Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Brown v. Clark County

United States District Court, D. Nevada

May 18, 2017

CHARON L. BROWN Plaintiff,
v.
CLARK COUNTY, NEVADA; CLARK COUNTY DETENTION CENTER; LAS VEGAS METROPOLITAN POLICE DEPT., a legal entity pursuant to N.R.S. 280.280 and SHERIFF JOSEPH LOMBARDO et, al. LVMPD John Doe's and Jane Doe's who are Las Vegas Metropolitan Police Officers; John Doe's and Jane Doe's who are classification Officers at Clark County Detention Center et, al, and all Clark County Detention Center records officers under title of Las Vegas Metropolitan Police Officers employed at Clark County Detention Center et, al, John Doe's and Jane Does #1-10 Records Officers et, al, and John Does and Janes Does #6-10 Classification Officers ct, al, along with Clark County Detention Centers private in house medical company NaphCare Drs and staff et, al, Health Service, Administrative assistant/risk management, HR Physicians, Director of nursing, medical records manager, head of sick call, clinical nursing supervisor, administrative appointment scheduler, another legal entity pursuant to N.R.S. 280.280 within Clark County Detention Center Under S.O.P. 13.00.00 along with John Doe #11-20 and Jane Doe #1-10 inclusive, Defendants.

          ALVERSON, TAYLOR. MORTENS EN & SANDERS SHIRLEY BLAZICH ESQ., MICHAEL T. MCLOUGMLIN. ESQ. ATTORNEYS FOR DEFENDANTS NAPHCARE, INC.

          LEWIS ROCA ROTHGERBER CHRISTIE. LLP MALANT DALE KOTCHKA-ALANES, ESQ. ATTORNEYS FOR PLAINTIFF CHARON L BROWN

          KAEMPFERCROWELL LYSSA S. ANDERSON. ESQ. ATTORNEYS FOR OFFICER DEFENDANTS

          STIPULATION AND PROTECTIVE ORDER REGARDING CONFIDENTIALITY FOR DOCUMENTS PRODUCED

         It is anticipated that discovery in this action may require certain parties and non-parties to disclose information and documents that may be confidential, proprietary and sensitive. The Las Vegas Metropolitan Police Department ("LVMPD"), NaphCare, Inc. ("NaphCare"), and Plaintiff Charon L. Brown agree as follows.

         1. Any Party (defined as a party to this stipulation, whether or not a party to the litigation) may designate all or any portion of a document, object, file, photograph, video, tangible thing, interrogatory answers, answers to requests for admissions, deposition testimony, or other material (the "Discovery Material") as "Confidential Information" following a good faith determination that the information so designated is or may reveal trade secrets or matters which are confidential or proprietary under applicable law. A Party shall designate Confidential Information by placing the legend "Confidential" on each page designated as Confidential Information, or securely affix the legend to the object or tangible thing. If any Discovery Material is disclosed in a form not appropriate for such placing or affixing a legend, it shall be designated in writing by the producing Party as Confidential Information at the time it is delivered to the receiving Party. The receiving Party shall treat copies, print-outs, derivative data or manipulations of such material in accordance with any designations of Confidential Information as provided for herein.

         Nothing herein shall be construed to restrict any Party's use of information that is possessed or known prior to disclosure by another Party, or is public knowledge, or is independently developed or acquired outside of the production and exchange covered by this Stipulated Confidentiality and Protective Order.

         2. The term "disclosure" shall include the dissemination, communication, publication or reproduction of any confidential material or the specific contents of the information contained therein, or the communication of any estimate or other information which facilitates the discovery of confidential information.

         3. As used in this Protective Order, the term "qualified persons" means (i) counsel of record for the parties to the litigation, including office associates, paralegals, and stenographic and clerical employees to whom disclosure is reasonably necessary; (ii) experts retained for the purpose of this litigation to whom disclosure is reasonably necessary and who reviewed and signed a copy of this Stipulation; (iii) parties to this action; and (iv) court personnel, including stenographic reporters engaged in such proceedings as are necessarily incident to this litigation.

         4. Confidential information shall be and remain confidential, and, except as allowed by this Protective Order, may not be disclosed or communicated, nor used for any purpose other than this litigation and any subsequent appeals.

         5. Any and all documents containing confidential information must be retained by counsel, and not be disclosed or made available to any person other than a qualified person who has read and acknowledged the terms of this Protective Order. Similarly, the confidential information contained within those documents may not be disclosed to any person other than a qualified person. To the extent reasonably necessary, copies of confidential documents may be provided to experts retained for the purpose of this litigation to whom disclosure is reasonably necessary and who have signed this Stipulation and Protective Order. Nothing in this Protective Order shall in any way affect the admissibility or use at trial of any of the documents produced under this Protective Order.

         6. Any person who is in possession of confidential information, or to whom confidential information is disclosed, is responsible for ensuring that such confidential information is not inadvertently disclosed by him or her. Failure to take all reasonable precautions to ensure against such inadvertent disclosure will be a breach of this Stipulation and Order.

         7. Counsel or parties receiving confidential information may not disclose that confidential information to any expert without first furnishing to that expert a copy of this Stipulation and Protective Order and obtaining a signed copy of this Stipulation and Protective Order from that expert.

         8. Any person who executes a copy of this Stipulation and Protective Order submits to the jurisdiction of this Court for purposes of enforcement of this Protective Order, either prior to or following trial of this action. Jurisdiction of this action is to be retained by this Court after final determination for purposes of enabling any party or persons affected by this Protective Order to apply to the Court for such direction or further decree as may be appropriate for the construction or enforcement of this Protective Order, or for such additional relief as may become appropriate.

         9. If any Party affected by this Protective Order objects to the designation by the disclosing Party of a document or item, pleading, or transcript of testimony as "CONFIDENTIAL, " the objecting Party shall give written notice of its objection to the disclosing Party and shall identify the document, pleading, and/or testimony at issue and the reason for the objection. The disclosing Party shall thereafter have twenty (20) business days within which to apply to the Court for appropriate protection of the document, pleading, and/or testimony pursuant to the Federal Rules of Civil Procedure. If the disclosing Party does not make application within twenty (20) business days after receipt of the written objection (or within the stipulated time period if stipulated to be longer or shorter than twenty (20) days), then the documents, pleadings, and/or testimony at issue shall no longer be deemed "CONFIDENTIAL." However, until expiration of the twenty (20) day time period (longer or ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.