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Clark v. Easter Seals Nevada

United States District Court, D. Nevada

October 4, 2019

MARISA CLARK, an individual, Plaintiff,
v.
EASTER SEALS NEVADA, a domestic corporation; CHRISTINE ZACK, an individual; BRIAN PATCHETT, an individual; Defendants.

          Sheri M. Thome, Esq. Chris Richardson, Esq. WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP Attorneys for Defendants Easter Seals Nevada, Christine Zack and Brian Patchett

          MULLINS & TRENCHAK, ATTORNEYS AT LAW Philip J. Trenchak, Esq. Victoria C. Mullins, Esq. Attorneys for Plaintiff Marisa Clark

          STIPULATED PROTECTIVE ORDER

         In order to protect the confidentiality of certain information obtained by the parties in connection with this case, Plaintiff Marisa Clark and Defendants Easter Seals Nevada (“Easter Seals”), Christine Zack (“Zack”) and Brian Patchett (“Patchett”), hereby agree as follows, subject to the approval of the Court:

         1. DEFINITIONS

         The terms defined in this paragraph shall have the meanings provided. Defined terms may be used in the singular or plural.

         1.1 “Litigation” specifically refers to the above-captioned case.

         1.2 “Producing Party” means the party, or the person or entity other than a party, that produces documents or information considered by that party, person, or entity to be Confidential Information, and includes a party asserting a confidentiality interest in information produced by others.

         1.3 “Receiving Party” means that party/person/entity receiving or requesting production of Confidential Information.

         1.4 “Confidential Information” means information, whether or not embodied in any physical medium, including all originals and copies of any document and/or information, used by the Producing Party in or pertaining to its business, information pertaining to third-party privacy interests, or information protected by the attorney-client privilege, the attorney work-product doctrine, the litigation privilege, the mediation privilege, or otherwise deemed confidential settlement discussions, which information the Producing Party reasonably and in good faith believes contains or concerns confidential, non-public, privileged, proprietary, and/or sensitive information, including, but not limited to, financial data, intellectual property, information involving privacy interests, information protected by privilege, and commercially and/or competitively sensitive information of a nonpublic nature, or received on a confidential basis.

         1.5 “Litigation Documents” means all pleadings, motions, affidavits, and related papers, all documents produced or exchanged in the course of this Litigation or any settlement negotiations, all written discovery responses, and all transcripts and testimony given in depositions, in hearings, or at trial.

         1.6 “Termination” means the dismissal of this Litigation, or entry of final judgment, or expiration of all periods to appeal or seek judicial review of this action.

         2. DESIGNATION OF CONFIDENTIAL INFORMATION

         2.1 Documents.

         A Producing Party may, in good faith, designate Confidential Information contained in a document or thing specifically by either marking the document or thing as “CONFIDENTIAL” or by designation, in writing, identifying the Bates stamp number which has been assigned to the document or thing.

         2.2 Depositions.

         A Producing Party may, in good faith, designate information or documents disclosed during deposition as Confidential Information by indicating on the record at the deposition that the deposition testimony, or any specified part of the testimony given or to be given, and/or all or any part of the document or thing marked for identification at such deposition is Confidential Information subject to the provisions of this Stipulated Protective Order. Within thirty (30) days after receipt of a deposition transcript, any Producing Party may specifically designate information not previously designated as confidential as Confidential Information, by notifying all parties in writing of any specific pages and lines of the transcript which contain the Confidential Information. Each party shall attach a copy of such written statement to the face of the transcript and each copy thereof in its possession, custody or control.

         2.2 Interrogatories.

         A Producing Party may, in good faith, designate Confidential Information contained in a response to an interrogatory by designating the responses Confidential, or by otherwise advising the Receiving Party in writing of such confidential status, and the Confidential Information may be served in a separate document if desired.

         3. USE OF CONFIDENTIAL INFORMATION

         3.1 All documents and information designated in good faith by a party to the Litigation as Confidential Information shall be used solely for the purposes of this Litigation and shall not be used for any other purpose, including, without limitation, any business or commercial purpose, product development, intellectual property development, or in any other legal proceeding, action or matter and shall not, directly or indirectly, in whole or in part, be revealed or disclosed, or made available for inspection or copying to persons other than Qualified Persons as defined in paragraph 3.2.

         3.2 “Qualified Person” for Confidential ...


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