E. Howard Musgrove v. Jackson Nurse Professionals, LLC et al
Filing
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AMENDED STIPULATED PROTECTIVE ORDER REGARDING CONTACTING PUTATIVE CLASS MEMBERS by Magistrate Judge Jean P. Rosenbluth re Stipulation for Protective Order 33 . (See Order for details). (bem)
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KENNETH D. SULZER (SBN 120253)
ksulzer@constangy.com
SARAH KROLL-ROSENBAUM (SBN 272358)
skroll-rosenbaum@constangy.com
SAYAKA KARITANI (SBN 240122)
skaritani@constangy.com
CONSTANGY, BROOKS, SMITH & PROPHETE, LLP
2029 Century Park East, Suite 1100
Los Angeles, CA 90067
Telephone: (310) 909-7775
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Attorneys for Defendant
JACKSON NURSE PROFESSIONALS, LLC
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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E. HOWARD MUSGROVE, an
individual on behalf of himself and
others similarly situated,
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Plaintiff,
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v.
JACKSON NURSE
PROFESSIONALS, LLC; a Georgia
limited liability company; and DOES 1
to 10 inclusive,
Case No. 2:17-cv-06565-FMO-JPR
AMENDED STIPULATED
PROTECTIVE ORDER REGARDING
CONTACTING PUTATIVE CLASS
MEMBERS
District Judge:
Hon. Fernando M. Olguin, Ctrm. 6D
Magistrate Judge:
Jean P. Rosenbluth, Ctrm. 690
Defendant.
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Having reviewed the Amended Stipulation and Protective Order re Contacting
Putative Class Members, and good cause shown, IT IS HEREBY ORDERED:
(1)
That Defendant Jackson Nurse Professionals, LLC (“JNP”) produce the
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available last-known contact information (i.e., home address and phone numbers) of
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its current and former employees who are or were employed by JNP in California at
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any time between September 6, 2013 and the present;
-1[PROPOSED] AMENDED STIPULATED PROTECTIVE ORDER; Case No. 17-CV-06565-FMO-JPR
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(2)
That, should Plaintiff’s counsel seek to use this contact information in
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this action for discovery purposes and/or to advise class members of this action,
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Plaintiff’s counsel shall inform each potential class member during the initial
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communication, whether in writing or verbally:
(a)
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that he or she has a right not to talk to counsel and that, if he or
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she elects not to talk to counsel, Plaintiff’s counsel will terminate
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the contact and not contact them again;
(b)
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that JNP was compelled by court order to disclose the contact
information;
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(c)
that the communication is highly confidential;
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(d)
that Plaintiff’s counsel will not use his or her contact information
for any purpose outside of this action; and
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(e)
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the identity and contact information of JNP’s counsel of record in
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this action, accompanied by a warning that JNP’s counsel does
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not represent the prospective class members.
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(3)
That Plaintiff’s counsel will not use this contact information of the
prospective class members for any purpose outside of this action.
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IT IS SO ORDERED:
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DATED: March 13, 2018
________________________________
Magistrate Judge Jean P. Rosenbluth
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-2[PROPOSED] AMENDED STIPULATED PROTECTIVE ORDER; Case No. 17-CV-06565-FMO-JPR
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