United States District Court, D. Nevada
H. Jefferson (Nev. Bar No. 7761), THE LAW OFFICE OF PHUNG H.
JEFFERSON, ESQ. PC, Edward H. Rippey (admitted pro hac vice),
Matthew V. Miller (admitted pro hac vice), COVINGTON &
BURLING LLP, Wendy L. Feng (admitted pro hac vice), COVINGTON
& BURLING LLP, Attorneys for Plaintiff Nevada Partners,
THEODORE PARKER, III, ESQ., Nevada Bar No. 4716, SHANA D.
WEIR, ESQ., Nevada Bar No. 9468, PARKER, NELSON &
ASSOCIATES, CHTD., Attorneys for Defendant Workforce
JOINT STIPULATED PROTECTIVE ORDER
J. Albregts, United States Magistrate Judge.
PURPOSES AND LIMITATIONS
and discovery activity in this action may involve production
of confidential or proprietary information for which special
protection from use for any purpose other than prosecuting
this litigation is warranted, subject to limited exceptions
listed below. Accordingly, Plaintiff Nevada Partners, Inc.,
and Defendant Workforce Connections hereby stipulate to and
respectfully petition the Court to enter this Joint
Stipulated Protective Order. See Fed. R. Civ. P.
parties acknowledge that this Order does not confer blanket
protections on disclosures or responses to discovery and that
the protection it affords from public disclosure and use
extends only to the limited information or items that are
entitled to protection under the applicable legal principles.
The parties further acknowledge that this Protective Order
does not entitle them to file Confidential Documents under
seal beyond the provisions of the Federal Rules of Civil
Procedure, the Local Rules, and the explicit terms of this
Documents: any document or documents containing
Protected Information, as defined herein, and designated as a
Party: a Party that designates material as Confidential
or Discovery Material: all items or information,
regardless of the medium or manner in which it is generated,
stored, or maintained (including, among other things,
testimony, transcripts, and tangible things), that are
produced or generated in disclosures or responses to
discovery in this matter.
any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.
any party to this action, including all of its officers,
directors, employees, and counsel of record (and their
Information: Any proprietary and commercially sensitive
information that is not publicly known or publicly available.
Party: a Party that receives Confidential Documents.
PROTECTION AGAINST UNAUTHORIZED DISCLOSURE AND USE OF
Party or Non-Party may use Protected Information,
Confidential Documents, or information derived therefrom
produced or disclosed during this litigation for any purpose
other than prosecuting this litigation, subject to the
limited exceptions of this Order.
Information and Confidential Documents must be stored and
maintained by a Receiving Party at a location and in a secure
manner that ensures that compliance with this Order is
LIMITATIONS ON ACCESS
as otherwise provided in this Protective Order, in subsequent
Court Orders, or by written agreement of the Designating
Party, Confidential Documents shall not be disclosed or shown
to anyone, except as follows:
(a) the Court and its staff;
(b) any court reporter who records any deposition or other
testimony in this case;
(c) any Party to this litigation (as defined herein);
(d) any deposition or trial witness;
(e) any vendor engaged by a Party to provide printing,
copying, or similar services for purposes of prosecuting this
(f) any actual or prospective expert or consultant identified
and/or retained by either party to assist it in the
litigation between the parties who has signed the
“Acknowledgment and ...