1 LOREN S. YOUNG, ESQ. Nevada Bar No. 7567 2 JULIE A. WHITE, ESQ. Nevada Bar No. 8725 3 LINCOLN, GUSTAFSON & CERCOS, LLP ATTORNEYS AT LAW 4 7670 W Lake Mead Blvd, Suite 200 Las Vegas, Nevada 89128 5 Telephone: (702) 257-1997 Facsimile: (702) 257-2203 6 lyoung@lgclawoffice.com jwhite@lgclawoffice.com 7 Attorneys for Defendant, 8 TARGET CORPORATION
9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 SANDRA HERNANDEZ-ARREAGA, an 12 individual, CASE NO: 2:25-cv-01950
13 Plaintiff, STIPULATED PROTECTIVE ORDER 14 v. REGARDING CONFIDENTIAL MATERIALS 15
16 TARGET CORPORATION dba TARGET STORE T-0680, a Foreign Corporation; DOE 17 INDIVIDUALS I through X, inclusive; and ROE BUSINESS ENTITIES I through X, inclusive 18 Defendants. 19 20 IT IS HEREBY STIPULATED AND AGREED, by the undersigned attorneys for the 21 respective parties, that with regard to material disclosed in the course of the above-captioned lawsuit 22 (“Lawsuit”) which constitute or contain trade secrets or other confidential research, development, or 23 commercial information of the parties (“Confidential Material”), the following procedures shall 24 govern: 25 1. This Order is meant to encompass all forms of disclosure which may contain 26 Confidential Material, including any document, pleading, motion, exhibit, declaration, affidavit, 27 deposition transcript, inspection and all other tangible items (electronic media, photographs, 28 videocassettes, etc.). 1 2. The parties may designate any Confidential Material produced or filed in this Lawsuit 2 as confidential and subject to the terms of this Order by marking such materials “Confidential”. If any 3 material has multiple pages, this designation need only be placed on the first page of such material. 4 Any material designated as “Confidential” shall not be disclosed to any person or entity, except to the 5 parties, counsel in this Lawsuit, and the Court. 6 3. Any material designated as confidential pursuant to paragraph 2 above shall be used 7 solely for the purposes of this Lawsuit and for no other purpose. 8 4. Prior to disclosure of any Confidential Material, each person to whom disclosure is to 9 be made shall execute a written “Confidentiality Agreement” (in the form attached hereto) consenting 10 to be bound by the terms of this Order. The parties, counsel for the respective parties (including legal 11 assistants and other personnel) and the Court are deemed to be bound by this Order and are not required 12 to execute a Confidentiality Agreement. 13 5. Only counsel of record in this Lawsuit shall be permitted to disseminate Confidential 14 Material. Upon dissemination of any Confidential Material, each non-designating counsel of record in 15 this Lawsuit shall maintain a written record as to: (1) the identity of any person given Confidential 16 Material, and (2) the identity of the Confidential Material so disseminated (such as by “Bates stamp” 17 number). Such record shall be made available to the designating party upon request. 18 6. If additional persons become parties to this Lawsuit, they shall not have access to any 19 Confidential Material until they execute and file with the Court their written agreement to be bound 20 by the terms of this Order. 21 7. In the event that any question is asked at a deposition that calls for the disclosure of 22 Confidential Material, the witness shall answer such question (unless otherwise instructed not to do 23 so on grounds of privilege) provided that the only persons in attendance at the deposition are persons 24 who are qualified to receive such information pursuant this Order. Deposition testimony may be 25 designated as confidential following the testimony having been given provided that: (1) such testimony 26 is identified and designated on the record at the deposition, or (2) non-designating counsel is notified 27 of the designation in writing within thirty days after receipt by the designating party of the respective 1 “Confidential” pursuant to paragraph 2 above. When Confidential Material is incorporated in a 2 deposition transcript, the party designating such information confidential shall make arrangements 3 with the court reporter not to disclose any information except in accordance with the terms of this 4 Order. 5 8. If a deponent refuses to execute a Confidentiality Agreement, disclosure of 6 Confidential Material during the deposition shall not constitute a waiver of confidentiality. Under such 7 circumstances, the witness shall sign the original deposition transcript in the presence of the court 8 reporter and no copy of the transcript or exhibits shall be given to the deponent. 9 9. With respect to any communications to the Court, including any pleadings, motions or 10 other papers, all documents containing Confidential Material shall be done in accordance with Local 11 Rules IA 10-4 and IA 10-5, in additions to the directives set forth in Kamakana v. City and County of 12 Honolulu, 447 F.3d 1172 (9th Cir. 2006) and Center for Auto Safety v. Chrysler Group, LLC, 809 F.3d 13 1092, 1097 (9th Cir. 2016). All communications shall indicate clearly which portions are designated 14 to be “Confidential” through a Motion to Seal and/or redaction 15 10. The Court may order the court files and records, or any part thereof, to be sealed or 16 redacted, provided the Court makes and enters written findings that the specific sealing or redaction 17 is justified by identified compelling privacy or safety interests that outweigh the public interest in 18 access to the court records. 19 11. If a non-designating party is subpoenaed or ordered to produce Confidential Material 20 by another court or administrative agency, such party shall promptly notify the designating party of 21 the pending subpoena or order and shall not produce any Confidential Material until the designating 22 party has had reasonable time to object or otherwise take appropriate steps to protect such Confidential 23 Material. 24 12. Pursuant to LR 1-1(b)(2), Judge Couvillier requires the parties to follow the procedures 25 outlined below regarding any discovery dispute. No discovery motion may be filed until the following 26 procedure has been followed and such motion is ordered by Judge Couvillier: 27 1. If a discovery dispute arises the parties must first meet and confer to try to resolve their 1 person, videoconference, or telephone. A mere exchange of letters or e-mails does not satisfy the meet 2 and confer requirement. 3 2. If the parties are unable to resolve their dispute informally after a good-faith effort, the 4 parties must file a single document captioned “Stipulation Regarding Discovery Dispute” that 5 addresses each one of the following items: 6 i.A brief, joint summary of the discovery dispute not to exceed one (1) page; 7 ii. A restatement of the full text of the discovery requests, or deposition question, in dispute 8 as originally stated and the responses to the requests. This may be done in single-spaced, 10-font. 9 iii. A joint summary of the meet-and-confer efforts as required by LR IA 1-3(f), which 10 includes: (1) a summary of discussions; (2) identification of time, place, manner, and participants; and 11 (3)certification from counsel that, despite a sincere effort, the parties were unable to resolve or narrow 12 the dispute without court intervention. This joint meet and-confer summary may not exceed two (2) 13 pages. 14 iv. An explanation, without boilerplate language, of the position taken by each side, not to 15 exceed two (2) pages per side. 16 v.Each side must make a proposal of compromise or resolution of the disputed discovery (e.g., 17 request, interrogatory, deposition question). The proposal may not exceed two (2) pages per side. 18 3.Upon review of the filed “Stipulation Regarding Discovery Dispute,” Judge Couvillier may 19 set a telephonic conference, order written briefing, or enter an order deciding the dispute without 20 conference or briefing.
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1 LOREN S. YOUNG, ESQ. Nevada Bar No. 7567 2 JULIE A. WHITE, ESQ. Nevada Bar No. 8725 3 LINCOLN, GUSTAFSON & CERCOS, LLP ATTORNEYS AT LAW 4 7670 W Lake Mead Blvd, Suite 200 Las Vegas, Nevada 89128 5 Telephone: (702) 257-1997 Facsimile: (702) 257-2203 6 lyoung@lgclawoffice.com jwhite@lgclawoffice.com 7 Attorneys for Defendant, 8 TARGET CORPORATION
9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 SANDRA HERNANDEZ-ARREAGA, an 12 individual, CASE NO: 2:25-cv-01950
13 Plaintiff, STIPULATED PROTECTIVE ORDER 14 v. REGARDING CONFIDENTIAL MATERIALS 15
16 TARGET CORPORATION dba TARGET STORE T-0680, a Foreign Corporation; DOE 17 INDIVIDUALS I through X, inclusive; and ROE BUSINESS ENTITIES I through X, inclusive 18 Defendants. 19 20 IT IS HEREBY STIPULATED AND AGREED, by the undersigned attorneys for the 21 respective parties, that with regard to material disclosed in the course of the above-captioned lawsuit 22 (“Lawsuit”) which constitute or contain trade secrets or other confidential research, development, or 23 commercial information of the parties (“Confidential Material”), the following procedures shall 24 govern: 25 1. This Order is meant to encompass all forms of disclosure which may contain 26 Confidential Material, including any document, pleading, motion, exhibit, declaration, affidavit, 27 deposition transcript, inspection and all other tangible items (electronic media, photographs, 28 videocassettes, etc.). 1 2. The parties may designate any Confidential Material produced or filed in this Lawsuit 2 as confidential and subject to the terms of this Order by marking such materials “Confidential”. If any 3 material has multiple pages, this designation need only be placed on the first page of such material. 4 Any material designated as “Confidential” shall not be disclosed to any person or entity, except to the 5 parties, counsel in this Lawsuit, and the Court. 6 3. Any material designated as confidential pursuant to paragraph 2 above shall be used 7 solely for the purposes of this Lawsuit and for no other purpose. 8 4. Prior to disclosure of any Confidential Material, each person to whom disclosure is to 9 be made shall execute a written “Confidentiality Agreement” (in the form attached hereto) consenting 10 to be bound by the terms of this Order. The parties, counsel for the respective parties (including legal 11 assistants and other personnel) and the Court are deemed to be bound by this Order and are not required 12 to execute a Confidentiality Agreement. 13 5. Only counsel of record in this Lawsuit shall be permitted to disseminate Confidential 14 Material. Upon dissemination of any Confidential Material, each non-designating counsel of record in 15 this Lawsuit shall maintain a written record as to: (1) the identity of any person given Confidential 16 Material, and (2) the identity of the Confidential Material so disseminated (such as by “Bates stamp” 17 number). Such record shall be made available to the designating party upon request. 18 6. If additional persons become parties to this Lawsuit, they shall not have access to any 19 Confidential Material until they execute and file with the Court their written agreement to be bound 20 by the terms of this Order. 21 7. In the event that any question is asked at a deposition that calls for the disclosure of 22 Confidential Material, the witness shall answer such question (unless otherwise instructed not to do 23 so on grounds of privilege) provided that the only persons in attendance at the deposition are persons 24 who are qualified to receive such information pursuant this Order. Deposition testimony may be 25 designated as confidential following the testimony having been given provided that: (1) such testimony 26 is identified and designated on the record at the deposition, or (2) non-designating counsel is notified 27 of the designation in writing within thirty days after receipt by the designating party of the respective 1 “Confidential” pursuant to paragraph 2 above. When Confidential Material is incorporated in a 2 deposition transcript, the party designating such information confidential shall make arrangements 3 with the court reporter not to disclose any information except in accordance with the terms of this 4 Order. 5 8. If a deponent refuses to execute a Confidentiality Agreement, disclosure of 6 Confidential Material during the deposition shall not constitute a waiver of confidentiality. Under such 7 circumstances, the witness shall sign the original deposition transcript in the presence of the court 8 reporter and no copy of the transcript or exhibits shall be given to the deponent. 9 9. With respect to any communications to the Court, including any pleadings, motions or 10 other papers, all documents containing Confidential Material shall be done in accordance with Local 11 Rules IA 10-4 and IA 10-5, in additions to the directives set forth in Kamakana v. City and County of 12 Honolulu, 447 F.3d 1172 (9th Cir. 2006) and Center for Auto Safety v. Chrysler Group, LLC, 809 F.3d 13 1092, 1097 (9th Cir. 2016). All communications shall indicate clearly which portions are designated 14 to be “Confidential” through a Motion to Seal and/or redaction 15 10. The Court may order the court files and records, or any part thereof, to be sealed or 16 redacted, provided the Court makes and enters written findings that the specific sealing or redaction 17 is justified by identified compelling privacy or safety interests that outweigh the public interest in 18 access to the court records. 19 11. If a non-designating party is subpoenaed or ordered to produce Confidential Material 20 by another court or administrative agency, such party shall promptly notify the designating party of 21 the pending subpoena or order and shall not produce any Confidential Material until the designating 22 party has had reasonable time to object or otherwise take appropriate steps to protect such Confidential 23 Material. 24 12. Pursuant to LR 1-1(b)(2), Judge Couvillier requires the parties to follow the procedures 25 outlined below regarding any discovery dispute. No discovery motion may be filed until the following 26 procedure has been followed and such motion is ordered by Judge Couvillier: 27 1. If a discovery dispute arises the parties must first meet and confer to try to resolve their 1 person, videoconference, or telephone. A mere exchange of letters or e-mails does not satisfy the meet 2 and confer requirement. 3 2. If the parties are unable to resolve their dispute informally after a good-faith effort, the 4 parties must file a single document captioned “Stipulation Regarding Discovery Dispute” that 5 addresses each one of the following items: 6 i.A brief, joint summary of the discovery dispute not to exceed one (1) page; 7 ii. A restatement of the full text of the discovery requests, or deposition question, in dispute 8 as originally stated and the responses to the requests. This may be done in single-spaced, 10-font. 9 iii. A joint summary of the meet-and-confer efforts as required by LR IA 1-3(f), which 10 includes: (1) a summary of discussions; (2) identification of time, place, manner, and participants; and 11 (3)certification from counsel that, despite a sincere effort, the parties were unable to resolve or narrow 12 the dispute without court intervention. This joint meet and-confer summary may not exceed two (2) 13 pages. 14 iv. An explanation, without boilerplate language, of the position taken by each side, not to 15 exceed two (2) pages per side. 16 v.Each side must make a proposal of compromise or resolution of the disputed discovery (e.g., 17 request, interrogatory, deposition question). The proposal may not exceed two (2) pages per side. 18 3.Upon review of the filed “Stipulation Regarding Discovery Dispute,” Judge Couvillier may 19 set a telephonic conference, order written briefing, or enter an order deciding the dispute without 20 conference or briefing. 21 4.If an adverse party or counsel is not responsive or fails to cooperate in this process, a party 22 may file a unilateral “Stipulation Regarding Discovery Dispute -Filed Unilaterally in Compliance with 23 Standing Order,” and set forth in detail efforts to meet and confer and obtain cooperation 24 13. Inadvertent failure to designate any material “Confidential” or shall not constitute a 25 waiver of an otherwise valid claim of confidentiality pursuant to this Order, so long as a claim of 26 confidentiality is asserted within fifteen days after discovery of the inadvertent failure. At such time, 27 arrangements shall be made by the parties to designate the material “Confidential” in accordance with 1 14. This Order shall be without prejudice to the right of any party to oppose production of 2 any information or object to its admissibility into evidence. 3 15. When any counsel of record in this Lawsuit or any attorney who has executed a 4 Confidentiality Agreement becomes aware of any violation of this Order, or of facts constituting good 5 cause to believe that a violation of this Order may have occurred, such attorney shall report that there 6 may have been a violation of this Order to the Court and all counsel of record. 7 16. Within thirty days after the termination of this Lawsuit (whether by dismissal or final 8 judgment), all Confidential Material (including all copies) shall be returned to counsel for the 9 designating party. In addition, counsel returning such material shall execute an affidavit verifying that 10 all Confidential Material produced to such counsel and any subsequently made copies are being 11 returned in their entirety pursuant to the terms of this order. Such a representation fully contemplates 12 that returning counsel has: (1) contacted all persons to whom that counsel disseminated Confidential 13 Material, and (2) confirmed that all such material has been returned to disseminating counsel. 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// ] After the termination of this Lawsuit, the provisions of this Order shall continue to be 2 || binding and this Court shall retain jurisdiction over the parties and any other person who has access to 3 || documents and information produced pursuant to this Order for the sole purpose of enforcement of its 4 || provisions. 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 DATED this 7" day of November, 2025. DATED this 7" day of November, 2025. 7 LINCOLN, GUSTAFSON & CERCOS THE702FIRM INJURY ATTORNEYS 8 /s/_Loren S. Young, Esq. /s/_Brett J. Schwartz, Esq. LOREN S. YOUNG, ESQ. BRETT J. SCHWARTZ, ESQ. 9 Nevada Bar No. 7567 Nevada Bar No.13755 JULIE A. WHITE, ESQ. BRADLEY J. MYERS, ESQ. 10 Nevada Bar No. 8725 Nevada Bar No. 8857 7670 W. Lake Mead Blvd., Suite 200 MICHAEL C, KANE, ESQ. 1] Las Vegas, Nevada 89128 Nevada Bar No. 10096 Attorneys for Defendant, 8335 W. Flamingo Road 12 TARGET CORPORATION Las Vegas, Nevada 89147 Attorney for Plaintiff 13 SANDRA HERNANDEZ-ARREAGA 14 15 16 || The stipulated protective order is granted in part and denied in part consistent with the above edits. I 17 || IS SO ORDERED. 18 ls Are, UNITED STATES MAGISTRATE JUDGE 19 DATED: November 12, 2025 20 21 22 23 24 25 26 27 28
1 CONFIDENTIALITY AGREEMENT 2 BEING DULY SWORN, I hereby attest to the following: 3 1. It is my understanding that confidential information will be provided to me pursuant to 4 the terms and restrictions of the Protective Order entered in Sandra Hernandez-Arreaga v. Target 5 Corporation, et al., Case No. 2:25-cv-01950, by the United States District Court, District of Nevada, 6 (“Court”). 7 2. I have been given a copy of and have read the Protective Order and have had its 8 meaning and effect explained to me by the attorneys providing me with such confidential information, 9 and that I hereby agree to be bound by it. 10 3. I further agree that I shall not disclose such confidential information to others, except 11 in accordance with the Protective Order, 12 4. It is my understanding that if I fail to abide by the terms of the Protective Order then I 13 may be subject to sanctions imposed by the Court for such a failure. 14 5. I hereby consent to the jurisdiction of the Court for purposes of enforcing the Protective 15 Order. 16 FURTHER AFFIANT SAYETH NOT. 17 This _______ day of _____________, 2025. 18 ____________________________________ 19 (Name) ___________________________________ 20 (Address, City, State, Zip) ____________________________________ 21 (Telephone #) 22 Relationship to this lawsuit: ______________ 23 ______________________________ (Signature) 24 Subscribed and sworn to before me 25 This ___ day of ____________, 2025. 26 27 _____________________________ Notary Public