Knowles v. United Debt Holdings, LLC et al
Filing
18
Stipulated PROTECTIVE ORDER signed by Magistrate Judge Gary S. Austin on 3/31/2015. (Martinez, A)
1 JEFFREY A. TOPOR (SBN 195545)
jtopor@snllp.com
2 LIANA MAYILYAN (SBN 295203)
lmayilyan@snllp.com
3 SIMMONDS & NARITA LLP
44 Montgomery Street, Suite 3010
4 San Francisco, CA 94104-4816
Telephone: (415) 283-1000
5 Facsimile: (415) 352-2625
6 Attorneys for Defendant
United Debt Holdings, LLC
7
8
9
THE UNITED STATES DISTRICT COURT
10
EASTERN DISTRICT OF CALIFORNIA
11
12
13
14
15
16
17
18
19
20
21
) CASE NO. 1:14-cv-01815-AWI-GSA
)
) STIPULATED
) PROTECTIVE ORDER
)
Plaintiff,
)
)
v.
)
)
UNITED DEBT HOLDINGS, LLC,
a Delaware Limited Liability
)
Company, NATIONWIDE
)
SERVICES, a New York Corporation, )
HARTFORD MEDIATION GROUP, )
a New Partnership, and PAYMENT
)
MANAGEMENT SOLUTIONS,
)
INC., a New York Corporation, and
)
DOES 1 through 500, inclusive,
)
)
Defendants.
)
)
MANDY KNOWLES, as an
individual, and on behalf of other
persons similarly situated,
22
23
24
25
26
27
28
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
1
1.
Disclosure and discovery activity in this action are likely to involve production
2
3
4
PURPOSES AND LIMITATIONS
of confidential, proprietary, or private information for which special protection from
public disclosure and from use for any other purpose other than prosecuting this
5
litigation may be warranted. Accordingly, the parties hereby stipulate to and petition
6
the court to enter the following Stipulated Protective Order. The parties acknowledge
7
that this Order does not confer blanket protections on all disclosures or responses to
8
discovery and that the protection it affords from public disclosure and use extends
9
only to the limited information or items that are entitled to confidential treatment
10 under the applicable legal principles. The parties further acknowledge, as set forth in
11 Section 12.3, below, that this Stipulated Protective Order does not entitle them to file
12 confidential information under seal; Civil Local Rule 141 sets forth the procedures
13 that must be followed and the standards that will be applied when a party seeks
14 permission from the court to file material under seal.
No document shall be filed under seal unless counsel secures a court order
15
16 allowing the filing of a document under seal. An application to file a document under
17 seal shall be served on opposing counsel, and on the person or entity that has custody
18 and control of the document, if different from opposing counsel. If opposing counsel,
19 or the person or entity who has custody and control of the document, wishes to
20 oppose the application, he/she must contact the chambers of the judge who will rule
21 on the application, to notify the judge’s staff that an opposition to the application will
22 be filed.
23 2.
DEFINITIONS
24
2.1
Challenging Party: a Party or Non-Party that challenges the designation
25 of information or items under this Order.
26
2.2
“CONFIDENTIAL” Information or Items: information (regardless of
27 how it is generated, stored or maintained) or tangible things that qualify for protection
28 under Federal Rule of Civil Procedure 26(c).
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
1
1
2
3
2.3
Counsel (without qualifier): Outside Counsel of Record and House
Counsel (as well as their support staff).
2.4
Designating Party: a Party or Non-Party that designates information or
4
items that it produces in disclosures or in responses to discovery as
5
“CONFIDENTIAL.”
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
12 an 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
2.8
Non-Party: any natural person, partnership, corporation, association, or
17 other legal entity not named as a Party to this action.
18
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
2.11 Producing Party: a Party or Non-Party that produces Disclosure or
26 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
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
2
1
demonstrations, and organizing, storing, or retrieving data in any form or medium)
2
and their employees and subcontractors.
2.13 Protected Material: any Disclosure or Discovery Material that is
3
4
designated as “CONFIDENTIAL.”
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
10 extracted from Protected Material; (2) all copies, excerpts, summaries, or
11 compilations of Protected Material; and (3) any testimony, conversations, or
12 presentations by Parties or their Counsel that might reveal Protected Material.
13 However, the protections conferred by this Stipulation and Order do not cover the
14 following information: (a) any information that is in the public domain at the time of
15 disclosure to a Receiving Party or becomes part of the public domain after its
16 disclosure to a Receiving Party as a result of publication not involving a violation of
17 this Order, including becoming part of the public record through trial or otherwise;
18 and (b) any information known to the Receiving Party prior to the disclosure or
19 obtained by the Receiving Parry after the disclosure from a source who obtained the
20 information lawfully and under no obligation of confidentiality to the Designating
21 Party. Any use of Protected Material at trial shall be governed by a separate
22 agreement or order.
23 4.
DURATION
24
Even after final disposition of this litigation, the confidentiality obligations
25 imposed by this Order shall remain in effect until a Designating Party agrees
26 otherwise in writing or a court order otherwise directs. Final disposition shall be
27 deemed to be the later of (1) dismissal of all claims and defenses in this action, with
28 or without prejudice; and (2) final judgment herein after the completion and
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
3
1
2
exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
including the time limits for filing any motions or applications for extension of time
3
pursuant to applicable law.
4
5.
5
6
7
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection:
Each Party or Non-Party that designates information or items for protection under this
Order must take care to limit any such designation to specific material that qualifies
8
under the appropriate standards. The Designating Party must designate for protection
9
only those parts of material, documents, items, or oral or written communications that
10 qualify - so that other portions of the material, documents, items, or communications
11 for which protection is not warranted are not swept unjustifiably within the ambit of
12 this Order.
13
Mass, indiscriminate, or routinized designations are prohibited. Designations
14 that are shown to be clearly unjustified or that have been made for an improper
15 purpose (e.g. to unnecessarily encumber or retard the case development process, or to
16 impose unnecessary expenses and burdens on other parties), expose the Designating
17 Party to sanctions.
18
If it comes to a Party’s or a non-party’s attention that information or items that
19 it designated for protection do not qualify for protection, that Designating Party must
20 promptly notify all other Parties that it is withdrawing the mistaken designation.
21
5.2
Manner and Timing of Designations: Except as otherwise provided in
22 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
23 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
24 under this Order must be clearly so designated before the material is disclosed or
25 produced.
26
27
Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic
28 documents, but excluding transcripts of depositions or other pretrial or trial
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
4
1
proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each
2
page that contains protected material. If only a portion or portions of the material on
3
a page qualifies for protection, the Producing Party also must clearly identify the
4
protected portion(s) (e.g., by making appropriate markings in 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
8
and before the designation, all of the material made available for inspection shall be
9
deemed “CONFIDENTIAL.” After the inspecting Party has identified the document
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
12 the specified documents, the Producing Party must affix the “CONFIDENTIAL”
13 legend to each page that contains Protected Material. If only a portion or portions of
14 the 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).
(b) for testimony given in deposition or in other pretrial or trial
17
18 proceedings, that the Designating Party identify on the record, before the close of the
19 deposition, hearing, or other proceeding, all protected testimony.
(c) for information produced in some form other than documentary and
20
21 for any other tangible items, that the Producing Party affix in a prominent place on
22 the exterior of the container or containers in which the information or item is stored
23 the legend “CONFIDENTIAL.” If only a portion or portions of the information or
24 item warrant protection, the Producing Party, to the extent practicable, shall identify
25 the 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
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
5
1
Designating Party’s right to secure protection under this Order for such material.
2
Upon timely correction of a designation, the Receiving Party must make
3
reasonable efforts to assure that the material is treated in accordance with the
4
provisions of this Order.
5
6.
6
7
8
9
CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges: Any Party or Non-Party may challenge a
designation of confidentiality at any time. Unless a prompt challenge to a
Designating Party’s confidentiality designation is necessary to avoid foreseeable,
substantial unfairness, unnecessary economic burdens, or a significant disruption or
10 delay of the litigation, a Party does not waive its right to challenge a confidentiality
11 designation by electing not to mount a challenge promptly after the original
12 designation is disclosed.
13
6.2
Meet and Confer: The Challenging Party shall initiate the dispute
14 resolution process by providing written notice of each designation it is challenging
15 and describing the basis for each challenge. To avoid ambiguity as to whether a
16 challenge has been made, the written notice must recite that the challenge to
17 confidentiality is being made in accordance with this specific paragraph of the
18 Protective Order. The parties shall attempt to resolve each challenge in good faith
19 and must begin the process by conferring directly (in voice to voice dialogue; other
20 forms of communication are not sufficient) within 14 days of the date of service of
21 notice. In conferring, the Challenging Party must explain the basis for its belief that
22 the confidentiality designation was not proper and must give the Designating Party an
23 opportunity to review the designated material, to reconsider the circumstances, and, if
24 no change in designation is offered, to explain the basis for the chosen designation.
25 A Challenging Party may proceed to the next stage of the challenge process only if it
26 has engaged in this meet and confer process first or establishes that the Designating
27 Party is unwilling to participate in the meet and confer process in a timely manner.
28
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
6
6.3
1
Judicial Intervention: If the Parties cannot resolve a challenge without
2
court intervention, the Designating Party shall file and serve a motion to retain
3
confidentiality (and in compliance with Civil Local Rule 141, if applicable) within 21
4
days of the initial notice of challenge or within 14 days of the parties agreeing that the
5
meet and confer process will not resolve their dispute, whichever is earlier. Each
6
such motion must be accompanied by a competent declaration affirming that the
7
movant has complied with the meet and confer requirements imposed in the
8
preceding paragraph. Failure by the Designating Party to make such a motion
9
including the required declaration within 21 days (or 14 days, if applicable) shall
10 automatically waive the confidentiality designation for each challenged designation.
11 In addition, the Challenging Party may file a motion challenging a confidentiality
12 designation at any time if there is good cause for doing so, including a challenge to
13 the designation of a deposition transcript or any portions thereof. Any motion
14 brought pursuant to this provision must be accompanied by a competent declaration
15 affirming that the movant has complied with the meet and confer requirements
16 imposed by the preceding paragraph.
The burden of persuasion in any challenge proceeding shall be on the
17
18 Designating Party. Frivolous challenges, and those made for an improper purpose
19 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
20 expose the Challenging Party to sanctions. Unless the Designating Party has waived
21 the confidentiality designation by failing to file a motion to retain confidentiality as
22 described above, all parties shall continue to afford the material in question the level
23 of protection to which it is entitled under the Producing Party’s designation until the
24 court rules on the challenge.
25 7.
ACCESS TO AND USE OF PROTECTED MATERIAL
26
7.1
Basic Principles: A Receiving Party may use Protected Material that is
27 disclosed or produced by another Party or by a Non-party in connection with this case
28 only for prosecuting, defending, or attempting to settle this litigation. Such Protected
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
7
1
2
3
4
Material may be disclosed only to the categories of persons and under the conditions
described in this Order. When the litigation has been terminated, a Receiving Party
must comply with the provisions of section 13 below (FINAL DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a
5
location and in a secure manner that ensures that access is limited to the persons
6
authorized under this Order.
7
8
9
7.2
Disclosure of “CONFIDENTIAL” Information or Items: Unless
otherwise ordered by the court or permitted in writing by the Designating Party, a
Receiving Party may disclose any information or item designated
10 “CONFIDENTIAL” only to:
11
(a) the Receiving Party’s Outside Counsel of record in this action, as
12 well as employees of said Outside Counsel to whom it is reasonably necessary to
13 disclose the information for this litigation and who have signed the
14 “Acknowledgment and Agreement to be Bound” that is attached hereto as Exhibit A;
15
(b) the officers, directors, and employees (including House Counsel) of
16 the Receiving Party to whom disclosure is reasonably necessary for this litigation and
17 who signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
18
(c) Experts (as defined in this Order) of the Receiving Party to whom
19 disclosure is reasonably necessary for this litigation and who have signed the
20 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
21
(d) the court and its personnel;
22
(e) court reporters and their staff, professional jury or trial consultants,
23 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary
24 for this litigation and who have signed the “Acknowledgment and Agreement to Be
25 Bound” (Exhibit A);
26
(f) during their depositions, witnesses in the action to whom disclosure is
27 reasonably necessary and who have signed the “Acknowledgment and Agreement to
28 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
8
1
by the court. Pages of transcribed deposition testimony or exhibits to depositions that
2
reveal Protected Material must be separately bound by the court reporter and may not
3
be disclosed to anyone except as permitted under this Stipulated Protective Order.
(g) the author of the document containing the information or a custodian
4
5
or other person who otherwise possessed or knew the information.
6
8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
7
OTHER LITIGATION
8
If a Party is served with a subpoena or an order issued in other litigation that
9
compels disclosure of any information or items designated in this action as
10 “CONFIDENTIAL,” that Party must:
11
(a) promptly notify in writing the Designating Party. Such notification
12 shall include a copy of the subpoena or court order.
13
(b) promptly notify in writing the party who caused the subpoena or
14 order to issue in the other litigation that some or all of the material covered by the
15 subpoena or order is subject to this Protective Order. Such notification shall include
16 a copy of this Stipulated Protective Order; and
17
(c) cooperate with respect to all reasonable procedures sought to be
18 pursued by the Designating Party whose Protected Material may be affected.
19
If the Designating Party timely seeks a protective order, the Party served with
20 the subpoena or court order shall not produce any information designated in this
21 action as “CONFIDENTIAL” before a determination by the court from which the
22 subpoena or order issued, unless the Party has obtained the Designating Party’s
23 permission. The Designating Party shall bear the burden and expense of seeking
24 protection in that court of its confidential material - and nothing in these provisions
25 should be construed as authorizing or encouraging a Receiving Party in this action to
26 disobey a lawful directive from another court.
27
28
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
9
1
9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2
PRODUCED IN THIS LITIGATION
3
(a)
4
5
6
7
Non-Party in this action and designated as “CONFIDENTIAL.” Such information
produced by Non-Parties in connection with this litigation is protected by the
remedies and relief provided by this Order. Nothing in these provisions should be
construed as prohibiting a Non-Party from seeking additional protections.
(b)
8
9
The terms of this Order are applicable to information produced by a
In the event that a Party is required, by a valid discovery request, to
produce a Non-Party’s confidential information in its possession, and the Party is
10 subject to an agreement with the Non-Party not to produce the Non-Party’s
11 confidential information, then the Party shall:
(1) promptly notify in writing the Requesting Party and the Non-Party
12
13 that some or all of the information requested is subject to a confidentiality agreement
14 with a Non-Party;
(2) promptly provide the Non-Party with a copy of the Stipulated
15
16 Protective Order in this litigation, the relevant discovery request(s), and a reasonably
17 specific description of the information requested; and
(3) make the information requested available for inspection by the Non-
18
19 Party.
20
(c)
If the Non-Party fails to object or seek a protective order from this court
21 within 14 days of receiving the notice and accompanying information, the Receiving
22 Party may produce the Non-Party’s confidential information responsive to the
23 discovery request. If the Non-Party timely seeks a protective order, the Receiving
24 Party shall not produce any information in its possession or control that is subject to
25 the confidentiality agreement with the Non-Party before a determination by the
26
27
28
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
10
1
court.1 Absent a court order to the contrary, the Non-Party shall bear the burden and
2
expense of seeking protection in this court of its Protected Material.
3
10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
4
5
Protected Material to any person or in any circumstance not authorized under this
6
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
7
writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
8
to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
9
persons to whom unauthorized disclosures were made of all the terms of this Order,
10 and (d) request such person or persons to execute the “Acknowledgment and
11 Agreement to Be Bound” that is attached hereto as Exhibit A.
12 11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
13
PROTECTED MATERIAL
14
When a Producing Party gives notice to Receiving Parties that certain
15 inadvertently produced material is subject to a claim of privilege or other protection,
16 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
17 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
18 may be established in an e-discovery order that provides for production without prior
19 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
20 parties reach an agreement on the effect of disclosure of a communication or
21 information covered by the attorney-client privilege or work product protection, the
22 parties may incorporate their agreement in the stipulated protective order submitted to
23 the court.
24 //
25 //
26
27
1
The purpose of this provision is to alert the interested parties to the existence of
28 confidentiality rights of a Non-Party and to afford the Non-Party an opportunity to
protect its confidentiality interests in this court.
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
11
1
12.
12.1 Right to Further Relief: Nothing in this Order abridges the right of any
2
3
person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections: By stipulating to the entry of this
4
5
MISCELLANEOUS
Protective Order no Party waives any right it otherwise would have to object to
6
disclosing or producing any information or item on any ground not addressed in this
7
Stipulated Protective Order. Similarly, no Party waives any right to object on any
8
ground to use in evidence of any of the material covered by this Protective Order.
12.3 Filing Protected Material: Without written permission from the
9
10 Designating Party or a court order secured after appropriate notice to all interested
11 persons, a Party may not file in the public record in this action any Protected
12 Material. A Party that seeks to file under seal any Protected Material must comply
13 with Civil Local Rule 141. Protected Material may only be filed under seal pursuant
14 to a court order authorizing the sealing of the specific Protected Material at issue. A
15 sealing order will issue only upon a request establishing that the Protected Material at
16 issue is privileged, protectable as a trade secret, or otherwise entitled to protection
17 under the law. If a Receiving Party’s request to file Protected Material under seal
18 pursuant to Civil Local Rule 141 is denied by the court, then the Receiving Party may
19 file the information in the public record pursuant to Civil Local Rule 141 unless
20 otherwise instructed by the court.
21 13.
FINAL DISPOSITION
22
Within 60 days after the final disposition of this action, as defined in paragraph
23 4, each Receiving Party must return all Protected Material to the Producing Party or
24 destroy such material. As used in this subdivision, “all Protected Material” includes
25 all copies, abstracts, compilations, summaries, and any other format reproducing or
26 capturing any of the Protected Material. Whether the Protected Material is returned
27 or destroyed, the Receiving Party must submit a written certification to the Producing
28 Party (and, if not the same person or entity, to the Designating Party) by the 60 day
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
12
1
deadline that (1) identifies (by category, where appropriate) all the Protected Material
2
that was returned or destroyed and (2) affirms that the Receiving Party has not
3
retained any copies, abstracts, compilations, summaries or any other format
4
reproducing or capturing any of the Protected Material. Notwithstanding this
5
provision, Counsel are entitled to retain an archival copy of all pleadings, motion
6
papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
7
deposition and trial exhibits, expert reports, attorney work product, and consultant
8
and expert work product, even if such materials contain Protected Material. Any such
9
archival copies that contain or constitute Protected Material remain subject to this
10 Protective Order as set forth in Section 4 (DURATION).
11
12 DATED: March 30, 2015
13
SIMMONDS & NARITA LLP
By: /s/ Liana Mayilyan
Attorneys for Defendant United Debt
Holdings, LLC
14
15
16
DATED: March 30, 2015
GALLO LLP
17
18
19
By: /s/ Dominic Valerian
Attorneys for Plaintiff
Mandy Knowles
20
21
22
23
24
25
26
27
28
KNOWLES v. UNITED DEBT HOLDINGS, LLC, et al. (CASE NO. 1:14-cv-01815-AWI-GSA)
STIPULATED PROTECTIVE ORDER
13
Order
The Court has reviewed the stipulation outlined above and adopts it as a stipulated
protective order in this case.1 To the extent motion practice is required, the parties are
advised to review Local Rules 141, 141.1, 230, and 251.
IT IS SO ORDERED.
Dated:
March 31, 2015
/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE
1
A fully executed version of the stipulation is available on the Court’s docket as ECF No. 16. That version also includes the
“Exhibit A” referenced in the stipulation.
14
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?