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Mora v. Prodani

United States District Court, D. Nevada

November 6, 2019

VERONICA MORA, an individual, Plaintiff,
v.
ELION PRODANI, an individual; WYNN RESORTS, LTD. dba WYNN RESORTS, a Nevada corporation, Defendant.

          GARG GOLDEN LAW FIRM ANTHONY B. GOLDEN, PUNEET K. GARG, MELODY R. RISSELL, ATKINSON WATKINS & HOFFMANN LLP JUSTIN L. WATKINS, RACHEAL A. ROSS, ATTORNEYS FOR PLAINTIFF VERONICA MORA

          JACKSON LEWIS P.C. DEVERIE J. CHRISTENSEN, DANIEL I. AQUINO, ATTORNEY FOR DEFENDANT WYNN LAS VEGAS, LLC

          HUTCHISON & STEFFEN JOSEPH R. GANLEY, JASON D. GUINASSO, HUTCHISON & STEFFEN, PLLC ATTORNEY FOR DEFENDANT ELION PRODANI

          STIPULATED PROTECTIVE ORDER

         Pursuant to Federal Rule of Civil Procedure 26(c), Defendant Elion Prodani, Defendant Wynn Las Vegas, LLC (misnamed and erroneously sued as Wynn Resorts, Ltd. dba Wynn Resorts), and Plaintiff Veronica Mora, by and through their respective counsel of record, hereby stipulate and agree that the handling of confidential material in these proceedings shall be governed by the provisions set forth below.

         I. APPLICATION

         This Protective Order shall govern the designation and handling of “Confidential Information” and “Confidential - Attorney's Eyes Only Information” (defined below) produced in discovery in this litigation, whether by voluntary production or disclosure or in response to any formal discovery procedure, including designation and handling of nonpublic information of a confidential nature. This Protective Order does not affect any party's obligations under the Civil Rules to produce documents as required by the rules of discovery or an order of the Court. The purpose of this Protective Order is to facilitate the handling of nonpublic information of a confidential, private, or proprietary nature.

         If a designating party files material concerning “Confidential Information” or “Confidential-Attorney's Eyes Only Information” in court and does not attempt to file it under seal, or if material is otherwise already part of the public record as of the entry of this Protective Order, the material in question will not be subject to this Protective Order. The mere filing of material containing “Confidential” or “Confidential-Attorney's Eyes Only” by the non-designating party does not remove the material from the protection of this Protective Order. If a non-designating party files material marked “Confidential Information” or “Confidential-Attorney's Eyes Only Information” by another party without first seeking permission of the court to file the same under seal, the non-filing party may seek appropriate relief to ensure protection under this Protective Order.

         II. DEFINITIONS

         A.Confidential Information” means: personal information of current or former employees of Defendant (such as addresses, telephone numbers, birth dates, marital status, dependent status and/or discipline or counseling received from Defendant); financial information, including, but not limited to, payroll records, tax returns, financial statements, banking records, and electronic data containing financial information and/or compensation or pay plans or scales; confidential proprietary and/or competitive business and gaming information; trade secrets; witness statements and/or investigation reports; performance projections; business strategies; and confidential proprietary information about affiliates, parents, subsidiaries and third-parties with whom the parties to this action have or have had business relationships. “Confidential Information” includes, without limitation, any document, information, or material that the producing party or protected person reasonably believes not to be in the public domain and reasonably believes contains information to which an individual or company has an established and legitimate right to privacy or confidentiality.

         B.Attorney's Eyes Only Information” is a subset of Confidential Information that includes any document or testimony identified by the party that contains highly sensitive, proprietary, or trade secret information, including, but not limited to medical records and healthcare information pertaining to any current or former employee of Defendant (other than Plaintiff); personnel documents that contain personal identification information such as social security numbers, financial information and/or rates of pay; information about prior, existing, and potential customers; surveillance information, including, but not limited to policies, practices, and procedures, location of cameras, methods of recording, video footage and reports. All references herein to “Confidential” information include “Confidential - Attorneys' Eyes Only, ” except where the permissible disclosure or dissemination of “Confidential - Attorneys' Eyes Only” information is more limited than permissible disclosure or dissemination of “Confidential” information.

         C. “Disclosed” is used in its broadest sense and includes, inter alia, directly or indirectly shown, divulged, revealed, produced, described, transmitted or otherwise communicated, in whole or in part.

         D. “Discovery Material(s)” means any documents, answers to interrogatories, responses to requests for admission, deposition testimony, deposition transcripts and exhibits, other responses to requests for information and/or written information, whether produced voluntarily or involuntarily, in response to discovery requests in this litigation by any party.

         E. “Document” is defined as the term is used in Federal Rule of Civil Procedure 34.

         F. “Under Seal” is defined as sealing confidential documents consistent with the procedure set forth in LR IA 10-5 of the Local Rules for United States District Court, District of Nevada (the “Court”). In the event that the Court publishes a new procedure for the ...


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