Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Ward v. State

United States District Court, D. Nevada

March 23, 2018

LARA WARD, an individual, Plaintiff,
v.
STATE OF NEVADA, ex rel. its BOARD OF MEDICAL EXAMINERS, DON ANDREAS, an Individual, PAMELA CASTAGNOLA, an Individual, KIM FRIEDMAN, an Individual, KATI PAYTON, an Individual, TODD RICH, an Individual, AND EDWARD COUSINEAU, an Individual; DOES I - X, Defendants.

          SUTTON HAGUE LAW CORPORATION, P.C., S. BRETT SUTTON JARED HAGUE ANTHONY E. GUZMAN II Attorneys for Defendants STATE OF NV BOARD OF MEDICAL EXAMINERS, PAMELA CASTAGNOLA, KIM FRIEDMAN, KATI PAYTON, and EDWARD COUSINEAU

          GARG GOLDEN LAW FIRM, ANTHONY GOLDEN Attorneys for Defendants DON ANDREAS

          HKM EMPLOYMENT ATTORNEYS, LLP, JENNY L. FOLEY Attorney for Plaintiff LARA WARD

          STIPULATION AND [PROPOSED] PROTECTIVE ORDER REGARDING CONFIDENTIALITY AGREEMENT

         Plaintiff, LARA WARD (“Plaintiff”) and Defendants, STATE OF NEVADA, ex rel. its BOARD OF MEDICAL EXAMINERS, PAMELA CASTAGNOLA, KIM FRIEDMAN, KATI PAYTON, DON ANDREAS, and EDWARD COUSINEAU (“Defendants”) (jointly the “parties”) by and through their respective attorneys of record, hereby stipulate and agree as follows:

         1. Parties' Acknowledgment and Agreement.

         The parties acknowledge and agree that certain information subject to discovery in the above-captioned matter may contain privileged information, trade secret, proprietary, private, confidential, and/or other business and/or personal information, which, if divulged, could damage one or more parties' business interests and/or could infringe on a constitutionally protected right of privacy. Subject to and without waiving any objections any party may have as to the discoverability of any information, the parties, by and through their respective attorneys of record, hereby stipulate and agree that documents and information produced during the course of discovery in this matter shall be protected against inappropriate disclosure in accordance with the terms and conditions set forth below.

         2. Scope of Stipulation and Protective Order.

         This Stipulation and [Proposed] Protective Order Regarding Confidentiality Agreement (“Stipulation and Protective Order”) shall govern all materials produced by the parties to this action in response to any discovery request in this action, including informal production and discovery produced by the parties prior to entering into this agreement (including, but not limited to, computer hardware, documents, and deposition transcripts) and all information contained in those materials, and all copies, excerpts, or summaries of those materials (hereinafter collectively referred to as “DISCOVERY MATERIAL”) and DISCOVERY MATERIAL produced by third parties in response to discovery if designated confidential by any of the Parties within 30 days of production of such information by a third party.

         3. Computer Hardware.

         Discovery requests concerning non-privileged information that is kept in electronic format in the normal course of Defendants' business shall be produced in electronic format. All other non-privileged information shall be produced in hard/paper copy format.

         4. Non-Party DISCOVERY MATERIAL.

         This Stipulation and Protective Order shall govern all DISCOVERY MATERIAL produced during discovery by any non-parties. In the event a non-party requests the protections provided by this Stipulation and Protective Order, such non-party will be treated as a party under this Stipulation and Protective Order.

         5. Definitions of and Limitations on Use of CONFIDENTIAL DISCOVERY MATERIAL.

         Confidential information subject to this Stipulation and Protective Order (“CONFIDENTIAL DISCOVERY MATERIAL”) is information that has not been made public and that refers to, describes, or consists of the disclosure of confidential, proprietary, medical, mental health or otherwise non-public business, technical, or financial information, employee personnel and earnings information, or information protected by third-party privacy rights. CONFIDENTIAL DISCOVERY MATERIAL includes not only the information contained in documents and other materials designated as such pursuant to this Stipulation and Protective Order, but also to any summaries, copies, abstracts, compilations, or other documents or material derived from CONFIDENTIAL DISCOVERY MATERIAL. The parties acknowledge that the only information to be designated as CONFIDENTIAL DISCOVERY MATERIAL is that which is properly subject to protection or which may be held confidential pursuant to NRS 630.336 and/or NRS 630.311. The party or third party asserting the “Confidential” designation as to any DISCOVERY MATERIAL shall have the burden of justifying that the designation is consistent with Nevada law. Until the Court or Arbitrator rules otherwise, the challenged DISCOVERY MATERIAL shall be treated as CONFIDENTIAL.

         6. Designation of Material as “Confidential.

         Any party to this Stipulation and Protective Order may, in good faith, designate DISCOVERY MATERIAL that consists of or includes non-public information that would reasonably be subject to protection as “Confidential.” Such DISCOVERY MATERIAL may include documents, deposition testimony, transcripts, and exhibits; responses to interrogatories; responses to requests for admission; and other written, recorded, or graphic information and materials produced by a party or non-party in the course of this action. Designation of DISCOVERY MATERIAL containing CONFIDENTIAL DISCOVERY MATERIAL shall be made by stamping the legend “Confidential-Subject to Protective Order” or “Confidential” on the document. Multi-paged CONFIDENTIAL DISCOVERY MATERIAL that is bound together need only be designated on the first page. If the CONFIDENTIAL DISCOVERY MATERIAL cannot be so labeled, it will be designated “Confidential” in some other conspicuous manner. Any “Confidential” designation that is inadvertently omitted during document production may be corrected by written notice to the other party. In the case of documents and other materials produced by a party, the “Confidential” designation shall be made at the time of production.

         7. Confidential Treatment for Documents not Designated.

         Any party may obtain confidential treatment for documents or other materials previously produced by any party or non-party without such designation if the party seeking the designation sends written notice of such designation to all other parties or non-parties in the possession of such documents or other materials and within thirty (30) days of their production marks the subject documents or other materials with the word “Confidential” and reproduces them. All documents and other materials produced by a non-party and not designated as “Confidential” by a party at the time of their production shall nonetheless be treated as CONFIDENTIAL DISCOVERY MATERIAL for thirty (30) days following such production.

         8. Designation of Confidential ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.