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Mancao v. Clark County District Attorney Family Support Division, ex. rel. Clark County

United States District Court, D. Nevada

April 3, 2018

NORALYN MANCAO, an individual, Plaintiff,
v.
CLARK COUNTY DISTRICT ATTORNEY FAMILY SUPPORT DIVISION, ex. rel. CLARK COUNTY, a political subdivision of he State of Nevada; EMPLOYEE(s) AGENT(s) DOES 1-10 and ROE ENTITIES; 1 through 10, inclusive, Defendants.

          THE THATER LAW GROUP, P.C. M. LANI ESTEBAN-TRINIDAD, ESQ. Nevada Bar No. 006967 Attorneys for Plaintiff

          LEWIS BRISBOIS BISGAARD & SMITH LLP, ROBERT W. FREEMAN, ESQ. Nevada Bar No. 003062 DANIELLE C. MILLER, ESQ. Nevada Bar No. 009127, Attorneys for Defendant Clark County

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         Plaintiff Noralyn Mancao, by and through her attorney, M. Lani Esteban-Trinidad, Esq., and Defendant Clark County, by and through its attorney, Robert W. Freeman, Esq., hereby agree and stipulate as follows:

         1. The parties enter into this Stipulation and Protective Order under Federal Rule of Civil Procedure 26(c) to establish procedures for the handling of documents produced by the parties in response to discovery requests.

         2. Any party may designate and mark certain documents produced in response to discovery requests as “CONFIDENTIAL” or “SUBJECT TO PROTECTIVE ORDER.” The party designating such documents shall be referred to as the Designating Party and any party in receipt of such documents shall be referred to as the Receiving Party. Documents so marked may be used only for purposes of this litigation.

         3. Except as otherwise ordered by this Court, documents marked “CONFIDENTIAL” or “SUBJECT TO PROTECTIVE ORDER” and the contents of documents so marked may be disclosed only to employees or agents of the following persons:

(a) Plaintiff and counsel of record for Plaintiff;
(b) Defendant and counsel of record for Defendant;
(c) the non-technical and clerical staff employed by counsel of record;
(d) interpreters and copying services employed by counsel of record's employer to the extent reasonably necessary to render professional services in this case;
(e) any private court reporter retained by counsel for depositions in this case;
(f) subject to the terms of paragraph 5, persons retained by counsel to serve as expert witnesses or consultants in this case; and
(g) personnel of the Court, including court reporters, officials and employees of the Clerk of Court, and staff of the presiding United States District Judge and United States Magistrate Judge, to the extent deemed necessary by the Court.

         4. If counsel for a Receiving Party determines that it is necessary to disclose any document marked “CONFIDENTIAL” or “SUBJECT TO PROTECTIVE ORDER” to any persons other than the individuals included in paragraph 3, that counsel shall set forth the grounds for the disclosure and seek the written consent of counsel for the Designating Party. The Designating Party shall respond to the Receiving Party's request within seven calendar days unless the Receiving Party agrees to a longer period. If counsel for the Designating Party does not consent, counsel for the Receiving Party and counsel for the Designating Party shall within five court days of the Designating Party's response meet and confer in person or telephonically regarding the issue, during which meeting and conference counsel for the Receiving Party shall specify the reasons why disclosure is necessary. If any agreement is not reached, the Designating Party shall move the Court within the ...


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