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Sanchez v. Noboa Amador

United States District Court, D. New Mexico

October 17, 2018

MARIANE SANCHEZ, Plaintiff,
v.
MIGUEL ANGEL NOBOA AMADOR, THE OWNER OF LA VILLA TRANSPORT, INC., THE REGISTERED OWNER OF THE TRACTOR/TRAILER, AND JORGE MUNGUIA, DEFENDANT DRIVER, Defendants.

          KENNEDY KENNEDY & IVES Shannon L. Kennedy

          SLOAN, HATCHER, PERRY, RUNGE, ROBERTSON & SMITH John Sloan Attorneys for Plaintiff Mariane Sanchez

          BUTT THORNTON & BAEHR, P.C. Approved via electronic mail 10-03-18 Maria S. Dudley Michael P. Clemens Attorneys for Defendants

          STIPULATED CONFIDENTIALITY AND PROTECTIVE ORDER

          STEPHAN M. VIDMAR UNITED STATES MAGISTRATE JUDGE

         THIS MATTER is before the Court on the stipulation of the parties for the entry of this confidentiality and protective order (“Protective Order”), it is hereby ORDERED as follows:

         1. Qualified Persons.

         “Qualified Persons” for confidential information means:

a. retained counsel for the parties in this litigation and their respective staff;
b. in-house counsel for the parties;
c. actual or potential independent experts or consultants (and their administrative or clerical staff) engaged in connection with this litigation who, prior to any disclosure of Confidential Information to such person, have agreed in writing to be bound by the terms of this Protective Order;
d. this Court and its staff and any other tribunal or dispute resolution officer duly appointed, assigned or retained in connection with this litigation; e. any party, if a natural person;
f. if the party is a legal entity other than a natural person, such officers or employees of the party who are involved in the prosecution or defense of this case who, prior to any disclosure of Confidential Information to such person, have been informed of the terms of this Protective Order and agree to be bound by its terms;
g. litigation vendors, court reporters, and other litigation support personnel;
h. any insurance claims adjuster and his or her supervisors, involved in the adjusting of any claim being litigated or presented in connection with the above-captioned case;
i. any person who was an author, addressee, or intended or authorized recipient of the Confidential Information and who agrees to keep the information confidential, provided that such persons may see and use the Confidential Information but not retain a copy; and
j. any such other person as this Court may designate after notice and an opportunity to be heard.

         2. ...


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