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Kendrick v. Clark County

United States District Court, D. Nevada

April 1, 2019

JOHNNY KENDRICK, Plaintiff,
v.
CLARK COUNTY, a political subdivision of the State of Nevada, Defendant.

          KEMP & KEMP VICTORIA L. NEAL, ESQ. Attorney for Plaintiff Johnny Kendrick

          CLARK COUNTY DISTRICT ATTORNEY SCOTT DAVIS Deputy District Attorney Attorneys for Defendant Clark County

          STIPULATION AND PROPOSED PROTECTIVE ORDER

         Plaintiff Johnny Kendrick, by and through his counsel of record, Victoria L. Neal, Esq. of the law firm Kemp & Kemp and Defendant Clark County, by and through its attorney Deputy District Attorney Scott Davis 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. This Stipulation and Protective Order establishes the parameters for disclosure and use of confidential documents. The categories of documents subject to this Stipulation and Protective Order are those documents that are considered to be confidential documents pursuant to federal, state or local law, including without limitation:

a. Employee personnel files of Clark County employees. Clark County Ordinance 2.40.040; Clark County Merit Personnel Policy I § III(F).
b. Investigation Files of the Clark County Office of Diversity. Nev. Rev. Stat. 613.075; Nevada Local Government Retention Schedule LRDA # 20071323.[1]

         3. Any party may designate and mark documents that the party believes to be within the scope of this Stipulation and Protective Order and that 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.

         4. 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 Clark County, Nevada, and the following persons:

(a) counsel of record for Plaintiff and Plaintiff;
(b) counsel of record for Defendants;
(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 ...

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