Jones et al v. City of North Las Vegas et al, No. 2:2021cv00241 - Document 13 (D. Nev. 2021)
Court Description: ORDER Granting 10 Stipulated Protective Order. Signed by Magistrate Judge Daniel J. Albregts on 6/11/2021. (Copies have been distributed pursuant to the NEF - JQC)
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Jones et al v. City of North Las Vegas et al Doc. 13 Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 1 of 13 1 2 3 4 5 6 7 8 9 10 11 Margaret A. McLetchie, Nevada Bar No. 10931 Alina M. Shell, Nevada Bar No. 11711 Leo S. Wolpert, Nevada Bar No. 12658 MCLETCHIE LAW 602 South Tenth Street Las Vegas, NV 89101 Telephone: (702) 728-5300 Facsimile: (702) 425-8220 Email: maggie@nvlitigation.com Jennifer L. Braster, Nevada Bar No. 9982 NAYLOR & BRASTER 1050 Indigo Drive, Suite 200 Las Vegas, NV 89145 Telephone: (702) 420-7000 Facsimile: (702) 420-7001 Email: jbraster@nblawnv.com Counsel for Plaintiffs, Genoa Jones and Cornell Tinsley 12 ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14 15 GENOA JONES and CORNELL TINSLEY, individuals, Case. No.: 2:21-cv-00241-GMN-DJA 16 17 Plaintiffs, vs. 18 19 20 21 CITY OF NORTH LAS VEGAS, Nevada, a Municipal Corporation; SERGEANT SCOTT SALKOFF, an individual; and OFFICER MICHAEL ROSE, an individual, 22 [PROPOSED] STIPULATED PROTECTIVE ORDER Defendants. 23 Plaintiffs GENOA JONES and CORNELL TINSLEY and Defendants CITY OF 24 NORTH LAS VEGAS, SERGEANT SCOTT SALKOFF, and OFFICER MICHAEL ROSE 25 by their respective counsel, having agreed to the following and for good cause under Rule 26 26(c)(1) of the Federal Rules of Civil Procedure, IT IS HEREBY ORDERED as follows: 27 1. 28 Disclosure and discovery activity in this action may involve production of PURPOSES AND LIMITATIONS. 1 Dockets.Justia.com ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 2 of 13 1 confidential, proprietary, or private information for which special protection from public 2 disclosure may be warranted under Rule 26(c)(1) of the Federal Rules of Civil Procedure. 3 The parties acknowledge that this Order does not confer blanket protections on all 4 disclosures or responses to discovery and that the protection it affords extends to only the 5 limited information or items that are entitled under law to treatment as confidential. 6 2. 7 All documents produced in the course of discovery, all responses to discovery 8 requests, and all deposition testimony and exhibits and any other materials which may be 9 subject to discovery (hereinafter collectively “Discovery Material”) shall be subject to this 10 stipulated protective order concerning confidential information as set forth below. A copy 11 of this Order must be included with any subpoena to any third party. Any party, or any third 12 party who produces documents in this litigation, may designate documents as Confidential 13 but only after review of the documents by an attorney who has, in good faith, determined 14 that the documents contain “Confidential Information,” as defined below, and pursuant to 15 the procedure set forth below. SCOPE. 16 3. 17 “Confidential Information” shall mean information meriting special protection 18 under the Federal Rules of Civil Procedure and applicable case law. Confidential 19 Information does not include information that (a) is in the public domain at the time of 20 disclosure; (b) becomes part of the public domain through no fault of the Receiving Party; 21 (c) the Receiving Party can show was in its rightful and lawful possession at the time of 22 disclosure; or (d) the Receiving Party lawfully receives from a Non-party later without 23 restriction as to disclosure. CONFIDENTIAL INFORMATION. 24 4. 25 Party: any party to this action, including all of its officers, directors, agents, and 26 attorney(s) of record for a Party in this action (including their associates, paralegals, and 27 support/ clerical staff). 28 OTHER DEFINITIONS. Non-party: any individual, corporation, association, or natural person or entity 2 Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 3 of 13 1 other than a party. 2 Protected Material: any Discovery Material containing Confidential Information 3 that is designated by a Party or Non-party as “CONFIDENTIAL,” unless the Receiving 4 Party challenges the confidentiality designation and (a) the Court decides such material is 5 not entitled to protection as confidential; (b) the Designating Party fails to apply the Court 6 for an order designating the material confidential within the time period specified below; or 7 (c) the Designating Party withdraws its confidentiality designation in writing. Producing Party: a Party or Non-party that produces Discovery Material in this 8 ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 9 action. 10 Receiving Party: a Party that receives Discovery Material from a Producing Party. 11 Designating Party: a Party or Non-party that designates Discovery Material as 12 “CONFIDENTIAL”. The Party or Non-party designating information or items as Protected 13 Material bears the burden of establishing good cause for the confidentiality of all such items. 14 Challenging Party: a party that elects to initiate a challenge to a Designating 15 Party’s confidentiality designation. 16 Confidentiality Log: a Confidentiality Log must accompany any production of 17 documents designated as “CONFIDENTIAL” that includes the Bates numbers of the 18 documents designated (or the portions thereof) as “Confidential” and the basis for doing so. 19 Each Producing Party shall keep this log cumulatively and re-produce it every time they 20 designate something as “CONFIDENTIAL” so that it is a cumulative record of what the 21 party has marked “CONFIDENTIAL.” 22 5. 23 Protected Material shall be so designated by the Producing Party by placing or 24 affixing the word “CONFIDENTIAL” on the document in a manner which will not interfere 25 with the legibility of the document and which will permit complete removal of the 26 “Confidential” designation. A Confidentiality Log must accompany any production of 27 Protected Material that includes the Bates numbers of the documents designated (or portions 28 thereof) as “CONFIDENTIAL” and the basis for doing so. Documents shall be designated FORM AND TIMING OF DESIGNATION. 3 ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 4 of 13 1 “Confidential” prior to, or contemporaneously with, the production or disclosure of the 2 documents. The designation of documents as “CONFIDENTIAL” shall be accompanied 3 with a Confidentiality Log in the form included at Exhibit A. 4 A Designating Party must exercise restraint and make good faith efforts to limit 5 CONFIDENTIAL designations to specific materials that qualify for protection under the 6 appropriate standard. Further, a Designating Party must use good faith efforts to designate 7 for protection only those parts of material, documents, items, or communications that 8 qualify—so that other portions of the materials, documents, items, or communications for 9 which protection is not warranted are not swept unjustifiably within the ambit of this Order. 10 If only a portion or portions of materials on a page or within a document merit protection, a 11 Producing Party must so indicate by making appropriate markings in the margins but not 12 over text. The accompanying log should clearly explain which portion is designated as 13 CONFIDENTIAL. 14 A Producing Party that makes original documents or materials available for 15 inspection need not designate them for protection until after the inspecting Party has 16 indicated which material it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for inspection shall be deemed 18 “Confidential.” After the inspecting Party has identified the documents it wants copied and 19 produced, the Producing Party must determine which documents, or portions thereof, 20 qualify for protection under this Order, and, before producing the specified documents, the 21 Producing Party must affix the appropriate legend on each page that contains Protected 22 Material. If only a portion or portions of the material on a page qualifies for protection, the 23 Producing Party also must clearly identify the protected portion(s) (e.g., by making 24 appropriated markings in the margins or by redacting protected portions). 25 Portions of depositions shall be designated CONFIDENTIAL when the deposition 26 is taken or within fourteen (14) business days after receipt of the transcript, if feasible. Such 27 designation shall be specific as to the portions to be protected and, if made by a Party, shall 28 be accompanied with a certification and log on the form, attached as Exhibit A. A 4 ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 5 of 13 1 Designating Party must exercise restraint and make good faith efforts to limit 2 “CONFIDENTIAL” designations to specific materials that qualify for protection under the 3 appropriate standards. 4 Inadvertent or unintentional production of Protected Material without prior 5 designation as “Confidential” shall not be deemed a waiver, in whole or in part, of the right 6 to designate documents as Protected Material as otherwise allowed by this Order. Further, 7 a Party may assert that disclosures or discovery material produced by another Party 8 constitute Protected Material by informing the opposing Party by following the procedures 9 set forth herein for a Designated Party. 10 6. 11 a. General Protections. Protected Material shall not be used or disclosed by the 12 parties or counsel for the parties or any other persons identified below (¶ 6.b.) for any 13 purposes whatsoever other than preparing for and conducting litigation in the above-entitled 14 action (including any appeal). PROTECTION OF PROTECTED MATERIAL. 15 b. Qualified Receiving Parties and Limited Third-Party Disclosures. Protected 16 Material shall be held in confidence by each qualified Receiving Party to whom it is 17 disclosed, shall be used only for purposes of this action, and shall not be disclosed to any 18 person who is not a qualified recipient. All Protected Material shall be carefully maintained 19 so as to preclude access by persons who are not qualified Receiving Parties. 20 Subject to these requirements, in addition to Parties and the Court, the following 21 categories of persons may be allowed to review Protected Material pursuant to this Order 22 after executing an acknowledgment (in the form set forth at Exhibit B hereto), that he or she 23 has read and understands the terms of this Order and is bound by it: 24 (1) Any officers, directors, or designated employees of a Party deemed 25 necessary by counsel of record in this action to aid in the prosecution, 26 defense, or settlement of this action; 27 28 (2) Professional outside vendors for attorneys of record (such as copying services and translators and interpreters), 5 Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 6 of 13 1 (3) Court reporters, deposition notaries and staff; 2 (4) The author of any document designated as CONFIDENTIAL or the 3 original source of Confidential Information contained therein; 4 (5) Persons other than legal counsel who have been retained or specially 5 employed by a party as an expert witness for purposes of this lawsuit or 6 to perform investigative work or fact research; 7 (6) Deponents during the course of their depositions; 8 (7) Counsel for issuers of insurance policies under which any issuer may be 9 liable to satisfy part or all of a judgment that may be entered in these 10 proceedings or indemnify or reimburse payments or costs associated with 11 these proceedings; (8) Any private mediator or arbitrator appointed by the Court or selected by ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 mutual agreement of the parties and the mediator or arbitrator’s 14 secretarial and clerical personnel; (9) Any other person as to whom the Producing Party has consented to 15 16 disclosure in advance and in writing, on notice to each Party hereto. 17 c. Control of Documents. Counsel for Parties shall take reasonable efforts to 18 prevent unauthorized disclosure of Protected Material pursuant to the terms of this Order. 19 No copies of Protected Material shall be made except by or on behalf of attorneys of record, 20 in-house counsel, or the parties in this action. 21 d. Copies. Any person making copies of Protected Material shall maintain all 22 copies within their possession or the possession of those entitled to access such information 23 under the Protective Order. All copies shall be immediately affixed with the designation 24 “CONFIDENTIAL” if the word does not already appear on the copy. All such copies shall 25 be afforded the full protection of this Order. 26 7. 27 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 28 Protected Material to any person or in any circumstance not authorized under this Stipulated UNAUTHORIZED DISCLOSURE. 6 Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 7 of 13 1 Protective Order, the Receiving Party must immediately (a) notify in writing the 2 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 3 copies of the Protected Material, (c) inform the person or persons to whom unauthorized 4 disclosures were made of all the terms of this Order, and (d) request such person or persons 5 to execute the “Acknowledgment and Agreement to Be Bound by Stipulated Protective 6 Order” (Exhibit B). 7 8. 8 The Parties shall follow Rule 10-5 of the Local Rules of Practice for the U.S. 9 District Court of Nevada and must file documents under seal under the Court’s electronic ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 10 FILING PROTECTED MATERIAL filing procedures. 11 Further, the Parties recognize the presumption of public access inherent in judicial 12 records and that a Protective Order does not establish that documents meet the standard for 13 sealing set forth in Rule 10-5 of the Local Rules of Practice for the U.S. District Court of 14 Nevada and the Ninth Circuit’s decisions in Kamakana v. City and County of Honolulu, 447 15 F.3d 1172 (9th Cir. 2006) and Ctr. for Auto Safety v. Chrysler Group, LLC, 809 F.3d 1092, 16 1097 (9th Cir.), cert. denied sub nom. FCA U.S. LLC v. Ctr. for Auto Safety, 137 S. Ct. 38 17 (2016). When a motion to seal is related to the merits of the case, a “party seeking to seal a 18 judicial record then bears the burden of overcoming this strong presumption by meeting the 19 ‘compelling reasons’ standard.” Kamakana, 447 F.3d at 1178. But when motion to seal is 20 unrelated to the merits of the case, a party may overcome this presumption by meeting a less 21 exacting “good cause standard.” Chrysler Group, 809 F.3d at 1097. To establish good cause, 22 a party must show specific prejudice or harm—such as protecting a party from annoyance, 23 embarrassment, oppression, or undue burden or expense—will result if the motion to seal is 24 denied. Id. (quoting Fed. R. Civ. P. 26(c)). Further, the Court should make an independent 25 determination regarding whether documents merits sealed status, and thus expressly 26 reserves the right to do. Kamakana 447 F.3d at 1186-87. 27 In recognition of this legal standard, and the fact that the party filing Protected 28 Material may not be the party that designated it confidential (and thus, may not believe good 7 Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 8 of 13 1 cause exists for sealing), the Parties suggest that the procedure set forth below is followed 2 if the sole ground for a motion to seal is that the opposing party (or non-party) has designated 3 a document as subject to protection pursuant to this Stipulated Protective Order: the Party 4 filing such Protected Materials may assert in the accompanying motion any reasons why the 5 Protected Materials should not, in fact, be kept under seal and the Designating Party, who 6 must be properly noticed, may likewise file a response asserting its position that the 7 Protected Material merits protection under Rule 26(c) of the Federal Rules of Civil 8 Procedure and attaching a declaration supporting the assertion that the designated material 9 meets the applicable standard. 10 9. 11 Any designation of Protected Material is subject to challenge. The following ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 procedures shall apply to any such challenge: a. Burden. The burden of proving the necessity of a “CONFIDENTIAL” 13 14 CHALLENGES TO PROTECTED MATERIAL. designation remains with the party asserting confidentiality. 15 b. Notice; Opportunity to Challenge. A party who contends that Protected 16 Material is not entitled to confidential treatment shall give written notice to the party who 17 affixed the “CONFIDENTIAL” designation of the specific basis for the challenge. The party 18 who so designated the documents shall have ten (10) days from service of the written notice 19 to determine if the dispute can be resolved without judicial intervention and, if not, to move 20 for an Order confirming the “CONFIDENTIAL” designation, and the status as Protected 21 Material. 22 c. Treatment as Protected Material until Order or Withdrawal. 23 Notwithstanding any challenge to the designation of documents as such, all material 24 previously designated “CONFIDENTIAL” shall continue to be treated as Protected Material 25 subject to the full protections of this Order until one of the following occurs: (1) the Party 26 who claims that the documents are Protected Material withdraws such designation in 27 writing; (2) the Party who claims that the documents are confidential fails to move timely 28 for an Order designating the documents as confidential as set forth in paragraph 9.b. above; 8 Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 9 of 13 1 or (3) the Court rules that the documents are not Protected Material and/or should no longer 2 be designated as “CONFIDENTIAL.” 3 d. No Waiver. Challenges to the confidentiality of documents may be made at any 4 time and are not waived by the failure to raise the challenge at the time of initial disclosure 5 or designation. 6 10. 7 All provisions of this Order restricting the use of Protected Material shall continue 8 to be binding after the conclusion of the litigation unless otherwise agreed or ordered. 9 However, the dismissal of this action will terminate the jurisdiction of this Court, including ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 10 DURATION; CONCLUSION OF LITIGATION. over this Order. 11 Within thirty (30) days of the final termination of in the above-entitled action, 12 which would be either a final judgment on all claims or stipulation and order for dismissal 13 with prejudice, all documents and information designated as CONFIDENTIAL by a 14 Designating Party and which has not been challenged, including any copies, or documents 15 containing information taken therefrom, shall be returned to the Designating Party. In the 16 alternative, within thirty (30) days of the final termination of this case, which would be 17 either a final judgment on all claims or stipulation and order for dismissal with prejudice, 18 all such documents, including copies, may be shredded or disposed of in a manner to ensure 19 the destruction thereof and a declaration certifying such destruction or disposal provided to 20 the Designating Party. To the extent a party has designated portions of a deposition 21 transcript as CONFIDENTIAL, the non-designating party is under no obligation or duty to 22 shred or dispose of the deposition transcript, however, the CONFIDENTIAL designation 23 will remain. 24 11. 25 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION. 26 If a Party is served with a subpoena or an order issued in other litigation that would 27 compel disclosure of Protected Material designated by another Party or Non-party, the Party 28 must so notify the Designating Party, in writing (by e-mail or fax, if possible) within three 9 Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 10 of 13 1 (3) court days after receiving the subpoena or order. Such notification must include a copy 2 of the subpoena or court order. 3 12. 4 This Order shall be subject to modification on motion of any Party or any other 5 person who may show an adequate interest in the above-entitled action to intervene for 6 purposes of addressing the scope and terms of this Order. The Order shall not, however, be 7 modified until the Parties shall have been given notice and an opportunity to be heard on 8 the proposed modification. ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 9 13. ORDER SUBJECT TO MODIFICATION. NO JUDICIAL DETERMINATION. 10 This Order is entered based on the representations and agreements of the Parties 11 and for the purpose of facilitating discovery. Nothing herein shall be construed or presented 12 as a judicial determination that any specific document or item of information designated as 13 CONFIDENTIAL by counsel is subject to protection under Rule 26(c) of the Federal Rules 14 of Civil Procedure or otherwise until such time as a document-specific ruling shall have 15 been made. 16 14. 17 a. Public Health and Safety. Nothing in this Order is intended to prevent any 18 Party from raising with the Court any concern that the disclosure of certain Protected 19 Material may have a possible adverse effect upon the general public health or safety, or the 20 administration or operation of government or public office. b. Right to Further Relief. Nothing is this Order abridges the right of any person 21 22 MISCELLANEOUS. to seek its modification by the Court in the future. 23 c. Right to Assert Other Objections. By stipulating to the entry of this Order, no 24 Party waives any right it otherwise would have to object to disclosing or producing any 25 information or item on any ground not addressed in this Order. Similarly, no Party waives 26 any right to object on any ground to use in evidence of any of the material covered by this 27 Protective Order. 28 /// 10 Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 11 of 13 1 15. 2 This Order shall take effect when entered and shall be immediately binding upon 3 the Parties (as defined herein). It shall also be binding upon subsequent parties that are added 4 to this matter, each of which shall execute Exhibit B (Agreement to be bound). PERSONS BOUND UPON ENTRY OF ORDER. 5 IT IS SO STIPULATED. 6 DATED this 9th day of June, 2021. DATED this 9th day of June, 2021. MCLETCHIE LAW NORTH LAS VEGAS ATTORNEY’S OFFICE /s/ Leo S. Wolpert Margaret A. McLetchie, NBN 10931 Alina M. Shell, NBN 11711 Leo S. Wolpert, NBN 12658 701 East Bridger Avenue, Suite 520 Las Vegas, NV 89101 Telephone: (702) 728-5300 Email: maggie@nvlitigation.com /s/ Rhiann Jarvis Denman Micaela Rustia Moore, NBN 9676 Noel E. Eidsmore, NBN 7688 Rhiann Jarvis Denman, NBN 13509 2250 Las Vegas Blvd. North, Suite 810 North Las Vegas, Nevada 89030 Telephone: (702) 633-1050 Email: jarvisr@cityofnorthlasvegas.com Counsel for Defendants, City of North Las Vegas, Sgt. Scott Salkoff, and Ofc. Michael Rose 7 8 9 10 11 ATTORNEYS AT LAW 602 SOUTH TENTH STREET LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 14 15 16 17 18 19 Jennifer L. Braster, Nevada Bar No. 9982 NAYLOR & BRASTER 1050 Indigo Drive, Suite 200 Las Vegas, NV 89145 Telephone: (702) 420-7000 Email: jbraster@nblawnv.com Counsel for Plaintiffs, Genoa Jones and Cornell Tinsley CITY 20 21 22 ORDER IT IS SO ORDERED. 23 24 25 26 U.S. DISTRICT COURT MAGISTRATE JUDGE DATED: 27 28 11 June 11, 2021 Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 12 of 13 EXHIBIT A [Name]’s LOG OF CONFIDENTIAL DESIGNATIONS 1 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 Date of Production Bates No. or Other Identifier Specific Description Documents or Information of Authority/Basis for Designation Case 2:21-cv-00241-GMN-DJA Document 10 Filed 06/09/21 Page 13 of 13 EXHIBIT B 1 ACKNOWLEDGMENT OF UNDERSTANDING AND AGREEMENT TO BE BOUND 2 3 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 4 5 6 7 GENOA JONES and CORNELL TINSLEY, individuals, Plaintiffs, vs. Case. No.: 2:21-cv-00241-GMN-DJA CITY OF NORTH LAS VEGAS, Nevada, a Municipal Corporation; SERGEANT SCOTT SALKOFF, an individual; and OFFICER MICHAEL ROSE, an individual, Defendants. ACKNOWLEDGMENT OF UNDERSTANDING AND AGREEMENT TO BE BOUND 8 9 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 11 12 The undersigned hereby acknowledges that he or she has read the Confidentiality 13 Order dated ________________, 2021, in the above-captioned action, understands the terms 14 thereof, and agrees to be bound by such terms. The undersigned submits to the jurisdiction 15 of the United States District Court for the District of Nevada relating to the Confidentiality 16 Order during the pendency of the above-entitled action and understands that the terms of 17 said Order obligate him/her to use discovery materials designated CONFIDENTIAL solely 18 for the purposes of the above-captioned action, and not to disclose any such Protected 19 Material to any person, firm, entity, or concern. The undersigned acknowledges that violation of the Stipulated Confidentiality 20 21 Order may result in penalties for contempt of court. 22 Name: Job Title: Employer: Business Address: 23 24 25 26 27 28 Date Signature
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