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Doe v. Clark County

United States District Court, D. Nevada

July 26, 2018

S.H. JOHN DOE, a minor child, by and through his Natural Parent and Legal Guardian, A.O. JANE DOE, an Individual; A.O. JANE DOE, Individually; Plaintiffs,
v.
CLARK COUNTY, a political subdivision of the State of Nevada; KEVIN BROWN, an Individual; JULIANE HUGHES, an Individual; EAGLE QUEST OF NEVADA, INC., a Nevada Corporation; EAGLE QUEST, a Nevada Domestic Corporation; IVAN RAY TIPPETTS, an Individual; LESLIE TIPPETTS, an Individual; SHERA WILLIAMS, an Individual, TOMISHA HORN, an Individual; ILIA HAMPTON, LCSW, QMPH, an Individual; TRENT HANSEN, LCSW, an Individual; Defendants.

          SPO LAGOMARSINO LAW ANDRE M. LAGOMARSINO, ESQ. State Bar No. 6711 Attorneys for Plaintiffs S.H DOE and A. O. DOE

          PROTECTIVE ORDER BETWEEN PLAINTIFFS AND LAS VEGAS METROPOLITAN POLICE DEPARTMENT REGARDING ALL POLICE REPORTS, RECORDS, PHOTOS, RECORDINGS, STATEMENTS, OR OTHER DOCUMENTS, PERTAINING TO CRIMINAL CASE EVENT NO. 170214-0685

         Plaintiffs S.H. DOE, an individual, by, and LVMPD, by and through their attorneys of record, by and through his Natural Parent and Legal Guardian, A.O. JANE DOE and A.O. JANE DOE, individually, by and through their undersigned attorneys of record, ANDRE M. LAGOMARSINO, ESQ. of LAGOMARSINO LAW, hereby file their Stipulated Protective Order Pursuant to NRCP 26(c) Regarding All Police Reports, Records, Photos, Recordings, Statements, or Other Documents Pertaining to L VMPD Criminal Case Event Number 170214-0685.

         A protective order regarding all police reports, records, photos, recordings, statements, or other documents pertaining to LVMPD's criminal case event No. 170214-0685 is appropriate. The above mentioned parties stipulate and request that the Court enter a protective order as follows:

         1. The protective order shall be entered pursuant to the Federal Rules of Civil Procedure.

         2. The protective order shall govern certain materials, produced by LVMPD to be deemed to be confidential. Such confidential information shall include: any private, personal information about the witnesses such as, but not limited to, dates of birth, social security numbers, addresses, telephone numbers, and any other confidential private information the recordings or incident report may contain;

         3. In the case of documents and the information contained therein, designation of confidential information shall be made by placing the following legend on the face of each document and each page so designated: "CONFIDENTIAL" or otherwise expressly identified as confidential.

         4. Confidential information shall be held in confidence by each qualified recipient to whom it is disclosed, shall be used only for purposes of this action, shall not be used for any business purpose, and shall not be disclosed to any person who it not a qualified recipient. All produced confidential information shall be carefully maintained so as to preclude access by persons who are not qualified recipients.

         5. Qualified recipients shall include only the following:

(a) In-house counsel and law firms for each party and the secretarial, clerical and paralegal staff of each;
(b) Deposition notaries and staff;
(c) Persons other than legal counsel who have been retained or specially employed by a party as an expert witness for purposes of this lawsuit or to perform investigative work or fact research;
(d) Deponents during the course of their depositions or potential witnesses of this case; and
(e) The parties to this litigation, their officers and professional employees.

         6. Deponents may be shown confidential materials during their deposition but shall not be permitted to keep copies of said confidential materials nor any portion of the ...


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