Paulina D Burton v. California Department of Forestry and Fire Protection et al

Filing 19

PROTECTIVE ORDER RE INFORMATION SUBJECT TO CIPA by Magistrate Judge Jay C. Gandhi, Pursuant to the parties Stipulation for Protective Order, IT IS HEREBY ORDERED as follows: (1) Only counsel for the parties may use the information pertaining to the h ome addresses and telephone numbers of former and current employees of defendant for the purposes of serving subpoenas for depositions or trial. The information pertaining to the home addresses and telephone numbers of former and current employees of defendant shall not be disclosed or used by plaintiff. re Stipulation for Protective Order 18 (SEE ORDER FOR FURTHER DETAILS) (lmh)

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UNITED STATES DISTRICT COURT FOR THE
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CENTRAL DISTRICT OF CALIFORNIA--WESTERN DIVISION
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Case No. CV11-9328 PSG (JCGx)

PAULINA D. BURTON,

v.

Plaintiff, PROTECTIVE ORDER RE
INFORMATION SUBJECT TO
CIPA

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ECC/OES FIRE DEPARTMENT
A/K/A “CAL-FIRE” AN AGENCY
OF THE STATE OF CALIFORNIA
AND DOES 1 Through 50, Inclusive,

Courtroom: 880
Judge:
The Honorable Philip S.
Gutierrez
Defendants.
Trial Date: January 15, 2013
Action Filed:
June 9, 2011

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ORDER
Pursuant to the parties’ Stipulation for Protective Order, IT IS HEREBY
ORDERED as follows:
(1) Only counsel for the parties may use the information pertaining to the
home addresses and telephone numbers of former and current employees of
defendant for the purposes of serving subpoenas for depositions or trial. The
information pertaining to the home addresses and telephone numbers of former and
current employees of defendant shall not be disclosed or used by plaintiff.

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Protective Order CV11-9328 PSG (JCGx)

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(2) The parties, through their counsel, may use the information produced by

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defendant in all law and motion proceedings, however, the parties agree that any

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information subject to this Protective Order shall be designated as “Confidential”

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and filed under seal pursuant to L.R. 79, and shall not be disclosed to plaintiff.

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(3) If counsel for either party wishes to disclose information protected by the

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California Information Practices Act to persons requested to furnish litigation

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services, other than their counsel, then said person(s) shall execute a written

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declaration substantially in the form of Exhibit “A” hereto. The information shall

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not be disclosed to plaintiff.

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(4) Upon completion of this action, plaintiff’s counsel shall certify to the

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Court that they have irretrievably destroyed or returned all documents containing

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information that have been produced pursuant to this Stipulation for Protective

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Order and Protective Order. Plaintiff’s counsel shall further certify that they have

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destroyed or returned all copies and/or duplicates, as defined by Rule 1001(4) of the

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Federal Rules of Evidence, that they have made of such documents.

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(5) This Order is not intended to compromise the rights of any party to object

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to discovery pursuant to the Federal Rules of Civil Procedure or any other

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governing authority nor is it intended to alter any burden of proof regarding any

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assertion of privilege in this matter.

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DATED: September 06, 2012

_______________________________
UNITED STATES
MAGISTRATE JUDGE

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Protective Order CV11-9328 PSG (JCGx)

EXHIBIT “A”

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I have read and I understand the Stipulation for Protective Order and

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Protective Order entered by the Court in the case Paulina D. Burton v. ECC/OES

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Fire Department a/k/a “Cal-Fire”, an Agency of the State of California, CV11-9328

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PSG (JCGx), and I agree to be bound by its terms.

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DATED:______________

__________________________________
Signature

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__________________________________
Printed Name

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LA2011505158
60844861.doc

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Protective Order CV11-9328 PSG (JCGx)