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Delmonte-Wright v. Geico Casualty Co.

United States District Court, D. Nevada

November 13, 2019

SHEILA ANN DELMONTE-WRIGHT, Plaintiff,
v.
GEICO CASUALTY COMPANY, a foreign entity; DOES I-X and ROE CORPORATIONS XI-XX, Defendants.

          McCormick, Barstow, Sheppard, Wayte & Carruth LLP Wade M. Hansard Nevada Bar No. 8104, Jonathan W. Carlson Nevada Bar No. 10536, Renee M. Maxfield Nevada Bar No. 12814, Attorneys for Defendant GEICO CASUALTY COMPANY and nonparty JUSTINE RUTTER

          BIGHORN LAW Kimball J. Jones, Nevada Bar No.: 12982 Jacob G. Leavitt, Nevada. Bar No, : 12608 Attorneys for Plaintiff

          STIPULATED PROTECTIVE ORDER PLAINTIFF DID NOT EXPRESSLY AGREE TO ENTRY OF THIS PROTECTIVE ORDER, BUT SHE CONSENTED TO ITS ISSUANCE BY FAILING TO OPPOSE THE MOTION AT DOCKET NO. 30. SEE LOCAL RULE 7-2(D).

         This Stipulation is entered into by and between Sheila Ann Delmonte-Wright and GEICO Casualty Company (referred to collectively as the “Parties”) by and through their attorneys of record, based on the following:

         The Parties assert that certain documentation and information sought constitutes confidential, proprietary, sensitive, trade secret, financial, business, and other commercial records and information entitled to protection from disclosure;

         The Parties desire to establish a mechanism to prevent the improper disclosure of such information and documentation produced;

         The Parties desire the procedures outlined in this Order shall apply to all documents, things and information subject to discovery from or disclosed by the Parties pursuant to the Nevada Rules of Civil Procedure.

         The Parties intend that this stipulation be binding upon them and enforceable as an Order of the Court. The Parties seek the Court's approval and entry of the terms of this stipulation as an Order of the Court.

         IT IS HEREBY ORDERED THAT:

         I. (1) The parties hereto recognize that some of the information, documents, and the things that may be disclosed or may be discoverable under the Rules of Civil Procedure in this action might allegedly include trade secret or other confidential information or proprietary business or commercial information of the party from which discovery is sought (“Confidential Information”), the public disclosure of which would likely be competitively harmful. To the extent the parties produce documents and/or other things allegedly containing Confidential Information which the producing party determines warrants protection, those documents shall be subject to this Stipulated Protective Order Regarding Confidentiality.

         (2) The parties hereto agree that limitations on the disclosure and use of Confidential Information are desirable for the orderly conduct of discovery in this action, while at the same time providing protection from the misuse of each party's Confidential Information.

         (3) Each party to this action who produces or discloses any documents, things, interrogatory answers, admissions, deposition transcripts, or information which the producing or disclosing party (“Producing Party”) reasonably believes to comprise or contain Confidential Information, and which the Producing Party desires to be subject to this Protective Order, shall have stamped or written upon that document or tangible thing one of the two following designations as reasonably determined by the Producing Party:

         (a) “CONFIDENTIAL”, or

         (b) “CONFIDENTIAL ATTORNEY'S EYES ONLY” All documents and tangible items so marked as provided in Paragraph I(3) must be visibly marked on each page or separate item by the Producing Party as “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEY'S EYES ONLY.” A deposition transcript may be designated “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEY'S EYES ONLY” by any party or witness by requesting such treatment thereof either (1) on the record, or (2) by written communication mailed within thirty (30) days after receipt by the witness or his counsel of the transcript. All parties shall treat a deposition transcript as “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEY'S EYES ONLY, ” respectively, during said thirty (30) day period. If “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEY'S EYES ONLY” treatment of a transcript is requested on the record, the court reporter shall be instructed to mark the face of the transcript(s) containing the designated testimony with the designation “CONFIDENTIAL” and/or “CONFIDENTIAL ATTORNEY'S EYES ONLY.” Copies of all exhibits designated “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEY'S EYES ONLY” shall be separately marked accordingly. If the designated transcript portions are filed with the Court, the designated portion shall at the time of filing be sealed as provided in Paragraph VIII below and within the sealed envelope, identified as being “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEY'S EYES ONLY.”

         II. (1) All documents and tangible things marked as CONFIDENTIAL or CONFIDENTIAL ATTORNEY'S EYES ONLY shall be held by the Party receiving same (the “Receiving Party”) in confidence and used solely for the purpose of this case. Counsel of record for the parties may maintain a copy of the Confidential Information for document retention purposes as well as their own documents that are work product or subject to attorney-client privilege. This Order shall continue to apply to ...


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