Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Benson v. Las Vegas Metropolitan Police Department

United States District Court, D. Nevada

December 26, 2019

MARY BENSON, an individual, Plaintiff,
v.
LAS VEGAS METROPOLITAN POLICE DEPARTMENT, in its official capacity; and, JOSEPH LOMBARDO, in his official capacity as Sheriff of the Las Vegas Metropolitan Police Department; Defendants.

          MARQUIS AURBACH COFFING Nick D. Crosby, Attorney for LVMPD Defendants

          MCLETCHIE LAW Margaret A. McLetchie, Alina M. Shell, Attorneys for Mary Benson

          STIPULATED PROTECTIVE ORDER

         Plaintiff MARY BENSON and Defendants LAS VEGAS METROPOLITAN POLICE DEPARTMENT and JOSEPH LOMBARDO (“LVMPD Defendants”), 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 No. 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 No. of the documents designated (or portions thereof) as “CONFIDENTIAL” and the basis for doing so. Documents designated as CONFIDENTIAL by the Producing Party shall be designated “CONFIDENTIAL” prior to, or contemporaneously with, the production or disclosure of the documents.

         A Party other than the Producing Party can designate material produced by a Producing Party but not designated as “CONFIDENTIAL” as “CONFIDENTIAL” via letter to the Producing Party and any Receiving Parties. Such designation ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.