Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Bobiles v. Las Vegas Review-Journal, Inc.

United States District Court, D. Nevada

September 4, 2019

RINA K. P. BOBILES, an individual and resident of Nevada, Plaintiff,
v.
LAS VEGAS REVIEW-JOURNAL, INC., a Delaware Corporation, GATEHOUSE MEDIA LLC, a Delaware Corporation, STEPHENS MEDIA, LLC, a Nevada Limited Liability Company, DOES I through X; and ROE BUSINESS ENTITIES I through X, inclusive, Defendants.

          MELANIE A. HILL, ESQ. MELANIE HILL LAW PLLC ATTORNEYS FOR PLAINTIFF RINA K.P. BOBILES

          MONTGOMERY Y. PAEK, ESQ. KELSEY E. STEGALL, ESQ. LITTLER MENDELSON, P.C. ATTORNEYS FOR DEFENDANTS LAS VEGAS REVIEW-JOURNAL, INC., GATEHOUSE MEDIA LLC, AND STEPHENS MEDIA, LLC

          [PROPOSED] STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION AND DOCUMENTS

         I. STIPULATION

         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 or other otherwise set forth herein) any document or response to discovery which that party or nonparty considers in good faith to contain confidential information including medical records, portions of employee personnel files, trade secrets, or confidential business or financial information, subject to protection under the Federal Rules of Civil Procedure or Nevada law (hereinafter "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 marked with the designation "CONFIDENTIAL").

         2. A party or non-party may designate information disclosed during a deposition 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." 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 the designating party shall be responsible for marking all previously unmarked copies of the Confidential Information that they seek to designate as "CONFIDENTIAL" and reserving the Confidential Information with the "CONFIDENTIAL designation.

         3. Except with the prior written consent of other parties, or upon prior order of this Court obtained upon notice to opposing counsel, Confidential Information marked "CONFIDENTIAL" 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) the plaintiff, 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 the Stipulated Protective Order Regarding Confidential Information and Documents 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 parties, 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 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.

         4. Any persons receiving Confidential Information shall not reveal or discuss such Confidential Information to or with any person who is not entitled to receive such ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.