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Torres v. Rothstein

United States District Court, D. Nevada

December 12, 2019

CANDY TORRES, Plaintiff,
v.
ALLAN ROTHSTEIN and KYLE PUNTNEY, Defendants. Related Cross-Complaint

          [PROPOSED] PROTECTIVE ORDER

         Pursuant to the stipulation of plaintiff Candy Torres and defendant Allan Rothstein, and good cause therefor, the Court enters the following protective order governing the confidentiality of information produced in discovery in this action.

         1. PURPOSE

         The parties anticipate that discovery in this action may involve the disclosure or production of private information that may be entitled to confidentiality protection under Fed.R.Civ.P. 26(c). To facilitate discovery in this action, the Court hereby issues the following protective order governing the confidentiality of materials obtain in discovery.

         2. DESIGNATING CONFIDENTIAL INFORMATION

         2.1. Under this Order, "Confidential Information" is information that qualifies for protection under Fed. R . Civ. P. 26(c).

         2.2 Information that has been disclosed to the public from any source or that may be obtained from any publicly available source does not qualify as Confidential Information under this Order.

         2.3 Application and Timing. This Order applies equally to the parties to this action as well as any non-party, such as a person producing records pursuant to a subpoena. Collectively, a party to this action or non-party is referred to as a “party” in this Order. Information must be designated as Confidential Information prior to its disclosure or production.

         2.4 How to Designate Information as Confidential. Any party disclosing or producing information may designate that information as Confidential Information. To designate information as Confidential Information, the designating party must affix to each page or otherwise label an item that contains the Confidential Information with the following legend, file name, or stamp: "Confidential, Subject to Protective Order." No. legend, watermark, or stamp shall be affixed to a document in a way that obscures the information contained in the document or defeats the ability of a party to search the document if produced or converted into an electronic format.

         2.5 Designation of Specific Information. If specific information appears in a document, item or file that qualifies as Confidential Information, see e.g., Fed.R.Civ.P. 5.2(a), then only that portion of the document, item or file shall be designed as Confidential Information. To designate specific information as Confidential Information, the designating party shall affix to each document page or label each item or file containing the specific Confidential Information the following legend, file name, or stamp: "Confidential, Portions Subject to Protective Order." In the disclosure or discovery response that accompanies the information so labeled, the designating party shall identify by document number or file name the specific portions of that document or electronic file that are subject to this Order.

         2.6 Depositions. To designate deposition testimony as Confidential Information, the party seeking the designation must indicate on the record before the deposition adjourns those portions of the transcript that contain Confidential Information. The portions of a transcript reflecting testimony that have been designated as Confidential Information shall be separately bound.

         2.7 Over-Designation Prohibited. Designation under this Order is allowed if and only if the designating party determines in good faith: [a] that the material contains Confidential Information that warrants protection under Fed.R.Civ.P. 26(c) and the terms of this Order and [b] that disclosure of the information to persons other than those identified in Paragraph 3 would cause a specific, demonstrable harm.

         2.8 Continuing duty. Each party has a continuing duty to assess whether information previously designated as Confidential Information is properly designated. If a designating party determines that information was improperly designated or no longer qualifies as Confidential Information, then the party shall promptly re-produce that information omitting the confidentiality legend, file name or stamp required under Paragraphs 2.4 or 2.5.

         3. DISCLOSURE OF CONFIDENTIAL INFORMATION

         3.1 Unless otherwise ordered by the Court or permitted in writing by the designating party, Confidential Information may be ...


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