KNeEvNadNaE BTaHr N Eo. .L 7Y07O1N , III KNeAvTadHaE BRaIrN NEo .F 6.2 P2A7 RKS 2 LAW OFFICES OF KENNETH E. LYON, III THORNDAL ARMSTRONG, PC 333 Flint Street 6590 S. McCarran Blvd., Ste B 3 Reno, Nevada 89501 Reno, Nevada 89501 4 Telephone: 775.786.4188 Telephone: 775.786.2882 Email: ken@lyonlaw.net Email: kfp@thorndal.com 5 Attorney for Plaintiff Attorney for Storey Defendants 6 7 JOHN ROUTSIS KARL S. HALL Nevada Bar No. 3197 Reno City Attorney 8 ROUTSIS HARDY-COOPER & PULVER HOLLY S. PARKER 505 Ridge Street Deputy City Attorney 9 Reno, Nevada 89501 Nevada Bar No. 10181 10 Telephone: 775.785.9166 Email: parkerh@reno.gov Email: john@rhcplaw.com PETER K. KEEGAN 11 Deputy City Attorney Attorney for Plaintiff Nevada Bar No. 12237 12 Email: keeganp@reno.gov Post Office Box 1900 13 Reno, Nevada 89505 14 Telephone: 775.334.2050 15 Attorneys for Reno Defendants 16 17 UNITED STATES DISTRICT COURT 18 DISTRICT OF NEVADA 19 20 TYLER WOOLLEY, 21 22 Plaintiff, vs. Case No. 3:25-cv-00191-MMD-CSD 23 JOSEPH WELCH, JACOB SMILEY, ERIC 24 KERN, TERRY WEST, STOREY STIPULATED PROTECTIVE ORDER COUNTY, a political subdivision of the State 25 of Nevada, THE CITY OF RENO, a political 26 subdivision of the State of Nevada. 27 Defendants. 28 Plaintiff Tyler Woolley, by and through his counsel, Kenneth E. Lyon, III, and John 2 Routsis; Defendants Joseph Welch, Jacob Smiley, Eric Kern, and Storey County, by and through 3 their counsel, Katherine F. Parks; and Defendants Terry West and the City of Reno, by and 4 through their counsel, Holly S. Parker and Peter K. Keegan (collectively “the Parties”), hereby 5 agree and stipulate to the entry of a Protective Order as follows: 6 7 1. Reason for the Order: The Parties have requested or may request production of 8 documentation that the Parties contend includes confidential information or highly 9 personal private information, including but not limited to Internal Affairs files, 10 photographs, employment records, personnel records, medical records, and possibly other 11 documentation that the Parties would object to production of as confidential and private 12 documentation, or for which they may seek a protective order, if the documentation 13 14 described herein were not protected by this Stipulated Protective Order. The purpose of 15 this Stipulated Protective Order is to facilitate the Parties in the discovery process. 16 However, the mere existence of this Protective Order does not waive the Parties’ right to 17 object to production and redact certain documentation or information. If any such 18 objection is made and the Parties are unable to agree, the production or protection of the 19 documentation or information shall be submitted to the Court for review and decision 20 21 concerning production or protection. 22 2. Any Party may designate as “confidential” (by stamping the relevant page or as otherwise 23 set forth herein) any document or response to discovery which that party considers in 24 good faith to contain information involving business, financial, employment, certain 25 investigative and/or Internal Affairs information, or other confidential or protected 26 information, subject to protection under the Federal Rules of Civil Procedure or Nevada 27 28 law (“Confidential Information”). Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be 2 designated. 3 3. A party may designate information disclosed during a deposition or in response to written 4 discovery as “confidential” by so indicating in said response or on the record at the 5 deposition and requesting the preparation of a separate transcript of such material. 6 7 Additionally, a party may designate in writing, within twenty (20) days after receipt of 8 said responses or of the deposition transcript for which the designation is proposed, that 9 specific pages of the transcript and/or specific responses be treated as Confidential 10 Information. Any other party may object to such proposal, in writing or on record. Upon 11 such objection, the Parties shall follow the procedures described in paragraph 8 below. 12 After any designation made according to the procedure set forth in this paragraph, the 13 14 designated documents or information shall be treated according to the designation until 15 the matter is resolved according to the procedures described in paragraph 9 below, and 16 counsel for all parties shall be responsible for making all previously unmarked copies of 17 the designated material in their possession or control with the specified designation. The 18 documents subject to the claim of confidentiality shall be identified either by clearly 19 describing the document or by referring to the document by its Bates-stamp numbers, 20 21 (e.g., COR-0000). 22 4. All Confidential Information produced or exchanged in the course of this case shall be 23 used by the Parties to whom the information is produced solely for the purpose of this 24 case. 25 5. Except with the prior written consent of other parties, or upon prior order of this Court 26 obtained upon notice to opposing counsel, Confidential Information shall not be disclosed 27 28 to any person other than: a. Counsel for the respective parties to this litigation, including in-house counsel and 2 co-counsel retained for this litigation; 3 b. Employees of such counsel; 4 c. Individual defendants, any officer or employee of a Party, to the extent deemed 5 necessary by counsel for the prosecution or defense of this litigation; 6 7 d. Consultants or expert witnesses retained for the prosecution or defense of this 8 litigation, provided that each such person shall execute a copy of the Certification 9 attached to this Order as Exhibit “A” (which shall be retained by counsel to the 10 party so disclosing the Confidential Information and made available for inspection 11 by opposing counsel during the pendency of the action) before being shown or 12 given any Confidential Information. 13 14 e. Any authors or recipients of the Confidential Information; 15 f. The Court, Court personnel, and court reporters; and 16 g. Witnesses (other than persons described in paragraph 4(e)). If a witness is shown 17 Confidential Information outside of a deposition or at trial, the witness shall sign 18 the Certification attached as Exhibit “A” before being shown Confidential 19 Information. If the witness is shown Confidential Information during a deposition, 20 21 the witness is not required to sign the Certification attached as Exhibit “A”; 22 however, the attorneys for the Parties attending the deposition will inform the 23 witness that the information has been designated as confidential. Witnesses 24 shown Confidential Information shall not be allowed to retain copies. 25 h. Any mediator(s) or settlement officer(s) mutually agreed upon by the parties. 26 27 28 i. Employees of discovery or copy services, microfilming or database services, trial 2 support firms and/or translators or other litigation support vendors who are 3 engaged by the Parties during this litigation. 4 6. Any persons receiving Confidential Information shall not reveal or discuss such 5 information to or with any person who is not entitled to receive such information, except 6 7 as set forth herein. 8 7. Unless otherwise permitted by statute, rule or prior court order, papers filed with the 9 Court under seal shall be accompanied by a contemporaneous motion for leave to file 10 those documents under seal and shall be filed consistent with the Court’s electronic filing 11 procedures in accordance with Local Rule IA 10-5. Notwithstanding any agreement 12 among the Parties, the party seeking to file a paper under seal bears the burden of 13 14 overcoming the presumption in favor of public access to papers filed in court.
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KNeEvNadNaE BTaHr N Eo. .L 7Y07O1N , III KNeAvTadHaE BRaIrN NEo .F 6.2 P2A7 RKS 2 LAW OFFICES OF KENNETH E. LYON, III THORNDAL ARMSTRONG, PC 333 Flint Street 6590 S. McCarran Blvd., Ste B 3 Reno, Nevada 89501 Reno, Nevada 89501 4 Telephone: 775.786.4188 Telephone: 775.786.2882 Email: ken@lyonlaw.net Email: kfp@thorndal.com 5 Attorney for Plaintiff Attorney for Storey Defendants 6 7 JOHN ROUTSIS KARL S. HALL Nevada Bar No. 3197 Reno City Attorney 8 ROUTSIS HARDY-COOPER & PULVER HOLLY S. PARKER 505 Ridge Street Deputy City Attorney 9 Reno, Nevada 89501 Nevada Bar No. 10181 10 Telephone: 775.785.9166 Email: parkerh@reno.gov Email: john@rhcplaw.com PETER K. KEEGAN 11 Deputy City Attorney Attorney for Plaintiff Nevada Bar No. 12237 12 Email: keeganp@reno.gov Post Office Box 1900 13 Reno, Nevada 89505 14 Telephone: 775.334.2050 15 Attorneys for Reno Defendants 16 17 UNITED STATES DISTRICT COURT 18 DISTRICT OF NEVADA 19 20 TYLER WOOLLEY, 21 22 Plaintiff, vs. Case No. 3:25-cv-00191-MMD-CSD 23 JOSEPH WELCH, JACOB SMILEY, ERIC 24 KERN, TERRY WEST, STOREY STIPULATED PROTECTIVE ORDER COUNTY, a political subdivision of the State 25 of Nevada, THE CITY OF RENO, a political 26 subdivision of the State of Nevada. 27 Defendants. 28 Plaintiff Tyler Woolley, by and through his counsel, Kenneth E. Lyon, III, and John 2 Routsis; Defendants Joseph Welch, Jacob Smiley, Eric Kern, and Storey County, by and through 3 their counsel, Katherine F. Parks; and Defendants Terry West and the City of Reno, by and 4 through their counsel, Holly S. Parker and Peter K. Keegan (collectively “the Parties”), hereby 5 agree and stipulate to the entry of a Protective Order as follows: 6 7 1. Reason for the Order: The Parties have requested or may request production of 8 documentation that the Parties contend includes confidential information or highly 9 personal private information, including but not limited to Internal Affairs files, 10 photographs, employment records, personnel records, medical records, and possibly other 11 documentation that the Parties would object to production of as confidential and private 12 documentation, or for which they may seek a protective order, if the documentation 13 14 described herein were not protected by this Stipulated Protective Order. The purpose of 15 this Stipulated Protective Order is to facilitate the Parties in the discovery process. 16 However, the mere existence of this Protective Order does not waive the Parties’ right to 17 object to production and redact certain documentation or information. If any such 18 objection is made and the Parties are unable to agree, the production or protection of the 19 documentation or information shall be submitted to the Court for review and decision 20 21 concerning production or protection. 22 2. Any Party may designate as “confidential” (by stamping the relevant page or as otherwise 23 set forth herein) any document or response to discovery which that party considers in 24 good faith to contain information involving business, financial, employment, certain 25 investigative and/or Internal Affairs information, or other confidential or protected 26 information, subject to protection under the Federal Rules of Civil Procedure or Nevada 27 28 law (“Confidential Information”). Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be 2 designated. 3 3. A party may designate information disclosed during a deposition or in response to written 4 discovery as “confidential” by so indicating in said response or on the record at the 5 deposition and requesting the preparation of a separate transcript of such material. 6 7 Additionally, a party may designate in writing, within twenty (20) days after receipt of 8 said responses or of the deposition transcript for which the designation is proposed, that 9 specific pages of the transcript and/or specific responses be treated as Confidential 10 Information. Any other party may object to such proposal, in writing or on record. Upon 11 such objection, the Parties shall follow the procedures described in paragraph 8 below. 12 After any designation made according to the procedure set forth in this paragraph, the 13 14 designated documents or information shall be treated according to the designation until 15 the matter is resolved according to the procedures described in paragraph 9 below, and 16 counsel for all parties shall be responsible for making all previously unmarked copies of 17 the designated material in their possession or control with the specified designation. The 18 documents subject to the claim of confidentiality shall be identified either by clearly 19 describing the document or by referring to the document by its Bates-stamp numbers, 20 21 (e.g., COR-0000). 22 4. All Confidential Information produced or exchanged in the course of this case shall be 23 used by the Parties to whom the information is produced solely for the purpose of this 24 case. 25 5. Except with the prior written consent of other parties, or upon prior order of this Court 26 obtained upon notice to opposing counsel, Confidential Information shall not be disclosed 27 28 to any person other than: a. Counsel for the respective parties to this litigation, including in-house counsel and 2 co-counsel retained for this litigation; 3 b. Employees of such counsel; 4 c. Individual defendants, any officer or employee of a Party, to the extent deemed 5 necessary by counsel for the prosecution or defense of this litigation; 6 7 d. Consultants or expert witnesses retained for the prosecution or defense of this 8 litigation, provided that each such person shall execute a copy of the Certification 9 attached to this Order as Exhibit “A” (which shall be retained by counsel to the 10 party so disclosing the Confidential Information and made available for inspection 11 by opposing counsel during the pendency of the action) before being shown or 12 given any Confidential Information. 13 14 e. Any authors or recipients of the Confidential Information; 15 f. The Court, Court personnel, and court reporters; and 16 g. Witnesses (other than persons described in paragraph 4(e)). If a witness is shown 17 Confidential Information outside of a deposition or at trial, the witness shall sign 18 the Certification attached as Exhibit “A” before being shown Confidential 19 Information. If the witness is shown Confidential Information during a deposition, 20 21 the witness is not required to sign the Certification attached as Exhibit “A”; 22 however, the attorneys for the Parties attending the deposition will inform the 23 witness that the information has been designated as confidential. Witnesses 24 shown Confidential Information shall not be allowed to retain copies. 25 h. Any mediator(s) or settlement officer(s) mutually agreed upon by the parties. 26 27 28 i. Employees of discovery or copy services, microfilming or database services, trial 2 support firms and/or translators or other litigation support vendors who are 3 engaged by the Parties during this litigation. 4 6. Any persons receiving Confidential Information shall not reveal or discuss such 5 information to or with any person who is not entitled to receive such information, except 6 7 as set forth herein. 8 7. Unless otherwise permitted by statute, rule or prior court order, papers filed with the 9 Court under seal shall be accompanied by a contemporaneous motion for leave to file 10 those documents under seal and shall be filed consistent with the Court’s electronic filing 11 procedures in accordance with Local Rule IA 10-5. Notwithstanding any agreement 12 among the Parties, the party seeking to file a paper under seal bears the burden of 13 14 overcoming the presumption in favor of public access to papers filed in court. Kamakana 15 v.City and County of Honolulu, 447 F.2d 1172 (9th Cir. 2006); Pintos v. Pac. Creditors 16 Ass’n, 605 F.3d 665, 677-78 (9th Cir. 2010). 17 8. A party may designate as “Confidential” documents or discovery materials produced by a 18 non-party by providing written notice to all parties of the relevant document numbers or 19 other identification within thirty (30) days after receiving such documents or discovery 20 21 materials. Any party may voluntarily disclose to others without restriction any 22 information designated by that party as confidential, although a document may lose its 23 confidential status if it is made public. 24 9. If a party contends that any material is not entitled to confidential treatment, such party 25 may at any time give written notice to the party who designated the material. The party 26 who designated the material shall have twenty-five (25) days from the receipt of such 27 28 written notice to apply to the Court for an order designating the material as confidential. The party seeking the order has the burden of establishing that the document is entitled to 2 protection. 3 10.Notwithstanding any challenge to the designation of material as Confidential 4 Information, all documents shall be treated as such and shall be subject to the provisions 5 hereof unless and until one of the following occurs: 6 7 a. The party claims that the material is Confidential Information withdraws such 8 designation in writing; or 9 b. The party who claims that the material is Confidential Information fails to apply 10 to the Court for an order designating the material confidential within the time 11 period specified in Paragraph 9 above after receipt of a written challenge to such 12 designation; or 13 14 c. The Court rules the material is not confidential. 15 11.All provisions of this Order restricting the communication or use of Confidential 16 Information shall continue to be binding after the conclusion of this action, unless 17 otherwise agreed or ordered. Upon conclusion of the litigation, a party in the possession 18 of Confidential Information, other than that which is contained in pleadings, 19 correspondence, and deposition transcripts, shall either (a) return such documents no later 20 21 than thirty (30) days after conclusion of this action to counsel for the party or non-party 22 who provided such information, or (b) destroy such documents within the time period 23 upon consent of the party who provided the information and certify in writing within 24 thirty (30) days that the documents have been destroyed. This requirement does not 25 include work-product of legal counsel, or information contained in pleadings, deposition 26 transcripts, or correspondence, which shall be maintained in confidence. 27 28 12.The terms of this Order do not preclude, limit, restrict, or otherwise apply to the use of 2 documents at trial. If the parties request that confidential documents be sealed at trial, 3 they will file a motion to seal the documents with the Court. 4 13.Nothing herein shall be deemed to waive any applicable privilege or work-product 5 protection, or to affect the ability of a party to seek relief for an inadvertent disclosure of 6 7 material protected by privilege or work-product protection. 8 14.Any witness or other person, firm or entity from which discovery is sought may be 9 informed of and may obtain the protection of this Order by written advice to the Parties’ 10 respective counsel or by oral advice at the time of any deposition or similar proceeding. 11 15.Nothing in this Stipulated Protective Order is intended to, or shall, deprive a party of the 12 right to object to the production of information or materials it believes is subject to 13 14 confidentiality or other protections from disclosure which exist under other authorities or 15 doctrines. 16 16.Should any party who is not a party to this Stipulated Protective Order seek access to the 17 Confidential Information referenced herein, by request, subpoena, or otherwise, from any 18 party to the Stipulated Protective Order, the party to this Stipulated Protective Order from 19 whom the information is requested shall: (a) promptly notify the party that designated the 20 21 confidential documentation or information of the request or subpoena; and shall (b) 22 inform the requesting party of the existence of this Stipulated Protective Order. 23 17.Amendment: This Stipulated Protective Order shall prohibit disclosure to all persons 24 other than those set forth herein. The parties may amend this Stipulated Protective Order 25 upon consent or upon application to the Court in which this action is pending. 26 Subsequent parties to this litigation may be given documents subject to this Stipulated 27 28 Protective Order, provided they first file with the court a Stipulation to be bound by the l terms of this Stipulated Protective Order. * || STIPULATED AND AGREED THIS 19" DAY OF AUGUST, 2025. Law Offices of Kenneth E. Lyon, III KARL S. HALL, Reno City Attorney /s/ Kenneth E. Lyon, II /s/ Holly S. Parker > || Kenneth E. Lyon, III Holly S. Parker « || Nevada Bar No. 7071 Deputy City Attorney Law Offices of Kenneth E. Lyon, III Peter K. Keegan 7 || 333 Flint Street Deputy City Attorney Reno, Nevada 89501 PO Box 1900 8 || (775) 786-4188 Reno, Nevada 89505 9 (775) 334-2050 Attorney for Plaintiff 10 Attorney for Reno Defendants 11 Thorndal Armstrong, PC
13 /s/ Katherine F_ Parks Katherine F. Parks, Esq. NBN 6227 14 Nevada Bar No. 6227 6590 S. McCarran Blvd., Suite B 15 Reno, Nevada 89509 6 (775) 786-2882 17 Attorney for Storey Defendants 18 ORDER 19 20 The Court will only retain jurisdiction over this protective order while the case is 21 || pending, and its jurisdiction will cease upon dismissal of the case. 22 |/IT IS SO ORDERED. CS 24 UNITED STATES GISTRATE JUDGE 25 DATED: August 19, 2025 26 27 28
EXHIBIT A 2 CERTIFICATION 3 I hereby certify my understanding that Confidential Information is being provided to me 4 pursuant to the terms and restrictions of the Protective Order dated ____________________, in 5 6 Woolley v. Welch, et.al, Case No. 3:25-cv-00191-MMD-CSD. 7 I have been given a copy of that Order and read it. I agree to be bound by the Order. I 8 will not reveal the Confidential Information to anyone, except as allowed by the Order. I will 9 maintain all such Confidential Information including copies, notes, or other transcriptions made 10 therefrom – in a secure manner to prevent unauthorized access to it. No later than thirty (30) days 11 after the conclusion of this action, I will return the Confidential Information – including copies, 12 13 notes or other transcriptions made therefrom – to the counsel who provided me with the 14 Confidential Information, or, if requested by counsel who provided me with the information, 15 certify in writing to the counsel who provided me with the Confidential Information that I have 16 destroyed the information. I hereby consent to the jurisdiction of the United States District Court 17 for the purpose of enforcing the Protective Order. 18 BY: ____________________________________ 19 Signature 20 ____________________________________ 21 Printed Name 22 DATED: ________________________________ 23 24 25 26 27 28