United States District Court, D. Nevada
JUSTIN L. TRIPP, Plaintiff,
CLARK COUNTY, LAS VEGAS POLICE DEPARTMENT, OFFICER J. TORRES, OFFICER M. ROSE, JOHN DOE #1, NAPHCARE, INC, et al., Defendants.
C. COUCHOT Nevada Bar No. 12946 SCHUERING ZIMMERMAN &
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
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):
OF PROTECTIVE ORDER
following definitions apply to the Protective Order:
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.
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
"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
Receiving Party. A Party that receives Disclosure or
Discovery Material or Confidential Information from a
Producing Party. A Party or third-party that produces
Disclosure or Discovery Material or Confidential Information
in this action.
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.
House Counsel. Attorneys who are employees of a Party.
Counsel (without qualifier). Outside Counsel and House
Counsel (as well as their support staffs).
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.
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.
use of the singular form of any word includes the plural, and