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Doe v. Carson City

United States District Court, D. Nevada

March 27, 2019

JANE DOE, a minor, by and through her natural parent, GRACE DOE; Plaintiff,
v.
CARSON CITY, a consolidated municipality and a political subdivision of the State of Nevada; JAYE PHILLIPS, individually; JACOBS ENTERTAINMENT, INC., a foreign corporation, Defendants.

          LAGOMARSINO LAW ANDRE M. LAGOMARSINO, ESQ. Nevada Bar No. 6711 Attorney for Plaintiff Jane Doe

          HALL JAFFE & CLAYTON Steven T. Jaffe, Esq. (#7035) Michelle Schwarz, Esq. (#5127) Attorneys for Defendant Jacobs Entertainment, Inc.

          ROBISON, SHARP, SULLIVAN & BURST Kent R. Robison, Esq. (#1167) Attorney for Defendant Carson City and Jaye Phillips

          STIPULATED PROTECTIVE ORDER GOVERNING THE CONFIDENTIAL INFORMATION AND DOCUMENTS OF MINORS

         Plaintiff Jane Doe (hereinafter “Plaintiff”) has filed an action in the above-captioned court against Defendants Carson City, Jaye Phillips, and Jacobs Entertainment, Inc. (collectively “Defendants”).

         On March 19, 2019, a hearing was held before Magistrate Judge William G. Cobb regarding Plaintiff's Emergency Motion to Compel Production of the Carson City District Attorney's Investigative Case File. The Court issued an Order granting Plaintiff's Motion and ordered that the documents in the District Attorney's file shall be produced after the parties have agreed to and the Court has approved an appropriate protective order.

         The Parties expect that confidential, non-public information and documents will need to be filed and disclosed in this matter. In addition to the definition of Confidential Information detailed below in Section I(D), “Confidential Information” includes, but is not limited to, the following:

A. Identification of Plaintiff, including information related to Plaintiff's name, home address, school address, contact information, medical records and/or treatment assessments as Plaintiff's safety/security may be compromised by the disclosure of such information
B. Identification of K.H., as well as any minor victims that may be discussed, including information related to their names, home address, school address, contact information, medical records and/or treatment assessments as their safety/security may be compromised by the disclosure of such information;
C. Personal identity information as contained in Local Rule IC 6-1;
D. Information prohibited from disclosure by statute.

         Information or documents that are available to the public may not be designated as Confidential Information.

         Discovery in this case required the production of documents, the answering of interrogatories, and requests to admit during which the aforementioned confidential and/or private information and documents of the Plaintiff, K.H., and other minor victims were exchanged and disclosed. Also, this case will require the taking of oral and/or written depositions during which the aforementioned confidential and/or private information and documents of the Plaintiff, K.H., and other minor victims will be exchanged and disclosed. To expedite the flow of discovery, facilitate the prompt resolution of disputes over confidentiality, and to protect material entitled to be kept confidential, the Parties agreed to limit the disclosure and use of confidential and private information and documents as stipulated, pursuant to this Stipulated Protective Order Governing the Confidential Information and Documents of Minors (“Protective Order”) after the close of discovery on the following terms:

         I. DEFINITIONS

         The following definitions shall apply to this Protective Order:

         A. This “Action” shall refer to the above-captioned proceeding in the United States District Court for the District of Nevada and any appeal thereof through final judgment.

         B. “Producing Party” shall mean any person or entity producing documents, information or other materials in this Action, including any Party to this Action or any third parties.

         C. “Party” shall mean the Plaintiff and Defendants in this Action, and any other person that may become a named Party to this Action.

         D. “Non-Parties” shall mean any natural person, partnership, corporation, association, or other legal entity not named as a Party to this Action.

         E. “Counsel” shall mean attorneys retained to represent or advise a party to this action, in which the attorneys have appeared in this Action on behalf of that party or are affiliated ...


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