Miller v. FedEx Office & Print Servs.

Full title: Breauna Miller Plaintiff, v. FedEx Office and Print Services, Inc.; A…

Court: United States District Court, District of Nevada

Date published: Aug 10, 2022

2:21-cv-01917 (D. Nev. Aug. 10, 2022)

Opinion

2:21-cv-01917

08-10-2022

Breauna Miller Plaintiff, v. FedEx Office and Print Services, Inc.; A Foreign Corporation, Doe Employees; Roe Distributors I-V; Roe Manufacturers I-V; Roe Designers I-V; Does I through X; and Roe Corporations I through X, inclusive Defendant.

Bre'Ahn Williams Marjorie L. Hauf, Esq. Nevada Bar No. 8111 Matthew Pfau, Esq. Nevada Bar No. 11439 Bre'Ahn Williams, Esq. Nevada Bar No. 15672 Attorneys for Plaintiff Breauna Miller Michael Lowry Michael P. Lowry, Esq. Nevada Bar No. 10666 Kevin A. Brown, Esq. Nevada Bar No. 7621 Counsel for Defendant FedEx Office and Print Services, Inc.

BRENDA WEKSLER, UNITED STATES MAGISTRATE JUDGE.

Bre'Ahn Williams

Marjorie L. Hauf, Esq.

Nevada Bar No. 8111

Matthew Pfau, Esq.

Nevada Bar No. 11439

Bre'Ahn Williams, Esq.

Nevada Bar No. 15672

Attorneys for Plaintiff Breauna Miller

Michael Lowry

Michael P. Lowry, Esq.

Nevada Bar No. 10666 Kevin A. Brown, Esq.

Nevada Bar No. 7621

Counsel for Defendant FedEx Office and Print Services, Inc.

STIPULATED PROTECTIVE ORDER

BRENDA WEKSLER, UNITED STATES MAGISTRATE JUDGE.

The parties, by and through their attorneys, stipulate as follows:

1. In the course of discovery, the parties may produce documents marked as “Confidential” to protect proprietary business information, commercially sensitive information, and/or other grounds available under F.R.C.P. 26(c). If the document contains multiple pages, each page of the document determined to be confidential by the producing party shall be marked confidential. In the event a party inadvertently fails to mark any document or pages of the document as “Confidential,” the party may do so at any time during the discovery period.

2. The parties agree that any document produced and marked confidential shall not be used by the non-producing party in any way except in connection with the preparation for or conduct of depositions, motions, hearings, or trial of this action (including any appeals related thereto), or as otherwise ordered by the Court. Attorneys representing the parties, their staff, consultants, and experts may have access to confidential documents provided they agree to abide by the terms of this stipulated protective order. The parties agree that any document produced and marked confidential shall not be disclosed to anyone else without the written consent of the party producing the confidential document or court order.

3. In the event any party wishes to challenge the “Confidential” designation, the parties agree to first attempt to reach agreement with the other party regarding the lifting of confidentiality before seeking court intervention.

4. Confidential documents may be used at depositions as exhibits in this action without prior notice to or approval of the party producing the confidential document; however, the portions of deposition transcripts that discuss the confidential documents shall be treated as confidential subject to the provisions of this stipulation.

5. The filings with the Court such as motions and related memoranda that discuss the contents of confidential documents and/or attach them as exhibits shall be under seal. Confidential documents shall remain confidential until such time that the confidentiality has been removed with written agreement of counsel or Court order. The issue of confidentiality of exhibits that may be used at trial shall be explored with the Court at the pretrial conference. The parties shall cooperate in seeking solutions such as redaction of the confidential portion of the document. No document produced as confidential shall be offered as a trial exhibit without the issues of confidentiality having been resolved by counsel for the producing party or the court.

6. At the conclusion of this litigation, information deemed confidential in this case shall not be used for any other purpose whatsoever, including business, commercial, or outside judicial proceedings, unless there is also a protective order in place in those cases.

7. This stipulated protective order applies to documents marked “Confidential” and already produced or to be produced after the Court orders and approves of this stipulation.

ORDER

IT IS ORDERED that ECF No. 26 is GRANTED. The parties are advised, however, that they must comply with the Local Rules and Ninth Circuit law regarding filing motions to seal any documents they want filed under seal.

IT IS SO ORDERED