1 JOINT PROTECTIVE ORDER BETWEEN PLAINTIFFS AND DEFENDANT CLARK 2 COUNTY 3 TERMS OF PROTECTIVE ORDER 4 DEFINITIONS 5 The following definitions apply to the Protective Order: 6 1. Party. Any party to this action, including all of its officers, directors, employees, 7 consultants, Experts, and Outside Counsel. Party, as used in this Protective Order, shall also refer 8 to Defendant, and its officers, agents and employees. 9 2. Disclosure or Discovery Material. All items or information, regardless of the 10 medium or manner generated, stored, or maintained (including, among other things, testimony, 11 transcripts, or tangible things) that are produced or generated in disclosures or responses to 12 discovery in this matter. 13 3. “Confidential” Information or Items. Information (regardless of how generated, 14 stored or maintained) or tangible things that qualify for protection under the law enforcement 15 investigative and/or official information privileges, or that contain Criminal History Information, 16 personal information regarding individuals including Social Security Numbers, dates of birth and 17 information which a person would have a reasonable expectation of privacy. Confidential 18 information shall also include the parties’ contact information disciplinary action of non-party 19 employees, and medical information. 20 4. Receiving Party. A Party that receives Disclosure or Discovery Material or 21 Confidential Information from a Producing Party. 22 5. Producing Party. A Party or third-party that produces Disclosure or Discovery 23 Material or Confidential Information in this action. 24 6. Designating Party. A Party or third-party that designates information or items that 25 it produces in disclosures or in responses to discovery as “Confidential.” 26 7. Protected Material. Any Disclosure or Discovery Material or Confidential 27 Information that is designated as “Confidential.” 1 8. Outside Counsel. Attorneys who are not employees of a Party but who are retained 2 to represent or advise a Party in this action. 3 9. House Counsel. Attorneys who are employees of a Party. 4 10. Counsel (without qualifier). Outside Counsel and House Counsel (as well as their 5 support staffs). 6 11. Expert. A person with specialized knowledge or experience in a matter pertinent 7 to the litigation retained by a Party or its Counsel to serve as an expert witness or as a consultant 8 in this action. This definition includes, but is not limited to, a professional jury or trial consultant 9 retained in connection with this litigation. 10 12. Professional Vendor. Person or entity that provides litigation support services 11 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, organizing, 12 storing, retrieving data in any form or medium; etc.) and its employees and subcontractors. 13 13. The use of the singular form of any word includes the plural, and vice versa. 14 SCOPE 15 The protection conferred by this Protective Order covers not only Protected Material, but 16 also any information copied or extracted therefrom, as well as all copies excerpts, summaries, or 17 compilations thereof, testimony, conversations, or presentations by parties or counsel to or in 18 court or in other settings that might reveal Protected Material. 19 DURATION 20 Even after the termination of this action, the confidentiality obligations imposed by this 21 Protective Order shall remain in effect until a Designating Party agrees otherwise in writing or a 22 court order otherwise directs. 23 DESIGNATING PROTECTED MATERIAL 24 1. Manner and Timing of Designations. Except as otherwise provided herein, or as 25 otherwise ordered, material that qualifies for protection under this Order must be clearly 26 designated before it is disclosed or produced. Designations in conformity with this Order 27 require: 1 a. For information in documentary form. That the Producing Party shall 2 affix the legend “Confidential” on each page that contains Protected Material. If only a portion 3 or portions of the material on a page qualifies for protection, the Producing Party also must 4 clearly identify the protected portion(s) (e.g., by making appropriate makings in the margins or 5 redacting protected portions). A Producing Party that makes original documents or materials 6 available for inspection need not designate them for protection until after the inspecting Party 7 has indicated which material it would like copied and produced. During the inspection and 8 before the designation, all of the material made available for inspection shall be deemed 9 “Confidential.” After the inspecting Party has identified the documents it wants copied and 10 produced, the Producing Party must determine which documents, or portions thereof, qualify for 11 protection under this Order, and, before producing the specified documents, the Producing Party 12 must affix the appropriate legend on each page that contains Protected Material. If only a portion 13 or portions of the material on a page qualifies for protection, the Producing Party also must 14 clearly identify the protected portion(s) (e.g., by making appropriated markings in the margins 15 or by redacting protected portions). 16 b. For testimony given in deposition or in other pretrial or trial proceedings. 17 That before the close of the deposition, hearing, or other proceeding, the Party or non-party 18 offering or sponsoring the testimony shall identify on the record all protected testimony and 19 further specify any portions of the testimony that qualify as “Confidential.” When it is 20 impractical to identify separately each portion of testimony that is entitled to protection, the Party 21 or non-party that sponsors, offers, or gives the testimony may invoke on the record (before the 22 deposition or proceeding is concluded) a right to have up to thirty (30) days to identify the 23 specific portions or the testimony as to which protection is sought. Only those portions of the 24 testimony that are appropriately designated for protection under the standards set forth herein 25 within the thirty (30) days shall be covered by the provisions of this Protective Order. Upon 26 request of a Designating Party, transcript pages containing Protected Material must be separately 27 bound by the court reporter, who must affix to the top of each such page the legend 1 “Confidential” as instructed by the Party or non-party offering or sponsoring the witness or 2 presenting the testimony. 3 c. For information produced in some form other than documentary, and for 4 any other tangible items. That the Producing Party affix in a prominent place on the exterior of 5 the container or containers in which the information or item is stored the legend “Confidential.” 6 If only portions of the information or item warrant protection, the Producing Party, to the extent 7 practicable, shall identify the protected portions. 8 2. Inadvertent Failure to Designate. Inadvertent failure to identify documents or 9 things as “Confidential” pursuant to this Protective Order shall not constitute a waiver of any 10 otherwise valid claim for protection, provided that the provisions of this paragraph are satisfied. 11 If the Designating Party discovers that information should have been but was not designated 12 “Confidential” or if the Designating Party receives notice that would enable the Designating 13 Party to learn that it has disclosed such information, the Designating Party must immediately 14 notify all other parties. In such event, within thirty (30) days of notifying all other Parties, the 15 Designating Party must also provide copies of the “Confidential” information designated in 16 accordance with this Protective Order.
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1 JOINT PROTECTIVE ORDER BETWEEN PLAINTIFFS AND DEFENDANT CLARK 2 COUNTY 3 TERMS OF PROTECTIVE ORDER 4 DEFINITIONS 5 The following definitions apply to the Protective Order: 6 1. Party. Any party to this action, including all of its officers, directors, employees, 7 consultants, Experts, and Outside Counsel. Party, as used in this Protective Order, shall also refer 8 to Defendant, and its officers, agents and employees. 9 2. Disclosure or Discovery Material. All items or information, regardless of the 10 medium or manner generated, stored, or maintained (including, among other things, testimony, 11 transcripts, or tangible things) that are produced or generated in disclosures or responses to 12 discovery in this matter. 13 3. “Confidential” Information or Items. Information (regardless of how generated, 14 stored or maintained) or tangible things that qualify for protection under the law enforcement 15 investigative and/or official information privileges, or that contain Criminal History Information, 16 personal information regarding individuals including Social Security Numbers, dates of birth and 17 information which a person would have a reasonable expectation of privacy. Confidential 18 information shall also include the parties’ contact information disciplinary action of non-party 19 employees, and medical information. 20 4. Receiving Party. A Party that receives Disclosure or Discovery Material or 21 Confidential Information from a Producing Party. 22 5. Producing Party. A Party or third-party that produces Disclosure or Discovery 23 Material or Confidential Information in this action. 24 6. Designating Party. A Party or third-party that designates information or items that 25 it produces in disclosures or in responses to discovery as “Confidential.” 26 7. Protected Material. Any Disclosure or Discovery Material or Confidential 27 Information that is designated as “Confidential.” 1 8. Outside Counsel. Attorneys who are not employees of a Party but who are retained 2 to represent or advise a Party in this action. 3 9. House Counsel. Attorneys who are employees of a Party. 4 10. Counsel (without qualifier). Outside Counsel and House Counsel (as well as their 5 support staffs). 6 11. Expert. A person with specialized knowledge or experience in a matter pertinent 7 to the litigation retained by a Party or its Counsel to serve as an expert witness or as a consultant 8 in this action. This definition includes, but is not limited to, a professional jury or trial consultant 9 retained in connection with this litigation. 10 12. Professional Vendor. Person or entity that provides litigation support services 11 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, organizing, 12 storing, retrieving data in any form or medium; etc.) and its employees and subcontractors. 13 13. The use of the singular form of any word includes the plural, and vice versa. 14 SCOPE 15 The protection conferred by this Protective Order covers not only Protected Material, but 16 also any information copied or extracted therefrom, as well as all copies excerpts, summaries, or 17 compilations thereof, testimony, conversations, or presentations by parties or counsel to or in 18 court or in other settings that might reveal Protected Material. 19 DURATION 20 Even after the termination of this action, the confidentiality obligations imposed by this 21 Protective Order shall remain in effect until a Designating Party agrees otherwise in writing or a 22 court order otherwise directs. 23 DESIGNATING PROTECTED MATERIAL 24 1. Manner and Timing of Designations. Except as otherwise provided herein, or as 25 otherwise ordered, material that qualifies for protection under this Order must be clearly 26 designated before it is disclosed or produced. Designations in conformity with this Order 27 require: 1 a. For information in documentary form. That the Producing Party shall 2 affix the legend “Confidential” on each page that contains Protected Material. If only a portion 3 or portions of the material on a page qualifies for protection, the Producing Party also must 4 clearly identify the protected portion(s) (e.g., by making appropriate makings in the margins or 5 redacting protected portions). A Producing Party that makes original documents or materials 6 available for inspection need not designate them for protection until after the inspecting Party 7 has indicated which material it would like copied and produced. During the inspection and 8 before the designation, all of the material made available for inspection shall be deemed 9 “Confidential.” After the inspecting Party has identified the documents it wants copied and 10 produced, the Producing Party must determine which documents, or portions thereof, qualify for 11 protection under this Order, and, before producing the specified documents, the Producing Party 12 must affix the appropriate legend on each page that contains Protected Material. If only a portion 13 or portions of the material on a page qualifies for protection, the Producing Party also must 14 clearly identify the protected portion(s) (e.g., by making appropriated markings in the margins 15 or by redacting protected portions). 16 b. For testimony given in deposition or in other pretrial or trial proceedings. 17 That before the close of the deposition, hearing, or other proceeding, the Party or non-party 18 offering or sponsoring the testimony shall identify on the record all protected testimony and 19 further specify any portions of the testimony that qualify as “Confidential.” When it is 20 impractical to identify separately each portion of testimony that is entitled to protection, the Party 21 or non-party that sponsors, offers, or gives the testimony may invoke on the record (before the 22 deposition or proceeding is concluded) a right to have up to thirty (30) days to identify the 23 specific portions or the testimony as to which protection is sought. Only those portions of the 24 testimony that are appropriately designated for protection under the standards set forth herein 25 within the thirty (30) days shall be covered by the provisions of this Protective Order. Upon 26 request of a Designating Party, transcript pages containing Protected Material must be separately 27 bound by the court reporter, who must affix to the top of each such page the legend 1 “Confidential” as instructed by the Party or non-party offering or sponsoring the witness or 2 presenting the testimony. 3 c. For information produced in some form other than documentary, and for 4 any other tangible items. That the Producing Party affix in a prominent place on the exterior of 5 the container or containers in which the information or item is stored the legend “Confidential.” 6 If only portions of the information or item warrant protection, the Producing Party, to the extent 7 practicable, shall identify the protected portions. 8 2. Inadvertent Failure to Designate. Inadvertent failure to identify documents or 9 things as “Confidential” pursuant to this Protective Order shall not constitute a waiver of any 10 otherwise valid claim for protection, provided that the provisions of this paragraph are satisfied. 11 If the Designating Party discovers that information should have been but was not designated 12 “Confidential” or if the Designating Party receives notice that would enable the Designating 13 Party to learn that it has disclosed such information, the Designating Party must immediately 14 notify all other parties. In such event, within thirty (30) days of notifying all other Parties, the 15 Designating Party must also provide copies of the “Confidential” information designated in 16 accordance with this Protective Order. After receipt of such re-designated information, the 17 “Confidential” information shall be treated as required by this Protective Order, and the 18 Receiving Party shall promptly, but in no event more than fourteen (14) calendar days from the 19 receipt of the re-designated information, return to the Designating Party all previously produced 20 copies of the same unlegended documents or things. The Designating Party and the Parties may 21 agree to alternative means. The Receiving Party shall receive no liability, under this Protective 22 Order or otherwise, for any disclosure of information contained in unlegended documents or 23 things occurring before the Receiving Party was placed on notice of the Designating Party’s 24 claims of confidentiality. 25 CHALLENGING CONFIDENTIALITY DESIGNATIONS 26 1. Meet and Confer. A Party that elects to initiate a challenge to a Designating 27 Party’s confidentiality designation must do so in good faith and must begin the process by 1 conferring with counsel for the Designating Party. The challenging Party must give the 2 Designating Party an opportunity of not less than ten (10) calendar days to review the designated 3 material, to reconsider the circumstances, and, if no change in the designations is offered, to 4 explain in writing the basis for the confidentiality designation. 5 2. Judicial Intervention. If the parties are unable to resolve a dispute regarding 6 confidentiality designations informally after a good-faith effort - including a meet and confer 7 between the lead counsel for each party via in person, videoconference, or telephone - the parties 8 must file a single document captioned “Stipulation Regarding Discovery Dispute” that includes 9 the following: 10 a. A brief, joint summary of the discovery dispute not to exceed one (1) page; 11 b. A restatement of the full text at issue. 12 c. A joint summary of the meet-and-confer efforts as required by LR IA 1- 13 3(f), which includes: (1) a summary of discussions; (2) identification of time, place, manner, and 14 participants; and (3) certification from counsel that, despite a sincere effort, the parties were 15 unable to resolve or narrow the dispute without court intervention. This joint meet-and-confer 16 summary may not exceed two (2) pages. 17 d. An explanation, without boilerplate language, of the position taken by each 18 side, not to exceed two (2) pages per side. 19 e. Each side’s proposal of compromise or resolution of the disputed discovery 20 (e.g., request, interrogatory, deposition question). The proposal may not exceed two (2) pages 21 per side. 22 Upon review of the filed “Stipulation Regarding Discovery Dispute,” Judge Couvillier 23 may set a telephonic conference, order written briefing, or enter an order deciding the dispute 24 without conference or briefing. 25 ACCESS TO AND USE OF PROTECTED MATERIAL 26 1. Basic Principles. A Receiving Party may use Protected Material that is disclosed 27 or produced by another Party or by a third-party in connection with this case solely for the limited 1 purposes of prosecuting, defending, attempting to settle, or settling this action. Such Protected 2 Material may be disclosed only to the categories of persons and under the conditions described in 3 the Protective Order. Protected Material must be stored and maintained by a Receiving Party at 4 a location and in a secure manner that ensures that access is limited to the persons authorized 5 under this Protective Order. 6 2. Disclosure of “Confidential” Information or Items. Unless otherwise ordered by 7 the Court or permitted in writing by the Designating Party, a Receiving Party may disclose any 8 information or item designated Confidential only to: 9 a. The Parties to this action and the Receiving Party’s Outside Counsel of 10 record in this action, as well as employees of said Counsel to whom it is reasonably necessary to 11 disclose the information for this litigation. Counsel of Record shall be responsible for advising 12 all of their staff of the existence of, and their confidentiality obligations under, the Protective 13 Order, and shall be responsible for any non-compliance with the Protective Order by members of 14 their staff that have not signed an agreement to be bound by the Protective Order; 15 b. The officers, directors, and employees of the Receiving Party to whom 16 disclosure is reasonably necessary for this litigation and who have signed or have agreed under 17 oath and on the record to be bound by the “Agreement to Be Bound by Protective Order” (Exhibit 18 A); 19 c. Experts of the Receiving Party to whom disclosure is reasonably necessary 20 for this litigation and who have signed or have agreed under oath and on the record to be bound 21 by the “Agreement to Be Bound by Protective Order” (Exhibit A); 22 d. The Court and its personnel, including (without limitation) jurors; 23 e. Court reporters, their staffs, and Professional Vendors to whom disclosure 24 is reasonably necessary for this litigation; 25 f. During their depositions or at trial, witnesses in the action to whom 26 disclosure is reasonably necessary. Witnesses will not be permitted to retain copies of Protected 27 Material unless they have signed or agreed under oath and on the record to be bound by the 1 “Agreement to Be Bound by Protective Order” (Exhibit A). Upon request of a Designating Party, 2 pages of transcribed deposition testimony or exhibits to depositions that reveal Protected Material 3 must be separately bound by the court reporter and may not be disclosed to anyone except as 4 permitted under this Protective Order; and 5 g. The author of the document or the original source of the information and 6 recipients or addressees in the normal course of business. 7 Notwithstanding the preceding of this paragraph VI(2), a Party that has produced its, his or her 8 own Protected Material may disclose such Protected Material to any persons, with or without any 9 conditions placed upon such disclosure, as the Party deems appropriate. 10 3. Trial and Dispositive Motion Disclosure: For the purpose of trial and/or 11 dispositive motions, the parties acknowledge that a “strong presumption in favor of access” exists. 12 A party seeking to seal a judicial record at trial and/or the dispositive motions stage bears the 13 burden of establishing “compelling reasons” by “articulating compelling reasons supported by 14 specific factual findings,” that outweigh the public policies favoring disclosure.1 15 4. Disclosure of Possession of Confidential Information. All persons described in 16 paragraph VI above shall not under any circumstances sell, offer for sale, advertise, or publicize 17 either the Confidential Information or the fact that such persons have obtained Confidential 18 Information. 19 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 20 LITIGATION 21 If a Receiving Party is served with a subpoena or an order issued in other litigation that 22 would compel disclosure of any information or items designated in this action as “Confidential” 23 the Receiving Party must so notify the Designating Party, in writing (by fax or email if possible) 24 immediately and in no event more than seven (7) calendar days after receiving the subpoena or 25 order. Such notification must include a copy of the subpoena or court order. The Receiving Party 26 27 1 See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1178-79 (9th Cir. 2006). 1 also must within ten (10) calendar days inform in writing the party who caused the subpoena or 2 order to issue in the other litigation that some or all the material covered by the subpoena or order 3 is the subject of this Protective Order and deliver to such party a copy of this Protective Order. 4 The Designating Party shall bear the burdens and the expenses of seeking protection in that court 5 of its Confidential material – and nothing in these provisions should be construed as authorizing 6 or encouraging a Receiving Party in this action to disobey a lawful directive from another court. 7 Once notice is given, and five business days have elapsed, the receiving party shall have no further 8 liability for disclosure pursuant to a subpoena or its equivalent. 9 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material 11 to any person or in any circumstance not authorized under this Protective Order, the Receiving 12 Party must immediately and within not more than seven (7) calendar days: (a) notify in writing 13 (using best efforts to use email or fax) the Designating Party of the unauthorized disclosures, (b) 14 use its best efforts to retrieve all copies of the Protected Material, (c) inform the person or persons 15 to whom unauthorized disclosures were made of all the terms of the Protective Order, and (d) 16 request such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 17 (Exhibit A). The Receiving Party shall promptly notify the Designating Party of the results of its 18 efforts with regards to (b), (c), and (d) herein. After a good faith meet and confer effort to resolve 19 and remaining disputes concerning compliance with this paragraph, and Party, Receiving Party 20 or Designating Party may seek relief from this Court for non-compliance with this provision. Said 21 relief may include, but is not limited to, preclusion of the Receiving Party’s use in this litigation 22 of the Protected Material that was disclosed contrary to this Protective Order, or any other 23 sanction deemed appropriate by the Court. 24 PUBLICLY AVAILABLE OR PREVIOUSLY POSSESSED INFORMATION 25 The restrictions in the preceding paragraphs regarding disclosure or Protected Material do not and 26 shall not apply to information or material that: was, is, or becomes public knowledge in a manner 27 other than by violation of the Protective Order, is acquired by the non-designating party from a 1 third-party having the right to disclose such information or material; or was lawfully possessed 2 by the non-designating party before the date of this Protective Order. The Designating Party shall 3 act in good faith to notify the Receiving Party of any change in circumstances that renders 4 Confidential Information or Items no longer Confidential within a reasonable time period after 5 the change becomes known to the Designating Party. 6 FILING PROTECTED MATERIAL 7 With respect to non-dispositive motions and pleadings, Protected Material or information derived 8 therefrom is included with, or the contents of such a document are disclosed in, any documents 9 filed with the Clerk or this Court or any other court, the filing Party shall file said document under 10 seal and in accordance with Local Rule 10-5(b). Unless otherwise agreed by the Parties to permit 11 service by some other means such as by email or facsimile, copies of any pleading, brief or other 12 document containing Protected Material that is served on opposing counsel shall be delivered in 13 a sealed envelope stamped: CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER and 14 shall be treated in accordance with the provisions of this Protective Order. Subject to the Court’s 15 convenience and needs, all material files in this fashion will be kept under seal by the Clerk until 16 further order from the Court. 17 FINAL DISPOSITION 18 Unless otherwise ordered or agreed in writing by the Producing Party, within sixty (60) calendar 19 days of a written request, after the final termination of this action, each Receiving Party must 20 return all Protected Material to the Producing Party. As used in this subdivision, “all Protected 21 Material” includes all copies, abstracts, compilations, summaries or any other form of 22 reproducing or capturing any of the Protected Material. With permission in writing from the 23 Designating Party, the Receiving Party may destroy some or all of the Protected Material instead 24 of returning it. If the Designating Party does not give permission in writing to destroy the 25 Protected Material in lieu of returning it, the Designating Party shall pay for the time and cost of 26 staff to locate the material and return it. Notwithstanding this provision, Counsel are entitled to 27 retain an archival copy of all pleadings, motion papers, transcripts, legal memoranda, 1 correspondence or attorney work product, even if such materials contain Protected Material. 2 Additionally, no Party shall be required to conduct e-mail searches to locate the existence of 3 Protected Material that may have been transmitted electronically in compliance with this Order. 4 Any such archival copies that contain or constitute Protected Material remain subject to this 5 Protective Order as set forth herein. In the event of an appeal, “Final Disposition” shall not occur 6 until the conclusion of all appeals. 7 ADDITIONAL PROVISIONS 8 1. Modification. The Parties may modify this Protective Order by written agreement, 9 subject to approval by the Court. The Court may modify this Protective Order. 10 2. Right to Assert Other Objections. This Protective Order does not affect or waive 11 any right that any Party otherwise would have to object to disclosing or producing any information 12 or item on any ground not addressed in this Protective Order. Similarly, this Protective Order 13 does not affect or waive any Party’s right to object on any ground to use in evidence any of the 14 material covered by this Protective Order. 15 3. Privileges Not Waived. This Protective Order does not affect or waive any 16 applicable privilege or work product protection, or affect the ability of a Producing Party to seek 17 relief for an inadvertent disclosure of material protected by privilege or work product protection. 18 4. Third Party Protections. Any witness or other person, firm, or entity from which 19 discovery is sought may be informed of and may obtain the protection of this Protective Order by 20 written notice to the Parties’ respective counsel or by oral notice at the time of any deposition or 21 similar proceeding. 22 5. Obligations to Third Parties. Nothing herein shall operate to relieve any Party or 23 non-party from any pre-existing confidentiality obligations currently owed by any Party or non- 24 party to any other Party or non-party. 25 6. Retention of Completed “Acknowledgment and Agreement to Be Bound” Forms 26 (Exhibit A). Completed “Acknowledgement and Agreement to Be Bound” Forms (Exhibit A) 27 (“form”) shall be maintained by the Party that obtained the completed form pursuant to this 1 || Protective Order. The Party retaining the completed form shall produce the form to resolve any 2 || good faith challenge by a Party or Designating Party or dispute concerning whether a person who 3 || is obligated under this Protective Order to complete the form did so properly and complied with 4 || the representations in the form and this Protective Order. If the parties are unable to resolve any 5 || such disputes or challenges through a good faith meet and confer process, the challenging Party 6 || or Designating Party may seek appropriate relief from this Court. 7 IT IS SO STIPULATED AND AGREED. 8 || DATED this 13 day of February, 2025. DATED this 13" day of February, 2025. ? LAGOMARSINO LAW MARQUIS AURBACH
Taylor N. Jorgensen /s/ Tabetha J. Steinberg ANDRE M. LAGOMARSINO, ESQ. (#6711) NICK D. CROSBY, ESQ. (#8996) TAYLOR N. JORGENSEN, ESQ. (#16259) TABETHA J. STEINBERG, ESQ. (#16756 3005 W. Horizon Ridge Pkwy., #241 10001 Park Run Drive B Henderson, Nevada 89052 Las Vegas, Nevada 89145 Telephone: (702) 383-2864 Telephone: (702) 382-0711 |] Facsimile: (702) 383-0065 Facsimile: (702) 382-5816 Attorneys for Plaintiffs Attorneys for Defendant Clark County
16 When filing protected material, the parties must comply with the procedures in Fed. R. Civ. P. 5.2 and LR IA 10-5, and meet the substantive standards of Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) and its progeny 18 IT IS SO ORDERED. L#, 19 aff o we fos 20 os Hon. Maximiléano'D. Coptvilli TI United States Magistrat¢ Judge 22 Date: 2621/2025 U 23 24 25 26 27
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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________, have read in its entirety and understand the Protective Order that was issued 4 by the United States District Court, for the District of Nevada on ______________, 2025, in the 5 case of Coleman et al. v. Telles et al. Case No. 2:24-CV-00930. I agree to comply with and to be 6 bound by all terms of this Protective Order and I understand and acknowledge that failure to so 7 comply could expose me to sanctions and punishment in the nature of contempt. I solemnly 8 promise that I will not disclose in any manner any information or item that is subject to this 9 Protective Order that any person entity except in strict compliance with the provisions of this 10 Order. Further, I solemnly promise that I will not offer to sell, advertise or publicize that I have 11 obtained any Protected Material subject to this Protective Order. 12 At the conclusion of this matter, I will return all Protected Material which came into my 13 possession to counsel for the party from whom I received the Protected Material, or I will destroy 14 those materials. I understand that any Confidential Information contained within any summaries 15 of Protected Material shall remain protected pursuant to the terms of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court, for the District of 17 Nevada for the purpose of enforcing the terms of this Protective Order, even if such enforcement 18 proceedings occur after termination of this action. 19 I certify under the penalty of perjury that the foregoing is true and correct. 20 Date: ____________________ 21 City and State where signed: __________________________________________ 22 Printed name: _______________________________ 23 Address: ___________________________________________________________ 24 Signature: __________________________________ 25