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Tolliver v. Lyon County School District

United States District Court, D. Nevada

April 16, 2018

CHARLES TOLLIVER; J.T.; a minor by and through her guardian ad litem CHARLES TOLLIVER; and T.M., a minor by and through her guardian ad litem NANCY MARRIOTT-TOLLIVER, Plaintiffs,
v.
LYON COUNTY SCHOOL DISTRICT, and CITY of YERINGTON, Defendants.

          LAW OFFICES OF TERRI KEYSER-COOPER, Attorney for Plaintiffs

          THORNDAL ARMSTRONG DELK BALKENBUSH & EISINGER, Katherine F. Parks, Esq Attorneys for Defendants CITY OF YERINGTON

          ERICKSON THORPE & SWAINSTON, LTD., Ann M. Alexander, Esq., Attorneys for Defendant LYON COUNTY SCHOOL DISTRICT

          STIPULATED PROTECTIVE ORDER

         Katherine F. Parks, Esq. - State Bar No. 6227 Thorndal Armstrong Delk Balkenbush & Eisinger 6590 S. McCarran Blvd., Suite B Reno, Nevada 89509 (775) 786-2882 kfp(ajthorndal. com Attorneys for Defendant CITY OF YERINGTON

         In order to protect the confidentiality of confidential information obtained by the parties in connection with this case, the parties hereby agree as follows:

1. Any party or non-party may designate as "confidential" (by stamping the relevant page or otherwise set forth herein) any document or response to discovery which that party or non-party considers in good faith to contain confidential information, including but not limited to personal information of juveniles or students, subject to protection under the Federal Rules of Civil Procedure, Family Educational Rights and Privacy Act, or state or federal law ("Confidential Information"). Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be so designated.
2. A party or non-party may designate information disclosed during a deposition or in response to written discovery as "confidential" by so indicating in said response or a party or non-party may designate in writing, within twenty (20) days after receipt of said responses or of the deposition transcript for which the designation is proposed, that specific pages of the transcript and/or specific responses be treated as "confidential" information. Any other party may object to such proposal, in writing or on the record. Upon such objection, the parties shall follow the procedures described in paragraph 8 below. After any designation made according to the procedure set forth in this paragraph, the designated documents or information shall be treated according to the designation until the matter is resolved according to the procedures described in paragraph 8 below, and counsel for all parties shall be responsible for making all previously unmarked copies of the designated material in their possession or control with the specific designation.
3. All information produced or exchanged in the course of this case (other than information that is publicly available) shall be used by the party or parties to whom the information is produced solely for the purpose of this case.
4. Except with the prior written consent of other parties, or upon the prior order of this Court obtained upon notice to opposing counsel, Confidential Information shall not be disclosed to any person other than:
(a) counsel for the respective parties to this litigation, including in-house counsel and co-counsel retained for this litigation;
(b) employees of such counsel;
(c) individual parties, class representatives, any officer or employee of a party, to the extent deemed necessary by Counsel for the prosecution or defense of this litigation;
(d) consultants or expert witnesses retained for the prosecution or defense of this litigation, provided that each such person shall execute a copy of the Certification annexed to this Order as Exhibit "A" (which shall be retained by counsel to the party so disclosing the Confidential Information and made available for inspection by opposing counsel during the pendency or after the termination of the action only upon good cause ...

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