Federal Deposit Insurance Corporation v. 26 Flamingo, LLC et al
Filing
65
PROTECTIVE ORDER. Signed by Magistrate Judge Nancy J. Koppe on 2/11/13. (Copies have been distributed pursuant to the NEF - EDS)
<![CDATA[
Case 2:11-cv-01936-JCM-NJK Document 64
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SPO
GORDON SILVER
ERIC OLSEN
Nevada Bar No. 3127
E-mail: ero@gordonsilver.com
JOEL Z. SCHWARZ
Nevada Bar No. 9181
E-mail: jschwarz@gordonsilver.com
DYLAN T. CICILIANO
Nevada Bar No. 12348
E-mail: dciciliano@gordonsilver.com
3960 Howard Hughes Pkwy., 9th Floor
Las Vegas, Nevada 89169
Fax: (702) 369-2666
Tel: (702) 796-5555
Filed 02/08/13 Page 1 of 12
LAW OFFICE OF GLENN WARD
CALSADA
GLENN WARD CALSADA
California Bar No. 134589
Admitted Pro Hac Vice
Email: glenn@calsadalaw.com
9924 Reseda Boulevard
Northridge, CA 91324
Tel: (818) 477-0314
Fax: (818) 473-4277
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BROWNSTEIN HYATT FARBER SCHRECK
KIRK LENHARD
Nevada Bar No. 1437
Email: KLenhard@BHFS.com
ALISA NAVE-WORTH
Nevada Bar No. 9272
Email: ANave-Worth@BHFS.com
100 N. City Parkway, #1600
Las Vegas, NV 89106
Tel: (702) 464-7045
Fax: (702) 382-8135
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Attorneys for Defendant/Counterclaimant 26 Flamingo, LLC
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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FEDERAL DEPOSIT INSURANCE
CORPORATION, AS RECEIVER FOR
COMMUNITY BANK OF NEVADA,
CASE NO. 2:11-cv-01936-JCM-RJJ
STIPULATED PROTECTIVE ORDER
Plaintiff,
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AS MODIFIED
(Paragraph 18)
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vs.
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26 FLAMINGO, LLC; OUTBACK
STEAKHOUSE OF FLORIDA, LLC, a Foreign
Limited Liability Company; DOE
INDIVIDUALS 1 through 10; and ROE
CORPORATIONS 1 through 10,
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Defendants.
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Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
1 of 12
103239-001/1802389
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Filed 02/08/13 Page 2 of 12
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Pursuant to Federal Rule of Civil Procedure 26(c), Defendant/Counterclaimaint 26
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FLAMINGO, LLC (“Defendant”), by and through counsel, the law firms of Gordon Silver;
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Brownstein Hyatt Farber Schreck; and the Law Offices of Glenn Ward Calsada, and
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Plaintiff/Counterdefendant Federal Deposit Insurance Corporation, as Receiver for Community
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Bank of Nevada (“Plaintiff,” together with Defendant, the “Parties”), by and through counsel, the
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law firm of Meier & Fine, LLC, hereby stipulate and agree that discovery in this Civil Action
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(“Action”) may involve the disclosure of certain documents, things and information that
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constitute or contain trade secrets or other confidential research, development or commercial
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information within the meaning of Rule 26(c) of the Federal Rules of Civil Procedure (“Fed. R.
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Civ. P.”), which must be protected in order to preserve legitimate business or privacy interests.
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Accordingly, good cause exists for the entry of this Protective Order pursuant to Fed. R. Civ. P.
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26(c) to protect against improper disclosure or use of confidential information produced or
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disclosed in this case. The Parties further stipulate and agree, subject to the approval of the
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Court, that the terms and conditions of this Stipulated Protective Order shall govern the handling
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of documents, depositions, pleadings, exhibits and all other information exchanged by the parties
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in this Civil Action, or provided by or obtained from non-parties in this Action.
SCOPE
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1. This Stipulated Protective Order shall apply to all documents, depositions, pleadings,
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exhibits and all other material or information subject to discovery in this Action, including
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responses to requests for production of documents, answers to interrogatories, responses to
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requests for admissions, deposition testimony, expert testimony and reports, and all other
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discovery taken pursuant to the Federal Rules of Civil Procedure, matters in evidence and any
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other information hereafter furnished, directly or indirectly, by or on behalf of any party, non-
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party or witness in connection with this Action (“Discovery Material”).
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2. As used herein, “Producing Party” shall refer to any party to this Action and to any non-
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party who produces Discovery Material, and “Receiving Party” shall refer to any individual who
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properly receives, is shown or is exposed to Discovery Material.
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Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
2 of 12
103239-001/1802389
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Filed 02/08/13 Page 3 of 12
DESIGNATION
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3. Any Producing Party may designate Discovery Material as “CONFIDENTIAL” in
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accordance with this Stipulated Protective Order if such party in good faith believes that such
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Discovery Material contains CONFIDENTIAL information as defined in Paragraph 4. The
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burden of establishing that Discovery Material is CONFIDENTIAL as defined herein shall be on
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the Producing Party. The designation of any Discovery Material as CONFIDENTIAL shall be
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deemed effective unless and until the Court orders otherwise or the Producing Party withdraws
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the designation.
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4. As used herein, CONFIDENTIAL Discovery Material refers to information that a
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Producing Party claims to be proprietary business information or information relating to the
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personal records or information of individuals or entities that are not parties to the above
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captioned matter.
USE
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5. Discovery Material designated CONFIDENTIAL under this Stipulated Protective Order
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may be used only for purposes of this litigation and any appeal therefrom, and shall not be used
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for any other purpose including, but not limited to, any business, proprietary, commercial,
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governmental or other legal purpose, including in connection with any other litigation, arbitration
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or claim. Nothing in this Stipulated Protective Order precludes a Producing Party from using or
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disseminating its own CONFIDENTIAL information.
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6. During the course of preparing for a deposition or trial, unless otherwise entitled to
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access under this Protective Order, a fact deponent or witness may be shown CONFIDENTIAL
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Discovery Material of another party or third party if, and only if, the Discovery Material reveals
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on its face that the deponent or witness authored or received the Discovery Material in the
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ordinary course of business and outside the context of this litigation. Nothing in this Paragraph
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shall preclude a Producing Party from showing Discovery Material that it has produced to its
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own deponent or witness, regardless of whether the Producing Party has designated the
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Discovery Material it produced as CONFIDENTIAL, and regardless of whether such deponent
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or witness is an author or recipient of the Discovery Material.
Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
3 of 12
103239-001/1802389
Case 2:11-cv-01936-JCM-NJK Document 64
Filed 02/08/13 Page 4 of 12
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7. During the course of a deposition or trial, unless otherwise entitled to access under this
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Protective Order, a fact deponent or witness may be shown CONFIDENTIAL Discovery
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Material of another party or third party, if and only if, the Discovery Material reveals on its face
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that the deponent or witness authored or received the Discovery Material in the ordinary course
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of business and outside the context of this litigation, or alternatively if foundation testimony or
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other Discovery Material establishes that the deponent or witness authored or received the
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Discovery Material in the ordinary course of business and outside the context of this litigation, or
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until such person has executed the Declaration and Undertaking to Be Bound by Stipulated
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Protective Order in the form attached as Exhibit A. A fact deponent or witness who is an officer,
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director or employee of a Producing Party may be shown any CONFIDENTIAL Discovery
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Material of the Producing Party of which he or she is an officer, director or employee.
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8. All Discovery Material designated CONFIDENTIAL shall be protected from disclosure
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as specified herein, unless a party obtains an Order of the Court declaring that all or certain
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portions of such Discovery Material are not, in fact, protected.
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9. Third parties may designate as CONFIDENTIAL transcripts of depositions of their
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witnesses and any documents or information they produce, whether voluntarily or by subpoena,
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to the same extent and in the same manner as parties to this Action, and any such Discovery
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Material shall be treated by parties to this Action in the same manner as materials and
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information so designated by a party. Third parties shall have the same rights and obligations
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under this Stipulated Protective Order as parties and may move the Court to enforce the
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provisions of this Stipulated Protective Order.
DISCLOSURE
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10. Unless otherwise directed by the Court or authorized in writing by the Producing Party,
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Discovery Material designated as CONFIDENTIAL may be disclosed by the Receiving Party
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only to the following persons:
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(a)
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employed by firms of record even if not otherwise identified specifically on
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pleadings;
Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
any outside counsel of record in this Action, including any attorneys
4 of 12
103239-001/1802389
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Filed 02/08/13 Page 5 of 12
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(b)
support personnel for counsel identified in Paragraphs 10(a), such as law
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clerks, analysts, paralegals, litigation assistants, secretaries and support staff;
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(c)
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retained by counsel identified in Paragraph 10(a) to assist in the preparation of
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this Action for trial, with disclosure only to the extent necessary to perform such
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work;
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(d)
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testimony;
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(e)
any outside expert or consultant who is expressly retained or sought to be
any court reporter, shorthand reporter or typist recording or transcribing
service contractors such as document copy services, trial technology
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consultants, jury consultants and graphic artists;
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(f)
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and
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(g)
personnel of the Court and all appropriate courts of appellate jurisdiction;
any other person agreed to by the Producing Party in writing.
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11. CONFIDENTIAL Discovery Material shall not be disclosed to any person described in
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Paragraphs 10(c), (e) or (g) unless and until such person has executed the Declaration and
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Undertaking to Be Bound by Stipulated Protective Order in the form attached as Exhibit A.
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CONFIDENTIAL Discovery Material shall not be disclosed to any person unless such person is
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authorized to receive CONFIDENTIAL Discovery Material pursuant to Paragraph 10 of this
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Stipulated Protective Order.
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12. As a condition precedent to disclosure of CONFIDENTIAL Discovery Material, at least
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seven (7) calendar days before the disclosure of any CONFIDENTIAL Discovery Material of
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any Producing Party is made to an individual described above in Paragraphs 10(a) or (c), counsel
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for the Receiving Party shall serve a Notice on the Producing Party identifying the individual by
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name and including a curriculum vitae or equivalent resume disclosing the individual’s
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employment history, past or present relationship with any of the parties, and an executed
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acknowledgement from the individual to whom the disclosure is to be made, in the form of
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Exhibit A attached hereto. Prior to disclosure of any CONFIDENTIAL Discovery Material
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produced by another party, the other party shall have seven (7) calendar days from receipt of the
Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
5 of 12
103239-001/1802389
Case 2:11-cv-01936-JCM-NJK Document 64
Filed 02/08/13 Page 6 of 12
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executed acknowledgement and curriculum vitae or resume to object to such disclosure. In the
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event of an objection to the proposed disclosure, the parties shall promptly confer in good faith
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to resolve the concerns giving rise to the objection. If the parties are unable to reach agreement
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regarding such disclosure, the objecting party must notify the Court on an expedited basis, and in
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no event later than fifteen (15) calendar days after receipt of the executed acknowledgement and
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curriculum vitae or resume. The burden shall be on the objecting party to demonstrate to the
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Court why the proposed disclosure should not be made. CONFIDENTIAL Discovery Material
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shall not be disclosed to such an individual pending the Court’s resolution of the dispute. The
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foregoing seven (7) and fifteen (15) calendar day periods may be extended by agreement of the
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parties or by Order of the Court.
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13. The recipient of any CONFIDENTIAL Discovery Material that is provided under this
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Stipulated Protective Order shall maintain such information in a secure and safe area and shall
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exercise reasonable and proper care with respect to the storage, custody, use and/or
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dissemination of such information.
INADVERTENT PRODUCTION/DESIGNATION
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14. The inadvertent production of a document subject to attorney-client privilege or work
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product immunity will not waive attorney-client privilege or work product immunity.
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addition, the fact that a document was inadvertently produced shall not be used in any manner as
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evidence in support of any alleged waiver of attorney-client privilege or work product immunity.
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If a party has inadvertently produced a document subject to a claim of attorney-client privilege or
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work product immunity, upon request, the document and all copies thereof shall be returned
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promptly, and in no event later than five (5) calendar days, after a request is made by the
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Producing Party, as required by Fed. R. Civ. P. 26(b)(5)(B). Moreover, any notes or summaries,
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other than those expressly permitted under this section, referring to or relating to any such
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inadvertently produced document subject to a claim of attorney-client privilege or work product
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immunity shall be destroyed. Nothing herein shall prevent the Receiving Party from preparing a
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record for its own use containing the date, author, address(es) and other such information as is
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reasonably necessary to identify the document and generally describe its nature to the Court in
Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
6 of 12
103239-001/1802389
In
Case 2:11-cv-01936-JCM-NJK Document 64
Filed 02/08/13 Page 7 of 12
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any motion to compel production of the document. Such a record of the identity and nature of a
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document may not be used for any purpose other than preparation of a motion to compel in this
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Action. After return of the document(s), the Receiving Party may challenge the Producing
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Party’s claim(s) of attorney-client privilege or work product immunity by making a motion to the
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Court.
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15. The inadvertent failure by a Producing Party to designate Discovery Material as
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CONFIDENTIAL shall not be a waiver of such designation provided that the Producing Party
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promptly informs the Receiving Party that such Discovery Material is CONFIDENTIAL, and in
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any event not more than five (5) business days from when the failure to designate first became
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known to the Producing Party. The inadvertent failure by a party to designate Discovery
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Material as CONFIDENTIAL shall not preclude the filing of a motion at a later date seeking to
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impose such designation or challenging the propriety thereof. The party receiving Discovery
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Material that the Producing Party inadvertently failed to designate as CONFIDENTIAL shall not
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be in breach of this Order for any use made of such Discovery Material before the Receiving
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Party is informed of the inadvertent failure to designate. Once the Receiving Party has been
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informed of the inadvertent failure to designate pursuant to this Paragraph, the Receiving Party
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shall take reasonable steps to, at the Producing Party’s option, either ensure that all copies of any
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such Discovery Materials are returned promptly to the Producing Party or ensure that all copies
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of any such Discovery Materials are marked with the proper designation and distributed only as
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permitted under this Stipulated Protective Order.
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16. In the event of disclosure of Discovery Material designated CONFIDENTIAL to any
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person not authorized to such access under this Stipulated Protective Order, the party responsible
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for having made such disclosure, and each party with knowledge thereof, shall immediately
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inform counsel for the party whose Discovery Material has been disclosed of all known relevant
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information concerning the nature and circumstances of the disclosure. The party responsible for
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improperly disclosing such Discovery Material shall also promptly take all reasonable measures
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to retrieve the improperly disclosed Discovery Material and to ensure that no further or greater
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unauthorized disclosure and/or use thereof is made.
Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
7 of 12
103239-001/1802389
Case 2:11-cv-01936-JCM-NJK Document 64
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OBJECTIONS TO DESIGNATIONS
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17. Any party may object to the designation by the Producing Party of any Discovery
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Material as CONFIDENTIAL. The process for making such an objection and for resolving the
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dispute shall be as follows:
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(a)
The objecting party shall notify the Producing Party in writing as to its
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objection(s) to the designations. This notice shall include, at a minimum, a
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specific identification of the designated Discovery Material objected to as well as
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the reason(s) for the objection.
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(b)
The objecting party shall thereafter have the burden of conferring either in
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person or by telephone with the Producing Party claiming protection, as well as
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any other interested party, in a good faith effort to resolve the dispute.
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(c)
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that the Discovery Material sought to be protected is not entitled to such
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designation. The Producing Party bears the burden to establish that the Discovery
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Material is CONFIDENTIAL and entitled to such protection under this Stipulated
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Protective Order.
Failing agreement, the objecting party may move the Court for a ruling
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18.18. Any Discovery Material designated CONFIDENTIAL under filedStipulated Court
Any documents designated as CONFIDENTIAL that are this with the Protective
shall be filed in Compliance with Local Rule 10-5(b) and the Court's order issued
Order that is filed with or submitted in camera to the Court by any party, including transcripts of
concurrently with this protective order.
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depositions or portions thereof, documents produced in discovery, information obtained from
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inspection of premises or things, and answers to interrogatories or requests for admissions,
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exhibits and all other documents which have previous thereto been designated as containing
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CONFIDENTIAL Discovery Material or any pleading or memorandum reproducing or
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containing such information, shall be filed or submitted in sealed envelopes bearing the title of
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this action and the notation:
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CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER
This document contains confidential information covered by a Stipulated
Protective Order of the Court and is submitted under seal or in camera
pursuant to that Order. The confidential contents of this document may not
be disclosed without express order of the Court.
Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
8 of 12
103239-001/1802389
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All such sealed envelopes shall not be opened except for the sole use of the Court or its
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employees or as otherwise ordered by the Court. Further, all such sealed envelopes shall be
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maintained by the Clerk of the Court separate from public records in these actions and shall be
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released only upon further order of the Court.
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19. Notwithstanding any such challenge to the designation of Discovery Material as
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CONFIDENTIAL, all such Discovery Material so designated shall be treated as such and shall
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be subject to the provisions of this Stipulated Protective Order until either the party who
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designated the Discovery Material as CONFIDENTIAL withdraws such designation in writing
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or the Court rules that the designation is not proper and that the designation be removed.
RETURN/DESTRUCTION OF MATERIALS
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20. Not later than sixty (60) calendar days after the termination of this Action, all
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CONFIDENTIAL Discovery Material, including all copies thereof, shall be returned to the
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Producing Party or destroyed, such election to be made by the Receiving Party, except that each
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party’s outside counsel may retain all papers filed with the Court, transcripts of testimony and
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exhibits, expert reports, discovery requests and responses, correspondence and their own work
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product containing CONFIDENTIAL information for archival purposes, and provided that such
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counsel shall not disclose any party’s CONFIDENTIAL Discovery Material contained therein to
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any person or entity except pursuant to a written agreement with the Producing Party or as
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otherwise provided in this Stipulated Protective Order. Not later than seventy-five (75) calendar
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days after the termination of this Action, the party receiving any CONFIDENTIAL Discovery
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///
Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
9 of 12
103239-001/1802389
Case 2:11-cv-01936-JCM-NJK Document 64
1
Filed 02/08/13 Page 10 of 12
Material shall certify in writing that all such material has been returned or destroyed.
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IT IS SO STIPULATED.
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DATED this
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GORDON SILVER
MEIER & FINE, LLC
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/s/ Joel Z. Schwarz
/s/ Peter Dunkley
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ERIC R. OLSEN
Nevada Bar No. 3127
JOEL Z. SCHWARZ
Nevada Bar No. 9181
DYLAN T. CICILIANO
Nevada Bar No. 12348
3960 Howard Hughes Pkwy., 9th Floor
Las Vegas, Nevada 89169
Tel: (702) 796-5555
GLENN R. MEIER
Nevada Bar No.6059
PETER E. DUNKLEY
Nevada Bar No. 11110
2300 West Sahara Avenue, Suite 1150
Las Vegas, NV 89102
Tel: (702) 673-1000
Attorneys for Federal Deposit Insurance
Corporation, as Receiver for Community Bank
of Nevada
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day of February, 2013.
DATED this
day of February, 2013.
BROWNSTEIN HYATT FARBER SCHRECK
KIRK LENHARD
Nevada Bar No. 1437
ALISA NAVE-WORTH
Nevada Bar No. 9272
100 N. City Parkway, #1600
Las Vegas, NV 89106
Tel: (702) 464-7045
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LAW OFFICES OF GLENN WARD CALSADA
GLENN WARD CALSADA
California Bar No. 134589
Admitted Pro Hac Vice
9924 Reseda Boulevard
Northridge, CA 91324
Tel: (818) 477-0314
Attorneys for 26 Flamingo, LLC
IT IS HEREBY ORDERED:
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____________________________________
UNITED STATES DISTRICT COURT
United States Magistrate Judge
JUDGE
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February 11, 2013
Dated:______________________________
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Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
10 of 12
103239-001/1802389
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Filed 02/08/13 Page 11 of 12
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EXHIBIT A
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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FEDERAL DEPOSIT INSURANCE
CORPORATION, AS RECEIVER FOR
COMMUNITY BANK OF NEVADA,
CASE NO. 2:11-cv-01936-JCM-RJJ
DECLARATION AND UNDERTAKING
TO BE BOUND BY STIPULATED
PROTECTIVE ORDER
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Plaintiff,
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vs.
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26 FLAMINGO, LLC; OUTBACK
STEAKHOUSE OF FLORIDA, LLC, a Foreign
Limited Liability Company; DOE
INDIVIDUALS 1 through 10; and ROE
CORPORATIONS 1 through 10,
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Defendants.
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I, __________________________________________________________, declare that:
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1.
My residence address is _____________________________________________.
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2.
My current employer is ______________________________________________
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and
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_________________________________________.
the
address
of
my
current
employment
is
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3.
My current occupation or job description is ______________________________.
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4.
[Experts Only] A copy of my curriculum vitae is attached hereto.
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5.
I have received and read the Stipulated Protective Order in this Action dated
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_________________________, and I understand its provisions. I agree (a) to be bound by the
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terms of the Stipulated Protective Order, (b) to use CONFIDENTIAL Discovery Material solely
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for this action and (c) not to disclose any CONFIDENTIAL Discovery Material to any person,
25
firm, corporation or other entity not qualified to have access to such information pursuant to the
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terms of the Stipulated Protective Order.
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///
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///
Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
11 of 12
103239-001/1802389
Case 2:11-cv-01936-JCM-NJK Document 64
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6.
Filed 02/08/13 Page 12 of 12
Upon termination of this Action, I will destroy or return to retaining counsel all
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CONFIDENTIAL Discovery Material and summaries, abstracts and indices thereof that come in
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my possession, and documents of things that I have prepared relating thereto.
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7.
I hereby submit to the jurisdiction of the United States District Court for the
5
District of Nevada for the purpose of enforcement of the Stipulated Protective Order. I
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understand that if I violate the provisions of the Stipulated Protective Order, I will be in violation
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of a Court Order and subject to sanctions or other remedies that may be imposed by the Court
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and may be liable in civil action by one or more of the parties in this Action.
I declare under penalty of perjury under the laws of the United States of America
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that the foregoing is true and correct.
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______________________________
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___________________________________
Date
Signature
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Gordon Silver
Attorneys At Law
Ninth Floor
3960 Howard Hughes Pkwy
Las Vegas, Nevada 89169
(702) 796-5555
12 of 12
103239-001/1802389
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