Rampula v. McGee et al

Filing 59

PROTECTIVE ORDER by Magistrate Judge John E. McDermott re Stipulation for Protective Order 57 . [See Order for details.] (san)

DENNIS W. RIHN, ESQ. (SBN 126233)
ATTORNEY AT LAW
2 215 North Marengo Avenue, Third Floor
Pasadena, CA 91101
3 Telephone: [phone]
Email: [e-mail]
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NINA J. BAUMLER, ESQ. (SBN 256728)
THE LAW OFFICE OF NINA BAUMLER
840 Apollo Street, Suite 311
6 El Segundo, CA 90245
Telephone: [phone]
7 Email: [e-mail]
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Attorneys for Plaintiff Elvira Rampula

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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CASE NO. 2:16-cv-03819-DMG-JEM

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Plaintiff,
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vs.
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JAMES MCGEE and JENNIFER)
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MCGEE,
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Defendants
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_______________________________)
ELVIRA RAMPULA,

[PROPOSED] PROTECTIVE ORDER
BASED UPON STIPULATION
DISTRICT JUDGE: THE
HONORABLE DOLLY M. GEE
MAGISTRATE JUDGE: THE
HONORABLE JOHN E. MCDERMOTT

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[Proposed] Protective Order

[PROPOSED] ORDER

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Based upon the stipulation of the parties, and good cause appearing:

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IT IS ORDERED:

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1.

responsive to requests for production no. 7.

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Defendants James and Jennifer McGee shall produce all documents

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Plaintiff’s attorneys shall not disclose such records (with the exception of

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records showing the hours worked by Elvira Rampula and Rico Canlas) to

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any third party without first giving defense counsel of record 30 days

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advance notice in writing of the intent to disclose such records.

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3.

During said 30 day notice period specified in the preceding paragraph,

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Defendants may seek to limit the disclosure of such items by agreement

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with Plaintiff’s counsel or by appropriate requests made to the Court.

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4.

This stipulation does not require advance notice that documents subject to

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this stipulation will be used by any party as trial exhibits and such items

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may be included in exhibit notebooks without advance notice.

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DATED: January 12, 2017

____________________________
THE HONORABLE JOHN E.
MCDERMOTT, MAGISTRATE
JUDGE OF THE UNITED
STATES DISTRICT COURT

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[Proposed] Protective Order