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Berry v. Las Vegas Metropolitan Police Department

United States District Court, D. Nevada

November 4, 2019

DeMARLO BERRY, an individual, Plaintiff,
v.
LAS VEGAS METROPOLITAN POLICE DEPARTMENT, a government entity; CLARK COUNTY, a political subdivision of the State of Nevada and a government entity; KAREN GOOD, an individual and an employee of a government entity; NORMAN ZIOLA, an individual and an employee of a government entity; PHIL FABIAN, an individual and an employee of a government entity; GREG JOLLEY, an individual and an employee of a government entity; WILLIAM KEETON, an individual and an employee of a government entity; and JOHN DOES 1 through 10, inclusive, Defendants.

          John T. Wendland, Esq. (Nevada Bar No. 7207) Weil & Drage, APC Attorneys for Plaintiff, DeMARLO BERRY

          Nick Brustin, Esq. (New York Bar No. 2844405) Emma Freudenberger, Esq. (New York Bar No. 4624045) Len Kamdang, Esq. (New York Bar No. 4345179) Admitted Pro Hac Vice NEUFELD SCHECK & BRUSTIN, LLP

          Craig C. Coburn, Esq. (Utah Bar No. 00688) Steven H. Bergman, Esq. (Utah Bar No. 13641) Samantha E. Wilcox, Esq. (Utah Bar No. 15284) Being Admitted Pro Hac Vice Application Pending RICHARDS BRANDT MILLER NELSON

          Craig R. Anderson, Esq Nevada Bar No. 6882 Kathleen A. Wilde, Esq. Nevada Bar No. 12522 10001 Park Run Drive Las Vegas, NV 89145 Attorneys for Las Vegas Metropolitan Police Department, Ofc. Karen Good, Ofc. Norman Ziola, Ofc. Greg Jolley, and Ofc. William Keeton

          Robert W. Freeman, Jr. Esq. Nevada Bar No. 3062 Eunice M. Beattie, Esq. Nevada Bar No. 14198 Attorney for Defendant Clark County

          Karen L. Bashor Nevada Bar No. 11913 Attorney for Defendant Clark County

          STIPULATED PROTECTIVE ORDER

          NANCY J. KOPPE UNITED STATES MAGISTRATE JUDGE

         PROPOSED PROTECTIVE ORDER

         COMES NOW, the parties, by and through their undersigned counsel of record and hereby stipulate and submit this Proposed Protective Order which will govern the handling of confidential discovery in this case.

         WHEREAS, the parties have agreed to the relief requested herein.

         WHEREAS, discovery in this case will require the disclosure of confidential documents and related information including, but not limited to private medical, personal and financial information and records of Plaintiff DeMarlo Berry. Accordingly, good cause having been shown:

         1. For the purposes of this Order, "Confidential Information" shall mean any documents, evidence, testimony, materials or other information, whether written or oral, exchanged, revealed or presented in these proceedings, designated in good faith as "Confidential" by either party. The Court declines to allow confidentiality designations based on broad categories of documents. Instead, a confidentiality designation may be made if there is a good faith basis grounded on the particular information at issue for each document. Documents and information shall not be designated Confidential Information to the extent they are otherwise publicly available.

         2. Confidential Information supplied by the parties shall be reviewed only by the parties in this litigation, attorneys and their supervisors as well as secretaries, investigators, paralegals, interns, staff, consultants, witnesses, any experts retained by the parties for purposes of this case and others by written consent of the parties or order by the court. Confidential Information supplied by the parties shall not be reviewed by or disclosed to any other persons not associated with this case and shall not otherwise be disclosed in any way that is inconsistent with the terms of this Order.

         3. If a party believes that any pleading, exhibit, deposition transcript, document or other written material to be produced by that party contains Confidential Information, the party shall either stamp each page containing such information as "Confidential" or designate such documents as "Confidential" by bates number in a writing directed to the opposing party's counsel. The inadvertent failure of a party to mark or designate information or testimony as Confidential at the time of its production or utterance shall not constitute a waiver of the protections provided herein, so long as said oversight is recognized and rectified in a reasonably ...


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