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Tripp v. Clark County

United States District Court, D. Nevada

November 12, 2019

JUSTIN L. TRIPP, Plaintiff,
v.
CLARK COUNTY, LAS VEGAS POLICE DEPARTMENT, OFFICER J. TORRES, OFFICER M. ROSE, JOHN DOE #1, NAPHCARE, INC, et al., Defendants.

          CHAD C. COUCHOT Nevada Bar No. 12946 SCHUERING ZIMMERMAN & DOYLE, LLP

          KIM MANDELBAUM Nevada Bar No. 318 MANDELBAUM ELLERTON & ASSOCIATES Attorneys for Defendants NAPHCARE, INC., HARRY DURAN, M.D., ERIC LOPEZ, PA, and RACHEL RUDD

          STIPULATED PROTECTIVE ORDER

         Plaintiff seeks to obtain, inspect and copy documents and/or things which Defendants NAPHCARE, INC., HARRY DURAN, M.D., ERIC LOPEZ, P.A., and RACHEL RUDD (hereinafter "DEFENDANTS") contends contains private and sensitive information, confidential information of DEFENDANTS, its officers and employees, its internal investigative and administrative actions, and other confidential information. Pursuant to an agreement by the Parties, the Court hereby enters the following Order for Protection (Protective Order):

         TERMS OF PROTECTIVE ORDER

         I. DEFINITIONS

         The following definitions apply to the Protective Order:

         1. Party. Any party to this action, including all of its officers, directors, employees, consultants, Experts, and Outside Counsel. Party, as used in this Protective Order, shall also refer to the Las Vegas Metropolitan Police Department, and its officers, agents and employees.

         2. Disclosure or Discovery Material. All items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

         3. "Confidential" Information or Items. Information (regardless of how generated, stored or maintained) or tangible things that qualify for protection under the law enforcement investigative and/or official information privileges, or that contain Criminal History Information, personal information regarding individuals including Social Security Numbers, dates of birth and information which a person would have a reasonable expectation of privacy. Confidential information shall also include information concerning, regarding, or as a result of covert or undercover law enforcement investigation(s) technique(s), method (s) or source(s), including the identity of any confidential informant, intelligence report, undercover officer information, or information referring to any undercover or active criminal investigations. Further, Confidential information shall also include any information protected from disclosure under Donrey v. Bradshaw, 106 Nev. 630 (1990) or an official or executive information privilege. Confidential information shall also include employee information, employee medical information, and employee disciplinary action, including any internal investigation concerning employee actions.

         4. Receiving Party. A Party that receives Disclosure or Discovery Material or Confidential Information from a Producing Party.

         5. Producing Party. A Party or third-party that produces Disclosure or Discovery Material or Confidential Information in this action.

         6. Designating Party. A Party or third-party that designates information or items that it produces in disclosures or in responses to discovery as "Confidential." 7. Protected Material. Any Disclosure or Discovery Material or Confidential Information that is designated as "Confidential." 8. Outside Counsel. Attorneys who are not employees of a Party but who areretained to represent or advise a Party in this action.

         9. House Counsel. Attorneys who are employees of a Party.

         10. Counsel (without qualifier). Outside Counsel and House Counsel (as well as their support staffs).

         11. Expert. A person with specialized knowledge or experience in a matter pertinent to the litigation retained by a Party or its Counsel to serve as an expert witness or as a consultant in this action. This definition includes, but is not limited to, a professional jury or trial consultant retained in connection with this litigation.

         12. Professional Vendor. Person or entity that provides litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, organizing, storing, retrieving data in any form or medium; etc.) and its employees and subcontractors.

         13. The use of the singular form of any word includes the plural, and vice versa.

         II. ...


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