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Hooper v. Elko County School District

United States District Court, D. Nevada

June 14, 2019

BRENNEN HOOPER; and, TERRY MADISON, individually and as Special Administrator of the Estate of Corbin Madison, deceased; Plaintiffs,
v.
ELKO COUNTY SCHOOL DISTRICT; and, CHRISTOPHER McANANY; Defendants.

          MATTHEW L. SHARP, LTD. Matthew L. Sharp

          BRADSHAW LAW LLC Denise A. Bradshaw Attorneys for Plaintiffs

          ERICKSON, THORPE & SWAINSTON Ann M. Alexander Attorneys for Defendants

          STIPULATION AND ORDER FOR PROTECTIVE ORDER REGARDING DOCUMENTS AND TESTIMONY PERTAINING TO PROPRIETARY DOCUMENTS

         WHEREAS the following, collectively referred to as “the Parties”, namely:

(1) Brennen Hooper; Terry Madison, individually and as Special Administrator of the Estate of Corbin Madison, deceased (collectively “Plaintiffs”), and
(2) Elko County School District and Christopher McAnany (jointly “Defendants”), by and through their respective counsel, enter into this Stipulation and Protective Order regarding Confidential Information as set forth below:

         In order to protect the confidentiality of Confidential Information obtained by the parties in connection with this case, the parties hereby agree as follows:

         1. Any party or non-party may designate as “confidential” (by stamping the relevant page or otherwise set forth herein) any document or response to discovery in which that party or non-party considers in good faith to contain information involving trade secrets, or confidential business or financial information, subject to protection under the Federal Rules of Civil Procedure or Nevada law (“Confidential Information”). Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be so designated.

         2. A party of non-party may designate information disclosed during a deposition or in response to written discovery as “confidential” by so indicating in said response or on the record at the deposition. A party or non-party may designate in writing, within twenty (20) days after receipt of said responses or of the deposition transcript for which the designation is proposed, that specific pages of the transcript and/or specific responses be treated as “confidential” information. Any other party may object to such proposal, in writing or on the record. Upon such objection, the parties shall follow the procedure described in paragraph 8 below. After any designation made according to the procedure set forth in this paragraph, the designated documents or information shall be treated according to the designation until the matter is resolved according to the procedures described in paragraph 8 below, and counsel for all parties shall be responsible for making all previously unmarked copies of the designated material in their possession or control with the specified designation.

         3. All information produced or exchanged in the course of this case (other than information that is publicly available) shall be used by the party or parties to whom the information is produced solely for the purpose of this case.

         4. Except with the prior written consent of other parties, or upon order of this Court obtained upon notice to opposing counsel, Confidential Information shall not be disclosed to any person other than:

(a) counsel for the respective parties to this litigation, including in-house counsel and co-counsel retained for this litigation;
(b) employees of such counsel;
(c) individual defendants, class representatives, any officer or employee of a party, to the extent deemed necessary by Counsel for the ...

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