1 || Luke Busby, Esq. _ || Nevada State Bar #10319 “ || 316 California Avenue 3 || Reno, Nevada 89509 (775) 453-0112 4 [email protected] || Attorney for the Plaintiff

7 UNITED STATES DISTRICT COURT a DISTRICT OF NEVADA 3 ERIN WARE, 10 Plaintiff, 2 Vv. Case No.: 3:22-cv-00037-ART-CSD 13 KEAST. et al., STIPULATED PROTECTIVE ORDER 14 Defendants. 16 17 14 In order to protect the confidentiality of confidential information obtained by the a9 || Parties in connection with this case, the Court Orders the following: 21 Any party or non-party may designate as "confidential" (by stamping the 22 || relevant page or otherwise as set forth herein) any document or response to discovery 23 || which that party or non-party considers in good faith to contain confidential 24 || information, subject to protection under the Federal Rules of Civil Procedure, or state or 2° |! federal law ("Confidential Information"). Where a document or response consists of 26 more than one page, the first page and each page on which confidential information appears shall be so designated. This protective order shall also constitute an

1 || authorizing order of a court of competent jurisdiction under 5 U.S.C. § 552a(b)(11) (part 2 || of the Privacy Act). 4 A party or non-party may designate information disclosed during a deposition or * in response to written discovery as "confidential" by so indicating in said response or a ° party or non-party may designate in writing, within twenty (20) days after receipt of said responses or of the deposition transcript for which the designation is proposed, that specific pages of the transcript and/or specific responses be treated as "confidential" information. Any other party may object to such proposal, in writing or on the record. ig || Upon such objection, the parties shall follow the procedures described in paragraph 8 11 || below. After any designation made according to the procedure set forth in this 12 || paragraph, the designated documents or information shall be treated according to the 13 || designation until the matter is resolved according to the procedures described in 14 || paragraph 8 below, and counsel for all parties shall be responsible for marking all previously unmarked copies of the designated material in their possession or control with the specific designation. All information produced or exchanged in the course of this case (other than information that is publicly available) shall be used by the party or parties to whom the

information is produced solely for the purpose of this case.

21 Except with the prior written consent of other parties and the non-party 22 || providing the Confidential Information, if applicable, or upon the prior order of this 23 || Court obtained upon notice to opposing counsel, Confidential Information shall not be 24 || disclosed to any person other than: fA (a) counsel for the respective parties to this litigation, including in-house counsel a6 and co-counsel retained for this litigation; a (b) employees of such counsel;

(c) individual parties, any officer or employee of a party, to the extent deemed 2 necessary by Counsel for the prosecution or defense of this litigation; 4 (d) consultants or expert witnesses retained for the prosecution or defense of this litigation, provided that each such person shall execute a copy of the ° Certification annexed to this Order as Exhibit "A" (which shall be retained by counsel to the party so disclosing the Confidential Information and made available for inspection by opposing counsel during the pendency or after the termination of the action only upon good cause shown and upon order of the 10 Court) before being shown or given any Confidential Information; 11 (e) any authors or recipients of the Confidential Information; 12 (f) the Court, Court personnel, and court reporters; and 13 (g) witnesses (other than persons described in paragraph 4(e)). A witness shall 14 sign the Certification before being shown a confidential document. Confidential Information may be disclosed to a witness who will not sign the Certification only in a deposition at which the party who designated the Confidential Information is represented or has been given notice that Confidential Information shall be designated "Confidential" pursuant to paragraph 2 above. Witnesses

x6 shown Confidential Information shall not be allowed to retain copies. 21 Any persons receiving Confidential Information shall not reveal or discuss such 22 || information to or with any person who is not entitled to receive such information, 23 || except as set forth herein. 24 Unless otherwise permitted by statute, rule, or prior court order, papers filed £5 || with the Court under seal shall be accompanied by a contemporaneous motion for |! leave to file those documents under seal, and shall be filed consistent with the court’s a electronic filing procedures in accordance with Local Rule IA 10-5. Notwithstanding

1 || any agreement among the parties, the party seeking to file a paper under seal bears 2 || the burden of overcoming the presumption in favor of public access to papers filed in 4 || court. Kamakana v. City and County of Honolulu,

(9th Cir. 2006); Pintos * Il v. Pac. Creditors Ass’n,

(9th Cir. 2010); Center for Auto Safety v. ° Chrysler Group, LLC,

(9th Cir. 2016). A party may designate as "Confidential" documents or discovery materials produced by a non-party by providing written notice to all parties of the relevant document numbers or other identification within thirty (80) days after receiving such ig || Gdocuments or discovery materials. Any party or non-party may voluntarily disclose to 41 |} others without restriction any information designated by that party or non-party as 12 || confidential, although a document may lose its confidential status if it is made public. 13 If a party contends that any material is not entitled to confidential treatment, 12 || such party may at any time give written notice to the party or non-party who designated the material. The party or non-party who designated the material shall have twenty-five (25) days from the receipt of such written notice to apply to the Court for an order designating the material as confidential. The party or non-party seeking the order has the burden of establishing that the document is entitled to protection.

x6 Notwithstanding any challenge to the designation of material as Confidential

21 Information, all documents shall be treated as such and shall be subject to the 32 || provisions hereof unless and until one of the following occurs: 23 (a) the party or non-party who claims that the material is Confidential Information 24 withdraws such designation in writing; or fA (b) the party or non-party who claims that the material is Confidential Information fails to apply to the Court for an order designating the material confidential within the time period specified above after receipt of a written challenge to

1 such designation; or 2 (c) the Court rules the material is not confidential. 4 All provisions of this Order restricting the communication or use of Confidential Information shall continue to be binding after the conclusion of this action, unless ° otherwise agreed or ordered. Upon conclusion of the litigation, a party in the possession of Confidential Information, other than that which is contained in pleadings, correspondence, and deposition transcripts, shall either (a) return such documents no later than thirty (80) days after conclusion of this action to counsel for the party or ig |) Non-party who provided such information, or (b) destroy such documents within the 11 || time period upon consent of the party who provided the information and certify in 12 || writing within thirty (30) days that the documents have been destroyed. 13 The terms of this Order do not preclude, limit, restrict, or otherwise apply to the 14 || use of documents at trial. Nothing herein shall be deemed to waive any applicable privilege or work product protection, or to affect the ability of a party to seek relief for an inadvertent disclosure of material protected by privilege or work product protection. Any witness or other person, firm, or entity from which discovery is sought may

x6 be informed of and may obtain the protection of this Order by written advice to the

21 parties’ respective counsel or by oral advice at the time of any deposition or similar 22 || proceeding. 23 (Signatures on following page) 24 25 26

1 4 Dated: Jul 18, 2025 BY: Couple 2. Kanda 4 Douglas R Rands Nevada Attorney General ° 100 N. Carson Street 6 Carson City, NV 89701-4717 775-684-1150 Fax: 775-684-1108 Email: [email protected] 2 By: hi | \e- . Puslrey to Luke Busby, Esq. Nevada State Bar #10319 11 316 California Avenue Reno, Nevada 89509 (775) 453-0112 13 [email protected] 14 15 cu oe 16 UNITED STATES MAGISTRATE JUDGE 18 DATED: duly 18, 2025 19 20 21

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1 é EXHIBIT "A" : CERTIFICATION | hereby certify my understanding that Confidential Information is being provided to me pursuant to the terms and restrictions of the Protective Order dated , 2025, in 7 Ware v. Keast et al., Civil No. 3:22-cv-00037-ART-CSD. | have been given a copy of that 8 Order and read it. | agree to be bound by the Order. | will not reveal the Confidential Information to anyone, except as allowed by the Order. | will maintain all such Confidential Information — including copies, notes, or other transcriptions made therefrom — in a secure manner to prevent unauthorized access to it. No later than thirty (30) days after the

13 conclusion of this action, | will return the Confidential Information — including copies, 14 notes, or other transcriptions made therefrom — to the counsel who provided me with the a Confidential Information. | hereby consent to the jurisdiction of the United States District + Court for the purpose of enforcing the Protective Order. 17 18 By: DATED: 20 21

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