plans and forecasts, operational plans and forecasts, and all private or sensitive commercial, technical, financial, proprietary, personal, personnel, underwriting, rating, claims and insurance policy information, which is not publicly known and cannot be ascertained from an inspection of publicly-available documents or materials. Confidential information may take the form of, but is not limited to, (a) documents, responses to request for production, interrogatory responses, or responses to requests for admissions; (b) hearing or deposition transcripts and related exhibits; and, (c) all copies, abstracts, excerpts, analyses, reports, and complete or partial summaries prepared from or containing, reflecting, or disclosing such confidential information.

         3. Material may also be designated as “Sensitive-Attorney Eyes Only.” Sensitive-Attorney Eyes Only Material must meet the Confidential designation requirements of Section I(2) and must be so proprietary or competitively sensitive or contain such highly sensitive and non- public business, technical, financial, personal, or other information that its disclosure to persons other than those enumerated in Section IV presents a high risk of serious or irreparable harm to the Designating Party. Additionally, Material may be designated as “Sensitive-Attorney Eyes Only” if such Material meets the Confidential designation requirements of Section I(2) and the Designating Party has a good faith belief that such records also have no relevance to any of the claims or defenses in this action.

         4. “Designating Party” refers to a party or non-party to this action who designates Material as Confidential or Sensitive-Attorney Eyes Only.

         5. “Requesting Party” refers to a party who has made a discovery request.

         6. “Receiving Party” refers to a party who receives, or is otherwise exposed to, Material during the course of this action.

         II. SCOPE OF PROTECTIVE ORDER

         1. Except as the parties may otherwise agree, or the Court may order, any Material produced in this action, which is designated Confidential or Sensitive-Attorney Eyes Only, including any report, excerpt, analysis, summary, or description of it, shall be strictly controlled by this Order, and no disclosure or use of such Material, by any Receiving Party, can be made except in accordance with the requirements of this Order. All Material designated Confidential or Sensitive-Attorney Eyes Only shall be used solely for the prosecution or defense of this action.

         2. This Order shall govern all Material produced in this action, including Material produced prior to entry of this Order.

         3. The protections of this Order shall not apply to Material that, prior to disclosure in this action, was within the actual possession or knowledge of a Receiving Party but was not subject to any confidentiality obligation between the Parties, was previously disclosed by a Designating Party to a non-party to this action without any obligation of confidentiality, or was actually public knowledge, provided that the Material did not become public knowledge through an act or omission of a Receiving Party. Material that was in the hands of the Receiving Party prior to disclosure in this action, however, and was subject to a confidentiality obligation between the Parties, shall be made subject to this Order. Any party who claims that the Material was, prior to disclosure in this action, within its actual possession or knowledge and was not subject to a confidentiality obligation or was public knowledge shall have the burden of proving that fact.

         4. Nothing in this Protective Order shall be construed to prohibit counsel from providing advice, guidance, or counsel to a party, regardless of whether such advice, guidance, or counsel is based, in whole or in part, upon information counsel learned from Material designated Confidential or Sensitive-Attorney Eyes Only, so long as counsel does not disclose Confidential or Sensitive-Attorney Eyes Only Material to anyone not permitted to receive such Material under this Order.

         III. DESIGNA TION OF MATERIA L

         A . GENERAL PROVISIONS

         1. A Designating Party may designate Material as Confidential or Sensitive-Attorney Eyes Only, only if the Material (1) is Confidential, as defined by Section I(2), or Sensitive-Attorney Eyes Only, as defined by Section I(3); and, (2) is not excluded from the scope of this Order by Section II(3). Rescind

         2. With regard to any Material produced or disclosed by Wells Fargo in response to Plaintiff's subpoenas, such Material shall be provided to both Plaintiff and Defendants' counsel with an initial designation of “Sensitive-Attorney Eyes Only” Within fourteen (14) days of the parties' counsels being provided access with said banking records, the designation of “Sensitive-Attorney Eyes Only” is automatically withdrawn unless and until a new designation is provided by Plaintiff or Defendants' counsel.

         3. A Designating Party's failure to designate Material as Confidential or Sensitive-Attorney Eyes Only at the time of production or disclosure of the Material does not waive its right to later designate the Material as Confidential or Sensitive-Attorney Eyes Only, so long as the Designating Party notifies all Parties in writing of the failure within a reasonable time period after learning that the Material was produced without an appropriate confidentiality designation. After any designation, each Receiving Party shall treat the designated Material as either Confidential or Sensitive-Attorney Eyes Only and subject to the protections of this Order.

         B . METHODS OF DESIGNATION

         1. A Designating Party may designate Material as Confidential by placing or affixing on the Material the word “Confidential.”

         2. A Designating Party may designate Material as Sensitive-Attorney Eyes Only by placing or affixing on the Material the words ...


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