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Currey v. Carson City School District

United States District Court, D. Nevada

November 8, 2017

JAMES CURREY, SR., J.C., a minor by and through his guardian ad litem JAMES CURREY; EMERIO RIVERA, AMALIA RIVERA, J.R.R.C, a minor by and through his guardian ad litem DENISE RIVERA; ROBERT PITTS, REBECCA PITTS, and K.B.P. a minor, by and through her guardian ad litem, REBECCA PITTS, Plaintiffs,
v.
CARSON CITY SCHOOL DISTRICT; LEE CONLEY; SUSAN MOULDEN; JAN ALBERTSON; VALENTINA MIDBOE; JENNIFER PALMER; TRAVIS LEE; CARL! BIANCHI and DOES 1-30; Defendants.

          WILLIAM F. HECKMAN, SBN 3072 THE LAW OFFICES OF WILLIAM F. HECKMAN, APC TODD BOLEY, SBN 64119 LAW OFFICES OF TODD BOLEY Attorneys for Plaintiffs.

          PETER D. DURNEY, ESQ. DURNEY & BRENNAN, LTD.

          CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         Pursuant to the Stipulation contained herein by and among counsel for Plaintiffs and counsel for Defendants, the Court hereby finds as follows:

         PURPOSES AND LIMITATIONS

         Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery, or any categories of information not specifically addressed herein, and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles, and designated "confidential" as described herein. The parties further acknowledge, as set forth further below, that this Stipulated Protective Order does not entitle them to file confidential information under seal or otherwise change Federal or Local rules, procedures, and standards to be applied when a party seeks permission from the court to file material under seal.

         1. The "Litigation" shall mean the above-captioned case, filed in the United States District Court, District of Nevada Case No. 3:17-cv-00386-HDM~WGC.

         2. "Documents" or "Information" shall mean and include any documents or portions thereof, or information extracted therefrom, (whether in hard copy or electronic form), records, correspondence, analyses, assessments, statements (financial or otherwise), responses to discovery, tangible articles or things, whether documentary or oral, and other information provided, served, disclosed, filed, or produced, whether voluntarily or through discovery or other means, in connection with this Litigation. A draft or non-identical copy is a separate document within the meaning of these terms.

         3. "Party" (or "Parties") shall mean one party (or all parties) in this Litigation and their in-house and outside counsel. "Producing Party" shall mean any person or entity who provides, serves, discloses, files, or produces any Documents or Information. "Receiving Party" shall mean any person or entity who receives any such Documents or Information.

         4. Any Party may designate any document, object, file, photograph, video, tangible thing, interrogatory answers, answers to requests for admissions, testimony, or other material or copies thereof (collectively, the "Discovery Material") as "Confidential Information" or following a good faith determination that the information so designated is or may reveal confidential, or proprietary matters.

         EXERCISE OF RESTRAINT AND CARE IN DESIGNATING MATERIAL FOR PROTECTION

         5. Each Party or Non-Party that designates information or items for protection under this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. Indiscriminate or routinized designations are prohibited.

         MANNER AND TIMING OF DESIGNATIONS

         6. CONFIDENTIAL Documents shall be so designated prior to their production by marking or stamping each page of the Document produced to or received from a Party with the legend "CONFIDENTIAL." The application of the legend must be made in a manner so as not to render the documents illegible, illegible after photocopying, or incapable of being subjected to Optical Scanning Recognition. If only a portion or portions of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins).

         7. Testimony taken at a deposition, or in other pretrial or trial proceedings, may be designated as CONFIDENTIAL by any Party making a statement to that effect on the record at the deposition. Arrangements shall be made with the court reporter taking and transcribing such deposition to separately bind such portions of the transcript and deposition exhibits containing Information designated as CONFIDENTIAL, and to label such portions appropriately. Counsel for the Parties may also designate an entire deposition transcript as CONFIDENTIAL at the time of the deposition. A party's failure to designate testimony confidential at the time of deposition shall not constitute the party's waiver of its right to correct its failure prior to a date ten business days after the party's receipt of the transcript, in which case all receiving parties shall honor the late designation as it would an inadvertent disclosure pursuant to paragraph 16 below.

         8. For information produced in some form other than documentary and for any other tangible items, that the Producing Party affix in a prominent place on the exterior of the container or containers in which the information or item is stored the legend "CONFIDENTIAL." If only a portion or portions of the information or item warrant protection, the Producing Party, to the extent practicable, shall identify the protected portion(s).

         ACCESS TO AND USE OF PROTECTED MATERIAL

         9. CONFIDENTIAL Information shall be maintained in strict confidence by the Parties who receive such information, shall be used solely for the purposes of this ...


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