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Doe v. Carson City

United States District Court, D. Nevada

April 24, 2019

JOHN and JANE DOE I, Guardians Ad Litem for JO ANN DOE I, a minor, individually, JOHN and JANE DOE II, Guardians Ad Litem for JOANN DOE II, a minor, individually, and JANE DOE III, Guardian Ad Litem for JOANN DOE III, a minor, individually, Plaintiffs,
v.
CARSON CITY, apolitical subdivision of the State of Nevada; DOES 1-10, Defendants.

          KENT R. ROBISON, ESQ., THERESE M. SHANKS, ESQ., RenoAttorneys for Defendant Carson City.

          Matthew L. Dion, Esq., WORK LAW LLC Matthew A, Work, Esq., DYER LAWRENCE, LLP Casey A. Gillham, Esq. Attorneys for Plaintiffs.

          STIPULATED PROTECTIVE ORDER GOVERNING THE CONFIDENTIAL INFORMATION AND DOCUMENTS OF MINORS

         Plaintiffs John and Jane Doe I, John and Jane Doe II, and Jane Doe III (hereinafter "Plaintiffs") have filed an action in the above-captioned Court against Defendant Carson City (hereinafter "Defendant").

         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 1(D), "Confidential Information" includes, but is not limited to, the following:

         A. Identification of Plaintiffs, including information related to Plaintiffs' name, home address, school address, contact information, medical records and/or treatment assessments as Plaintiffs' 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; and

         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 Plaintiffs, 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 Plaintiffs, 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 Plaintiffs and Defendant 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 with a law firm which has appeared on behalf of that Party.

         F. "Expert" shall mean a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its Counsel to serve as an expert witness or as a consultant in this action.

         G. Consistent with that which is defined as confidential above, "Confidential Information" shall be defined as such documents, deposition testimony or other information disclosed during discovery in this Action which the Producing Party or another Party reasonably and in good faith contains information that should be protected from disclosure as a public record or to Non-Parties, Counsel, and Expert witnesses. Any Party may designate any information or documents as Confidential in the reasonable exercise of such Party's sole discretion; provided, however, by agreeing ...


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