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Wolf v. Clark County

United States District Court, D. Nevada

November 30, 2017

BRUCE WOLFE, as Litigation Guardian Ad Litem for C.A.R., D.O.B. 1/19/2002, C.J.R., D.O.B. 1/17/2005 and G.Y.R., D.O.B 10/7/2006 Plaintiffs,
v.
CLARK COUNTY, THE STATE OF NEVADA DEPARTMENT OF HEALTH AND HUMAN SERVICES, NEVADA DIVISION OF CHILDREN AND FAMILY SERVICES AND JOHN AND JANE DOE 1-10. Defendants.

          ALLEN M. RESSLER, ESQ. (WSBA #5330) LAW OFFICES OF RESSLER & TESH Penthouse Suite

          JUSTIN L. WILSON, ESQ. JONES WILSON LLP

          OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI Felicia Galati, Esq. Attorney for Defendant Clark County

          STIPULATION AND [PROPOSED] PROTECTIVE ORDER

         1. Plaintiffs and Defendants, through their respective counsel and subject to the Court's approval, hereby stipulate and agree as follows, pursuant to Fed.R.Civ.P. 26(c), with respect to the disclosure of Confidential Information.

         2. The parties to this action submit this Stipulation and Protective Order (hereinafter “Order”) solely for the purpose of facilitating the exchange of documents and information between the parties in this action without involving the Court unnecessarily in the process. Nothing in this Order nor the production of any information or documents under the terms of this Order nor any proceedings pursuant to this Order shall be deemed to have the effect of an admission or waiver by any party or of altering the confidentiality or non-confidentiality of any such document or information or altering any existing obligation of any party or absence thereof.

         PROCEDURES REGARDING CONFIDENTIAL INFORMATION

         3. The parties define “Oregon and Washington case records” as all documents, which are in the custody of Plaintiffs or any other documents obtained by any party in this action from Oregon Department of Human Services (“Oregon DHS) and Washington Department of Social and Human Services (“Washington DSHS”), relating to Oregon DHS and Washington DSHS investigations, custody, and placement of Plaintiffs, including, but not limited to, documents relating to all Plaintiffs' institutional, foster family, and kin placements; foster family's licensing files; education, mental health, and health services; and court proceedings. These “case records” shall also include the files and documents of any child who has been or is in Oregon DHS and Washington DSHS custody. The term “document” and “documents” include any written, printed, typed, recorded, electronic or graphic material of every type and description, and each and every thing from which information can be processed or transcribed, including computer readable storage material. Documents include, but are not limited to, the following: records, handwritten notes, reports, agreements, memoranda, email communications and photographs.

         4. The parties acknowledge that Oregon DHS and Washington DSHS case records and the files and documents of any child who has been or is in their custody contain sensitive information that is generally protected from disclosure pursuant to federal and state law, including without limitation:

         (a) Information that identifies by name or address, or could reasonably lead to the disclosure of the name or address of any applicant for or recipient of child welfare, foster care, or adoption assistance services [45 C.F.R. 1355.21];

         (b) The names and addresses of applicants for and recipients of child welfare, foster care, or adoption assistance services and the amounts of financial assistance provided to them [45 C.F.R. 205.50];

         (c) Information related to the social and economic conditions or circumstances of particular individual applicants for or recipients of child welfare, foster care, or adoption services [45 C.F.R. 205.50];

         (d) Agency evaluations of information about particular individual applicants for or recipients of child welfare, foster care, or adoption assistance services [45 C.F.R. 205.50];

         (e) Medical data concerning particular individual applicants for or recipients of child welfare, foster care, or adoption assistance services [45 C.F.R. 205.50]; and

         (f) All records of child abuse reports and all information obtained in investigating reports of child abuse and neglect [45 C.F.R. 1340.14].

         The parties also acknowledge that all files or documents of any child who has been or is in Oregon DHS and Washington DSHS custody shall come within ...


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