Shaw v. NP Santa Fe, LLC et al, No. 2:2018cv00515 - Document 35 (D. Nev. 2018)
Court Description: ORDER Granting 31 Stipulation re Protective Order. Signed by Magistrate Judge Peggy A. Leen on 12/17/2018. (Copies have been distributed pursuant to the NEF - MR)
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Shaw v. NP Santa Fe, LLC et al 1 2 3 4 5 Doc. 35 Margaret A. McLetchie, NBN 10931 Alina M. Shell, NBN 11711 MCLETCHIE LAW 701 East Bridger Ave., Suite 520 Las Vegas, NV 89101 Telephone: (702) 728-5300 Attorneys for Plaintiff, Tony Shaw UNITED STATES DISTRICT COURT 6 DISTRICT OF NEVADA 7 8 TONY SHAW, 9 10 Case. No.: 2:18-cv-00515-JCM-PAL Plaintiff, [PROPOSED] STIPULATED PROTECTIVE ORDER vs. 11 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 14 15 NP SANTA FE, LLC DBA SANTA FE STATION HOTEL & CASINO, a Nevada Limited Liability Company; STATION CASINOS, LLC, a Nevada Limited Liability Company; and RED ROCK RESORTS, INC., a Delaware corporation, 16 Defendants. 17 18 The parties to this action, by their respective counsel, having agreed to the 19 following, and for good cause shown pursuant to Fed. R. Civ. P 26(c)(1), IT IS HEREBY 20 ORDERED as follows: 21 1. PURPOSES AND LIMITATIONS. 22 Disclosure and discovery activity in this action may involve production of 23 confidential, proprietary, or private information for which special protection from public 24 disclosure may be warranted pursuant to Rule 26(c)(1) of the Federal Rules of Civil 25 Procedure. The parties acknowledge that this Order does not confer blanket protections on 26 all disclosures or responses to discovery and that the protection it affords extends only to 27 the limited information or items that are entitled under law to treatment as confidential. 28 /// 1 Dockets.Justia.com Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 2 of 17 1 2. 2 All documents produced in the course of discovery, all responses to discovery 3 requests, and all deposition testimony and exhibits and any other materials which may be 4 subject to discovery (hereinafter collectively “Discovery Material”) shall be subject to this 5 stipulated protective order concerning confidential information as set forth below. Any 6 party, or any third party who produces documents in this litigation, may designate 7 documents as CONFIDENTIAL but only after review of the documents by an attorney who 8 has, in good faith, determined that the documents contain “Confidential Information,” as 9 defined below, and pursuant to the procedure set forth below. ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 10 3. SCOPE. CONFIDENTIAL INFORMATION. 11 “Confidential Information” shall mean information meriting special protection 12 under the Federal Rules of Civil Procedure and applicable case law. Confidential 13 Information does not include information that: (a) is in the public domain at the time of 14 disclosure; (b) becomes part of the public domain through no fault of the Receiving Party; 15 (c) the Receiving Party can show was in its rightful and lawful possession at the time of 16 disclosure; or (d) the Receiving Party lawfully receives from a Non-party later without 17 restriction as to disclosure. 18 4. 19 Party: any party to this action, including all of its officers, directors, agents, and 20 attorney(s) of record for a Party in this action (including their associates, paralegals, and 21 support/ clerical staff). 22 23 OTHER DEFINITIONS. Non-party: any individual, corporation, association, or natural person or entity other than a party. 24 Protected Material: any Discovery Material containing Confidential Information 25 that is designated by a Party or Non-party as “CONFIDENTIAL,” unless the Receiving 26 Party challenges the confidentiality designation and (a) the Court decides such material is 27 not entitled to protection as confidential; (b) the Designating Party fails to apply to the Court 28 for an order designating the material confidential within the time period specified below; or 2 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 3 of 17 1 (c) the Designating Party withdraws its confidentiality designation in writing. 2 3 action. 4 Receiving Party: a Party that receives Discovery Material from a Producing Party. 5 Designating Party: a Party or Non-party that designates Discovery Material as 6 “CONFIDENTIAL”. The Party or Non-party designating information or items as Protected 7 Material bears the burden of establishing good cause for the confidentiality of all such items. 8 Challenging Party: a party that elects to initiate a challenge to a Designating 9 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM Producing Party: a Party or Non-party that produces Discovery Material in this Party’s confidentiality designation. 10 5. 11 Protected Material shall be so designated by the Producing Party by placing or 12 affixing the word “CONFIDENTIAL” on the document in a manner which will not interfere 13 with the legibility of the document and which will permit complete removal of the 14 “CONFIDENTIAL” designation. Documents shall be designated “CONFIDENTIAL” prior 15 to, or contemporaneously with, the production or disclosure of the documents. FORM AND TIMING OF DESIGNATION. 16 A Designating Party must exercise restraint and make good faith efforts to limit 17 CONFIDENTIAL designations to specific materials that qualify for protection under the 18 appropriate standard. Further, a Designating Party must use good faith efforts to designate 19 for protection only those parts of material, documents, items, or communications that 20 qualify – so that other portions of the materials, documents, items, or communications for 21 which protection is not warranted are not swept unjustifiably within the ambit of this Order. 22 If only a portion or portions of materials on a page or within a document merit protection, a 23 Producing Party must so indicate by making appropriate markings in the margins but not 24 over text or by redacting protected portions. 25 A Confidentiality Log must accompany any production of Protected Material that 26 includes the Bates numbers of the documents designated (or the portions thereof) as 27 “Confidential” and the basis for doing so. A certification by the reviewing attorney shall be 28 made concurrently with the disclosure of the document using the form attached hereto as 3 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 4 of 17 1 Exhibit A which shall be executed subject to the standards of Rule 11 of the Federal Rules 2 of Civil Procedure, and shall be accompanied by a Confidentiality Log in the form included 3 at Exhibit A. If an unrepresented Non-party is a Producing Party and desires to designate 4 documents as Confidential as a Designating Party, a certification need not be executed but 5 a Confidentiality Log of all confidential designations still must be provided. 6 A Producing Party that makes original documents or materials available for 7 inspection need not designate them for protection until after the inspecting Party has 8 indicated which material it would like copied and produced. During the inspection and 9 before the designation, all of the material made available for inspection shall be deemed 10 “Confidential.” After the inspecting Party has identified the documents it wants copied and 11 produced, the Producing Party must determine which documents, or portions thereof, 12 qualify for protection under this Order, and, before producing the specified documents, the 13 Producing Party must affix the appropriate legend on each page that contains Protected 14 Material. If only a portion or portions of the material on a page qualifies for protection, the 15 Producing Party also must clearly identify the protected portion(s) (e.g., by making 16 appropriated markings in the margins or by redacting protected portions). 17 Portions of depositions shall be designated CONFIDENTIAL when the deposition 18 is taken or within fourteen (14) business days after receipt of the transcript, if feasible. Such 19 designation shall be specific as to the portions to be protected. A Designating Party must 20 exercise restraint and make good faith efforts to limit “CONFIDENTIAL” designations to 21 specific materials that qualify for protection under the appropriate standards. 22 Inadvertent or unintentional production of Protected Material without prior 23 designation as “CONFIDENTIAL” shall not be deemed a waiver, in whole or in part, of the 24 right to designate documents as Protected Material as otherwise allowed by this Order. 25 Further, a Party may assert that disclosures or discovery material produced by another Party 26 constitute Protected Material by informing the opposing Party by following the procedures 27 set forth herein for a Designated Party. 28 /// 4 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 5 of 17 1 6. 2 a. General Protections. Protected Material shall not be used or disclosed by the 3 parties or counsel for the parties or any other persons identified below (¶ 6.b.) for any 4 purposes whatsoever other than preparing for and conducting litigation in the above-entitled 5 action (including any appeal). 6 b. Qualified Receiving Parties and Limited Third Party Disclosures. Protected 7 Material shall be held in confidence by each qualified Receiving Party to whom it is 8 disclosed, shall be used only for purposes of this action, and shall not be disclosed to any 9 person who is not a qualified recipient. All Protected Material shall be carefully maintained 10 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM PROTECTION OF PROTECTED MATERIAL. so as to preclude access by persons who are not qualified Receiving Parties. 11 Subject to these requirements, in addition to Parties and the Court, the following 12 categories of persons may be allowed to review Protected Material pursuant to this Order 13 after executing an acknowledgment (in the form set forth at Exhibit B hereto), that he or she 14 has read and understands the terms of this Order and is bound by it: 15 (1) Any officers, directors, or designated employees of a Party deemed 16 necessary by counsel of record in this action to aid in the 17 prosecution, defense, or settlement of this action; 18 19 (2) Professional outside vendors for attorneys of record (such as copying services and translators and interpreters), 20 (3) Court reporters, deposition notaries and staff; 21 (4) The author of any document designated as CONFIDENTIAL or the 22 original source of Confidential Information contained therein; 23 (5) Persons other than legal counsel who have been retained or 24 specially employed by a party as an expert witness for purposes of 25 this lawsuit or to perform investigative work or fact research; 26 (6) Deponents during the course of their depositions; 27 (7) Counsel for issuers of insurance policies under which any issuer 28 may be liable to satisfy part or all of a judgment that may be entered 5 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 6 of 17 1 in these proceedings or indemnify or reimburse payments or costs 2 associated with these proceedings; 3 (8) Any private mediator or arbitrator appointed by the Court or 4 selected by mutual agreement of the parties and the mediator or 5 arbitrator’s secretarial and clerical personnel; 6 (9) Any other person as to whom the Producing Party has consented 7 to disclosure in advance and in writing, on notice to each Party 8 hereto. 9 c. Control of Documents. Counsel for Parties shall take reasonable efforts to 10 prevent unauthorized disclosure of Protected Material pursuant to the terms of this Order. 11 No copies of Protected Material shall be made except by or on behalf of attorneys of record, 12 in-house counsel or the parties in this action. 13 d. Copies. Any person making copies of Protected Material shall maintain all 14 copies within their possession or the possession of those entitled to access to such 15 information under the Protective Order. All copies shall be immediately affixed with the 16 designation “CONFIDENTIAL” if the word does not already appear on the copy. All such 17 copies shall be afforded the full protection of this Order. 7. UNAUTHORIZED DISCLOSURE. 18 19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 20 Protected Material to any person or in any circumstance not authorized under this Stipulated 21 Protective Order, the Receiving Party must immediately (a) notify in writing the 22 Designating Party of the unauthorized disclosure(s), (b) use its best efforts to retrieve all 23 copies of the Protected Material, (c) inform the person or persons to whom unauthorized 24 disclosure(s) were made of all the terms of this Order, and (d) request such person or persons 25 to execute the “Acknowledgment and Agreement to Be Bound by Stipulated Protective 26 Order” (Exhibit A). 27 /// 28 /// 6 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 7 of 17 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 1 8. FILING PROTECTED MATERIAL 2 Subject to the Federal Rules of Evidence, Protected Material may be filed with the 3 Court or offered in evidence or hearing or trial of this case. This Order does not seal court 4 records in this case or apply to disclosure of Protected Material at trial. Further, the parties 5 understand that documents may be filed under seal only with the permission of the Court 6 after proper motion. Further, the fact that documents have been designated as 7 “CONFIDENTIAL” shall not be admissible evidence that the documents in fact contain 8 information entitled to protection from disclosure under the law. 9 However, in the event a Party seeks to file Protected Materials with the Court, 10 those documents shall be filed under seal pursuant to Rule 10-5 of the Local Rules of 11 Practice for the U.S. District Court of Nevada. The Party filing such Protected Materials 12 may assert in the accompanying motion any reasons why the Protected Materials should 13 not, in fact, be kept under seal and the Designating Party, who must be properly noticed, 14 may likewise file a motion asserting its position that the Protected Material merits protection 15 under Rule 26(c) of the Federal Rules of Civil Procedure and attaching a declaration 16 supporting the assertion that the designated material meets the applicable standard. In such 17 instances, absent extraordinary circumstances making prior consultation impractical or 18 inappropriate, the Party seeking to submit the Protected Materials to the Court shall first 19 consult with counsel for the Designating Party. 20 Further, the Parties recognize the presumption of public access inherent in judicial 21 records and that a Protective Order does not establish that documents meet the “standard for 22 sealing set forth in Rule 10-5 of the Local Rules of Practice for the U.S. District Court of 23 Nevada and the Ninth Circuit’s decisions in Kamakana v. City and County of Honolulu, 447 24 F.3d 1172 (9th Cir. 2006) and Ctr. for Auto Safety v. Chrysler Group, LLC, 809 F.3d 1092, 25 1097 (9th Cir. 2016), cert. denied sub nom. FCA U.S. LLC v. Ctr. for Auto Safety, 137 S. 26 Ct. 38 (2016). “A party seeking to seal a judicial record then bears the burden of overcoming 27 this strong presumption by meeting the ‘compelling reasons' standard.” Kamakana, 447 28 F.3d at 1178. The only exception to this rule is that only good cause need be established 7 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 8 of 17 1 “for sealed materials attached to a discovery motion unrelated to the merits of a case.” 2 Chrysler Group¸809 F. 3d at 1097 (citing Phillips ex rel. Estates of Byrd v. Gen. Motors 3 Corp., 307 F.3d 1206, 1213–14 (9th Cir.2002).). Further, the Court should make an 4 independent determination regarding whether documents merits sealed status, and thus 5 expressly reserves the right to do. Kamakana, 447 F.3d at 1186-87. 6 9. 7 Any designation of Protected Material is subject to challenge. The following 8 procedures shall apply to any such challenge: a. Burden. The burden of proving the necessity of a “CONFIDENTIAL” 9 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 10 CHALLENGES TO PROTECTED MATERIAL. designation remains with the party asserting confidentiality. 11 b. Notice; Opportunity to Challenge. A party who contends that Protected 12 Material is not entitled to confidential treatment shall give written notice to the party who 13 affixed the “CONFIDENTIAL” designation of the specific basis for the challenge. The party 14 who so designated the documents shall have ten (10) days from service of the written notice 15 to determine if the dispute can be resolved without judicial intervention and, if not, to move 16 for an Order confirming the “CONFIDENTIAL” designation, and the status as Protected 17 Material. 18 c. Treatment as Protected Material until Order or Withdrawal. 19 Notwithstanding any challenge to the designation of documents as such, all material 20 previously designated “CONFIDENTIAL” shall continue to be treated as Protected Material 21 subject to the full protections of this Order until one of the following occurs: (1) the Party 22 who claims that the documents are Protected Material withdraws such designation in 23 writing; (2) the Party who claims that the documents are confidential fails to move timely 24 for an Order designating the documents as confidential as set forth in paragraph 9.b. above; 25 or (3) the Court rules that the documents are not Protected Material and/or should no longer 26 be designated as “CONFIDENTIAL.” 27 /// 28 /// 8 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 9 of 17 1 d. No Waiver. Challenges to the confidentiality of documents may be made at any 2 time and are not waived by the failure to raise the challenge at the time of initial disclosure 3 or designation. 4 10. DURATION; CONCLUSION OF LITIGATION. 5 All provisions of this Order restricting the use of Protected Material shall continue 6 to be binding after the conclusion of the litigation unless otherwise agreed or ordered. 7 However, the dismissal of this action will terminate the jurisdiction of this Court, including 8 over this Order. 9 Within thirty (30) days of the final termination of in the above-entitled action, 10 which would be either a final judgment on all claims or stipulation and order for dismissal 11 with prejudice, all documents and information designated as CONFIDENTIAL by a 12 Designating Party and which has not been challenged, including any copies, or documents 13 containing information taken therefrom, shall be returned to the Designating Party. In the 14 alternative, within thirty (30) days of the final termination of this case, which would be 15 either a final judgment on all claims or stipulation and order for dismissal with prejudice, 16 all such documents, including copies, may be shredded or disposed of in a manner to ensure 17 the destruction thereof and a declaration certifying such destruction or disposal provided to 18 the Designating Party. To the extent a party has designated portions of a deposition 19 transcript as CONFIDENTIAL, the non-designating party is under no obligation or duty to 20 shred or dispose of the deposition transcript, however, the CONFIDENTIAL designation 21 will remain. 22 11. 23 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION. 24 If a Party is served with a subpoena or an order issued in other litigation that would 25 compel disclosure of Protected Material designated by another Party or Non-party, the Party 26 must so notify the Designating Party, in writing (by e-mail or fax, if possible) within three 27 (3) court days after receiving the subpoena or order. Such notification must include a copy 28 of the subpoena or court order. 9 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 10 of 17 1 12. ORDER SUBJECT TO MODIFICATION. 2 This Order shall be subject to modification on motion of any Party or any other 3 person who may show an adequate interest in in the above-entitled action to intervene for 4 purposes of addressing the scope and terms of this Order. The Order shall not, however, be 5 modified until the Parties shall have been given notice and an opportunity to be heard on 6 the proposed modification. 7 13. 8 This Order is entered based on the representations and agreements of the Parties 9 and for the purpose of facilitating discovery. Nothing herein shall be construed or presented 10 as a judicial determination that any specific document or item of information designated as 11 CONFIDENTIAL by counsel is subject to protection under Rule 26(c) of the Federal Rules 12 of Civil Procedure or otherwise until such time as a document-specific ruling shall have 13 been made. NO JUDICIAL DETERMINATION. 14 14. 15 a. Public Health and Safety. Nothing in this Order is intended to prevent any 16 Party from raising with the Court any concern that the non-disclosure of certain Protected 17 Material may have a possible adverse effect upon the general public health or safety, or the 18 administration or operation of government or public office. 19 20 MISCELLANEOUS. b. Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. 21 c. Right to Assert Other Objections. By stipulating to the entry of this Order, no 22 Party waives any right it otherwise would have to object to disclosing or producing any 23 information or item on any ground not addressed in this Order. Similarly, no Party waives 24 any right to object on any ground to use in evidence of any of the material covered by this 25 Protective Order. 26 /// 27 /// 28 /// 10 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 11 of 17 1 15. 2 This Order shall take effect when entered and shall be immediately binding upon 3 4 5 PERSONS BOUND UPON ENTRY OF ORDER. the Parties (as defined herein). IT IS SO STIPULATED. DATED this 3rd day of December, 2018. DATED this 3rd day of December, 2018. 6 10 /s/ Alina M. Shell Margaret A. McLetchie, NBN 10931 Alina M. Shell, NBN 11711 MCLETCHIE LAW 701 East Bridger Avenue, Suite 520 Las Vegas, NV 89101 11 Attorneys for Plaintiff 7 8 9 /s/ David B. Farkas, Esq. David B. Farkas, Esq. (Pro Hac Vice) Carol Yur, Esq. (Pro Hac Vice) DLA PIPER LLP (US) 2000 Avenue of the Stars, Suite 400, North Tower Los Angeles, CA 90067 Lawrence J. Semenza III, Esq., NBN 7174 Christopher D. Kircher, Esq., NBN 11176 Jarrod L. Rickard, Esq., NBN 10203 SEMENZA KIRCHER RICKARD 10161 Park Run Drive, Suite 150 Las Vegas, NV 89145 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 14 15 Attorneys for Defendants 16 ORDER 17 18 19 IT IS SO ORDERED. Dated this 17th day of December, 2018. 20 21 _______________________________ U.S. DISTRICT MAGISTRATE JUDGE 22 23 24 25 26 27 28 11 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 12 of 17 1 EXHIBIT A 2 3 4 5 6 7 8 9 10 11 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 12 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 13 of 17 1 CERTIFICATION BY COUNSEL OF DESIGNATION OF INFORMATION AS CONFIDENTIAL 2 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 3 4 5 Case No.: 2:18-cv-00515-JCM-PAL TONY SHAW, 6 7 CERTIFICATION BY COUNSEL OF DESIGNATION OF INFORMATION AS CONFIDENTIAL Plaintiff, 8 9 10 11 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 vs. NP SANTA FE, LLC DBA SANTA FE STATION HOTEL & CASINO, a Nevada Limited Liability Company; STATION CASINOS, LLC, a Nevada Limited Liability Company; and RED ROCK RESORTS, INC., a Delaware corporation, 14 Defendants. 15 16 Documents produced herewith, whose Bates numbers have been listed on the 17 18 19 attached Confidentiality Log, have been marked as CONFIDENTIAL subject to the Confidentiality Order entered in this action which Order is dated _______________, 2018. By signing below, I am certifying that I have personally reviewed the marked 20 21 22 documents and believe, based on that review that they are properly subject to protection under the terms of Paragraph 3 of the Confidentiality Order. I am a member of the Bar of the United States District Court for the District of 23 24 Nevada. My Nevada Bar number is . Date Signature of Counsel 25 26 27 28 Printed Name of Counsel 13 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 14 of 17 1 LOG OF CONFIDENTIAL DESIGNATIONS 2 3 4 5 Date of Bates Specific Description Production Number Documents or Information or Other Identifier 6 7 8 9 10 11 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14 of Authority/Basis Designation for Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 15 of 17 1 EXHIBIT B 2 3 4 5 6 7 8 9 10 11 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 16 of 17 ACKNOWLEDGMENT OF UNDERSTANDING AND AGREEMENT TO BE BOUND 1 2 3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA 5 TONY SHAW, Case. No.: 2:18-cv-00515-JCM-PAL 6 Plaintiff, 7 8 vs. ACKNOWLEDGMENT OF UNDERSTANDING AND AGREEMENT TO BE BOUND 9 10 11 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 NP SANTA FE, LLC DBA SANTA FE STATION HOTEL & CASINO, a Nevada Limited Liability Company; STATION CASINOS, LLC, a Nevada Limited Liability Company; and RED ROCK RESORTS, INC., a Delaware corporation, 14 Defendants. 15 The undersigned hereby acknowledges that he or she has read the Confidentiality 16 Order dated ________________, 2018, in the above-captioned action, understands the terms 17 thereof, and agrees to be bound by such terms. The undersigned submits to the jurisdiction 18 of the United States District Court for the District of Nevada relating to the Confidentiality 19 Order during the pendency of the above-entitled action, the undersigned further agrees to 20 submit to the jurisdiction of the United States District Court for the District of Nevada for 21 the purpose of enforcing the terms of this Stipulated Protective Order, even if such 22 enforcement proceedings occur after termination in this action, and understands that the 23 terms of said Order obligate him/her to use discovery materials designated 24 CONFIDENTIAL solely for the purposes of the above-captioned action, and not to disclose 25 any such Protected Material to any person, firm, entity, or concern. 26 /// 27 /// 28 /// 16 Case 2:18-cv-00515-JCM-PAL Document 31 Filed 12/03/18 Page 17 of 17 1 2 The undersigned acknowledges that violation of the Stipulated Confidentiality Order may result in penalties for contempt of court. 3 Name: Job Title: Employer: Business Address: 4 5 6 7 8 9 Date Signature 10 11 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17
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