Doe v. County of Kern, et al.
Filing
29
PROTECTIVE ORDER, signed by Magistrate Judge Jennifer L. Thurston on 7/18/2016. (Hall, S)
1 CHAIN | COHN | STILES
David K. Cohn, Esq. (SBN 68768) | dcohn@chainlaw.com
2 Neil K. Gehlawat, Esq. (SBN 289388) | ngehlawat@chainlaw.com
1731 Chester Avenue
3
Bakersfield, CA 93301
(661) 323-4000
4 Telephone:
Facsimile:
(661) 324-1352
5
THE LAW OFFICE OF THOMAS C. SEABAUGH
6 Thomas C. Seabaugh, Esq., SBN 272458 | tseabaugh@seabaughfirm.com
128 North Fair Oaks Avenue
7
Pasadena, California 91103
8 Telephone: (818) 928-5290
9 Attorneys for Plaintiff
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11
UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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JANE DOE, an individual,
CASE NO. 1:15-CV-01637-DAD-JLT
Plaintiff,
15
PROTECTIVE ORDER
v.
16
(Doc. 28)
17 COUNTY OF KERN, a municipality;
CESAR NAVEJAR, an individual; and
18 DOES 1-10,
19
Defendants.
20
COME NOW the Parties in this matter and jointly present this Protective Order for the
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Court’s approval.
PROTECTIVE ORDER
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1.
PURPOSE AND LIMITATIONS
Disclosure and discovery activity in this action are likely to involve production of
confidential, proprietary, or private information for which special protection from public
disclosure and from use for any purpose other than prosecuting this litigation may be warranted.
Accordingly, the Parties in Jane Doe v. County of Kern and Cesar Navejar, USDC Eastern District
CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
(661) 323-4000
-1PROTECTIVE ORDER
1 of California Case No. 1:15-CV-01637-DAD-JLT petitioned the Court to enter the following
2 Protective Order. Good Cause appearing, the Court ORDERS as follows:
3
This Order does not confer blanket protections on all disclosures or responses to discovery
4 and that the protection it affords from public disclosure and use extends only to the limited
5 information or items that are entitled to confidential treatment under the applicable legal
6 principals. As set forth in Section 12.3, below, this Protective Order does not entitle the parties to
7 file confidential information under seal.
8 2.
DEFINITIONS
9
2.1
Challenging Party: a Party or Non-Party that challenges the designation of
10 information or items under this Order.
11
2.2
“CONFIDENTIAL” Information or items: information (regardless of how it is
12 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule
13 of Civil Procedure26(c).
14
2.3
Counsel (without qualifier): Outside Counsel of Record and House Counsel (as
15 well as their support staff).
16
2.4
Designating party: a Party or Non-Party that designates information or items that it
17 produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
18
2.5
Disclosure or Discovery Material: all items or information, regardless of the
19 medium or manner in which it is generated, store, or maintained (including, among other things,
20 testimony, transcripts, and tangible things), that are produced or generated in disclosures or
21 responses to discovery in this matter.
22
2.6
Expert: a person with specialized knowledge or experience in a matter pertinent to
23 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
24 consultant in this action.
25
2.7
House Counsel: attorneys who are employees of a party to this action. House
26 Counsel does not include Outside Counsel of Record or any other outside counsel.
27
2.8
Non-Party: any natural person, partnership, corporation, association, or other legal
28 entity not names as a Party to this action.
CHAIN | COHN | STILES
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-2PROTECTIVE ORDER
1
2.9
Outside Counsel of Record: attorneys who are not employees of a party to this
2 action but are retained to represent or advise a party to this action and have appeared in this action
3 on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
4
2.10
Party: any party to this action, including all of its officers, directors, employees,
5 consultants, retained experts, and Outside Counsel of Record (and their support staffs).
6
2.11
Producing Party: a Party or Non-Party that produces Disclosure or Discovery
7 Material in this action.
8
2.12
Professional Vendors: persons or entities that provide litigation support services
9 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
10 organizing, storing, or retrieving data in any form or medium) and their employees and
11 subcontractors.
12
2.13
Protected Material: any Disclosure or Discovery Material that is designated as
13 “CONFIDENTIAL.”
14
2.14
Receiving Party: a Party that receives Disclosure or Discovery Material from a
15 Producing Party.
16 3.
SCOPE
17
The protections conferred by this Order cover not only Protected Material (as defined
18 above), but also (1) any information copied or extracted from Protected Material; (2) all copies,
19 excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations,
20 or presentations by Parties or their Counsel that might reveal Protected Material. However, the
21 protections conferred by this Order do not cover the following information: (a) any information
22 that is in the public domain at the time of disclosure to a Receiving Party or becomes part of the
23 public domain after its disclosure to a Receiving Party as a result of publication not involving a
24 violation of this Order, including becoming part of the public record through trial or otherwise;
25 and (b) any information known to the Receiving Party prior to the disclosure or obtained by the
26 Receiving Party after the disclosure from a source who obtained the information lawfully and
27 under no obligation of confidentiality to the Designating Party. Any use of Protected Material at
28 trial shall be governed by a separate agreement or order.
CHAIN | COHN | STILES
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1 4.
DURATION
2
Even after final disposition of this litigation, the confidentiality obligations imposed by this
3 Order shall remain in effect until Designating Party agrees otherwise in writing or a court order
4 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims
5 and defenses in this action, with or without prejudice; and (2) final judgment herein after the
6 completion and exhaustion of all appeals, rehearings, remands, trials or reviews of this action,
7 including the time limits for filing any motions or applications for extension of time pursuant to
8 applicable law.
9 5.
DESIGNATING PROTECTED MATERIAL
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5.1
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Each Party or Non-Party that designates information or items for protection under this
Exercise of Restraint and care in Designating Material for Protection
12 Order must take care to limit any such designation to specific material that qualifies under the
13 appropriate standards. The Designating Party must designate for protections only those parts of
14 material, documents, items, or oral or written communications that qualify – so that other portions
15 of the material, documents, items, or communications for which protection is not warranted are
16 not swept unjustifiable within the ambit of this Order.
17
Mass, indiscriminate, or routinized designations are prohibited. Designations that are
18 sworn to be clearly unjustified or that have been made for an improper purpose (e.g., to
19 unnecessarily encumber or retard the case development process or to impose unnecessary
20 expenses and burdens on other parties) expose the Designating Party to sanctions.
21
If it comes to a Designating Party’s attention that information or items that it designated
22 for protections do not qualify for protection, the Designating Party must promptly notify all other
23 Parties that it is withdrawing the mistaken designation.
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5.2
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Except as otherwise provided in this Order (see, e.g., second paragraph of section 5.2 (a)
Manner and Timing of Designations
26 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for
27 protections under this Order must be clearly so designated before the material is disclosed or
28 produced. Designation in conformity with Order requires:
CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
(661) 323-4000
-4PROTECTIVE ORDER
1
(a)
For information in documentary form (e.g., paper or electronic documents,
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but excluding transcripts of depositions or other pretrial or trial proceedings), that
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the Producing Party affix the legend “CONFIDENTIAL” to each page that contains
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protected material. If only a portion or portions of the material on a page qualifies
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for protection the Producing Party also must clearly identify the protected
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portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-
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Party that makes original documents or materials available for inspection need not
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designate them for protection until after the inspecting Party has indicated which
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material it would like copied and produced. During the inspection and before the
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designation, all of the material made available for inspection shall be deemed
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“CONFIDENTIAL.” After the inspecting Party has identified the documents it
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wants copied and produced, the Producing Party must determine which documents,
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or portions thereof, qualify for protection under this Order. Then, before producing
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the specified documents, the Producing Party must affix the “CONFIDENTIAL”
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legend to each page that contains Protected Material.
16 If only a portion or portions of the material on a page qualifies for protection, the Producing Party
17 also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the
18 margins).
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(b)
for testimony given in deposition or in other pretrial or trial proceedings,
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that the Designating Party identify on the record, before the close of the deposition,
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hearing, or other proceeding, all protected testimony.
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(c)
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other tangible items, that the Producing Party affix in a prominent place on the
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exterior of the container or containers in which the information or item is stored the
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legend “CONFIDENTIAL.” If only a portion or portions of the information or
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item warrant protection, the Producing Party, to the extent practicable, shall
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identify the protected portion(s).
for information produced in some form other than documentary and for any
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CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
(661) 323-4000
-5PROTECTIVE ORDER
1
5.3
2
If timely corrected, an inadvertent failure to designate qualified information or items does
Inadvertent Failures to Designate
3 not, standing alone, waive the Designating Party’s right to secure protection under this Order for
4 such material. Upon timely correction of a designation, the Receiving Party must make reasonable
5 efforts to assure that the material is treated in accordance with the provisions of this Order.
6 6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
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6.1
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Any Party may challenge a designation of confidentiality at any time. Unless a prompt
Timing of Challenges
9 challenge to a Designating Party’s confidentiality designation is necessary to avoid foreseeable,
10 substantial unfairness, unnecessary economic burdens, or a significant disruption or delay of the
11 litigation, the challenge must be brought within a reasonable time or it is waived.
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6.2
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The Challenging Party shall initiate the dispute resolution process by providing written
Meet and Confer
14 notice of each designation it is challenging and describing the basis for each challenge. To avoid
15 ambiguity as to whether a challenge has been made, the written notice must recite that the
16 challenge to confidentiality is being made in accordance with this specific paragraph of the
17 Protective Order. The parties shall attempt to resolve each challenge in good faith and must begin
18 the process by conferring directly (in voice to voice dialogue; other forms of communication are
19 not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging Party
20 must explain the basis for its belief that the confidentiality designation was not proper and must
21 give the Designating Party an opportunity to review the designated material, to reconsider the
22 circumstances, and, if no change in designation is offered, to explain the basis for the chosen
23 designation. A Challenging Party may proceed to the next state of the challenge process only if it
24 has engaged in this meet and confer process first or establishes that the Designating Party is
25 unwilling to participate in the meet and confer process in a timely manner.
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6.3
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If the Parties cannot resolve a challenge after meeting and conferring, the Challenging
Judicial Intervention
28 Party SHALL initiate an informal, telephonic conference with the assigned Magistrate Judge. At
CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
(661) 323-4000
-6PROTECTIVE ORDER
1 that conference, the Court will attempt to resolve the matter without need for formal motion
2 practice. If, in the Court’s view, the matter can only be resolved through formal motion practice,
3 the Court will authorize the Challenging party to file a motion which SHALL comply with Local
4 Rule 251(c).
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As with motions to compel, the Challenging Party SHALL bear the initial burden of
6 demonstrating that the Designating Party has improperly marked the material as confidential. If
7 this showing is made, the burden will shift and as with motions for protective orders under Federal
8 Rules of Civil Procedure 26(c), the burden of establishing the need for the confidentiality – as with
9 any evidentiary privilege – must be borne by the Designating Party who is asserting it. Frivolous
10 challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary
11 expenses and burdens on other parties) may expose the Challenging Party to sanctions. All parties
12 shall continue to afford the material in question the level of protection to which it is entitled under
13 the Producing Party’s designation until the Court rules on the challenge.
14 7.
ACCESS TO AND USE OF PROTECTED MATERIAL
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7.1
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A Receiving Party may use Protected Material that is disclosed or produced by another
Basic Principles
17 Party or by a Non-Party in connection with this this case only for prosecuting, defending, or
18 attempting to settle this litigation. Such Protected Material may be disclosed only to the
19 categories of persons and under the conditions described in this Order. When the litigation has
20 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
21 DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a location and in
23 a secure manner that ensures that access is limited to the persons authorized under this Order.
Disclosure of “CONFIDENTAL” Information or Items
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7.2
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Unless otherwise ordered by the court or permitted in writing by the Designating Party, a
26 Receiving Party may disclose any information or item designated “CONFIDENTIAL” only to:
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(a)
the Receiving Party’s Outside Counsel of Record in this action, as well as
employees of said Outside Counsel of Record to whom it is reasonably necessary to
CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
(661) 323-4000
-7PROTECTIVE ORDER
1
disclose the information for this litigation and who have signed the “Acknowledgement
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and Agreement to Be Bound” that is attached hereto as Exhibit A;
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(b)
the officers, directors, and employees (including House Counsel) of the
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Receiving Party to whom disclosure is reasonably necessary for this litigation and who
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have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(c)
Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this litigation and who have signed the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d)
the court and its personnel;
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(e)
court reporters and their staff, professional jury or trial consultants, mock
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jurors, and Professional Vendors to whom disclosure is reasonably necessary for this
12
litigation and who have signed the “Acknowledgement and Agreement to Be Bound”
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(Exhibit A);
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(f)
during their depositions, witnesses in the action whom disclosure is
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reasonably necessary and who have signed the “Acknowledgement and Agreement to Be
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Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the
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court. Pages transcribed deposition testimony or exhibits to depositions that reveal
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Protected Material must be separately bound by the court reporter and may not be
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disclosed to anyone except as permitted under this Protective Order.
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(g)
the author or recipient of a document containing the information or a
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custodian or other person who otherwise possessed or knew the information.
22 8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
23 OTHER LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation that compels
25 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
26 must:
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(a)
promptly notify in writing the Designation Party. Such notification shall
include a copy of the subpoena or court order;
CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
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-8PROTECTIVE ORDER
1
(b)
promptly notify in writing the party who caused the subpoena or order to
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issue in the other litigation that some or all of the material covered by the subpoena or
3
order is subject to this Protective Order. Such notification shall include a copy of this
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Protective Order; and
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(c)
cooperate with respect to all reasonable procedures sought to be pursued by
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the Designating Party who’s Protected Material may be affected. If the Designating Party
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timely seeks a protective order, the Party served with the subpoena or court order shall not
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produce any information designated in this action as “CONFIDENTIAL” before a
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determination by the court from which the subpoena or order issued, unless the Party has
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obtained the Designating Party’s permission. The Designating Party shall bear the burden
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and expense of seeking protection in that court of its confidential material – and nothing in
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these provisions should be construed as authorizing or encouraging a Receiving Party in
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this action to disobey a lawful directive from another court.
14 9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN
15 THIS LITIGATION
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(a)
The terms of this Order are applicable to information produced by a Non-
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Party in this action and designated as “CONFIDENTIAL.” Such information produced by
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Non-Parties in connection with this litigation is protected by the remedies and relief
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provided by this Order. Nothing in these provisions should be construed as prohibiting a
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Non-Party from seeking additional protections.
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(b)
In the event that a Party is required, by a valid discovery request, to produce
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a Non-Party’s confidential information in its possession, and the Party is subject to an
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agreement with the Non-party not to produce the Non-Party’s confidential information,
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then the Party shall:
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(1)
promptly notify in writing the Requesting Party and the Non-Party
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that some or all of the information requested is subject to a confidentiality
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agreement with a Non-Party;
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CHAIN | COHN | STILES
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BAKERSFIELD, CA 93301
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1
(2)
promptly provide the Non-Party with a copy of the Protective Order
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in this litigation, the relevant discovery request(s), and a reasonably specific
3
description of the information requested; and
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(3)
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Party.
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(c)
make the information requested available for inspection by the Non-
If the Non-Party fails to object or seek a protective order from this court
7
within 14 days of receiving the notice and accompanying information, the Receiving Party
8
may produce the Non-Party’s confidential information responsive to the discovery request.
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If the Non-Party timely seeks a protective order, the Receiving Party shall not produce any
10
information in its possession or control that is subject to the confidentiality agreement with
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the Non-Party before a determination by the court. Absent a court order to the contrary,
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the Non-Party shall bear the burden and expense of seeking protection in this court of its
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Protected Material.
14 10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
15
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
16 Material to any person or in any circumstance not authorized under this Protective Order, the
17 Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized
18 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c)
19 inform the person or persons to whom unauthorized disclosures were made of all the terms of this
20 Order, and (d) request such person or persons to execute the “Acknowledgement and Agreement
21 to Be Bound” that is attached hereto to as Exhibit A.
22 11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
23 PROTECTED MATERIAL
24
When a Producing Party gives notice to Receiving Parties that certain inadvertently
25 produced material is subject to a claim of privilege or other protection, the obligations of the
26 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
27 provision is not intended to modify whatever produce may be established in an e-discovery order
28 that provides for production without prior privilege review. Pursuant to Federal Rule of Evidence
CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
(661) 323-4000
-10PROTECTIVE ORDER
1 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a
2 communication or information covered by the attorney-client privilege or work product protection,
3 the parties may incorporate their agreement in the stipulated protective order submitted to the
4 Court.
5 12.
MISCELLANEOUS
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12.1
7
Nothing in this Order abridges the right of any person to seek its modification by the court
Right to Further Relief
8 in the future.
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10
12.2
Right to Assert Other Obligations
The entry of this Protective Order does not imply and Party’s waiver of any right it
11 otherwise would have to object to disclosing or producing any information or item on any ground
12 not addressed in this Protective Order. Similarly, no Party waives any right to object on any
13 ground to use in evidence of any of the material covered by this Protective Order.
14
12.3
15
Without written permission from the Designating Party or a court order secured after
Filing Protected Material
16 appropriate notice to all interested persons, a Party may not file in the public record in this action
17 any Protected Material. A Party that seeks to file under seal any Protected Material must comply
18 with the applicable local rules. Protected Material may only be filed under seal pursuant to a court
19 order authorizing the sealing of the specific Protected Material at issue. A sealing order will issue
20 only upon a request establishing that the Protected Material at issue is privileged, protectable as a
21 trade secret, or otherwise entitled to protection under the law. If a Receiving Party’s request to file
22 Protected Material under seal is denied by the court, then the Receiving Party may file the
23 information in the public record unless otherwise instructed by the court.
24 13.
FINAL DISPOSITION
25
Within 60 days after the final disposition of this action, as defined in paragraph 4, each
26 Receiving Party must return all Protected Material to the Producing Party or destroy such material.
27 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
28 summaries, and any other format reproducing or capturing any of the Protected Material. Whether
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1731 CHESTER AVENUE
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-11PROTECTIVE ORDER
1 the Protected Material is returned or destroyed, the Receiving Party must submit a written
2 certification to the Producing Party (and, if not the same person or entity, to the Designating Party)
3 by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected
4 Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained
5 any copies, abstracts, compilations, summaries or any other format reproducing or capturing any
6 of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
7 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
8 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product,
9 and consultant and expert work product, even if such materials contain Protected Material. Any
10 such archival copes that contain or constitute Protected Material remain subject to this Protective
11 Order as set forth in Section4 (DURATION).
12 DATED:
July __, 2016
CHAIN | COHN | STILES
13
/s/ Neil K. Gehlawat
BY: ______________________________
Neil K. Gehlawat
Attorney for Plaintiff
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16 DATED:
July __, 2016
LAW OFFICE OF THOMAS C.
SEABAUGH
17
/s/ Thomas C. Seabaugh
BY: ______________________________
Thomas C. Seabaugh
Attorney for Plaintiff
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DATED:
July __, 2016
COUNTY COUNSEL, COUNTY OF KERN
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/s/ Marshall S. Fontes
BY: ______________________________
Marshall S. Fontes
Attorney for Defendant, County of Kern
22
23
24 DATED:
July __, 2016
WEAKLEY & ARENDT. LLP
25
/s/ James D. Weakley
BY: ______________________________
James D. Weakley
Attorney for Defendant, Cesar Navejar
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CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
(661) 323-4000
-12PROTECTIVE ORDER
1
2 IT IS SO ORDERED.
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CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
(661) 323-4000
Dated:
July 18, 2016
/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE
1
2
EXHIBIT A
3
ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
4
I, _______________________ [print or type full name], of
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__________________________ [print or type full address], declare under penalty of perjury that I
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have read in its entirety and understand the Protective Order that was issued by the Unites States
7
District Court for the Eastern District of California on _________________, 2016 in the case of
8
Jane Doe v. County of Kern and Cesar Navejar, USDC Eastern District of California Case No.
9
1:15-CV-01637-DAD-JLT.
10
I agree to comply with and to be bound by all the terms of this Protective Order and I
11
understand and acknowledge that failure to so comply could expose me to sanctions and
12
punishment in the nature of contempt. I solemnly promise that I will not disclose in any matter
13
any information or item that is subject to this Protective Order to any person or entity except in
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strict compliance with the provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District Court for the
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Eastern District of California for the purpose of enforcing the terms of this Protective Order, even
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if such enforcement proceedings occur after termination of this action.
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I hereby appoint _________________________________ [print/type full name] of
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_______________________________________ [print/type full address and telephone number] as
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my California agent for service of process in connection with this action or any proceedings
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related to enforcement of this Protective Order.
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Date:__________________
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CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
(661) 323-4000
City and State were sworn and signed: ________________________________
Printed name: ________________________
Signature: ____________________________
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