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Marina Gardens-BDS, LLC v. Houston Specialty Insurance Co.

United States District Court, D. Nevada

September 3, 2019

MARINA GARDENS - BDS, LLC., a Nevada Limited Liability Company; MARINA GARDENS - RAF, a Nevada Limited Liability Company, Plaintiffs,
v.
HOUSTON SPECIALTY INSURANCE COMPANY, a Texas Corporation; ENGLE MARTIN & ASSOCIATES, LLC, a Georgia Limited Liability Company; DOES I-XXX; and ABC CORPORATIONS A-Z; inclusive, Defendants.

          LEVERTY & ASSOCIATES LAW CHTD., Patrick R. Leverty, Esq., William R. Ginn, Esq., ATTORNEYS FOR PLAINTIFFS MARINA GARDENS BDS, LLC, AND MARINA GARDENS - RAF

          SHACKELFORD, BOWEN, MCKINLEY & NORTON, LLP, Stephen R. Wedemeyer Matthew A. Foytlin Admitted Pro Hac Vice THORNDAL ARMSTRONG DELK BALKENBUSH & EISINGER Katherine F. Parks, Esq., ATTORNEYS FOR DEFENDANTS HOUSTON SPECIALTY INSURANCE COMPANY AND ENGLE MARTIN &ASSOCIATES, LLC

          STIPULATED PROTECTIVE ORDER

         COMES NOW Defendant, Houston Specialty Insurance Company (“Defendant”), by and through its attorneys of record, Thorndal Armstrong Delk Balkenbush & Eisinger, and hereby responds to Plaintiffs' Request for Production of Documents as follows:

         In order to protect the confidentiality of confidential information obtained by the parties in connection with this case, the parties hereby stipulate and agree as follows:

         1. Any party or non-party may designate as “confidential” (by stamping the relevant page ‘Confidential' or as otherwise as set forth herein) any document, material, item or thing (regardless of medium or manner generated, stored or maintained), produced pursuant to FRCP 26(a), response to written discovery, or testimony adduced at deposition which has not been made public and that the designating party considers in good faith to contain information or financial information and subject to protection under the Federal Rules of Civil Procedure (“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 the response or on the record at the deposition. Additionally, a party or non-party may designate in writing, within twenty (20) days after production of written discovery responses or receipt of the deposition transcript for which the designation is proposed, the specific pages of the transcript and/or specific responses to 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 marking 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 the Court obtained upon notice to opposing counsel, Confidential Information shall not be disclosed to any person other than:

(a) Individual plaintiffs and defendants, class representatives, and any officer or employee of a party, to the extent deemed necessary by Counsel for the prosecution or defense of this litigation;
(b) Counsel for the respective parties to this litigation, including in-house counsel, of counsel and co-counsel retained for this litigation;
(c) Employees of such counsel;
(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 the opposing party, or one of its competitors, the party shall notify the opposing party, or designating non-party, 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 ...

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