E. Howard Musgrove v. Jackson Nurse Professionals, LLC et al

Filing 34

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)
[e-mail]
SARAH KROLL-ROSENBAUM (SBN 272358)
[e-mail]
SAYAKA KARITANI (SBN 240122)
[e-mail]
CONSTANGY, BROOKS, SMITH & PROPHETE, LLP
2029 Century Park East, Suite 1100
Los Angeles, CA 90067
Telephone: [phone]

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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