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United States District Court District of Nevada Bruce Wolf v. Clark County

United States District Court, D. Nevada

January 29, 2018

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BRUCE WOLF, as Litigation Guardian Ad Litem For C.A.R, D.O.B., 2002, C.J.R., D.O.B., 2005 and G, Y.R. D.O.B., 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,

          FELICIA GALATI, ESQ. Nevada Bar No. 7341 OLSON, CANNON, GORMLEY ANGULO & STOBERSKI Attorneys for Defendant CLARK COUNTY

          OLSON, CANNON, GORMLEY ANGULO & STOBERSKI FELICIA GALATI, ESQ. Attorney for Defendant CLARK COUNTY

          STIPULATION AND [PROPOSED] PROTECTIVE ORDER

         1. On 12/13/17, this Court granted a protective order relating to Clark County Department of Family Services documents. (Docket #44) This Protective Order is different from Docket #44 in that it pertains to Eighth Judicial District Court, Family Division, J case documents, that are confidential and the related District Attorney files containing documents regarding those same cases only. This protective order has become necessary due to Plaintiffs' discovery demands, including a unilateral 1 week deadline to produce these documents.

         2. 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.

         3. 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

         The parties define "J case records" as all documents, which are in the custody of County Defendants, including such documents it obtained from the Eighth Judicial District Court, Family Division, and such documents contained in the District Attorney Juvenile tiles relating to Plaintiffs J cases. 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: pleadings or any other papers filed in court, records, handwritten notes, reports, agreements, memoranda, email communications, photographs, and UNITY database entries.

         4. The parties acknowledge that J case records and the files and documents of any child 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; Nev. Rev. Stat. Ann. § 432B.28O]. The parties also acknowledge that all files or documents of any child who has been the subject of any J case shall come within the provisions and protections of this Order.

         5. J case records shall be deemed to be Confidential Information pursuant to this Order and defendants shall label them as Confidential upon production.

         6. A party may also label as "Confidential" any discovery that is served or produced in this litigation (including subpoenas and deposition testimony), if the marking party believes that the information contained in such discovery qualifies for protection under standards developed under Fed.R.Civ.P. 26(c) or state or federal law, including the right to ...


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