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Basile v. Novak

United States District Court, D. Nevada

October 29, 2019

CHRISTOPHER BASILE, Plaintiff,
v.
KIRSTEN NOVAK, Defendant.

          Kristen T. Gallagher, Esq. (NSBN 9561) Amanda M. Perach, Esq. (NSBN 12399) McDONALD CARANO LLP Attorneys for Plaintiff

          David J. Winterton, Esq. (NSBN 4142) Attorneys for Defendant

          STIPULATED CONFIDENTIALITY AND PROTECTIVE ORDER

         Plaintiff Christopher Basile (“Basile”) and defendant Kirsten Novak (“Novak” and with Basile, the “Parties”), by and through their respective counsel of record, hereby stipulate, agree and respectfully request that in order to facilitate the exchange of information and documents which may be subject to confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights, an order be entered as follows:

         1. In this Stipulation and Protective Order, the words set forth below shall have the following meanings:

a. “Proceeding” means the proceeding entitled Christopher Basile adv. Kirsten Novak, No. 2:19-cv-00429-JAD-BNW.
c. “Material” means any documents, testimony, information or tangible items produced, provided or created in connection with this Proceeding.
d. “Confidential Material” means any documents, testimony, information or tangible items produced, provided or created in connection with this Proceeding that are reasonably and in good faith believed by a Designating Party to contain trade secrets, proprietary business information, competitively sensitive information, personal or private financial information, health information, or any other information the disclosure of which would, in the reasonable and good faith judgment of the Designating Party, be detrimental to its livelihood and reputation, or the conduct of its business.
e. “Designating Party” means the Party that designates Material as “Confidential.”
f. “Disclose” or “Disclosed” or “Disclosure” means to produce, provide, reveal, divulge, give, or make available Materials, or any part thereof, or any information contained therein, in connection with this Proceeding.
g. “Document” means any discoverable item pursuant to the Federal Rules of Civil Procedure that has been or will be produced (i) before discovery for settlement purposes, or in discovery in this Proceeding by any person, and (ii) any copies, reproductions, or summaries of all or any part of the foregoing.
h. “Information” means the content of documents, testimony or tangible items.
i. “Testimony” means all depositions, declarations, affidavits, or other testimony taken during or generated in connection with this Proceeding.

         2. All material received by any Party pursuant to a discovery request, subpoena, court order, Federal Rule of Civil Procedure, or by any other means within the context of this Proceeding, whether such Material is designated as Confidential Material or not, shall be used solely for the purposes of the prosecution, defense and/or settlement of this Proceeding, including any appeals, and shall not be used for any other purpose whatsoever, including, without limitation, any other litigation or proceedings or any business, competitive or private or purpose or function. However, notwithstanding any other paragraph of this Stipulation and Protective Order, no Party shall be restricted by this Stipulation and Protective Order in dealing as it chooses with any material that was rightfully in its possession prior to receiving such material in discovery in this proceeding

         3. The Designating Party shall have the right to designate as “Confidential” any documents, testimony, information or tangible items that the Designating Party reasonably and in good faith believes to contain trade secrets, proprietary business information, competitively sensitive information, personal or private financial information, or health information.

         4. The entry of this Stipulation and Protective Order does not alter, waive, modify, or abridge any right, privilege or protection otherwise available to any Party with respect to the discovery of matters, including but not limited to any Party's right to assert the attorney-client privilege, the attorney work product doctrine, or other privileges, or any Party's right to contest any such assertion.

         5. Any documents, testimony, information or tangible items to be designated as “Confidential” must be clearly so designated before the document, testimony, information or tangible item is disclosed or produced. The means of designating documents, testimony, information and tangible items as confidential is as follows:

a. For documents (apart from transcripts of depositions or other pretrial or trial proceedings), the Designating Party must affix the legend “Confidential” on each page of any document containing such designated Confidential Material. The “Confidential” legend should not ...

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