United States District Court, D. Nevada
MARIA CORREA, both individually and as representative for THE ESTATE OF ABEL CORREA; GILBERTO CORREA; MOISES CORREA and RICARDO CORREA, Plaintiffs,
LAS VEGAS METROPOLITAN POLICE DEPARTMENT, apolitical subdivision of the State of Nevada; JOSEPH LOMBARDO, individually and in his official capacity as Sheriff of Clark County; GLENN TAYLOR, individually; ELI PRUNCHAK, individually; ROE and DOE SUPERVISORS, not yet known, Defendants.
amended on p. 10
R. Grimes, Esq. Nevada Bar No. 12972 Attorney for plaintiffs
Marquis Aurbach Coffing Craig R. Anderson, Esq. Nevada Bar
No. 6882 Attorneys for Defendants LVMPD, Sheriff Lombardo,
Ofc. Taylor and Ofc. Prunchak
seeks to obtain, inspect and copy documents and/or things
which the Las Vegas Metropolitan Police Department
("LVMPD") contends contains private and sensitive
information, confidential information of LVMPD, its officers
and employees, its internal investigative and administrative
actions, and other confidential information. Pursuant to an
agreement by the Parties, the Court hereby enters the
following Order for Protection ("Protective
OF PROTECTIVE ORDER
following definitions apply to the Protective Order:
Party. Any party to this action, including all of
its officers, directors, employees, consultants, Experts, and
Outside Counsel. Party, as used in this Protective Order,
shall also refer to the Las Vegas Metropolitan Police
Department, and its officers, agents and employees.
Disclosure or Discovery Material. All items or
information, regardless of the medium or manner generated,
stored, or maintained (including, among other things,
testimony, transcripts, or tangible things) that are produced
or generated in disclosures or responses to discovery in this
"Confidential" Information or Items.
Information (regardless of how generated, stored or
maintained) or tangible things that qualify for protection
under the law enforcement investigative and/or official
information privileges, or that contain Criminal History
Information, personal information regarding individuals
including Social Security Numbers, dates of birth and
information which a person would have a reasonable
expectation of privacy. Confidential information shall also
include information concerning, regarding, or as a result of
covert or undercover law enforcement investigation(s)
technique(s), method(s) or source(s), including the identity
of any confidential informant, undercover officer
information, or information referring to any undercover or
active criminal investigations. Further, Confidential
information shall also include any information protected from
disclosure under Donrey v. Bradshaw, 106 Nev. 630
(1990) or an official or executive information privilege.
Confidential information shall also include employee
information, employee medical information, and employee
disciplinary action, including any internal investigation
concerning employee actions.
Receiving Party. A Party that receives Disclosure or
Discovery Material or Confidential Information from a
Producing Party. A Party or third-party that
produces Disclosure or Discovery Material or Confidential
Information in this action.
Designating Party. A Party or third-party that
designates information or items that it produces in
disclosures or in responses to discovery as
Protected Material. Any Disclosure or Discovery
Material or Confidential Information that is designated as
Outside Counsel. Attorneys who are not employees of
a Party but who are retained to represent or advise a Party
in this action.
House Counsel. Attorneys who are employees of a
Counsel (without qualifier). Outside Counsel and
House Counsel (as well as their support staffs).
Expert. A person with specialized knowledge or
experience in a matter pertinent to the litigation retained
by a Party or its Counsel to serve as an expert witness or as
a consultant in this action. This definition includes, but is
not limited to, a professional jury or trial consultant
retained in connection with this litigation.
Professional Vendor. Person or entity that provides
litigation support services (e.g., photocopying,
videotaping, translating, preparing exhibits or
demonstrations, organizing, storing, retrieving data in any
form or medium; etc.) and its employees and subcontractors.
use of the singular form of any word includes the plural, and
protection conferred by this Protective Order covers not only
Protected Material, but also any information copied or
extracted therefrom, as well as all copies excerpts,
summaries, or compilations thereof, testimony, conversations,
or presentations by parties or counsel to or in court or in
other settings that might reveal Protected Material.
after the termination of this action, the confidentiality
obligations imposed by this Protective Order shall remain in
effect until a Designating Party agrees ...