United States District Court, D. Nevada
JAVIER CABRERA, an individual; DEBORAH MILLER, an individual, CHERIE MANCINI, an individual, NEVADA SERVICE EMPLOYEES UNION STAFF UNION (“NSEUSU”), an unincorporated association, Plaintiffs,
SERVICE EMPLOYEES INTERNATIONAL UNION. a nonprofit cooperative corporation; LUISA BLUE, in her official capacity as Trustee of Local 1107; MARTIN MANTECA, in his official capacity as Deputy Trustee of Local 1107; MARY K. HENRY, in her official capacity as Union President; CLARK COUNTY PUBLIC EMPLOYEES ASSOCIATION dba NEVADA SERVICE EMPLOYEES UNION aka SEIU 1107, a non-profit cooperative corporation; DOES 1-20; and ROE CORPORATIONS 1-20, inclusive, Defendants.
CHRISTENSEN JAMES & MARTIN Evan L. James, Esq. Attorneys
for Defendant Local 1107, Luisa Blue, and Martin Manteca
Michael J. Mcavoyamaya, Esq. Attorney for Plaintiffs
ROTHNER, SEGALL & GREENSTONE Eli Naduris-Weissman, Esq.
Attorneys for SEIU and Mary K. Henry
ROTHNER, SEGALL & GREENSTONE JONATHAN COHEN ELI
NADURIS-WEISSMAN CARLOS COYE
STIPULATION FOR ENTRY OF PROTECTIVE ORDER
parties, by and through their undersigned counsel, hereby
stipulate to the entry of the following protective order to
govern the designation and production of confidential
information or documents.
Court enters the following protective order to govern the
designation and production of confidential information or
documents so designated by Plaintiffs and Defendants.
Purposes and Limitations
activity in this action is likely to involve production of
confidential, proprietary, or private information for which
special protection from public disclosure and from use for
any purpose other than prosecuting this litigation would be
warranted. Accordingly, the parties have stipulated to and
petitioned the Court to enter the following Protective Order.
parties acknowledge that this Protective Order does not
confer blanket protections on all disclosures or responses to
discovery and that the protection it affords extends only to
the limited information or items that are entitled under the
applicable legal principles to treatment as confidential. The
parties further acknowledge, as set forth below, that this
Protective Order creates no entitlement to file confidential
information under seal. Local Rule IA 10-5 sets forth the
procedures that must be followed and reflects the standards
that will be applied when a party seeks permission from the
Court to file material under seal.
Party: Any party to this action, including all of
its officers, directors, employees, consultants, retained
experts, and outside counsel (and their support staff).
Disclosure or Discovery Material: All items or
information, regardless of the medium or manner generated,
stored, or maintained (including, among other things,
testimony, transcripts, or tangible things) that are produced
or generated in disclosures or responses to discovery in this
"Confidential" Information or Items:
Information (regardless of how generated, stored or
maintained) or tangible things that qualify for protection
under standards developed under Federal Rule of Civil
"Highly Confidential - Attorneys' Eyes
Only" Information or Items: Extremely sensitive
"Confidential Information or Items" whose
disclosure to another Party or nonparty would create a
substantial risk of serious injury that could not be avoided
by less restrictive means.
Receiving Party: A Party that receives Disclosure or
Discovery Material from a Producing Party.
Producing Party: A Party or nonparty that produces
Disclosure or Discovery Material in this action.
Designating Party: A Party or nonparty that
designates information or items that it produces in
disclosures or in responses to discovery as
"Confidential" or "Highly Confidential
-Attorneys' Eyes Only."
Protected Material: Any Disclosure or Discovery
Material that is designated as "Confidential" or as
"Highly Confidential - Attorneys' Eyes Only."
Outside Counsel: Attorneys who are not employees of
a Party but who are retained to represent or advise a Party
in this action.
House Counsel: Attorneys who are employees of a
Counsel (without qualifier): Outside Counsel and
House Counsel (as well as their support staffs).
Expert: A person with specialized knowledge or
experience in a matter pertinent to the litigation who has
been retained by a Party or its counsel to serve as an expert
witness or as a consultant in this action and who is not a
past or a current employee of a Party or of a competitor of a
Party and who, at the time of retention, is not anticipated
to become an employee of a Party or a competitor of a Party.
This definition includes a professional jury or trial
consultant retained in connection with this litigation.
Professional Vendors: Persons or entities that
provide litigation support services (e.g., photocopying;
videotaping; translating; preparing exhibits or
demonstrations; organizing, storing, retrieving data in any
form or medium; etc.) and their employees and subcontractors.
Calculating Time: all deadlines included in this
protective order are to be calculated pursuant to ...