Bernadette Blackwood et al v. N&M Dairy et al

Filing 73

PROTECTIVE ORDER by Magistrate Judge Sheri Pym [NOTE CHANGE MADE BY THE COURT TO 3(e)] (SEE ORDER FOR DETAILS). (kca)

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Lee N. Smith SBN 138071
Lori J. Gualco SBN 95232
Daniel C. Stein SBN 250102
Craig A. Tristão SBN 256528
PERKINS, MANN & EVERETT
INCORPORATED
7815 N. Palm Avenue, Suite 200
Fresno, California 93711
Telephone [phone]
Facsimile [phone]

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Attorney for: Defendants MARY DE VRIES, NEIL DE VRIES, JAMES DE
VRIES and RANDY DE VRIES

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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Case No.: 5:14-cv-00395-JGB-SP
BERNADETTE BLACKWOOD,
individually and as guardian ad litem for
PROTECTIVE ORDER
K.B. and E.B; et al.;

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[NOTE CHANGE MADE BY THE
COURT TO ¶ 3(e)]

Plaintiffs,

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v.
MARY DE VRIES, individually and
dba
N&M DAIRY (aka N&M DAIRY # 1
and N&M DAIRY # 2) and as trustee of
the NEIL AND MARY DE VRIES
FAMILY TRUST; et al.;

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Defendants.

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ORDER

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Good cause appearing therefor, it is ORDERED as follows:

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1.

All Well Completion Reports shall be discoverable in this action,

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notwithstanding any objections based on privacy, confidentiality, Water Code §13752,

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or other limitations.

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PERKINS, MANN &
EVERETT, INC.

{00307455.DOC;1}

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____________________________________________________________________________________________
ORDER ON STIPULATION FOR PROTECTIVE ORDER

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2.

The DWR shall mark any documents or data that it produces as

“CONFIDENTIAL” prominently on the front page of each such document.

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3.

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Any document or data marked “CONFIDENTIAL” shall be treated as

follows:

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(a)

the document or data may be used only for purposes of this litigation;

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(b)

it may not be disclosed to anyone who is not a party to this litigation, an

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expert or a consultant retained by a party to this litigation, an attorney for a party, or an

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employee of one of the above;
(c)

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any copy of the document shall contain the “CONFIDENTIAL” mark on

(d)

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within 30 days of the conclusion of the litigation, all copies of the

it;

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confidential documents or data must be returned to DWR or destroyed, and the Parties

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must each inform DWR, and each other, in writing that this obligation has been

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satisfied;

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(e)

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if filed and/or lodged in the above action, the document shall be filed

and/or lodged with a sealing application pursuant to Local Rule 79-5;
(f)

the document shall not be disclosed to any person, other than the Parties,

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their counsel of record, or any employee of one of the Parties or their attorneys of

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record, who has not completed and signed the non-disclosure agreement attached hereto

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as Exhibit A.

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4.

The Parties and their attorneys of record shall complete and sign the non-

disclosure agreement attached hereto as Exhibit A.
5.

The Parties shall keep a record of any person who has signed a non-

disclosure agreement pursuant to paragraph 3(f) above, and provide such record to

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PERKINS, MANN &
EVERETT, INC.

{00307455.DOC;1}

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____________________________________________________________________________________________
ORDER ON STIPULATION FOR PROTECTIVE ORDER

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DWR upon request.

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Date: April 28, 2015

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_______________________________________
The Honorable Sheri Pym
United States Magistrate Judge

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Copies to counsel of record

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PERKINS, MANN &
EVERETT, INC.

{00307455.DOC;1}

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____________________________________________________________________________________________
ORDER ON STIPULATION FOR PROTECTIVE ORDER