Estate of Raul Herrera III et al v. City of Ontario et al

Filing 29

STIPULATED PROTECTIVE ORDER by Magistrate Judge Sheri Pym. (ad)

Download PDF
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 THE ESTATE OF RAUL HERRERA III and JOE HERRERA, Plaintiffs, 12 13 14 15 16 ) ) ) ) ) ) ) ) ) ) ) ) ) ) v. CITY OF ONTARIO, BRAD KAYLOR, ZACH MCWATERS, SCOTT SCHAFFER, MICHAEL MORA and DOES 1 through 10, inclusive, Defendants. 17 Case No: 5:17-CV-00082 SP Hon. Sheri Pym STIPULATED PROTECTIVE ORDER 18 19 20 21 1. A. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely 22 to involve production of confidential, proprietary, or private 23 information, including confidential personnel records of peace 24 officers, for which special protection from public disclosure 25 and from use for any purpose other than prosecuting this 26 litigation would be warranted. 27 stipulate to and petition the Court to enter the following 28 Stipulated Protective Order. Accordingly, the parties hereby The parties acknowledge that this {DSR/00051297. } -1STIPULATED PROTECTIVE ORDER 1 Stipulated Protective Order does not confer blanket protections 2 on all disclosures or responses to discovery and that the 3 protection it affords extends only to the limited information or 4 items that are entitled under the applicable legal principles to 5 treatment as confidential. 6 set forth in section 12, below, that this Stipulated Protective 7 Order creates no entitlement to file confidential information 8 under seal; Civil Local Rule 79-5 sets forth the procedures that 9 must be followed and reflects the standards that will be applied The parties further acknowledge, as 10 when a party seeks permission from the court to file material 11 under seal. 12 this Stipulated Protective Order shall preclude either party 13 from asserting that a document is of such a confidential or 14 private nature that it should not be produced or that it should 15 only be produced in redacted form, or from seeking a protective 16 order to preclude the production of certain documents. The parties further acknowledge that nothing in 17 B. GOOD CAUSE STATEMENT 18 This action is likely to involve confidential information, 19 including personnel records of the Defendant police officers, 20 information otherwise generally unavailable to the public, or 21 which may be privileged or otherwise protected from disclosure 22 under state or federal statutes, court rules, case decisions or 23 common law. Accordingly, to expedite the flow of information, to 24 facilitate the prompt resolution of disputes over 25 confidentiality of discovery materials, to adequately protect 26 information the parties are entitled to keep confidential, to 27 ensure that the parties are permitted reasonable necessary uses 28 of such material in preparation for and in the conduct of trial, {DSR/00051297. } -2STIPULATED PROTECTIVE ORDER 1 to address their handling at the end of the litigation, and 2 serve the ends of justice, a protective order for such 3 information is justified in this matter. It is the intent of the 4 parties that the information will not be designated as 5 confidential for tactical reasons and that nothing be so 6 designated without a good faith belief that it has been 7 maintained in a confidential, non-public manner, and there is 8 good cause why it should not be part of the public record of 9 this case. 10 11 2. DEFINITIONS 2.1. Party: any party to this action, including all of its 12 officers, directors, employees, consultants, retained experts, 13 and outside counsel (and their support staff). 14 2.2. Disclosure or Discovery Material: all items or 15 information, regardless of the medium or manner generated, 16 stored, or maintained (including, among other things, testimony, 17 transcripts, or tangible things) that are produced or generated 18 in disclosures or responses to discovery in this matter. 19 2.3. “Confidential” Information or Items: information 20 (regardless of how generated, stored or maintained) or tangible 21 things that contain information involving trade secrets, 22 confidential business, personal or financial information or 23 confidential personnel records. 24 25 26 27 2.4. Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 2.5. Producing Party: a Party or non-party that produces Disclosure or Discovery Material in this action. 28 {DSR/00051297. } -3STIPULATED PROTECTIVE ORDER 1 2.6. Designating Party: a Party or non-party that 2 designates information or items that it produced in disclosures 3 or in responses to discovery as “Confidential.” 4 5 2.7. Protected Material: any Disclosure or Discovery Material that is designated as “Confidential.” 6 2.8 Outside Counsel: attorneys (as well as their support 7 staff) who are not employees of a Party but who are retained to 8 represent or advise a Party in this action. 9 2.9 Expert: a person with specialized knowledge or 10 experience in a matter pertinent to the litigation who has been 11 retained by a Party or its counsel to serve as an expert witness 12 or as a consultant in this action and who is not a past or a 13 current employee of a Party or of a competitor of a Party and 14 who, at the time of retention, is not anticipated to become an 15 employee of a Party or a competitor of a Party. 16 includes a professional, jury or trial consultant retained in 17 connection with this litigation. 18 This definition 2.10 Professional Vendors: persons or entities that provide 19 litigation support services (e.g., photocopying, videotaping, 20 translating, preparing exhibits or demonstrations, organizing, 21 storing, retrieving data in any form or medium, etc.) and their 22 employees and subcontractors. 23 3. 24 SCOPE The protections conferred by this Stipulated Protective 25 Order cover not only Protected Material (as defined above), but 26 also any information copied or extracted therefrom, as well as 27 all copies, excerpts, summaries, or compilations thereof, plus 28 testimony, conversations, or presentations by parties or counsel {DSR/00051297. } -4STIPULATED PROTECTIVE ORDER 1 to or in court or in other settings that might reveal Protected 2 Material. 3 Any use of Protected Material at trial shall be governed by 4 the orders of the trial judge. 5 use of Protected Material at trial. 6 4. 7 This Order does not govern the DURATION Once a case proceeds to trial, all of the information that 8 was designated as confidential or maintained pursuant to this 9 protective order becomes public and will be presumptively 10 available to all members of the public, including the press, 11 unless compelling reasons supported by specific factual findings 12 to proceed otherwise are made to the trial judge in advance of 13 the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 14 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 15 showing for sealing documents produced in discovery from 16 “compelling reasons” standard when merits-related documents are 17 part of court record). Accordingly, the terms of this protective 18 order do not extend beyond the commencement of the trial. 19 5. 20 DESIGNATING PROTECTED MATERIAL 5.1. Exercise of Restraint and Care in Designating Material 21 for Protection. Each Party or non-party that designates 22 information or items for protection under this Stipulated 23 Protective Order must take care to limit any such designation to 24 specific material that qualifies under the appropriate legal 25 standards. 26 protection only those parts of material, documents, items, or 27 oral or written communications that qualify - so that other 28 portions of the material, documents, items, or communications A Designating Party must take care to designate for {DSR/00051297. } -5STIPULATED PROTECTIVE ORDER 1 for which protection is not warranted are not swept 2 unjustifiably within the ambit of this Stipulated Protective 3 Order. 4 Mass, indiscriminate, or routinized designations are 5 prohibited. 6 unjustified or that have been made for an improper purpose 7 (e.g., unnecessarily to encumber the case development process or 8 to impose unnecessary expenses or burdens on other parties) may 9 expose the Designating Party to sanctions. Designations that are shown to be clearly 10 If it comes to a Party’s or a non-party’s attention that 11 information or items that it designated for protection do not 12 qualify for protection, that Party or non-party must promptly 13 notify all other parties that it is withdrawing or modifying the 14 mistaken designation. 15 5.2. Manner and Timing of Designations. Except as 16 otherwise provided in this Stipulated Protective Order (see, 17 e.g., second paragraph of section 5.2(a), below), or as 18 otherwise stipulated or ordered, material that qualifies for 19 protection under this Stipulated Protective Order must be 20 clearly so designated before the material is disclosed or 21 produced. 22 23 Designation in conformity with this Stipulated Protective Order requires: 24 a. For information in documentary form (apart from 25 transcripts of depositions or other pretrial or trial 26 proceedings), that the Producing Party affix the legend 27 “CONFIDENTIAL” at the bottom-right of each page that 28 contains Protected Material. If only a portion or portions {DSR/00051297. } -6STIPULATED PROTECTIVE ORDER 1 of the material on a page qualifies for protection, the 2 Producing Party must also clearly identify the protected 3 portion(s) (e.g., by making appropriate markings in the 4 margins). 5 A Party or non-party that makes original documents or 6 materials available for inspection need not designate them 7 for protection until after the inspecting Party has 8 indicated which material it would like copied and produced. 9 During the inspection and before the designation, all of 10 the material made available for inspection shall be deemed 11 “CONFIDENTIAL.” 12 the documents it wants copied and produced, the Producing 13 Party must determine which documents, or portions thereof, 14 qualify for protection under this Stipulated Protective 15 Order. 16 Producing Party must affix the appropriate legend 17 (“CONFIDENTIAL”) at the bottom-right of each page that 18 contains Protected Material. If only a portion or portions 19 of the material on a page qualifies for protection, the 20 Producing Party must also clearly identify the protected 21 portion(s) (e.g., by making appropriate markings in the 22 margins). 23 b. After the inspecting Party has identified Then, before producing the specified documents, the For testimony given in deposition or in other 24 pretrial or trial proceedings, that the Party or non-party 25 offering or sponsoring the testimony identify on the 26 record, before the close of the deposition, hearing, or 27 other proceeding, all protected testimony, and further 28 specify any portions of the testimony that qualify as {DSR/00051297. } -7STIPULATED PROTECTIVE ORDER 1 “CONFIDENTIAL.” 2 separately each portion of testimony that is entitled to 3 protection, and when it appears that substantial portions 4 of the testimony may qualify for protection, the Party or 5 non-party that sponsors, offers, or gives the testimony may 6 invoke on the record (before the deposition or proceeding 7 is concluded) a right to have up to 20 days to identify the 8 specific portions of the testimony as to which protection 9 is sought and to specify the level of protection being When it is impractical to identify 10 asserted (“CONFIDENTIAL”). 11 testimony that are appropriately designated for protection 12 within the 20 days shall be covered by the provisions of 13 this Stipulated Protective Order. 14 Only those portions of the Transcript pages containing Protected Material must be 15 separately bound by the court reporter, who must affix to 16 the top of each such page the legend “CONFIDENTIAL,” as 17 instructed by the Party or non-party offering or sponsoring 18 the witness or presenting the testimony. 19 c. For information produced in some form other than 20 documentary, and for any other tangible items, that the 21 Producing Party affix in a prominent place on the exterior 22 of the container or containers in which the information or 23 item is stored the legend “CONFIDENTIAL.” 24 of the information or item warrant protection, the 25 Producing Party, to the extent practicable, shall identify 26 the protected portions, specifying whether they qualify as 27 “CONFIDENTIAL.” 28 {DSR/00051297. } -8STIPULATED PROTECTIVE ORDER If only portions 1 5.3. Inadvertent Failures to Designate. If timely 2 corrected, an inadvertent failure to designate qualified 3 information or items as “CONFIDENTIAL” does not, standing alone, 4 waive the Designating Party’s right to secure protection under 5 this Stipulated Protective Order for such material. 6 is appropriately designated as “CONFIDENTIAL” after the material 7 was initially produced, the Receiving Party, on timely 8 notification of the designation, must make reasonable efforts to 9 assure that the material is treated in accordance with the 10 provisions of this Stipulated Protective Order. 11 6. If material 12 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1. Timing of Challenges. Unless a prompt challenge to a 13 Designating Party’s confidentiality designation is necessary to 14 avoid foreseeable substantial unfairness, unnecessary economic 15 burdens, or a later significant disruption or delay of the 16 litigation, a Party does not waive its right to challenge a 17 confidentiality designation by electing not to mount a challenge 18 promptly after the original designation is disclosed. 19 6.2. Meet and Confer. A Party that elects to initiate a 20 challenge to a Designating Party’s confidentiality designation 21 must do so in good faith and pursuant to the dispute resolution 22 process under Local Rule 37-1, et seq. 23 6.3. Burden of Persuasion. The burden of persuasion in any 24 such challenge proceeding shall be on the Designating Party. 25 Frivolous challenges, and those made for an improper purpose 26 (e.g., to harass or impose unnecessary expenses and burdens on 27 other parties) may expose the Challenging Party to sanctions. 28 Until the Court rules on the challenge, all parties shall {DSR/00051297. } -9STIPULATED PROTECTIVE ORDER 1 continue to afford the material in question the level of 2 protection to which it is entitled under the Producing Party’s 3 designation. 4 7. 5 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1. Basic Principles. A Receiving Party may use Protected 6 Material that is disclosed or produced by another Party or by a 7 non-party in connection with this case only for prosecuting, 8 defending, or attempting to settle this litigation. 9 Protected Material may be disclosed only to the categories of 10 persons and under the conditions described in this Stipulated 11 Protective Order. 12 Receiving Party must comply with the provisions of section 13, 13 below (FINAL DISPOSITION). 14 Such When the litigation has been terminated, a Protected Material must be stored and maintained by a 15 Receiving Party at a location and in a secure manner that 16 ensures that access is limited to the persons authorized under 17 this Stipulated Protective Order. 18 7.2. Disclosure of “CONFIDENTIAL” Information or Items. 19 Unless otherwise ordered by the Court or permitted in writing by 20 the Designating Party, a Receiving Party may disclose any 21 information or item designated CONFIDENTIAL only to: 22 a. the Receiving Party’s Outside Counsel of record in 23 this action and said Counsel’s paralegals, as well as other 24 employees of said Counsel to whom it is reasonably necessary to 25 disclose the information for this litigation and who have signed 26 the “Agreement to Be Bound by Protective Order” that is attached 27 hereto as Exhibit A; 28 {DSR/00051297. } -10STIPULATED PROTECTIVE ORDER 1 b. the officers, directors, and employees of the 2 Receiving Party to whom disclosure is reasonably necessary for 3 this litigation and who have signed the “Agreement to Be Bound 4 by Protective Order” (Exhibit A); 5 c. Experts (as defined in this Stipulated Protective 6 Order) of the Receiving Party to whom disclosure is reasonably 7 necessary for this litigation and who have signed the “Agreement 8 to Be Bound by Protective Order” (Exhibit A); 9 d. the Court and its personnel; 10 e. court reporters, their staffs, and professional 11 vendors to whom disclosure is reasonably necessary for this 12 litigation; 13 f. professional jury or trial consultants, mock jurors, 14 and Professional Vendors to whom disclosures is reasonably 15 necessary for this lawsuit and who have signed the 16 "Acknowledgement and Agreement to be Bound"(Exhibit A); 17 g. during their depositions, witnesses, and attorneys for 18 the witnesses, in the action to whom disclosure is reasonably 19 necessary, provided that they have signed the "Acknowledgement 20 and Agreement to be Bound"(Exhibit A). 21 deposition testimony or exhibits to depositions that reveal 22 Protected Material must be separately bound by the court 23 reporter and may not be disclosed to anyone except as permitted 24 under this Stipulated Protective Order. 25 26 h. Pages of transcribed the author of the document or the original source of the information. 27 28 {DSR/00051297. } -11STIPULATED PROTECTIVE ORDER 1 i. Any mediator or settlement officer, and their 2 supporting personnel, mutually agreed upon by any of the parties 3 engaged in settlement discussions. 4 8. 5 LITIGATION 6 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER If a Receiving Party is served with a subpoena or an order 7 issued in other litigation that would compel disclosure of any 8 information or items designated in this action as 9 “CONFIDENTIAL,” the Receiving Party must: 10 (a) notify the Designating Party, in writing (by fax 11 or email, if possible) immediately after receiving the 12 subpoena or order. 13 of the subpoena or court order; Such notification must include a copy 14 (b) immediately inform in writing the Party who caused 15 the subpoena or order to issue in the other litigation that 16 some or all the material covered by the subpoena or order 17 is the subject of this Stipulated Protective Order. 18 addition, the Receiving Party must deliver a copy of this 19 Stipulated Protective Order promptly to the Party in the 20 other action that caused the subpoena or order to issue; 21 and 22 In (c) cooperate with respect to all reasonable 23 procedures sought to be pursued by the Designating Party 24 whose Protected Material may be affected. 25 The purpose of imposing these duties is to alert the 26 interested parties to the existence of this Stipulated 27 Protective Order and to afford the Designating Party in this 28 case an opportunity to try to protect its confidentiality {DSR/00051297. } -12STIPULATED PROTECTIVE ORDER 1 interests in the court from which the subpoena or order issued. 2 If the Designating Party timely seeks a protective order in 3 relation to the subpoena or order issued in other litigation, 4 the Party served with the subpoena or order shall not produce 5 any information designated in this lawsuit as "CONFIDENTIAL" 6 before the determination by the court from which the subpoena or 7 order issued, unless the party has obtained the Designating 8 Party's permission. 9 burdens and the expenses of seeking protection in that court of The Designating Party shall bear the 10 its confidential material - and nothing in these provisions 11 should be construed as authorizing or encouraging a Receiving 12 Party in this action to disobey a lawful directive from another 13 court. 14 9. 15 THIS LITIGATION 16 A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN (a) The terms of this Order are applicable to information 17 produced by a Non-Party in this Action and designated as 18 “CONFIDENTIAL.” Such information produced by Non-Parties in 19 connection with this litigation is protected by the remedies and 20 relief provided by this Order. Nothing in these provisions 21 should be construed as prohibiting a Non-Party from seeking 22 additional protections. 23 (b) In the event that a Party is required, by a valid 24 discovery request, to produce a Non-Party’s confidential 25 information in its possession, and the Party is subject to an 26 agreement with the Non-Party not to produce the Non-Party’s 27 confidential information, then the Party shall: 28 {DSR/00051297. } -13STIPULATED PROTECTIVE ORDER 1 (1) promptly notify in writing the Requesting Party 2 and the Non-Party that some or all of the information 3 requested is subject to a confidentiality agreement with a 4 Non-Party; 5 (2) promptly provide the Non-Party with a copy of the 6 Stipulated Protective Order in this Action, the relevant 7 discovery request(s), and a reasonably specific description 8 of the information requested; and 9 (3) make the information requested available for 10 inspection by the Non-Party, if requested. 11 (c) If the Non-Party fails to seek a protective order from 12 this Court within 14 days of receiving the notice and 13 accompanying information, the Receiving Party may produce the 14 Non-Party’s confidential information responsive to the discovery 15 request. If the Non-Party timely seeks a protective order, the 16 Receiving Party shall not produce any information in its 17 possession or control that is subject to the confidentiality 18 agreement with the Non-Party before a determination by the 19 Court. Absent a court order to the contrary, the Non-Party shall 20 bear the burden and expense of seeking protection in this Court 21 of its Protected Material. 22 10. 23 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or 24 otherwise, it has disclosed Protected Material to any person or 25 in any circumstance not authorized under this Stipulated 26 Protective Order, the Receiving Party must immediately (a) 27 notify in writing the Designating Party of the unauthorized 28 disclosures, (b) use its best efforts to retrieve all copies of {DSR/00051297. } -14STIPULATED PROTECTIVE ORDER 1 the Protected Material, (c) inform the person or persons to 2 whole unauthorized disclosures were made of all the terms of 3 this Stipulated Protective Order, and (d) request such person or 4 persons to execute the “Acknowledgment and Agreement to Be 5 Bound” that is attached hereto as Exhibit A. 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 7 MATERIAL 8 9 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced material is subject to a 10 claim of privilege or other protection, the obligations of the 11 Receiving Parties are those set forth in Federal Rule of Civil 12 Procedure 26(b)(5)(B). This provision is not intended to modify 13 whatever procedure may be established in an e-discovery order 14 that provides for production without prior privilege review. 15 Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as 16 the parties reach an agreement on the effect of disclosure of a 17 communication or information covered by the attorney-client 18 privilege or work product protection, the parties may 19 incorporate their agreement in the stipulated protective order 20 submitted to the Court. 21 12. 22 FILING PROTECTED MATERIAL Without written permission from the Designating Party or a 23 Court order secured after appropriate notice to all interested 24 persons, a party may not file in the public record in this 25 action any protected material. 26 seal any protected material must comply with Civil Local Rule 27 79-5. A party that seeks to file under Protected Material may only be filed under seal pursuant 28 {DSR/00051297. } -15STIPULATED PROTECTIVE ORDER 1 to a Court order authorizing the sealing of the specific 2 Protected Material at issue. 3 13. 4 FINAL DISPOSITION Upon written request after the settlement or other 5 termination of this action, each receiving party must return all 6 protected material to the producing party or destroy such 7 material within sixty days after the final termination of this 8 action. As used in this subdivision, “all protected material” 9 includes all copies (except as designated below), abstracts, 10 compilations, summaries or any other form of reproducing or 11 capturing any of the protected material. The receiving party may 12 destroy some or all of the protected material instead of 13 returning it. 14 destroyed, the receiving party must submit a written 15 certification to the producing party (and, if not the same 16 person or entity, to the designating party) by the sixty-day 17 deadline affirming that all the protected material was returned 18 or destroyed and that the receiving party has not retained any 19 copies, abstracts, compilations, summaries or other forms of 20 reproducing or capturing any of the protected material. 21 Notwithstanding this provision, counsel are entitled to retain 22 an archival copy of all pleadings, motion papers, transcripts, 23 legal memoranda, correspondence or attorney work product, even 24 if such materials contain protected material. Any such archival 25 copies that contain or constitute protected material remain 26 subject to this stipulated protective order as set forth in 27 section 4 (duration), above. Whether the protected material is returned or 28 {DSR/00051297. } -16STIPULATED PROTECTIVE ORDER 1 14. 2 MISCELLANEOUS 14.1. Right to Further Relief. Nothing in this 3 Stipulated Protective Order abridges the right of any person to 4 seek its modification by the Court in the future. 5 14.2. Right to Assert Other Objections. By stipulating 6 to the entry of this Stipulated Protective Order, no Party 7 waives any right it otherwise would have to object to disclosing 8 or producing any information or item on any ground not addressed 9 in this Stipulated Protective Order. Similarly, no Party waives 10 any right to object on any ground to use in evidence of any of 11 the material covered by this Stipulated Protective Order. 12 15. 13 VIOLATION Any violation of this Order may be punished by any and all 14 appropriate measures including, without limitation, contempt 15 proceedings and/or monetary sanctions. 16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17 PEREIRA LAW 18 By: 19 20 COTA COLE & HUBER LLP 21 By: 22 23 24 25 /S/CHRISTIAN F. PEREIRA CHRISTIAN F. PEREIRA Attorneys for Plaintiffs /S/DENNIS M. COTA DENNIS M. COTA Attorneys for Defendants FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. DATED: May 24, 2017 26 27 28 HON. SHERI PYM UNITED STATES MAGISTRATE JUDGE {DSR/00051297. } -17STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 3 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4 5 I, 6 [print or type full name], of [print or type full address], declare under 7 penalty of perjury that I have read in its entirety and 8 understand the Stipulated Protective Order that was issued by 9 the United States District Court for the Central District of 10 California on [date] in the case of The Estate of Raul Herrera 11 III, et al., v. City of Ontario, et al., Case No. 5:17-cv-82 SP. 12 I agree to comply with and to be bound by all the terms of this 13 Stipulated Protective Order and I understand and acknowledge 14 that failure to so comply could expose me to sanctions and 15 punishment in the nature of contempt. I solemnly promise that I 16 will not disclose in any manner any information or item that is 17 subject to this Stipulated Protective Order to any person or 18 entity except in strict compliance with the provisions of this 19 Order. I further agree to submit to the jurisdiction of the 20 United States District Court for the Central District of 21 California for the purpose of enforcing the terms of this 22 Stipulated Protective Order, even if such enforcement 23 proceedings occur after termination of this action. I hereby 24 appoint 25 26 [print or type full name] of [print or type full address and telephone number] as my California agent for service 27 of process in connection with this action or any proceedings 28 related to enforcement of this Stipulated Protective Order. {DSR/00051297. } -18STIPULATED PROTECTIVE ORDER City and State 1 Date: 2 where sworn and signed: 3 Printed name: 4 Signature: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 {DSR/00051297. } -19STIPULATED PROTECTIVE ORDER

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?