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Taylor v. Costco Wholesale Corp.

United States District Court, D. Nevada

June 4, 2019

LULA TAYLOR, individually, Plaintiff,
COSTCO WHOLESALE CORPORATION, a Washington Corporation; and 1-10 does, inclusive, Defendants.

          Michael E. Sullivan, Esq. #5142 Michael A. Burke, Esq. #11527 Hannah E. Winston, Esq. #14520 ROBISON, SHARP, SULLIVAN & BRUST Attorneys for Defendant COSTCO WHOLESALE CORPORATION


          Lulu Taylor Plaintiff in Pro Se


         In order to protect the confidentiality of confidential information obtained by the parties in connection with this case, PLAINTIFF LULA TAYLOR and DEFENDANT COSTCO WHOLE SALE CORPORATION by and through their attorneys of record Michael E. Sullivan, Esq., Michael A. Burke, Esq., and Hannah E. Winston, Esq. of Robison, Sharp, Sullivan & Brust, 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, or confidential business or financial information, subject to protection under the Federal Rules of Civil Procedure or Nevada law ("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. 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.

         3. All information produced or exchanged in the course of this case (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.

         4. 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 and provided that if the party chooses a consultant or expert employed by COSTCO WHOLESALE CORPORATION or one of its competitors, the party shall notify the opposing party, or designating nonparty, before disclosing any Confidential Information to that individual and shall give the opposing party an opportunity to move for' a protective order preventing or limiting such disclosure;

         (e) any authors or recipients of the Confidential Information;

         (f) the Court, Court personnel, and court reporters; and (g) witnesses (other than persons described in paragraph 4(e)). A witness shall sign the Certification before being shown a confidential document. Confidential Information may be disclosed to a witness who will not sign the Certification only in a deposition at which the party who designated the Confidential Information is represented or has been given notice that Confidential Information shall be designated "Confidential" pursuant to paragraph 2 above. Witnesses shown Confidential Information shall not be allowed to retain copies. 5. Any persons receiving ...

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