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Henderson v. Clark County School District

United States District Court, D. Nevada

January 29, 2018

GARLAND HENDERSON, et al., Plaintiff,


          CLARK COUNTY SCHOOL DISTRICT Office of the General Counsel S. SCOTT GREENBERG NV Bar No. 4622 Attorneys for Defendant, Clark COUNTY SCHOOL DISTRICT

          LAW OFFICES OF ROBERT P. SPRETNAK ROBERT SPRETNAK NV Bar No. 5135 Attorney for Plaintiffs


         The parties to this action, identified below, herein enter the following stipulations and agreements and request the Court enter an Order for the same:

         A. Counsel for Plaintiffs, Garland Henderson and Tammie Keith-Henderson, collectively the “Plaintiffs, ” and B. Counsel for Defendant, CLARK COUNTY SCHOOL DISTRICT (CCSD), hereby agree to the following regarding potential production of employment records of non-party District employees:


         1. The "Litigation" shall mean the above-captioned case, Henderson, et al. v. Clark County School District, 2:17-cv-01767-JAD-NJK, United States District Court, District of Nevada, 2. It is acknowledged there is a presumption of public access to judicial files and records and that good cause must be shown to overcome this presumption. Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1179 (9th Cir. 2006). The parties believe good cause exists, as set forth hereinafter, and submit this Stipulated Confidentiality Agreement and Protective Order (hereinafter ive Order") for the purpose of facilitating the exchange of documents and information between the parties in this action without having to unnecessarily involve the Court in the discovery process and in order to protect privacy interests of third parties as necessary. Except as otherwise set forth herein, nothing in this Protective Order nor the production of any information or documents under the terms of this Protective Order nor any proceedings in this matter will be deemed an admission or waiver by any Party of any confidentiality protection otherwise applicable to any document or information produced in this Litigation.

         3. "Documents" shall mean and include any documents (whether in hard copy or electronic form), records, correspondence, analyses, assessments, photographs, memoranda, email communications, statements (financial or otherwise), audio recordings, video recordings, 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. "Information" means any information contained within a Document.

         4. "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.


         5. The Parties agree that any Document or Information which is: (1) a personnel document/information of a non-party District employee, or (2) a medical record of either Plaintiff, may be designated by the Producing Party as "CONFIDENTIAL" under the terms of this Protective Order and any such designated Document or Information shall not be provided to or made available to third parties except as permitted by, and in accordance with, the provisions of this Protective Order.

         6. Confidential Documents shall be so designated by marking or stamping each page of the Document produced to or received from a Party with the legend "CONFIDENTIAL - SUBJECT PROTECTIVE ORDER" and the Document and Information contained therein shall be deemed to be a Confidential Document or Information pursuant to this Protective Order.

         7. Testimony taken at a deposition reflecting upon documents/information designated CONFIDENTIAL pursuant to this stipulation may also be designated as CONFIDENTIAL by any Party making a statement to that effect on the record at the deposition or within ten (10) business days of receipt of the transcript. If deposition testimony is to be designated confidential then within 10 days of first receipt of a transcript, or longer time period agreed to by counsel in writing when necessary due to the length of a transcript, the designating party shall send all other parties a designation in letter form stating by specific citation to page and line No. the part being designated as confidential under this Agreement. Additionally, the designating party shall send a copy of the designating letter to the court reporter requesting that it be placed with any transcript of the designated deposition.

         8. CONFIDENTIAL Documents and Information shall be maintained in strict confidence by the Parties who receive such Documents and Information, shall only be used for the purpose of prosecution, defense, or settlement of this action, and for ...

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