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Solomon v. Las Vegas Metropolitan Police Department

United States District Court, D. Nevada

September 9, 2019

NEBYOU SOLOMON, an individual, Plaintiff,
v.
LAS VEGAS METROPOLITAN POLICE DEPARTMENT; JOSEPH LOMBARDO, individually and in his official capacity as Sheriff; JOHN L. PELLETIER, an individual; RICHARD E. MAUPIN, an individual; RYAN J. FRYMAN, an individual; JUAN D. CONTRERAS, an individual; ALLEN J. PAVESE, an individual; BRANDON M. MEADS, an individual; FASHION SHOW MALL, LLC, a Nevada limited-liability company; UNIVERSAL PROTECTION SERVICE, LLC, a Nevada limited-liability company; DOE SECURITY GUARDS I - III, individuals, Defendants.

          MARQUIS AURBACH COFFING Nick D. Crosby Attorney for LVMPD Defendants

          KAEMPFER CROWELL Bryan M. Viellion Attorney for Fashion Show Mall LLC

          [PROPOSED] STIPULATED PROTECTIVE ORDER

          DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE

         Plaintiff NEBYOU SOLOMON and Defendants LAS VEGAS METROPOLITAN POLICE DEPARTMENT, JOSEPH LOMBARDO, JOHN L. PELLETIER, RICHARD E. MAUPIN, RYAN J. FRYMAN, JUAN D. CONTRERAS, ALLEN J. PAVESE, and BRANDON M. MEADS (“LVMPD Defendants”) and Defendant FASHION SHOW MALL, LLC, and Defendant UNIVERSAL PROTECTION SERVICE, LLC, by their respective counsel, having agreed to the following and for good cause under Rule 26(c)(1) of the Federal Rules of Civil Procedure, IT IS HEREBY ORDERED as follows:

         1. PURPOSES AND LIMITATIONS.

         Disclosure and discovery activity in this action may involve production of confidential, proprietary, or private information for which special protection from public disclosure may be warranted under Rule 26(c)(1) of the Federal Rules of Civil Procedure. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends to only the limited information or items that are entitled under law to treatment as confidential.

         2. SCOPE.

         All documents produced in the course of discovery, all responses to discovery requests, and all deposition testimony and exhibits and any other materials which may be subject to discovery (hereinafter collectively “Discovery Material”) shall be subject to this stipulated protective order concerning confidential information as set forth below. A copy of this Order must be included with any subpoena to any third party. Any party, or any third party who produces documents in this litigation, may designate documents as Confidential but only after review of the documents by an attorney who has, in good faith, determined that the documents contain “Confidential Information, ” as defined below, and pursuant to the procedure set forth below.

         3. CONFIDENTIAL INFORMATION.

         “Confidential Information” shall mean information meriting special protection under the Federal Rules of Civil Procedure and applicable case law. Confidential Information does not include information that (a) is in the public domain at the time of disclosure; (b) becomes part of the public domain through no fault of the Receiving Party; (c) the Receiving Party can show was in its rightful and lawful possession at the time of disclosure; or (d) the Receiving Party lawfully receives from a Non-party later without restriction as to disclosure.

         4. OTHER DEFINITIONS.

         Party: any party to this action, including all of its officers, directors, agents, and attorney(s) of record for a Party in this action (including their associates, paralegals, and support/ clerical staff).

         Non-party: any individual, corporation, association, or natural person or entity other than a party.

         Protected Material: any Discovery Material containing Confidential Information that is designated by a Party or Non-party as “CONFIDENTIAL, ” unless the Receiving Party challenges the confidentiality designation and (a) the Court decides such material is not entitled to protection as confidential; (b) the Designating Party fails to apply the Court for an order designating the material confidential within the time period specified below; or (c) the Designating Party withdraws its confidentiality designation in writing.

         Producing Party: a Party or Non-party that produces Discovery Material in this action.

         Receiving Party: a Party that receives Discovery Material from a Producing Party.

         Designating Party: a Party or Non-party that designates Discovery Material as “CONFIDENTIAL”. The Party or Non-party designating information or items as Protected Material bears the burden of establishing good cause for the confidentiality of all such items.

         Challenging Party: a party that elects to initiate a challenge to a Designating Party's confidentiality designation.

         Confidentiality Log: a Confidentiality Log must accompany any production of documents designated as “CONFIDENTIAL” that includes the Bates numbers of the documents designated (or the portions thereof) as “Confidential” and the basis for doing so. Each Producing Party shall keep this log cumulatively and re-produce it every time they designate something as “CONFIDENTIAL” so that it is a cumulative record of what the party has marked “CONFIDENTIAL.”

         5. FORM AND TIMING OF DESIGNATION.

         Protected Material shall be so designated by the Producing Party by placing or affixing the word “CONFIDENTIAL” on the document in a manner which will not interfere with the legibility of the document and which will permit complete removal of the “Confidential” designation. A Confidentiality Log must accompany any production of Protected Material that includes the Bates numbers of the documents designated (or portions thereof) as “CONFIDENTIAL” and the basis for doing so. Documents shall be designated “Confidential” prior to, or contemporaneously with, the production or disclosure of the documents. The designation of documents as “CONFIDENTIAL” shall be accompanied with a Confidentiality Log in the form included at Exhibit A.

         A Designating Party must exercise restraint and make good faith efforts to limit CONFIDENTIAL designations to specific materials that qualify for protection under the appropriate standard. Further, a Designating Party must use good faith efforts to designate for protection only those parts of material, documents, items, or communications that qualify-so that other portions of the materials, documents, items, or communications for which protection is not warranted are not swept unjustifiably within the ambit of this Order. If only a portion or portions of materials on a page or within a document merit protection, a Producing Party must so indicate by making appropriate markings in the margins but not over text. The accompanying log should clearly explain which portion is designated as CONFIDENTIAL.

         A Producing Party that makes original documents or materials available for inspection need not designate them for protection until after the inspecting Party has indicated which material it would like copied and produced. During the inspection and before the designation, all of the material made available for inspection shall be deemed “Confidential.” After the inspecting Party has identified the documents it wants copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under this Order, and, before producing the specified documents, the Producing Party must affix the appropriate legend on each page that contains Protected Material. If only a portion or portions of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriated markings in the margins or by redacting protected portions).

         Portions of depositions shall be designated CONFIDENTIAL when the deposition is taken or within fourteen (14) business days after receipt of the transcript, if feasible. Such designation shall be specific as to the portions to be protected and, if made by a Party, shall be accompanied with a certification and log on the form, attached as Exhibit A. A Designating Party must exercise restraint and make good faith efforts to limit ...


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