Phillips, et al. v. County of Fresno, et al.

Filing 66

STIPULATION FOR PROTECTIVE ORDER and ORDER THEREON signed by Magistrate Judge Barbara A. McAuliffe on 12/9/2014. (Rooney, M)

Download PDF
1 2 3 4 5 James D. Weakley, Esq. James J. Arendt, Esq. Bar No. 082853 Bar No. 142937 WEAKLEY & ARENDT, LLP 1630 EAST SHAW AVE., SUITE 176 FRESNO, CALIFORNIA 93710 TELEPHONE: (559) 221-5256 FACSIMILE: (559) 221-5262 6 7 8 Attorneys for Defendant, COUNTY OF FRESNO, MARGARET MIMS, TOM GATTIE, RICK HILL, LUE HER, KONG YANG, BRANDON CASTRO, EDWARD MORENO, GEORGE LAIRD AND PRATAP NARAYAN 9 10 11 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ) ) ) ) ) Plaintiffs, ) ) vs. ) COUNTY OF FRESNO; MARGARET MIMS; ) CORRECTIONAL OFFICER L. HERR #9899, ) ) CORRECTIONAL OFFICER CASTRO; ) JOHN DOE AND RICHARD ROE, ) individually and in their official capacities as ) correctional and classification officers of the ) Fresno County Sheriff’s Department; ) EDWARD MORENO, M.D.; GEORGE LAIRD; PRATAP NARAYAN; NANCY POE ) ) and CARL COE, individually and in their official capacities as health care workers in the ) ) Fresno County jail system, and DOES 1-50, ) ) Defendants. ) RICHARD PHILLIPS, in his capacity as the administrator of the ESTATE OF TROY PHILLIPS; TIFFANY PHILLIPS, CASE NO. 1:13-cv-00538 AWI BAM STIPULATION FOR PROTECTIVE ORDER AND ORDER THEREON Complaint Filed: 04/15/13 STIPULATED PROTECTIVE ORDER1 1 2 1. PURPOSES AND LIMITATIONS 3 Disclosure and discovery activity in this action are likely to involve 4 production of confidential, proprietary, or private information for which special 5 protection from public disclosure and from use for any purpose other than 6 prosecuting this litigation may be warranted. Accordingly, the parties hereby 7 stipulate to and petition the court to enter the following Stipulated Protective Order. 8 The parties acknowledge that this Order does not confer blanket protections on all 9 disclosures or responses to discovery and that the protection it affords from public 10 disclosure and use extends only to the limited information or items that are entitled 11 to confidential treatment under the applicable legal principles. The parties further 12 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective 13 Order does not entitle them to file confidential information under seal. Local Rule 14 141 sets forth the procedures that must be followed and the standards that will be 15 applied when a party seeks permission from the court to file material under seal. 16 2. 17 18 DEFINITIONS 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 19 2.2 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for protection 21 under Federal Rule of Civil Procedure 26(c). 22 2.3 Counsel (without qualifier): 23 Counsel (as well as their support staff). 24 /// 25 Outside Counsel of Record and House /// 26 27 28 1 This document is based on the model protective order for standard litigation promulgated by the Northern District of California. It has been modified only to omit or replace references to that district and its local rules. 2 1 2 3 4 2.4 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as: CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER Richard Phillips v. County of Fresno 5 6 2.5 Disclosure or Discovery Material: all items or information, regardless of 7 the medium or manner in which it is generated, stored, or maintained (including, 8 among other things, testimony, transcripts, and tangible things), that are produced or 9 generated in disclosures or responses to discovery in this matter. 10 2.6 Expert: a person with specialized knowledge or experience in a matter 11 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 12 expert witness or as a consultant in this action. 13 2.7 House Counsel: attorneys who are employees of a party to this action. 14 House Counsel does not include Outside Counsel of Record or any other outside 15 counsel. 16 17 18 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.9 Outside Counsel of Record: attorneys who are not employees of a party 19 to this action but are retained to represent or advise a party to this action and have 20 appeared in this action on behalf of that party or are affiliated with a law firm which 21 has appeared on behalf of that party. 22 2.10 Party: any party to this action, including all of its officers, directors, 23 employees, consultants, retained experts, and Outside Counsel of Record (and their 24 support staffs). 25 26 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 27 2.12 Professional Vendors: persons or entities that provide litigation support 28 services (e.g., photocopying, videotaping, translating, preparing exhibits or 3 1 demonstrations, and organizing, storing, or retrieving data in any form or medium) 2 and their employees and subcontractors. 3 2.13 Protected Material: 4 designated as “Confidential Material.” any Disclosure or Discovery Material that is 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material 5 6 from a Producing Party. 7 3. SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 Protected Material (as defined above), but also (1) any information copied or extracted 10 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 11 Protected Material; and (3) any testimony, conversations, or presentations by Parties 12 or their Counsel that might reveal Protected Material. However, the protections 13 conferred by this Stipulation and Order do not cover the following information: (a) 14 any information that is in the public domain at the time of disclosure to a Receiving 15 Party or becomes part of the public domain after its disclosure to a Receiving Party as 16 a result of publication not involving a violation of this Order, including becoming part 17 of the public record through trial or otherwise; and (b) any information known to the 18 Receiving Party prior to the disclosure or obtained by the Receiving Party after the 19 disclosure from a source who obtained the information lawfully and under no 20 obligation of confidentiality to the Designating Party. Any use of Protected Material at 21 trial shall be governed by a separate agreement or order. 22 4. DURATION 23 Even after final disposition of this litigation, the confidentiality obligations 24 imposed by this Order shall remain in effect until a Designating Party agrees 25 otherwise in writing or a court order otherwise directs. Final disposition shall be 26 deemed to be the later of (1) dismissal of all claims and defenses in this action, with or 27 without prejudice; and (2) final judgment herein after the completion and exhaustion 28 of all appeals, rehearings, remands, trials, or reviews of this action, including the time 4 1 limits for filing any motions or applications for extension of time pursuant to 2 applicable law. 3 5. 4 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 5 Each Party or Non-Party that designates information or items for protection under this 6 Order must take care to limit any such designation to specific material that qualifies 7 under the appropriate standards. The Designating Party must designate for protection 8 only those parts of material, documents, items, or oral or written communications that 9 qualify – so that other portions of the material, documents, items, or communications 10 for which protection is not warranted are not swept unjustifiably within the ambit of 11 this Order. 12 Mass, indiscriminate, or routinized designations are prohibited. Designations 13 that are shown to be clearly unjustified or that have been made for an improper 14 purpose (e.g., to unnecessarily encumber or retard the case development process or to 15 impose unnecessary expenses and burdens on other parties) expose the Designating 16 Party to sanctions. 17 If it comes to a Designating Party’s attention that information or items that it 18 designated for protection do not qualify for protection, that Designating Party must 19 promptly notify all other Parties that it is withdrawing the mistaken designation. 20 5.2 Manner and Timing of Designations. Except as otherwise provided in 21 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 22 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 23 under this Order must be clearly so designated before the material is disclosed or 24 produced. 25 26 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 27 documents, but excluding transcripts of depositions or other pretrial or trial 28 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” pursuant 5 1 to section 2.4 above, to each page that contains protected material. If only a portion or 2 portions of the material on a page qualifies for protection, the Producing Party also 3 must clearly identify the protected portion(s) (e.g., by making appropriate markings in 4 the margins). 5 A Party or Non-Party that makes original documents or materials available for 6 inspection need not designate them for protection until after the inspecting Party has 7 indicated which material it would like copied and produced. During the inspection and 8 before the designation, all of the material made available for inspection shall be 9 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 10 it wants copied and produced, the Producing Party must determine which documents, 11 or portions thereof, qualify for protection under this Order. Then, before producing the 12 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend 13 to each page that contains Protected Material. If only a portion or portions of the 14 material on a page qualifies for protection, the Producing Party also must clearly 15 identify the protected portion(s) (e.g., by making appropriate markings in the 16 margins). 17 (b) for testimony given in deposition or in other pretrial or trial proceedings, 18 that the Designating Party identify on the record, before the close of the deposition, 19 hearing, or other proceeding, all protected testimony. 20 (c) for information produced in some form other than documentary and for 21 any other tangible items, that the Producing Party affix in a prominent place on the 22 exterior of the container or containers in which the information or item is stored the 23 legend “CONFIDENTIAL.” If only a portion or portions of the information or item 24 warrant protection, the Producing Party, to the extent practicable, shall identify the 25 protected portion(s). 26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 27 failure to designate qualified information or items does not, standing alone, waive the 28 Designating Party’s right to secure protection under this Order for such material. 6 1 Upon timely correction of a designation, the Receiving Party must make reasonable 2 efforts to assure that the material is treated in accordance with the provisions of this 3 Order. 4 6. 5 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 6 designation of confidentiality at any time. Unless a prompt challenge to a Designating 7 Party’s confidentiality designation is necessary to avoid foreseeable, substantial 8 unfairness, unnecessary economic burdens, or a significant disruption or delay of the 9 litigation, a Party does not waive its right to challenge a confidentiality designation by 10 electing not to mount a challenge promptly after the original designation is disclosed. 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 12 process by providing written notice of each designation it is challenging and 13 describing the basis for each challenge. To avoid ambiguity as to whether a challenge 14 has been made, the written notice must recite that the challenge to confidentiality is 15 being made in accordance with this specific paragraph of the Protective Order. The 16 parties shall attempt to resolve each challenge in good faith and must begin the 17 process by conferring directly (in voice to voice dialogue; other forms of 18 communication are not sufficient) within 14 days of the date of service of notice. In 19 conferring, the Challenging Party must explain the basis for its belief that the 20 confidentiality designation was not proper and must give the Designating Party an 21 opportunity to review the designated material, to reconsider the circumstances, and, if 22 no change in designation is offered, to explain the basis for the chosen designation. A 23 Challenging Party may proceed to the next stage of the challenge process only if it has 24 engaged in this meet and confer process first or establishes that the Designating Party 25 is unwilling to participate in the meet and confer process in a timely manner. 26 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 27 intervention, the Designating Party shall file and serve a motion to retain 28 confidentiality within 21 days of the initial notice of challenge or within 14 days of 7 1 the parties agreeing that the meet and confer process will not resolve their dispute, 2 whichever is earlier. Each such motion must be accompanied by a competent 3 declaration affirming that the movant has complied with the meet and confer 4 requirements imposed in the preceding paragraph. Failure by the Designating Party to 5 make such a motion including the required declaration within 21 days (or 14 days, if 6 applicable) shall automatically waive the confidentiality designation for each 7 challenged designation. In addition, the Challenging Party may file a motion 8 challenging a confidentiality designation at any time if there is good cause for doing 9 so, including a challenge to the designation of a deposition transcript or any portions 10 thereof. Any motion brought pursuant to this provision must be accompanied by a 11 competent declaration affirming that the movant has complied with the meet and 12 confer requirements imposed by the preceding paragraph. 13 The burden of persuasion in any such challenge proceeding shall be on the 14 Designating Party. Frivolous challenges, and those made for an improper purpose 15 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 16 expose the Challenging Party to sanctions. Unless the Designating Party has waived 17 the confidentiality designation by failing to file a motion to retain confidentiality as 18 described above, all parties shall continue to afford the material in question the level 19 of protection to which it is entitled under the Producing Party’s designation until the 20 court rules on the challenge. 21 7. 22 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a Non-Party in connection with this case 24 only for prosecuting, defending, or attempting to settle this litigation. Such Protected 25 Material may be disclosed only to the categories of persons and under the conditions 26 described in this Order. When the litigation has been terminated, a Receiving Party 27 must comply with the provisions of section 13 below (FINAL DISPOSITION). 28 Protected Material must be stored and maintained by a Receiving Party at a 8 1 location and in a secure manner that ensures that access is limited to the persons 2 authorized under this Order. 3 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 4 otherwise ordered by the court or permitted in writing by the Designating Party, a 5 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 6 only to: 7 (a) the Receiving Party’s Outside Counsel of Record in this action, as well 8 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 9 disclose the information for this litigation and who have signed the “Acknowledgment 10 and Agreement to Be Bound” that is attached hereto as Exhibit A; 11 (b) the officers, directors, and employees (including House Counsel) of the 12 Receiving Party to whom disclosure is reasonably necessary for this litigation and 13 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (c) Experts (as defined in this Order) of the Receiving Party to whom 15 disclosure is reasonably necessary for this litigation and who have signed the 16 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (d) the court and its personnel; 18 (e) court reporters and their staff, professional jury or trial consultants, 19 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary 20 for this litigation and who have signed the “Acknowledgment and Agreement to Be 21 Bound” (Exhibit A); 22 (f) during their depositions, witnesses in the action to whom disclosure is 23 reasonably necessary and who have signed the “Acknowledgment and Agreement to 24 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered 25 by the court. Pages of transcribed deposition testimony or exhibits to depositions that 26 reveal Protected Material must be separately bound by the court reporter and may not 27 be disclosed to anyone except as permitted under this Stipulated Protective Order. 28 (g) the author or recipient of a document containing the information or a 9 1 custodian or other person who otherwise possessed or knew the information. 2 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 3 OTHER LITIGATION 4 If a Party is served with a subpoena or a court order issued in other litigation 5 that compels disclosure of any information or items designated in this action as 6 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification shall 7 8 include a copy of the subpoena or court order; 9 (b) promptly notify in writing the party who caused the subpoena or order to 10 issue in the other litigation that some or all of the material covered by the subpoena or 11 order is subject to this Protective Order. Such notification shall include a copy of this 12 Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued 13 14 by the Designating Party whose Protected Material may be affected. 15 If the Designating Party timely seeks a protective order, the Party served with 16 the subpoena or court order shall not produce any information designated in this 17 action as “CONFIDENTIAL” before a determination by the court from which the 18 subpoena or order issued, unless the Party has obtained the Designating Party’s 19 permission. The Designating Party shall bear the burden and expense of seeking 20 protection in that court of its confidential material – and nothing in these provisions 21 should be construed as authorizing or encouraging a Receiving Party in this action to 22 disobey a lawful directive from another court. 23 9. 24 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this action and designated as “CONFIDENTIAL.” Such information 27 produced by Non-Parties in connection with this litigation is protected by the 28 remedies and relief provided by this Order. Nothing in these provisions should be 10 1 construed as prohibiting a Non-Party from seeking additional protections. 2 (b) In the event that a Party is required, by a valid discovery request, to 3 produce a Non-Party’s confidential information in its possession, and the Party is 4 subject to an agreement with the Non-Party not to produce the Non-Party’s 5 confidential information, then the Party shall: 6 (1) promptly notify in writing the Requesting Party and the Non-Party 7 that some or all of the information requested is subject to a confidentiality agreement 8 with a Non-Party; (2) 9 promptly provide the Non-Party with a copy of the Stipulated 10 Protective Order in this litigation, the relevant discovery request(s), and a reasonably 11 specific description of the information requested; and (3) make the information requested available for inspection by the Non- 12 13 Party. 14 (c) If the Non-Party fails to object or seek a protective order from this court 15 within 14 days of receiving the notice and accompanying information, the Receiving 16 Party may produce the Non-Party’s confidential information responsive to the 17 discovery request. If the Non-Party timely seeks a protective order, the Receiving 18 Party shall not produce any information in its possession or control that is subject to 19 the confidentiality agreement with the Non-Party before a determination by the court. 20 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 21 of seeking protection in this court of its Protected Material. 22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 Protected Material to any person or in any circumstance not authorized under this 25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 26 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 27 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 28 persons to whom unauthorized disclosures were made of all the terms of this Order, 11 1 and (d) request such person or persons to execute the “Acknowledgment and 2 Agreement to Be Bound” that is attached hereto as Exhibit A. 3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other protection, 7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 9 may be established in an e-discovery order that provides for production without prior 10 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 11 parties reach an agreement on the effect of disclosure of a communication or 12 information covered by the attorney-client privilege or work product protection, the 13 parties may incorporate their agreement in the stipulated protective order submitted to 14 the court. 15 12. 16 17 MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Protective Order no Party waives any right it otherwise would have to object to 20 disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use in evidence of any of the material covered by this Protective Order. 23 12.3 Filing Protected Material. Without written permission from the 24 Designating Party or a court order secured after appropriate notice to all interested 25 persons, a Party may not file in the public record in this action any Protected Material. 26 A Party that seeks to file under seal any Protected Material must comply with Local 27 Rule 141. Protected Material may only be filed under seal pursuant to a court order 28 authorizing the sealing of the specific Protected Material at issue. A sealing order will 12 1 issue only upon a request establishing that the Protected Material at issue is 2 privileged, protectable as a trade secret, or otherwise entitled to protection under the 3 law. If a Receiving Party's request to file Protected Material under seal is denied by 4 the court, then the Receiving Party may file the information in the public record unless 5 otherwise instructed by the court. 6 13. FINAL DISPOSITION 7 Within 60 days after the final disposition of this action, as defined in paragraph 8 4, each Receiving Party must return all Protected Material to the Producing Party or 9 destroy such material. As used in this subdivision, “all Protected Material” includes 10 all copies, abstracts, compilations, summaries, and any other format reproducing or 11 capturing any of the Protected Material. Whether the Protected Material is returned or 12 destroyed, the Receiving Party must submit a written certification to the Producing 13 Party (and, if not the same person or entity, to the Designating Party) by the 60 day 14 deadline that (1) identifies (by category, where appropriate) all the Protected Material 15 that was returned or destroyed and (2) affirms that the Receiving Party has not 16 retained any copies, abstracts, compilations, summaries or any other format 17 reproducing or capturing any of the Protected Material. Notwithstanding this 18 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 19 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 20 deposition and trial exhibits, expert reports, attorney work product, and consultant and 21 expert work product, even if such materials contain Protected Material. Any such 22 archival copies that contain or constitute Protected Material remain subject to this 23 Protective Order as set forth in Section 4 (DURATION). 24 25 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 26 DATED: December 9, 2014 27 28 LAW OFFICES OF ANTHONY BOSKOVICH By: /s/ Anthony Boskovich ___ Anthony Boskovich, Attorneys for Plaintiff 13 1 2 DATED: December 9, 2014 GRENIER LAW GROUP PLLC By: 3 4 5 DATED: December 9, 2014 6 WEAKLEY & ARENDT, LLP By: 7 8 /s/ Stan M. Doerrer_____ Peter C. Grenier Stan M. Doerrer Attorneys for Plaintiffs /s/ James D. Weakley James D. Weakley James J. Arendt Attorneys for Defendants 9 ORDER 10 The Court has reviewed the stipulation outlined above (Doc. 65) and adopts the 11 stipulation. However, the terms related to judicial intervention outlined in paragraph 12 6.3 will not be automatic, rather, the Court will determine on a case-by-case basis 13 whether judicial intervention is warranted. Relatedly, the parties are strongly 14 encouraged to resolve any disputes arising from this agreement independently and 15 without court involvement. 16 17 18 19 20 21 22 23 24 25 26 27 Dated : December 9, 2014 /s/Barbara A. McAuliffe United States Magistrate Judge /// /// /// /// /// /// /// /// /// /// 28 14 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury that 5 I have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Eastern District of California on 7 [date] in the case of Richard Phillips, et. al. v. County of Fresno, et. al., United States 8 District Court Case No.: 1:13-cv-00538-AWI-BAM. I agree to comply with and to be 9 bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the 15 Eastern District of California for the purpose of enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of this 17 action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 Printed name: _______________________________ 26 Signature: __________________________________ 27 28 15

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?