AE v. County of Tulare et al

Filing 130

PROTECTIVE ORDER signed by Magistrate Judge Dennis L. Beck on 8/12/2011. (Hernandez, M)

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MARK S. POSARD (SBN: 208790)
GEORGE A. ACERO (SBN: 226709)
GORDON & REES LLP
655 University Avenue, Suite 200
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants
TULARE YOUTH SERVICES BUREAU and
ADRAIN MARQUEZ (ERRONEOUSLY SUED AT ADRIAN)

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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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AE, a minor, by and through his Guardian ad
Litem, MARIBEL HERNANDEZ,

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Plaintiff,
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vs.
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COUNTY OF TULARE, et al.,
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Defendants.
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CASE NO. 1:09-CV-02204-LJO-DLB
STIPULATION OF
CONFIDENTIALITY AND
PROTECTIVE ORDER

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Plaintiff AE, a minor, by and through his Guardian ad Litem, MARIBEL HERNANDEZ

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(“Plaintiff”), and Defendants YADIRA PORTILLO, COURTNEY WAMPLER, CWA FELIX,

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HEIDI WILLIAMS, SANDRA CEBALLOS, FAMILY BUILDERS FOSTER CARE, TULARE

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YOUTH SERVICES BUREAU and ADRAIN MARQUEZ (ERRONEOUSLY SUED AT

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ADRIAN) (collectively “Defendants”) through their respective counsel, seek this Court’s

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approval of this Stipulation of Confidentiality and Protective Order.

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WHEREAS, pretrial discovery in the above-captioned action (the “Action”), may require

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disclosure of confidential information and documents, including confidential records of minors,

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confidential personnel information about employees of a party, or other confidential commercial

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information (the “Confidential Materials”);

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WHEREAS, Defendants and Plaintiff (collectively the “Parties”) desire to maintain the
confidentiality of the Confidential Materials.
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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties to this
Action, through their respective counsel, as follows:

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CONFIDENTIAL MATERIALS
1.

Each Party to this Action who, in response to a discovery request, or by way of

voluntary disclosure, produces or discloses (the “Disclosing Party”) any matter, including

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documents, things, testimony or information which such Party reasonably and in good faith

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believes

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“CONFIDENTIAL.” When third party documents are involved, such as documents provided via

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a subpoena, the parties can also agree to treat the documents as confidential for purposes of this

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agreement. When third-party documents are involved, the party whom receives these documents

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275 Battery Street, Suite 2000
San Francisco, CA 94111

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from a third party shall be treated as the “disclosing party” for purposes of this protective order.

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2.

to

comprise or contain Confidential

Materials

may designate the same

The Disclosing Party shall designate as “CONFIDENTIAL” any information or

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documents produced in discovery which it asserts in good faith should be protected from

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disclosure on the grounds that the information constitutes confidential or private information

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subject to a legally protected right of privacy, including privacy rights protected by the

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California and United States Constitutions, or any other state or federal law. This order shall not

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affect any information obtained outside of the discovery process unless the parties agree

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otherwise. In a case where confidential documents or information is produced in discovery, and

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such documents or information are also obtained from an independent source, the independently

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obtained information shall not be subject to this order unless the parties agree otherwise.

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3.

All information designated as “CONFIDENTIAL” by the Disclosing Party shall

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not be disclosed by any of the other Parties to any person or entity other than those persons

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designated herein and, in any event, shall not be used for any purpose other than in connection

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with the Action. Such information may be disclosed only to the following:

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A.

The Court (subject to provisions for filing under seal, set out below);

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B.

Counsel of record for any Party, including their associates, paralegals, and clerical

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personnel;

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C.

The Parties, including employees and agents of the Parties;
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D.

Persons retained or consulted by the Parties or their attorneys for purposes of this

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litigation (including, but not limited to, accountants, marketing consultants, financial advisors,

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statisticians and economists), if such persons reasonably require the information to enable them

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to assist counsel in the prosecution or defense of this litigation, provided that no such disclosure

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shall be made to any person employed by any competitor of Defendant, except upon further

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order of the Court;

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E.

Any court reporter who takes testimony;

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F.

A non expert witness or potential witness at or for any deposition or other

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proceeding in this Action (aside from trial) who may have knowledge of or information
concerning matters contained in any “confidential” document;

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G.

Insurance adjusters, third party claims administrators, and risk managers who are

working on this case; and

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H.

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To the extent any expert consultants, witnesses, or potential witnesses prepare summaries

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of “CONFIDENTIAL” materials, or cause such summaries to be prepared, such summaries shall

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be subject to the terms of this Protective Order.

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4.

Any other person as to whom the Parties in writing agree.

No disclosure of Confidential Materials designated as “CONFIDENTIAL” by any

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Disclosing Party may be made to any person pursuant to the terms of paragraphs 3(D), 3(F) or

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3(G) unless that person first executes an agreement to be bound by the terms of this Order in the

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form attached hereto as Exhibit “A.” This Order shall be binding upon the Parties, counsel for

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any Party, and all persons who, pursuant to the preceding sentence, have executed an agreement

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to be bound by the terms of this Order. Any entity Defendants, and any counsel for the parties,

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shall take reasonable steps to ensure that any employees who obtain CONFIDENTIAL

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information do not disclose it.

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paragraph 8), no person or entity upon whom this Order is binding shall use Confidential

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Materials designated as “CONFIDENTIAL” for any purpose other than in connection with the

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Action.

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5.

Except as stated otherwise herein (including as stated in

Counsel shall keep a record of all copies of each “CONFIDENTIAL” document
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distributed, in whole or in part, to any qualified person. Any copy so distributed shall be

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returned to the distributing counsel after the completion of the qualified person’s consultation or

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representation in this action.

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6.

With respect to documents which the Disclosing Party reasonably believes

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contain CONFIDENTIAL Materials, the Disclosing Party shall either stamp such documents

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“CONFIDENTIAL”

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“CONFIDENTIAL” and provide a description of the designated categories of the confidential

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documents at the time of delivery of the confidential documents. Such documents will also bear

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a Bates stamp number, or have some other manner of making them readily identifiable.

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7.

when

delivered

or

designate

categories

of

documents

as

To the extent Confidential Materials or information obtained therefrom are used

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275 Battery Street, Suite 2000
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in the taking of depositions, such documents or information shall remain subject to the

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provisions of this Protective Order. On the record at a deposition (with the party clearly defining

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when the confidential portion starts and ends), a Party may designate as “CONFIDENTIAL” the

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testimony which discloses information obtained from materials that have been previously

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designated as confidential. Confidential portions of deposition transcripts shall be treated in the

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same manner as any other “document” described in this Order. During the time a deponent is

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asked to testify about information marked as “CONFIDENTIAL,” the disclosing party or witness

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shall have the right to exclude from attendance at said deposition any person other than the

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deponent, the deponent’s attorney, counsel of record herein, any expert or consultant (if

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necessary to the deposition), the court reporter or videographer, interpreter (if necessary to the

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deposition), or any party to the action (or one representative of the party in the case of entity

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Defendants).

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8.

Nothing in this Protective Order shall prevent any Party from disclosing its own

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Confidential Materials as it deems appropriate. Such disclosure shall not, in itself, constitute a

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waiver of the designation of such confidential materials as “CONFIDENTIAL.” Once disclosed

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to a third party (except disclosure in conjunction with juvenile court proceedings and/or

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disclosure to third parties necessary for the litigation such as expert witnesses, copying services,

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a translator, etc.), however, that document will no longer be deemed “CONFIDENTIAL.”
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9.

If any Party objects to the designation of any Confidential Materials as

“CONFIDENTIAL,” the objecting party may request in writing of the Designating Party that

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such designation be removed. The written request shall be made within 30 days of when the

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party receives the confidential information and specifically identify the precise material or

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information at issue. Thereafter, the parties shall, in good faith, meet and confer on the issues

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raised in the objections. If not resolved via a meet and confer process, the Designating Party

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may make a motion to seek determination that such a claim of confidentiality or privilege applies

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within 30 days of service of the objections. If the Designating Party does not make such a

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motion within 30 days, the material or information at issue shall be deemed non-confidential for

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purposes of this protective order. The Designating Party shall have the burden of proof to

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275 Battery Street, Suite 2000
San Francisco, CA 94111

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establish the applicability of the claim of confidentiality or privilege. Pending the Court’s

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determination of such issues, documents shall be treated as designated. If a party objects to the

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designation of any document as confidential, the producing party may, within 15 days, request

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that the document over which the objections were made be returned. The Party who receives

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such notice must, within 10 days, return the documents (and any copies) to the producing party.

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The objecting party can then use any procedure available under the Code of Civil Procedure

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(including a motion to compel), to again obtain the document over which the objections to the

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confidentiality status were made.

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10.

For applications and motions to the Court in which a Party submits confidential

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documents or information, the moving party shall be required to file a stipulation, motion, or

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application to seal all documents containing confidential information that are submitted to the

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Court unless the party reasonably believes the confidential aspect of the information can be fully

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shielded via redactions. The party seeking to file redactions shall provide five (5) days notice of

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the nature of the redactions prior to filing, if practicable. The Designating Party shall fully

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cooperate with the non-designating Party to have the documents or information filed under seal,

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including by signing a stipulation to that effect. While the party producing the confidential

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information may have to attempt to submit the documents under seal, it is up to the party

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designating the information as confidential to provide any briefing necessary to convince the
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Court the documents should be sealed. Such briefing may be included in a stipulation or a

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separate filing submitted to the court regarding the motion/application to seal documents. In the

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event that a motion or application to file under seal is denied, the Party shall redact confidential

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information from such documents to the extent such information is unnecessary to the matter

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being adjudicated.

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Any court hearing which refers to or describes confidential information may, in

the Court’s discretion, be in camera.
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If

a

Party

in

possession

of

Confidential

Materials

designated

as

“CONFIDENTIAL” receives a subpoena from a non party to this Protective Order which seeks

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production or other disclosure of Confidential Materials, it or he shall immediately give written

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275 Battery Street, Suite 2000
San Francisco, CA 94111

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notice to counsel for the Party who designated the Confidential Materials as “CONFIDENTIAL”

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stating the Confidential Materials sought and enclosing a copy of the subpoena. Where possible,

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at least 10 days’ notice before production or other disclosure should be given. In no event shall

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production or disclosure be made before telephonic notice, which includes a voicemail message,

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is given and, whenever possible, sufficiently in advance of production or disclosure to afford the

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Party to whom such notice has been given at least three (3) business (i.e., non-holiday,

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weekdays) days to take appropriate action, including seeking judicial relief. The provisions in

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this paragraph shall not apply to any documents the parties receive from Child Welfare Services.

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Should any party receive a subpoena, or other legal process, seeking documents obtained from

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Child Welfare Services, that party is not required to notify the other parties in this case about the

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request for the documents. However, when documents received from Child Welfare Services are

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marked confidential pursuant to this protective order, and a party in possession of the Child

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Welfare Services document receives a request for such documents, that party receiving the

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request shall indicate to the requesting party that the documents are subject to the terms of the

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protective order and will only produce the documents if required to do so by law, including

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where required to do so pursuant to a court order.

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13.

Upon final resolution of this Action, including appeals, all Parties and persons to

whom any Confidential Materials have been disclosed or provided shall either destroy all such
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Confidential Materials or return them to the Disclosing Party. Notwithstanding the foregoing,

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counsel for each party may retain a record including the following, irrespective of whether or not

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it contains information designated as CONFIDENTIAL, its correspondence files relating to this

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litigation, its pleadings files (including all briefs, memoranda, affidavits, and all papers served by

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and on the party represented), any briefs and appendices on appeal, all legal research

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memoranda, and all attorney and consultant work product. Such material shall continue to

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remain subject to the provisions of this agreement.

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obligations over this Protective Order will not terminate upon final resolution of this Action, and

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that this Protective Order will remain in effect in perpetuity.

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14.

The Parties further agree that their

Neither the taking of any action in accordance with the provisions of this

Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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Protective Order, nor the failure to object thereto, shall be construed as a waiver of any claim or

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defense in this Action. The entry of this Order shall not be construed as a waiver of the right to

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object to the furnishing of information or documents in response to discovery and the Parties

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expressly reserve their right to withhold information or documents on the basis of such

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objections.

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15.

This Protective Order shall not prevent any Party from applying to the Court for

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relief therefrom, or from applying to the Court for further or additional protective orders, or from

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agreeing to modify this Protective Order, subject to the approval of the Court.

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16.

Neither the taking of any action in accordance with the provisions of this Order,

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nor the failure to designate information as confidential in this order, shall be construed as a

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waiver of any claim or defense in this action or a waiver of any rights under the Evidence Code

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or Code of Civil Procedure. This Order also shall not be construed as a waiver of any right to

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object to the furnishing of information in response to discovery. Except as expressly provided,

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this order shall not relieve any party of the obligation to produce information properly sought in

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the course of discovery where production is required by law.

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17.

After the date of the Protective Order, if a Party through inadvertence produces or

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provides discovery of any Confidential Materials without designating it as such in accordance

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with paragraphs 1, 6 and 7 of this Order, the Disclosing Party may give written notice to the
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Party or Parties that have received the Confidential Materials, within 45 days of the inadvertent

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disclosure, that the document(s), information, response, testimony, or other discovery are

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Confidential Materials and should be treated as confidential in accordance with the provisions of

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this Order. The Party or Parties that have received the materials must treat the materials as

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confidential from the date such notice is received and the time to object to the confidential

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designation begins on that date. The inadvertent disclosure of any confidential document or

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information shall not be deemed a waiver of confidentiality (for purposes of this order) as to any

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other document in which such information may be contained.

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18.

This protective order shall not apply to any juvenile court documents as defined

by California Welfare and Institutions Code § 827 (including copies) that are maintained by a

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San Francisco, CA 94111

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Child Welfare Department, and any records obtained pursuant to a petition filed under California

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Welfare and Institution Code § 827. Such documents shall be handled pursuant to a separate

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court order.

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19.

The Parties, and any other person subject to the terms of this Order, agree that

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after this Action is terminated, this Court shall have and retain jurisdiction over him, her, or it for

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the purpose of enforcing this Order.

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20.

In the event of any dispute over the terms of this Order, the Parties stipulate and

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agree that no part of this Order shall be construed against either Party on the basis of authorship.

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Dated: August 10, 2011

RODRIGUEZ & ASSOCIATES

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By: /s/ Charles R. Chapman
Daniel Rodriguez
Charles R. Chapman
Attorneys for Plaintiff
AE, a minor, by and through his Guardian ad
Litem, MARIBEL HERNANDEZ,

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Dated: August 10, 2011

County Counsel for the County of Tulare

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By:

/s/ Judy Chapman, Esq.
Judy Chapman, Esq.
Deputy County Counsel
Attorneys for Defendants YADIRA
PORTILLO, COURTNEY WAMPLER, CWA
FELIX, HEIDI WILLIAMS (sued as
TIFFANY BREEN)

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Dated: August 10, 2011

WEST & MIYAMOTO

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By: /s/ Eugene F. West
Eugene F. West
Attorneys for Defendant SANDRA
CEBALLOS

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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Dated: August 10, 2011

BORTON PETRINI, LLP

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By: /s/ James J. Braze
James J. Braze
Gail S. Braze
Attorneys for Defendant FAMILY BUILDERS
FOSTER CARE

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Dated: August 10, 2011

GORDON & REES LLP

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By:
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/s/ George A. Acero
Mark S. Posard
George A. Acero
Attorneys for Defendants TULARE YOUTH
SERVICES BUREAU and
ADRAIN MARQUEZ

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275 Battery Street, Suite 2000
San Francisco, CA 94111

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The parties must comply with Local Rule of Practice for the Eastern District of California
RULE 141 (Fed. R. Civ. P. 5.2, 26) (Fed. R. Crim. P. 49, 49.1) which provides:
SEALING OF DOCUMENTS
(a)
Sealing Documents: General Principles. Documents may be sealed only by
written order of the Court, upon the showing required by applicable law. To ensure that
documents are properly sealed, specific requests to seal must be made even if an existing
protective order, statute, or rule requires or permits the sealing of the document. Notice
that a request to seal has been made will typically be filed in the publicly available case
file. Unless the Court orders otherwise, court orders sealing documents will also be filed
in the publicly available case file and will not reveal the sealed information. Access to all
documents filed under seal will be restricted to the Court and authorized court personnel.
(b)
Requests to Seal. If a party seeks to seal documents, the party shall submit,
in the manner prescribed below, a “Notice of Request to Seal Documents,” a “Request to
Seal Documents,” a proposed order, and all documents covered by the request.
Except in pre-indictment criminal investigations in which sealing is sought,
the “Notice of Request to Seal Documents” shall be filed electronically, or for
nonelectronic filers, shall be submitted on paper to the Clerk for filing by hand delivery,
by same-day or overnight delivery service provided by a courier, or by U.S. Mail, and
shall be served on all parties. The Notice shall describe generally the documents sought
to be sealed, the basis for sealing, the manner in which the “Request to Seal Documents,”
proposed order, and the documents themselves were submitted to the Court, and whether
the Request, proposed order, and documents were served on all other parties.
Except in criminal pre-indictment matters, the “Request to Seal
Documents,” the proposed order, and all documents covered by the Request shall be
either (1) e-mailed to the appropriate Judge or Magistrate Judge’s proposed orders email
box listed on the Court’s website, with the e-mail subject line including the case number
and the statement: “Request to Seal Documents”; or (2) submitted on paper to the Clerk
by hand delivery, by same-day or overnight courier, or by U.S. Mail; the envelope
containing the Request, proposed order an documents shall state in a prominent manner
“Request to Seal Documents.” If the Request, proposed order, and documents are
delivered to the Clerk, the party seeking sealing shall submit a self-addressed, stamped
envelope for return of the documents. In either case, the Request, proposed order, and
submitted documents shall not be filed at this time.

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Except in matters in which it is clearly appropriate not to serve the
“Request to Seal Documents,” proposed order, and/or documents upon the parties, which
would include criminal pre-indictment matters, all Requests, proposed orders, and
submitted documents shall be served on all parties on or before the day they are
submitted to the Court. See L.R. 135.
The “Request to Seal Documents” shall set forth the statutory or other
authority for sealing, the requested duration, the identity, by name or category, of persons
to be permitted access to the documents, and all other relevant information. If the
Request, proposed order, and/or documents covered by the Request were submitted
without service upon one or more other parties, the Request also shall set forth the basis
for excluding any party from service. The documents for which sealing is requested shall
be paginated consecutively so that they may be identified without reference to their
content, and the total number of submitted pages shall be stated in the request.
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(c)
Oppositions to Sealing Requests. Except in criminal pre-indictment
matters, and unless otherwise ordered by the Court, a party may submit an opposition to
the “Request to Seal Documents” within three days of the date of service of the “Notice
of Request to Seal Documents.” The opposition shall be either: (1) e-mailed to the
appropriate Judge or Magistrate Judge’s proposed orders e-mail box listed on the Court’s
website, with the e-mail subject line including the case number and statement:
“Opposition to Request to Seal Documents”; or (2) submitted on paper to the Clerk by
hand delivery, by same-day or overnight courier, in an envelope stating in a prominent
manner “Opposition to Request to Seal Documents.” The Opposition shall be served on
the party or parties requesting sealing and on any other party served with the “Request to
Seal Documents.” The Opposition shall not be filed at this time.

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(d)
Orders on Sealing Requests. Unless the Court orders otherwise, following
review of a “Request to Seal Documents,” the documents sought to be sealed, and any
opposition to the Request, the Court will file in the publicly available case file an order
granting or denying the Request. The order shall identify the documents for which sealing
has been granted or denied by page number without revealing their contents. The Court
may file a more detailed ruling under seal. The publicly filed order or the docket shall
include a notation that a sealed order has been filed.

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(e)

Disposition of Documents.

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Upon issuance of an order on a sealing request and unless the Court has
ordered otherwise, the Clerk will file under seal the request, proposed order, and any
opposition. Disposition of the documents covered by the request to seal depends on
whether the request is denied or granted.
(1) Denial. If a Request is denied in full or in part, the Clerk will return to
the submitting party the documents for which sealing has been denied.

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(2) Grant. If a Request is granted in full or in part, the disposition of
documents to be sealed depends upon whether the requesting party is authorized to file
electronically.

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(i) Electronic Filer. If the requesting party is authorized to file
electronically, then counsel for the requesting party shall either e-mail to the Clerk, at the
e-mail address for sealed documents listed on the Court’s website, an electronic copy of
the documents covered by the sealing order, in .pdf format as an attachment, or submit to
the Clerk by hand-delivery, U.S. mail, or same-day or overnight courier, a CD containing
a copy of the documents in .pdf format. If submitted by e-mail, the subject line of the email shall include the case number and the body of the e-mail shall identify the order
authorizing the sealing of the attached documents. If submitted by hand, U.S. mail, or
courier, the envelope containing the CD shall state in a prominent manner: "Sealed
Documents” and shall identify the order authorizing sealing. The Clerk will file the
documents under seal and will then return to the submitting party any documents
submitted by hand, U.S. mail, or courier and any CD.
(ii) Non-Electronic Filer. If the requesting party is not authorized
to file electronically, the Court will transmit to the Clerk the documents to be sealed
along with the order authorizing sealing. The Clerk will scan the documents to be sealed
and file them under seal. The Clerk will then return the documents to the submitting
party.

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(f)
Unsealing Documents. Upon the motion of any person, or upon the
Court’s own motion, the Court may, upon a finding of good cause or consistent with
applicable law, order documents unsealed. See Fed. R. Civ. P. 5.2, Fed. R. Crim. P. 49.1.

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IT IS SO ORDERED.

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Dated:

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/s/ Dennis

August 12, 2011

L. Beck

UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:

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275 Battery Street, Suite 2000
San Francisco, CA 94111

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