McKenna v. David Z. Chesnoff, Chtd. P.C. et al

Filing 18

STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER. Signed by Magistrate Judge Carl W. Hoffman on 3/17/15. (Copies have been distributed pursuant to the NEF - MMM)

1 Dennis L. Kennedy, Nev. Bar No. 1462

Sarah E. Harmon, Nev. Bar No. 8106
2 Kelly B. Stout, Nev. Bar No. 12105

BAILEY.:. KENNEDY
3 8984 Spanish Ridge Avenue

Las Vegas, Nevada 89148-1302
4 Telephone Number: [phone]

Fax Number: [phone]
5 DKennedy(fBaileyKennedy.com

SHarmon(fBaileyKennedy.com
6 KStout(fBaileyKennedy.com

7 Attorneys for Plaintif
8

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

9

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MICHELLE MCKENNA
Plaintiff,

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Case No. 2:14-cv-1 773-JAD-CWH
vs.

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.il)~c 13 DAVID Z. CHESNOFF, CHTD. P.e. D/B/A
CHESNOFF & SCHONFELD; DAVID Z.
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14 CHESNOFF; AND RICHARD A.
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SCHONFELD,
Defendants.
15

16
17

STIPULATED CONFIDENTIALITY AGREEMENT
AND (PROPOSED) PROTECTIVE ORDER

18

19

WHEREAS Plaintiff Michelle McKenna ("Plaintiff') and Defendants David Z. Chesnoff,

20 Chtd. P.C. d/b/a Chesnoff & Schonfeld, David Z. Chesnoff, and Richard A. Schonfeld

21 (collectively "Defendants") believe that discovery conducted during this litigation may involve
22 the disclosure of confidential and/or privileged i documents and/or information;

23 WHEREAS the Plaintiff and Defendants Uointly, the "Parties"), by, between, and among

24 their respective counsel, having stipulated and agreed to the terms set forth herein, and good
25
Plaintiff

has alleged attorney malpractice arising out of

Defendants' representation of

Plaintiff in the

26 underlying case, McKenna v. Jones, Case No. A-630290, which was fied in the Eighth Judicial District Court, in

and for Clark County, Nevada, on November 28,2010 ("Jones Action").

Page 1 of 13

1 cause having been shown, wish to provide for the confidential treatment of all such Confidential
2 Material (as defined below);

3 WHEREAS the Parties agree to the entry of an order, pursuant to Federal Rule of Civil
Evidence 502, governing the review, copying,

4 Procedure 26(c) and Federal Rule of

5 dissemination, and fiing of confidential documents and information to be produced by any Pary

6 and its respective counselor by any non-party during the course of discovery in this matter to the
7 extent set forth below;

8 Subject to the Court's approval, the Parties hereby stipulate and agree to the following
9 protective order:

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i.

10

DEFINITIONS.

tî i:!~ 11 A. DESIGNATING PARTY. "Designating Party" shall mean any person or entity,
~ di 12 regardless of whether a Pary to this action, who produces Coufideutial Iuformation (as defined

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B.

RECEIVING PARTIES. "Receiving Parties" shall mean all persons or entities,

15 regardless of whether a Party to this action, who receive Confidential Information in connection

16 with this litigation.
17

C.

CONFIDENTIAL INFORMATION. "Confidential Information" shall mean all

18 documents and testimony, and all information contained therein or derived therefrom, that is:
19

1. Produced for or disclosed to Receiving Parties;

20

2. Considered by the Designating Party in good faith to constitute or to contain

21

confidential, proprietary, financial, or otherwise sensitive or privileged

22

information, whether embodied in physical objects, documents, or the factual

23

knowledge of persons, including, but not limited to, medical information,

24

financial information, and attorney-client privileged communications and

25

work product relating to the Defendants' representation of

26

Jones Action; and

27

Page 2 of

13

the Plaintiff

in the

3. Identified by the Designating Party in the manner described below in Section

1

II.

2
3

D.

CONFIDENTIALITY LEGEND. "Confidentiality Legend" shall refer to the marking

4 on documents or information with the phrase "CONFIDENTIAL-Subject to Cour Order" or
5 "CONFIDENTIAL."

6 II. DESIGNATION OF CONFIDENTIAL INFORMATION.
7 A. DESIGNATION. When the Designating Party produces, discloses, or otherwise
8 reveals Confidential Information, any such document, transcript, material, item, or thing deemed
9 to be confidential shall be clearly designated or marked with the appropriate Confidentiality

10 Legend and treated as confidentiaL.

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1. In the case of deposition testimony, the designation shall be made by making

12

an oral statement to such effect on the record during the course of the

13

deposition, or by written notification to all Parties within thirty (30) days

14

following receipt of the transcript of such deposition and the exhibits thereto

15

(or later with leave of Court or by agreement among the Parties). Written

16

designation must be made by reference to the specific page(s) and line

17

number(s). Prior to the expiration of such thirty (30) day period (or until a

18

designation is made by counsel, if such a designation is made in a shorter

19

period of time), all such documents shall be treated as Confidential

20

Information.

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2. In the case of

written documents, including, but not limited to, documentary

22

evidence, affdavits, declarations, statements, written responses to requests for

23

production of documents, and responses to interrogatories or requests for

24

admission, the appropriate Confidentiality Legend shall be placed on each

25

page of any such written documents that contain information deemed by the

26

Designating Party to be Confidential Information.

27

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1

3. If only a part or portion of a written document warrants protection under this

2

Order, the Designating Party, to the extent practicable, shall identify the

3

protected partes) or portiones) and clearly designate or mark the same

4

appropriate Confidentiality Legend.

5

4. If

with the

the document, material, item, or thing is stored or recorded electronically,

6

and a legend cannot be stamped or affxed upon it, the Designating Party may

7

designate or mark the same as "CONFIDENTIAL-Subject to Cour Order"

8

or "CONFIDENTIAL" by a cover letter or cover page.

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5. Documents produced by third parties shall be deemed Confidential

thirty (30) days in order to permit the Parties to

10

Information for a period of

11

review the documents and determine if any portion of the documents shall be

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designated as Confidential Information. Within the thirty (30) day period, a
Party that determines that documents produced by a third party include

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Confidential Information shall inform all other Parties of the specific

15

documents or information that shall be deemed confidential and provide

16

replacement copies of the Confidential Information that bear the appropriate

17

Confidentiality Legend.

18

B. TIME FOR MAKING DESIGNATION. Any such designation or marking shall take

19 place prior to production or disclosure by the Designating Party; provided, however, that in the

20 event that any document, material, item, or thing that may contain Confidential Information is
21

made available for inspection by a Party, there wil be no waiver of confidentiality by the

22 inspecting of such document, material, item, or thing before it is copied and designated or
23 marked with a Confidentiality Legend, and the inspecting Party shall treat the inspected

24 material(s) as confidential, unless otherwise indicated by the Party permitting inspection.
25

C. REPRESENTATION BY DESIGNATING PARTY. By designating or marking any

26 document, transcript, material, item, or thing as containing Confidential Information, the

27

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1 Designating Party is certifying to the Court that there is a good faith basis, both in law and in
2 fact, for the designation or marking within the meaning ofF.R.C.P. 26(g).
3

D.

WITHDRAWAL OF CONFIDENTIALITY DESIGNATION. A Designating Party may

4 withdraw its previous designation of documents or information as confidential upon written
5 notice to the Receiving Parties and reproduction of the formerly designated documents without a

6 Confidentiality Legend.

7

E.

DISPUTE REGARDING CONFIDENTIALITY DESIGNATION. If, at any time, a Party

8 wishes for any reason to dispute the Designating Party's designation of a document, transcript,
9 material, item, or thing as Confidential Information and/or object to the inclusion of Confidential

~

10 Information in any pleading, motion, brief, memorandum, or other paper fied with the Court,

~ l!~ 11 such Party (the "Disputing Party") shall notify the Designating Party of such dispute, in writing.

~ ~~t: 12 1. The Disputing Party shall, in writing, specifically identify the document,
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is in dispute, by Bates Number or any other means sufficient to put the other

15

Paries on notice of the information in dispute, and set forth the precise factual

16

and/or legal basis of its dispute with regard to each such document, transcript,

17

material, item, or thing.

18

2. The Designating Party shall have fourteen (14) business days to respond. If

19

the Designating Party refuses to remove the Confidential Legend, the Parties

20

must participate in a discovery dispute conference at a mutually-agreeable

21

date and time.

22

3. If

the Parties are thereafter unable to amicably resolve the dispute, the

23

Disputing Party may apply by motion to the Court for a ruling as to whether

24

the designated material may, in accordance with this Order, be properly

25

treated as confidential, provided such motion is made within thirty (30) days

26

from the date on which the Parties, after their good faith attempt, were unable

27

to resolve the dispute, or such other time period as the Parties may agree. The

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1

Designating Party shall have the burden of establishing that the disputed

2

document, transcript, material, item, or thing contains Confidential

3

Information entitled to protection under this Order.
F.

4

DOCUMENTS AND MATERIALS PREVIOUSLY DESIGNATED CONFIDENTIAL. This

5 Order shall apply to any document, transcript, material, item, or thing designated as Confidential

6 Information prior to the entry of this Order.

III. USE OF CONFIDENTIAL INFORMATION.

7

A. USE GENERALLY. All Confidential Information shall be used by the Parties, or

8

9

non-parties to whom Confidential Information is produced, disclosed, or otherwise made
this litigation and for no other

10

available as permitted by this Order, solely for the purposes of

11

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purpose without prior written approval from the Court or the prior written consent of the Parties.

13

revealed to anyone other than as provided under Section IV of

14

the manner set forth herein until such Confidentiality Legend is removed by the Designating

15

Party or by order of the Cour, as well as any other court which may be handling appeals in this

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this Order, and shall be handled in

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17

B.

18

1. Store and maintain such Confidential Information in a secure manner, within

their exclusive possession and control;

19

20

2. Take all measures reasonably necessary and appropriate to maintain the

confidentiality of such Confidential Information; and

21

3. Not permit or participate in the unauthorized production, disclosure, or use of

22
23

24

PROCEDURE. The Receiving Parties must proceed as follows:

such Confidential Information.

C.

LIMITED PURPOSE. Confidential Information shall be utilized by the Receiving

25 Parties and/or its counsel only for purposes of

this litigation and for no other purposes except that

26 the Receiving Parties, if necessary, may show Confidential Information to parties identified in

27 Section IV. Extracts, sumaries, copies, abstracts, or other documents, derived in whole or in
Page 6 of 13

1 part from material designated as Confidential Information, shall also be treated as confidential in

2 accordance with the provisions of this Stipulated Order.
D.

3

FILED DOCUMENTS. Any Party seeking to fie with the Cour, a pleading,

4 motion, or other paper containing or disclosing such Confidential Information shall request leave
5 to file the information under seaL. The documents and/or information shall be filed under seal

6 and shall bear the legend:

7

THIS DOCUMENT CONTAINS CONFIDENTIAL
INFORMATION COVERED BY A PROTECTIVE
ORDER OF THE COURT AND IS SUBMITTED
UNDER SEAL PURSUANT TO THAT PROTECTIVE
ORDER. THE CONFIDENTIAL CONTENTS OF
THIS DOCUMENT MAY NOT BE DISCLOSED
WITHOUT EXPRESS ORDER OF THE COURT.

8

9

10

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Any such filing of Confidential Information shall be done in a maner consistent with

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information under seaL. Moreover, said

federal custom and procedures regarding the filing of

13

Confidential Information shall be kept under seal until further order of the Cour; however, such

14

Confidential Information shall be available to the Court and counsel of record, and to all other

15

persons entited to receive Confidential Information under the terms of this Order. Upon failure

16

of

17

may do so after learning of

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the filing or lodging Party to properly file Confidential Information under seal, any other Party

the defective filing or lodging. Notice of such action shall be given

18 to all paries.
19

20

IV.
A.

ACCESS TO CONFIDENTIAL INFORMATION.

PERSONS ALLOWED ACCESS TO CONFIDENTIAL INFORMATION. Any

21 information, documents, transcripts, materials, items, or things designated or marked as
22 containing Confidential Information shall not be used or shown, disclosed, revealed,
23 disseminated, copied, or in any way communicated to any person or entity for any purpose

24 whatsoever; provided, however, that Confidential Information may be disclosed, revealed or

25 otherwise made available to the following recipients:

26
27

1. Personnel of the Parties actually engaged in assisting in the preparation of this

action for trial or other proceeding herein
Page 7 of 13

1

2. Counsel for the Parties to this action and their associated attorneys, paralegals,

2

and other professional personnel (including support staff) who are directly

3

assisting such counsel in the preparation of this action for trial or other

4

proceeding herein, and are under the supervision or control of such counsel;

5

3. Expert witnesses or consultants (and their associated personnel and staff)

6

retained by the Parties or their counsel to furnish technical or expert services

7

in connection with this action or to give testimony with respect to the subject

8

matter of this action at the trial of this action or other proceeding herein;

9

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4. The Cour and its personnel, jurors, and alternate jurors;

10

5. An officer before whom a deposition is taken, including stenographic

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reporters and any necessary secretarial, clerical, or other personnel of such

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officer;

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6. Outside photocopying, graphic production services, or litigation support

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services;

15

7. Trial and deposition witnesses; and

16

8. Any other person or non-party as to whom the Parties to this Order agree in

17

writing may be given access to any discovery material(s) containing

18

Confidential Information.

19

Notwithstanding the foregoing, if Confidential Information is disclosed to a witness,

20 expert, or other third party pursuant to subparagraphs (3), (7), or (8), the witness, expert, or third
21

party must execute the "Acknowledgment and Agreement to Be Bound," attached hereto as

22 Exhibit A, prior to the disclosure of any Confidential Information to such witness, expert, or
23

third pary. The executed Acknowledgment and Agreement to be Bound must be disclosed to all

24

Parties by no later than: (a) for testifying experts - the date of

25

report; (b) for deposition or trial witnesses - the date of

the disclosure of

the expert's

the deposition and/or the offering of

26 testimony at trial, prior to the disclosure of the Confidential Information; and (c) for all other
27 third parties - at least 7 days prior to the disclosure of the Confidential Information. With regard
Page 8 of 13

1 to the disclosure to witnesses and other third parties, under subparagraphs (b) and (c) in the

the

2 preceding paragraph, the Designating Party shall have five (5) business days from receipt of

3 Acknowledgment and Agreement to Be Bound to serve a written objection to disclosure and/or a

4 request for futher information. Any written objection shall state with specificity the reason(s)
5 for such objection. No disclosure of Confidential Information may be made to the witness or
6 third party until the Designating Party's objection is resolved by agreement of

the Parties or

7 court order.

8 If the Designating Party requests further information, the Party intending to disclose or
9 reveal the Confidential Information must, within 10 business days of the request, provide the

10 Designating Party with the following: (a) the specific Confidential Information intended to be

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1 1 disclosed or revealed; and (b) the general purpose for making the disclosure to the witness or
12 other third pary.

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Within five (5) days of

receipt of

the objection, the Parties shall meet and confer to

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14 attempt to resolve the objection. If an agreement is not reached, the Party proposing disclosure

15 to the witness or other third pary may fie a motion seeking permission to make the disclosure of
16 Confidential Information. On any such motion, the Designating Party shall bear the burden of
17 showing why disclosure to the witness or other third party should be precluded.

18 If a Party wishes to disclose Confidential Information to a consultant or consulting
19 expert, the consultant or consulting expert must execute the Acknowledgment and Agreement to

20 Be Bound prior to disclosure of the Confidential Information, a copy of which must be

21 maintained by counsel for the Pary. The consultant's or consulting expert's Acknowledgment

22 and Agreement to Be Bound need not be disclosed to the other Parties except upon agreement of

23 the Parties or court order.
24

B.

ENDORSEMENT OF STIPULATION AND PROTECTIVE ORDER. All persons or

25 entities obtaining, receiving, or being given access to Confidential Information, in accordance
26 with the terms and conditions of

this Order, consent to the continuing

jurisdiction of

27 for the purose(s) of enforcing this Order and/or remedying any violations thereof.

Page 9 of 13

the Court

V. INADVERTENT PRODUCTION OF CONFIDENTIAL
1 INFORMATION

WITHOUT A

DESIGNATION.

2 A. In the event a Designating Party inadvertently produces documents or information
3 that it considers to be or to contain Confidential Information, without having first designated the

4 material as such, the Designating Party may so designate it. Within thirty (30) days oflearning of
5 the inadvertent production of such material (or later with leave of Court or by agreement among
6 the Parties), the Designating Party must give written notice to all Parties that it claims that the
7 material is or contains Confidential Information, in whole or in part. Upon such notice, the

8 Designating Party shall provide all Parties who have received a copy of such materials with a

9 replacement copy marked with the Confidentiality Legend. All Parties receiving the replacement

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10 copy shall promptly destroy, sequester, or return to the Designating Party, the unmarked copy of
11

the materiaL.

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VI. RESERVATION OF RIGHTS.
A.

Notwithstanding the foregoing, this Order shall not be construed:

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1. To apply to any document(s) or information that has been or become part of

14
15

the public domain by publication or otherwise and not due to any

16

unauthorized act or omission on the part of the Receiving Parties; or

2. To apply to any document(s) or information that, under law, has been declared

17

to be in the public domain.

18

19

B.

Producing or receiving documents and other information in accordance with this

20 Order or failng to object thereto, shall not:
21

1. Constitute a waiver by any person or Party of any right to object to or seek a

22

further protective order with respect to any request for information in this or

23

in any other action;

24

2. Operate as an admission by any Party that any particular documents or other

25

information comprise or reflect trade secrets, proprietary information or any

26

other type of confidential information;

27
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1

the Parties to object to the

3. Prejudice or waive in any way, the rights of

2

production of documents they consider not subject to discovery for any reason

3

other than the confidentiality of

the documents;

4. Prejudice or waive in any way, the rights of any Party to object to the

4
5

authenticity, relevancy, or admissibility into evidence of any document,

6

testimony, or other evidence subject to the Stipulated Order; or

7

5. Prejudice or waive in any way, any claim or defense with respect to the

proceeding.

8

9

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C.

Nothing in this Order shall prevent any Party from using or disclosing its own

10 documents or information.
11

D. In the event that disclosure of any Confidential Information is sought from anyone

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other legal process, such person or entity shall, upon receipt of such request, notify the

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Designating Party within seven (7) days of the request for disclosure. The Designating Party

15

may then seek to prevent disclosure by filing a motion for protective order or take other

16

appropriate action and, if so, the Confidential Information shall not be disclosed until the

17

Designating Party's objection and/or motion for protective order has been resolved by agreement

18 of

19

the Parties or court order.
E.

This Order may be modified or amended by agreement of all parties, subject to

20 approval by the Court, or by order of the Court for good cause shown.
21

F.

This Order shall not act as a shield for any person or entity to refuse to disclose

22 any information that it is, by law, rule, and/or court order, obligated to disclose.
23

G.

This Order shall not be interpreted in a manner that would violate any applicable

24 canons of ethics or codes of professional responsibilty. Nothing in this Order shall prohibit or

25 interfere with the abilty of counsel for any Pary, or of experts specially retained for this case, to
26 represent any individual, corporation, or other entity adverse to any Party of

27 connection with any other matters.
Page 11 of 13

its affiiate(s) in

H.

1

In the event that any person or entity subject to this Order violates or gives reason

2 to believe that he or she wil violate this Order, the aggrieved Party shall be entitled to petition
3 the Court for an appropriate remedy.

VII.

4

A.

5

DURATION OF ORDER.

Absent prior written consent of all Parties, the terms and conditions of this Order

6 shall survive and remain in effect after the termination of this Case, including any appeals,
7 except that:

1. There shall be no restriction on documents that are used as exhibits in Court

8

9

t.

(unless such exhibits were fied under seal); and

2. A Party may seek the written permission of the Designating Pary or further

10

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order of

the Court with respect to dissolution or modification of

this Order.

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B.
This Order shall be binding upon the Parties, their counsel, successors, executors,
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14 divisions, employees, agents, independent contractors, or other persons or entities over which the

15 Parties have control or which purort to act on the Parties' behalves.
16

II /

17

II /

18

II /

19

II /

20 II /
21

II /

22 II /
23

II /

24 II /
25

II /

26 II /
27 II /
Page 12 of 13

1

C.

The Court shall retain continuing jurisdiction to enforce this Order, make any

2 such amendment(s), modification(s) and/or alteration(s) to this Order as may be appropriate,
3 and/or resolve any dispute(s) arising out of or concerning the use, production and/or disclosure

4 of Confidential Information as provided under this Order.

5
6 DATED this 13th day of

March, 2015.

DATED this 13th day of

March, 2015.

7

By: lsi Kelly B. Stout
8 Dennis L. Kennedy
Sarah E. Harmon
9
10

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Kelly B. Stout

BAILEY.:. KENNEDY
8984 Spanish Ridge Avenue

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Las Vegas, Nevada 89148
Attorneys for Plaintif

By: lsi Brian K. Terry
Brian K. Teny
Kenneth R. Lund
THORNDAL ARMSTRONG DELK
BALKENBUSH & EISINGER
1 100 East Bridger Avenue
Las Vegas, Nevada 89101

Attorneys for Defendants

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IT IS SO ORDERED:
15

16

UNITED STATES MAGISTRATE JUDGE

17
18

Dated:

19

Respectfully Submitted By:

20

21 By: lsi Kelly B. Stout
Dennis L. Kennedy
22 Sarah E. Harmon
Kelly B. Stout

23 BAILEY.:. KENNEDY
8984 Spanish Ridge Avenue
24 Las Vegas, Nevada 89148

25 Attorneys for Plaintif
26
27
Page 13 of 13

March 17, 2015

EXHIBIT A

EXHIBIT A

1 ENDORSEMENT OF STIPULATED CONFIDENTIALITY AGREEMENT
AND PROTECTIVE ORDER
2
I,

(print or type name), hereby

3

acknowledge and certify that I have received and read in its entirety a copy of the Stipulated
4

Confidentiality Agreement and Protective Order (the "Order") entered on the

day

of

5

, 2015, in the matter entitled McKenna v. David Z. Chesnoff Chtd P. c., Case
6
No. 2:

14-cv-1773-JAD-CWH (the "Case"), which is pending before the U.S. District Court in

7
the District of

Nevada (the "Court").

8

the Order, agree to comply with and be bound

I understand the terms and conditions of

9

by all of its provisions, and consent to the continuing jurisdiction of the Court with respect to
10

enforcement of the Order, even if such enforcement proceeding( s) occur after the case is
11

the

terminated. I futher acknowledge that failure to comply with the terms and/or conditions of

12

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Order could expose me to sanctions and punishment in the nature of contempt.

I agree that I shall not use or disclose any Confidential Information (as defined in the

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Order) for any purpose other than as provided in the Order. I wil maintain any Confidential
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Information in a safe and secure manner.

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DATED this

day

,20_.

of

17
18

Signature
19

20

Printed Name

21

Company
22
23

Street Address

24

City, State Zip Code
25

26

Phone Number

27
28

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