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Eliason v. Clark County

United States District Court, D. Nevada

July 18, 2018

ROBERT ELIASON, an individual and in his official capacity as Constable of North Las Vegas Township, Plaintiff,
v.
CLARK COUNTY, a political subdivision of the State of Nevada; STATE OF NEVADA ex rel NEVADA COMMISSION ON PEACE OFFICER STANDARDS & TRAINING, a regulatory agency of the State of Nevada, Defendants.

          EVANS FEARS & SCHUTTERT| LLP KELLY A. EVANS, ESQ. CHAD R. FEARS, ESQ. And ASHCRAFT & BARR | LLP JEFFREY F. BARR, ESQ. Attorneys for Plaintiff Robert Eliason

          OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI THOMAS D. DILLARD, JR., ESQ. Attorneys for Defendant Clark County

          ADAM P. LAXALT, ATTORNEY GENERAL MICHAEL D. JENSEN, ESQ. Attorneys for Defendant State of Nevada ex rel. Nevada Commission on Peace Officers Standards and Training

          STIPULATED PROTECTIVE ORDER

         1. PURPOSES AND LIMITATIONS

         Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted.

         This Order does not confer blanket protections on all disclosures or responses to discovery and the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. As set forth below, this Protective Order does not entitle the Parties to file confidential information under seal; LR IA 10-5 sets forth the procedures that must be followed when a party seeks permission from the Court to file material under seal.

         Confidential information protected by this Protective Order is “declared by law to be confidential” for purposes of NRS ch. 239 and shall not be disclosed pursuant to any public records request or Freedom of Information Act request or any other such statute, law, or regulation.

         2. DEFINITIONS

         2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.

         2.2 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 2.3 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter.

         2.4 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action; (2) is not a current employee of a Party; and (3) at the time of retention, is not anticipated to become an employee of a Party or of a Party's competitor. This definition includes a professional jury or trial consultant retained in connection with this litigation.

         2.5 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Information or Items: extremely sensitive employment, educational, and health information or Items, disclosure of which to another Party or Non-Party requires a high level of protection due to significant privacy interests of the Designating Party. HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Information or Items include any documents or information prohibited from disclosure by statute, including but not limited to FERPA and HIPPAA in the possession, custody, or control of any Party or Non-Party.

         HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Information or Items may be disclosed to two representatives of a Receiving Party designated in advance, provided that such Receiving Party representative execute an Acknowledgement and Agreement to Be Bound in substantially the form of Exhibit A to this Order.

         2.6 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action.

         2.7 Outside Counsel of Record: attorneys who are not employees of a party to this action but are retained to represent or advise a party to this action and have appeared in this action on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.

         2.8 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs).

         2.9 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action.

         2.10 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.

         2.11 Protected Material: any Disclosure or Discovery Material that is designated as “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY.” 2.2 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

         3. SCOPE

         The protections conferred by this Order cover not only Protected Material (as defined above), but also any information copied or extracted from Protected Material; all copies, excerpts, summaries, or compilations of Protected Material; and any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material. However, the protections conferred by this Order do not cover the following information: (a) any information that is in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of publication not involving a violation of this Order, including becoming part of the public record through trial or otherwise; and (b) any information known to the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from a ...


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