Thomas v. Chrysler Group LLC et al

Filing 29

PROTECTIVE ORDER Granting 28 Consent MOTION for Protective Order Governing Confidentiality of Documents. Signed by Magistrate Judge George Foley, Jr on 9/24/14. (Copies have been distributed pursuant to the NEF - MMM)

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GREG W. MARSH, ESQ.
Nevada Bar No. 322
LAW OFFICES OF GREG W. MARSH
731 South Seventh Street
Las Vegas, Nevada 89101
Tel: [phone]
Fax: [phone]
[e-mail]
PAUL G. CEREGHINI, ESQ.
Nevada Bar No. 10000
CURTIS J. BUSBY, ESQ.
Nevada Bar No. 6581
BOWMAN AND BROOKE LLP
2901 North Central Avenue, Suite 1600
Phoenix, Arizona 85012
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendant/Crossdefendant Chrysler Group LLC
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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)
)
)
Plaintiff,
)
)
vs.
)
CHRYSLER
GROUP,
LLC;
CAROL
M.)
)
DOUGLASS; DOES I through X; and ROE)
CORPORATIONS XI THROUGH XX, inclusive,
)
)
Defendants.
)
)
)
CAROL M. DOUGLASS,
)
)
Crossclaimant,
)
)
)
vs.
)
)
CHRYSLER GROUP, LLC.
)
)
Crossdefendant.
DAMION L. THOMAS,

CASE NO. 2:14-cv-671-JAD-GWF
PROTECTIVE ORDER GOVERNING
CONFIDENTIALITY OF
DOCUMENTS

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Defendant Chrysler Group LLC ("Chrysler Group"), by and through its attorneys of

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record, Curtis J. Busby, of Bowman and Brooke LLP, and Greg W. Marsh, of the Law

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Offices of Greg W. Marsh; Plaintiff Damion Thomas, by and through his attorney of record,

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George T. Bochanis, of George T. Bochanis, Ltd.; and Defendant/Crossclaimant Carol M.

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Douglass, by and through her attorney of record George M. Ranalli and Steven M.

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Goldstein, of Ranalli & Zaniel, hereby stipulate and agree as follows:

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WHEREAS the Parties already have or anticipate that they will produce documents

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or provide information in the above-captioned matter that may contain personal,

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confidential, proprietary, trade secret, or competitively sensitive information ("Confidential

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Information");

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WHEREAS the Parties hereby enter into the terms of this Protective Order Governing

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Confidentiality Of Documents pursuant to Fed. R. Civ. P. 26(c) limiting the dissemination of

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Confidential Information that may be produced or otherwise disclosed in the above captioned

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matter.

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Based on the foregoing,

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IT IS HEREBY STIPULATED AND AGREED as follows:

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1.

Whether by automatic disclosure or in response to written discovery, the

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parties may designate as “protected” or “subject to protective order” or with a similar

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designation any portion of its documents produced or discovery responses that contain

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Confidential Information, including personal, trade secret or other confidential research,

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development or commercial information or which is otherwise considered protected under

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applicable law. Testimony and other information based upon documents so designated

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shall be considered protected and subject to this Protective Order.

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2.

Information contained therein shall be disclosed only to counsel of record in

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this action or only to individuals certified by such counsel as employed by or assisting

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counsel in preparation for, or at the trial of, this action.

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Confidential Information is to be disclosed shall first be advised by counsel making

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Any person or firm to whom

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disclosure that, pursuant to this Protective Order, such person or firm may not divulge any

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such information to any other person.

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3.

Any such documents or information shall be used only for the purpose of

prosecuting this action.
4.

In the event that any party seeks to attach Confidential Information to any

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pleading, motion, deposition transcript or other paper filed with Clerk of the Court, the party

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filing the pleading, motion, deposition transcript or other paper must comply with the Ninth

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th
Circuit's directives in Kamakana v. City and County of Honolulu, 447 F.3d 1172 (9 Cir.

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2006), and the following:
a.

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The Confidential Information to be submitted with the pleading, motion,

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deposition transcript, or other paper must be submitted only for in camera inspection

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in accordance with L.R. 10-5(a); or
b.

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The Confidential Information to be submitted with the pleading, motion,

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deposition transcript, or other paper must be submitted under seal using the court's

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electronic filing procedures as stated in L.R. 10-5(b).

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5.

The production of such documents or information by any party shall not

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constitute a waiver of any privilege or other claim or right of withholding or confidentiality that

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it may have.

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6.

Should any party dispute the need for any particular document(s) or information

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to be entitled to protection pursuant to the Order, then within thirty (30) days following receipt

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of said document(s) the party disputing confidentiality shall notify the other parties, through

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their attorneys, of such dispute, following which the party producing the document or

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information shall have thirty (30) days to file a motion before the Court requesting a protective

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order. Information or documents that are disputed pursuant to this paragraph will remain

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protected pending the Court’s review and decision regarding this matter.

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7.

Upon the termination of this action, copies of all documents and information

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furnished by Chrysler Group to Plaintiff or any other party to this action, together with all

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originals and copies of notes, sketches, data, compilations, extracts and reproductions

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furnished by Chrysler Group, shall be returned to counsel for Chrysler Group, together with a

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letter from any counsel receiving documents pursuant to this Order stating that all documents

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and copies of such documents that were provided by Chrysler Group have been returned to

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Chrysler Group.

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IT IS SO ORDERED:

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______________________________________________________
GEORGE FOLEY, JR.
UNITED STATES MAGISTRATE JUDGE

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September 24, 2014
DATED: _________________________

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DATED this 23rd day of September, 2014.

DATED this 23rd day of September, 2014.

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GEORGE T. BOCHANIS, LTD.

BOWMAN AND BROOKE LLP

By: /s/ George T. Bochanis (w/permission)
GEORGE T. BOCHANIS, ESQ.
Nevada Bar No. 2262
631 South Ninth Street
Las Vegas, NV 89101

By: /s/ Curtis J. Busby
CURTIS J. BUSBY, ESQ.
Nevada Bar No. 6581
2901 North Central Avenue,
Suite 1600
Phoenix, Arizona 85012

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Attorneys for Plaintiff

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In conjunction with:
GREG W. MARSH, ESQ.
Nevada Bar No. 322
LAW OFFICES OF GREG W. MARSH
731 South Seventh Street
Las Vegas, Nevada 89101

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Attorneys for
Defendant/Crossdefendant
Chrysler Group LLC

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DATED this 23rd day of September, 2014.

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RANALLI & ZANIEL

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By: /s/ George M. Ranalli (w/persmission)
GEORGE M. RANALLI, ESQ.
Nevada Bar No. 5748
Steven M. Goldstein
Nevada Bar No. 6318
2400 W. Horizon Ridge Parkway
Henderson, NV 89052

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Attorneys for Defendant Carol M. Douglas

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