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King v. Mutual of Omaha Insurance Co.

United States District Court, D. Nevada

July 12, 2019

STACEY KING, an individual, Plaintiff,
v.
MUTUAL OF OMAHA INSURANCE COMPANY, a foreign business corporation, Defendant.

          Kristina N. Holmstrom State Bar No. 10086 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Attorneys for Mutual of Omaha Insurance Company

          PROTECTIVE ORDER

         IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA

         The Court recognizes that many of the documents and much of the information being sought through discovery in the above-captioned action are, for competitive reasons, normally kept confidential by the parties. The materials to be exchanged throughout the course of the litigation between the parties may contain trade secret or other confidential research, development, or commercial information, as is contemplated by Federal Rule of Civil Procedure 26(c)(1)(G). The parties have agreed to be bound by the terms of this Protective Order (“Order”) in this Action to facilitate the document production and disclosure, and protect the respective interests of the parties in their trade secrets and/or confidential information. This Order shall remain in effect unless modified pursuant to the terms contained in this Order

         IT IS THEREFORE ORDERED THAT:

         The following Definitions shall apply in this Order:

         A. The term “Confidential Information” will mean and include information contained or disclosed in any materials, including documents, portions of documents, answers to interrogatories, responses to requests for admissions, trial testimony, deposition testimony, and transcripts of trial testimony and depositions. Confidential Information may be copies and/or summaries, digests or abstracts derived therefrom, but all such copies, digests, abstracts and summaries shall be considered CONFIDENTIAL and shall be subject to the provisions of this Order.

         B. The term “Counsel” will mean outside counsel of record, and other attorneys, paralegals, secretaries, and other support staff employed in Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

         C. The term “Action” will mean the lawsuit captioned Stacey King v. Mutual of Omaha Insurance Company, No. 2:18-cv-01821-JCM-CWH pending in the United States District Court for the District of Nevada.

         The following provisions shall apply in this litigation:

         1. Each party to this litigation that produces or discloses any materials, answers to interrogatories, responses to requests for admission, trial testimony, deposition testimony, and transcripts of trial testimony and depositions, or information that the producing party believes should be subject to this Protective Order may designate the same as “CONFIDENTIAL.” Any party may designate information as “CONFIDENTIAL” only if, in the good faith belief of such party and its Counsel, that unrestricted disclosure of such information could be harmful to the business or operations of such party. This includes, but is not limited to, trade secret or other confidential research, development, financial, customer related data or other commercial information. Confidential Information shall be so designated by marking the respective pages of the document, and where appropriate, the entire document with the legend “CONFIDENTIAL.” Any such designation shall be precise and specific as to the document or parts of documents designated as “CONFIDENTIAL, ” including identification by Bates Numbers.

         2. Documents made available for inspection in response to a request for production need not be marked “CONFIDENTIAL” prior to inspection. However, the producing party following an inspection can mark those documents designated for copying that contain Confidential Information as “CONFIDENTIAL.” 3. Designation of materials as “CONFIDENTIAL” shall not operate as an admission by any party receiving the materials that the information is or is not: (a) confidential; (b) privileged; (c) relevant; or (d) admissible in evidence at trial.

         4. Other individuals or entities producing documents or information in this lawsuit, including individuals or entities responding to subpoenas, may use the “CONFIDENTIAL” designation under this Order consistent with their legitimate interests to protect information that they deem to be confidential or proprietary.

         5. Whenever a deposition taken on behalf of any party involves the disclosure of Confidential Information of any party:

(a) the deposition or portions of the deposition must be designated as containing Confidential Information subject to the provisions of this Order; such designation must be made on the record whenever possible, but a party may designate portions of depositions as containing Confidential Information after transcription of the proceedings; a party will have until thirty (30) days after receipt of the deposition transcript to inform the other party or parties to the Action of the portions of the transcript to be designated “CONFIDENTIAL.”
(b) the disclosing party will have the right to exclude from attendance at the deposition, during such time as the Confidential Information is to be disclosed, any person other than the deponent, Counsel (including their staff, associates, and all other employees of such counsel who are assisting in the prosecution and/or defense of this suit), the court reporter, and the person(s) agreed upon pursuant to paragraph 8, below; and
(c) The originals of the deposition transcripts and all copies of the deposition must bear the legend “CONFIDENTIAL, ” as appropriate, and the original or any copy ultimately presented to a court for filing must not be filed unless it can be accomplished under seal, identified as being subject ...

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