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Quintanilla v. Pilot Thomas Logistics, LLC

United States District Court, D. Nevada

January 7, 2020

AMBER QUINTANILLA, an individual, Plaintiff,
v.
PILOT THOMAS LOGISTICS, LLC, a Domestic Limited-Liability Company, Defendant.

          OGLETREE, DEAKINS, NASH, SMOAK & STEWART, PC. MOLLY REZAC, ESQ. ATTORNEY FOR DEFENDANT PILOT THOMAS LOGISTICS LCC

          OGLETREE, DEAKINS, NASH, SMOAK & STEWART, PC. LARA C. DE LEON, ESQ. ATTORNEY FOR DEFENDANT PILOT THOMAS LOGISTICS LCC

          WILLIAM J. GEDDES KRISTEN R. GEDDES THE GEDDES LAW FIRM, PC.ATTORNEYS FOR PLAINTIFF AMBER QUINTANILLA

          STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIALITY OF DOCUMENTS PRODUCED IN LITIGATION

          WILLIAM G. COBB UNITED STATES MAGISTRATE JUDGE.

         Pursuant to Federal Rule of Civil Procedure ("Fed. R. Civ. P.") 26(f) and U.S. District Court of Nevada Rule ("Local Rule") 26-1(e), the parties through their respective counsel, hereby submit the following Stipulated Protective Order.

         I. RECITALS

         WHEREAS: the parties to the above-captioned litigation anticipate that discovery will require the parties to disclose records and information that are confidential and sensitive, including because such records are anticipated to include the parties' private employment records and private medical records; and

         WHEREAS: the parties seek to protect and prevent the improper dissemination of such confidential and private records and information to third parties, during the course of litigation and after the litigation has ended;

         II. STIPLUATION

         THEREFORE: the parties, by and through their respective counsel of record, hereby stipulate and request the Court issue an Order (" Stipulated Protective Order"), protecting the confidential nature of certain records and information as may be produced during the course of the above-captioned matter, as follows:

         1. If any person or entity, whether or not a party to the instant action, produces or receives answers to interrogatories, or documents or other things, which the producing or receiving person or entity considers to be "Confidential Information," as defined in § II(3)(A)(I) infra- or

         2. If there is deposition testimony which any person or entity, whether or not a party to the instant action, believes contains "Confidential Information," as defined in § II(3)(A)(I) infra- or

         3. Third parties produce information which the third parties assert is confidential, the following procedure shall govern pursuant to Federal Rule of Civil Procedure ("Fed. R. Civ. P.") 26 (c) et. seq,

         A. Any documents (and the contents thereof), things or information falling within the definition of "Confidential Information," set forth in § II(3)(A)(I) infra, that are produced may be designated and marked, in whole or in part, without regard to whether redactions are made, "Confidential" by the party producing the documents or information, at the ...


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