Davis v. Kings County Probation

Filing 21

STIPULATED PROTECTIVE ORDER Regarding Plaintiff's Tax Returns, signed by Magistrate Judge Sandra M. Snyder on 1/10/12. (Hellings, J)

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James J. Arendt, Esq.
Michelle E. Sassano, Esq.

Bar No. 142937
Bar No. 232368

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WEAKLEY & ARENDT, LLP
1630 East Shaw Avenue, Suite 176
Fresno, California 93710
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant, COUNTY OF KINGS

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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DAVID L. DAVIS,

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Plaintiff,
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v.
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KINGS COUNTY PROBATION and DOES )
1 to 50 inclusive,
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Defendants.
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____________________________________ )

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CASE NO. 1:10-CV-01953-AWI-SMS
STIPULATED PROTECTIVE ORDER
REGARDING PLAINTIFF’S TAX
RETURNS

WHEREAS, Defendant has sought discovery of documents supporting Plaintiff’s claims of

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wage loss or earning capacity loss, the parties hereby stipulate to the production of Plaintiff’s

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income tax returns which support such claim.

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IT IS HEREBY STIPULATED, by, among and between the parties hereto through their

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counsel of record that any portions of the documents described above are subject to the following

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Protective Order:

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1.

The disclosed documents shall be used solely in connection with the civil case of

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David L. Davis v. Kings County Probation, filed in the United States District Court, Eastern District

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of California, Case No. 1:10-CV-01953 AWI SMS, in the preparation and trial of this case, or any

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related proceeding, and not for any other purpose or in any other litigation.

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2.

The documents may only be disclosed to the following persons:

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a)

Counsel and the parties to this action;

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b)

Paralegal, clerical, and secretarial personnel regularly employed by counsel

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referred to in subpart (a) directly above, including stenographic deposition reporters retained in

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connection with this action;

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c)

Court personnel including stenographic reporters engaged in proceedings as

are necessarily incidental to the preparation for the trial of the civil action;

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d)

Any expert or consultant retained in connection with this action;

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e)

The finder of fact at the time of trial subject to the court’s rulings on in limine

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motions and objections of counsel.

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3.

This Protective Order is without prejudice to the right of any party to oppose

production or inadmissibility of documents or information for any legal reason.

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4.

Each person to whom disclosure is made with the exception of counsel, who are

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presumed to know the contents of this Protective Order shall, prior to the time of disclosure, be

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provided by the person furnishing him or her such material, a copy of the Protective Order. Such

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person must consent to be subject to the jurisdiction of the United States District Court, Eastern

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District of California, with respect to any proceeding related to enforcement of this Protective

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Order, including without limitation, any proceeding for contempt. Provisions of this Protective

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Order, insofar as they restrict disclosure and use of the material, shall be in effect until further order

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of this Court.

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5.

After the conclusion of this litigation, all documents, in whatever form stored or

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reproduced, containing information received pursuant to the provisions of this Protective Order will

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remain confidential. The conclusion of this litigation means a termination of the case following

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applicable post-trial motions, appeal and/or retrial. After the conclusion of this litigation, all

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confidential documents received under the provisions of this Protective Order, including copies

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made, shall be destroyed, or tendered back to the attorneys for plaintiff David L. Davis.

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Respectfully submitted,

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DATED: January 4, 2012

WEAKLEY & ARENDT, LLP

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By:

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/s/ James J. Arendt
James J. Arendt
Michelle E. Sassano
Attorneys for DEFENDANT COUNTY OF KINGS

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DATED: January 4, 2012

GUBLER, KOCH, DEGN & GOMEZ, LLP

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By:

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/s/ Thomas W. Degn
Thomas W. Degn
Attorneys for PLAINTIFF DAVID L. DAVIS

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IT IS SO ORDERED.

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Dated:
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January 10, 2012

/s/ Sandra M. Snyder
UNITED STATES MAGISTRATE JUDGE

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