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Doe v. Clark County

United States District Court, D. Nevada

November 29, 2017

S.H. JOHN DOE, a minor child, by and through his Natural Parent and Legal Guardian, A.O. JANE DOE, an Individual; A.O. JANE DOE, Individually; Plaintiffs,
v.
CLARK COUNTY, a political subdivision of the State of Nevada; KEVIN BROWN, an Individual; JULIANE HUGHES, an Individual; EAGLE QUEST OF NEVADA, INC., a Nevada Corporation; EAGLE QUEST, a Nevada Domestic Corporation; IVAN RAY TIPPETTS, an Individual; LESLIE TIPPETTS, an Individual; SHERA WILLIAMS, an Individual, TOMISHA HORN, an Individual; ILIA HAMPTON, LCSW, QMPH, an Individual; TRENT HANSEN, LCSW, an Individual; Defendants.

          Lagomarsino Law, ANDRE M. LAGOMARSINO, ESQ., Attorney for Plaintiffs S.H. John Doe and A.O. Jane Doe.

          OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI, THOMAS A. DILLARD, JR., ESQ., Attorney for Defendants Clark County, Kevin Brown, and Juliane Hughes.

          [PROPOSED] STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFFS AND DEFENDANTS [1]

         The parties to this action, Plaintiffs S.H. JOHN DOE, a minor child, by and through his Natural Parent and Legal Guardian, A.O. JANE DOE and A.O. JANE DOE, individually (“Plaintiffs”), and Defendants CLARK COUNTY; KEVIN BROWN; JULIANE HUGHES; EAGLE QUEST OF NEVADA, INC.; EAGLE QUEST; IVAN RAY TIPPETTS; LESLIE TIPPETTS; ILIA HAMPTON, LCSW, QMPH; and TRENT HANSEN, LCSW (“Defendants”), by and through their respective counsel, hereby stipulate and request that the Court enter a stipulated protective order pursuant as follows: . . .

         1. The Protective Order shall be entered pursuant to the Federal Rules of Civil Procedure.

         2. The Protective Order shall govern all materials deemed to be “Confidential Information.” Such Confidential Information shall include the following:

(a) Any and all documents referring or related to S.H. JOHN DOE or A.O. JANE DOE;
(b) Any documents from the juvenile Court file of Plaintiff S .H. JOHN DOE;
(c) Any documents relating to the medical and/or health information of Plaintiffs;
(d) Any portions of depositions (audio or video) where Confidential Information is disclosed or used as exhibits;
(e) Any proprietary business documents; and
(f) Any and all documents referring, or related, to the juvenile identified as C.J. in the Complaint and allegedly involved in the incident of February 14, 2017.

         3. In the case of documents and the information contained therein, designation of Confidential Information produced shall be made by placing the following legend on the face of the document and each page so designated “CONFIDENTIAL” or otherwise expressly identified as confidential.

         4. Confidential Information shall be held in confidence by each qualified recipient to whom it is disclosed, shall be used only for purposes of this action, shall not be used for any business purpose, and shall not be disclosed to any person who is not a qualified recipient. All produced Confidential Information shall ...


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