United States District Court, D. Nevada
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
ROBISON, SHARP, SULLIVAN & BRUST MICHAEL E. SULLIVAN.
ESQ. MICHAEL A. BURKE, ESQ. HANNAH E. WINSTON, ESQ.
Taylor Plaintiff in Pro Se
STIPULATED PROTECTIVE ORDER
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:
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
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.
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.
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:
counsel for the respective parties to this litigation,
including in-house counsel and co- counsel retained for this
employees of such counsel;
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;
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;
authors or recipients of the Confidential Information;
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 ...