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Roknich v. Target Corp.

United States District Court, D. Nevada

May 30, 2019

IRMA ROKNICH, Plaintiff,
v.
TARGET CORPORATION, DOES 1-100, and ROE BUSINESS ENTITIES 101-200, Defendants.

          BERNSTEIN AND POISSON, LLP Jamie H. Corcoran, Esq. Attorneys for Plaintiff

          LINCOLN, GUSTAFSON & CERCOS LLP Loren S. Young Attorneys for Defendant

          STIPULATED PROTECTIVE ORDER

         THE PARTIES TO THIS LAWSUIT: Plaintiff, by and through her attorney of record, JAMIE H. CORCORAN, ESQ. and SCOTT POISSON, ESQ. of the LAW OFFICE OF BERNSTEIN & POISSON, and TARGET CORPORATION, by and through its attorneys of record, LOREN S. YOUNG, ESQ. of LINCOLN, GUSTAFSON & CERCOS, LLP, do hereby stipulate to the entry of the following Protective Order.

         IT IS HEREBY STIPULATED AND AGREED that any and all documents produced or to be produced by any party to this action pursuant to any Subpoena, Interrogatory, Request for Production of Documents, Request for Admission, and/or Deposition Notice served by any other party, or testimony by way of deposition, interrogatory or at trial or hearing concerning the design, manufacture, contracts and/or sales of any products, or the internal operating procedures of the defendants, which are proprietary, confidential, and/or trade secrets, shall be subject to this Order. These documents and testimony are referred to as "Protected Documents" and "Protected Testimony" as hereinafter defined, and are to be maintained in a confidential manner under the procedures as hereinafter set forth:

         1. The term "Protected Document" as used herein shall mean any document (including, but not limited to, any and all excerpts, digests, summaries or indices thereof) produced during discovery and designated at the time of production as a "Protected Document." Designating any such document as a "Protected Document" must be made in good faith and for good cause. A "Protected Document" shall continue to be a "Protected Document" until such time as the producer of such document expressly agrees in writing that the document is no longer considered to be a "Protected Document" or there is a finding by this Court that the document is not the proper subject of protection.

         2. The term "Protected Testimony" as used herein shall mean any testimony given by way of deposition, interrogatory or at trial of this action (including, but not limited to, any and all excerpts, digests, summaries or indices thereof) that is designated at the time the testimony is given and/or designated by the defendant to be "Protected Testimony." Designating any such testimony as "Protected Testimony" must be made in good faith and for good cause. "Protected Testimony" shall continue to be "Protected Testimony" until such time as the testifying party expressly agrees in writing that the testimony is no longer considered to be "Protected Testimony" or there is a finding by this Court that the testimony is not the proper subject of protection.

         3. The documents designated and produced as "Protected Documents" and testimony designated as "Protected Testimony" shall be given confidential treatment as described below.

         4. Without further order of this Court, requesting or receiving parties may disclose the contents of "Protected Documents" and "Protected Testimony" only to the following persons ("Qualified Persons"):

a. Counsel of record in this action for requesting or receiving party;
b. Regular employees of such counsel assigned to and necessary to assist such counsel in the preparation or trial of this action;
c. Experts retained in this matter but only for use in this matter, and subject to all of the terms and conditions of this Order;
d. Parties to this matter but only on a need-to-know basis to the extent necessary for the defense or prosecution of this case, and subject to all of the terms and conditions of this Order and provided that no disclosure shall be made to any person employed by any competitor of the party producing the "Protected Document" or giving "Protected Testimony" except upon further order of this Court;
e. A court reporter or other such staff but only to the extent of transcribing "Protected Testimony" and/or copying "Protected Documents" for placement into sealed container(s) accompanying and/or attached to ...

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