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Nevada Partners, Inc. v. Workforce Connections

United States District Court, D. Nevada

October 1, 2019

NEVADA PARTNERS, INC., a Nevada corporation, Plaintiff,
v.
WORKFORCE CONNECTIONS, Southern Nevada's Local Workforce Development Board, Defendant

          Phung 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, Inc.

          THEODORE PARKER, III, ESQ., Nevada Bar No. 4716, SHANA D. WEIR, ESQ., Nevada Bar No. 9468, PARKER, NELSON & ASSOCIATES, CHTD., Attorneys for Defendant Workforce Connections.

          JOINT STIPULATED PROTECTIVE ORDER

          Daniel J. Albregts, United States Magistrate Judge.

         I. PURPOSES AND LIMITATIONS

         Disclosure 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. 26(c).

         The 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 Order.

         II. DEFINITIONS

         Confidential Documents: any document or documents containing Protected Information, as defined herein, and designated as a Confidential Document.

         Designating Party: a Party that designates material as Confidential Documents.

         Disclosure 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.

         Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action.

         Party: any party to this action, including all of its officers, directors, employees, and counsel of record (and their support staffs).

         Protected Information: Any proprietary and commercially sensitive information that is not publicly known or publicly available.

         Receiving Party: a Party that receives Confidential Documents.

         III. PROTECTION AGAINST UNAUTHORIZED DISCLOSURE AND USE OF PROTECTED MATERIAL

         No 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.

         Protected 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 maintained.

         IV. LIMITATIONS ON ACCESS

         Except 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 litigation;
(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 ...

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