Taylor v. The GEO Group, Inc. et al

Filing 11

ORDER GRANTING 10 STIPULATED PROTECTIVE ORDER as Modified by the Court, signed by Magistrate Judge Jennifer L. Thurston on 2/16/2017. (Hall, S)

1

4

LITTLER MENDELSON, P.C.
MATTHEW E. FARMER, Bar No. 190484
NATALIE M. JANSEN, Bar No. 286401
5200 North Palm Avenue, Suite 302
Fresno, CA 93704.2225
Telephone:
559.244.7500
Facsimile:
559.244.7525

5

Attorneys for Defendants

6

THE GEO GROUP, INC. and GEO
CORRECTIONS AND DETENTION, LLC

2
3

7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

CHRISTINE TAYLOR,

12

Plaintiff,

13

v.

14

THE GEO GROUP, INC. and GEO
CORRECTIONS AND DETENTION,
LLC,

15
16

Case No. 1:16-CV-01484-JLT
ORDER GRANTING STIPULATED
PROTECTIVE ORDER AS MODIFIED BY
THE COURT
(Doc. 10)

Defendants.

17
18
19

1.

PURPOSES AND LIMITATIONS

20

Disclosure and discovery activity in this action are likely to involve production of

21

confidential, proprietary, or private information for which special protection from public disclosure

22

and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly,

23

the parties hereby stipulate to and petition the court to enter the following Stipulated Protective

24

Order.

25

disclosures or responses to discovery and that the protection it affords from public disclosure and use

26

extends only to the limited information or items that are entitled to confidential treatment under the

27

applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, below, that

The parties acknowledge that this Order does not confer blanket protections on all

28
LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

(NO. 1:16-CV-01484-JLT)

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

this Stipulated Protective Order does not entitle them to file confidential information under seal;

2

Civil Local Rule 79-5 Local Rule 141 sets forth the procedures that must be followed and the

3

standards that will be applied when a party seeks permission from the court to file material under

4

seal.

5

2.

DEFINITIONS

6
7

2.1

Challenging Party: a Party or Non-Party that challenges the designation of

information or items under this Order.

8

2.2

“CONFIDENTIAL” Information or Items: information (regardless of how it

9

is generated, stored or maintained) or tangible things marked “CONFIDENTIAL” by producing

10

party including any documents or materials, including but not limited to medical records, FMLA and

11

leave records, financial data, data relevant to the security of the prison, and PII (personally

12

identifiable information) of prison personnel, including addresses, social security and telephone

13

numbers, and dates of birth, which the Parties designate as confidential. Information covered by the

14

Health Insurance Portablity Act (“HIPAA”), a federal law which protects patient’s health and related

15

financial information from inappropriate and unauthorized usage, is also considered a Confidential

16

Document..

17
18
19
20
21

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 items

that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
2.5

Disclosure or Discovery Material: all items or information, regardless of the

22

medium or manner in which it is generated, stored, or maintained (including, among other things,

23

testimony, transcripts, and tangible things), that are produced or generated in disclosures or

24

responses to discovery in this matter.

25

2.6

Expert:

a person with specialized knowledge or experience in a matter

26

pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert

27

witness or as a consultant in this action.

28
LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

2.7

House Counsel: attorneys who are employees of a party to this action. House

(NO. 1:16-CV-01484-JLT)

2.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

Counsel does not include Outside Counsel of Record or any other outside counsel.

2
3

2.8

Non-Party: any natural person, partnership, corporation, association, or other

legal entity not named as a Party to this action.

4

2.9

Outside Counsel of Record: attorneys who are not employees of a party to

5

this action but are retained to represent or advise a party to this action and have appeared in this

6

action on behalf of that party or are affiliated with a law firm which has appeared on behalf of that

7

party.

8
9

2.10

any party to this action, including all of its officers, directors,

employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs).

10
11

Party:

2.11

Producing Party: a Party or Non-Party that produces Disclosure or Discovery

Material in this action.

12

2.12

Professional Vendors:

persons or entities that provide litigation support

13

services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and

14

organizing, storing, or retrieving data in any form or medium) and their employees and

15

subcontractors.

16
17

2.13

Protected Material: any Disclosure or Discovery Material that is designated

as “CONFIDENTIAL.”

18

2.14

19

a Producing Party.

20

3.

Receiving Party: a Party that receives Disclosure or Discovery Material from

SCOPE

21

The protections conferred by this Stipulation and Order cover not only Protected

22

Material (as defined above), but also (1) any information copied or extracted from Protected

23

Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any

24

testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected

25

Material.

26

following information: (a) any information that is in the public domain at the time of disclosure to a

27

Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a

28

result of publication not involving a violation of this Order, including becoming part of the public

LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

However, the protections conferred by this Stipulation and Order do not cover the

(NO. 1:16-CV-01484-JLT)

3.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

record through trial or otherwise; and (b) any information known to the Receiving Party prior to the

2

disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the

3

information lawfully and under no obligation of confidentiality to the Designating Party. Any use of

4

Protected Material at trial shall be governed by a separate agreement or order.

5

4.

DURATION

6

Even after final disposition of this litigation, the confidentiality obligations imposed

7

by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court

8

order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all

9

claims and defenses in this action, with or without prejudice; and (2) final judgment herein after the

10

completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,

11

including the time limits for filing any motions or applications for extension of time pursuant to

12

applicable law.

13

5.

14

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection. Each

15

Party or Non-Party that designates information or items for protection under this Order must take

16

care to limit any such designation to specific material that qualifies under the appropriate standards.

17

The Designating Party must designate for protection only those parts of material, documents, items,

18

or oral or written communications that qualify – so that other portions of the material, documents,

19

items, or communications for which protection is not warranted are not swept unjustifiably within

20

the ambit of this Order.

21

Mass, indiscriminate, or routinized designations are prohibited. Designations that are

22

shown to be clearly unjustified or that have been made for an improper purpose (e.g., to

23

unnecessarily encumber or retard the case development process or to impose unnecessary expenses

24

and burdens on other parties) expose the Designating Party to sanctions.

25

If it comes to a Designating Party’s attention that information or items that it

26

designated for protection do not qualify for protection, that Designating Party must promptly notify

27

all other Parties that it is withdrawing the mistaken designation.

28
LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

5.2

Manner and Timing of Designations. Except as otherwise provided in this

(NO. 1:16-CV-01484-JLT)

4.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,

2

Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so

3

designated before the material is disclosed or produced.

4

Designation in conformity with this Order requires:

5

(a)

for information in documentary form (e.g., paper or electronic documents, but

6

excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party

7

affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion

8

or portions of the material on a page qualifies for protection, the Producing Party also must clearly

9

identify the protected portion(s) (e.g., by making appropriate markings in the margins).

10

A Party or Non-Party that makes original documents or materials available for

11

inspection need not designate them for protection until after the inspecting Party has indicated which

12

material it would like copied and produced. During the inspection and before the designation, all of

13

the material made available for inspection shall be deemed “CONFIDENTIAL.”

14

inspecting Party has identified the documents it wants copied and produced, the Producing Party

15

must determine which documents, or portions thereof, qualify for protection under this Order. Then,

16

before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL”

17

legend to each page that contains Protected Material. If only a portion or portions of the material on

18

a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s)

19

(e.g., by making appropriate markings in the margins).

20

(b)

After the

for testimony given in deposition or in other pretrial or trial proceedings, that

21

the Designating Party identify on the record, before the close of the deposition, hearing, or other

22

proceeding, all protected testimony.

23

(c)

for information produced in some form other than documentary and for any

24

other tangible items, that the Producing Party affix in a prominent place on the exterior of the

25

container or containers in which the information or item is stored the legend “CONFIDENTIAL.” If

26

only a portion or portions of the information or item warrant protection, the Producing Party, to the

27

extent practicable, shall identify the protected portion(s).

28
LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

(NO. 1:16-CV-01484-JLT)

5.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

to designate qualified information or items does not, standing alone, waive the Designating Party’s

2

right to secure protection under this Order for such material.

3

designation, the Receiving Party must make reasonable efforts to assure that the material is treated in

4

accordance with the provisions of this Order.

5

6.

6

Upon timely correction of a

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges. Any Party or Non-Party may challenge a designation

7

of confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality

8

designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens,

9

or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a

10

confidentiality designation by electing not to mount a challenge promptly after the original

11

designation is disclosed.

12

6.2

Meet and Confer. The Challenging Party shall initiate the dispute resolution

13

process by providing written notice of each designation it is challenging and describing the basis for

14

each challenge. To avoid ambiguity as to whether a challenge has been made, the written notice

15

must recite that the challenge to confidentiality is being made in accordance with this specific

16

paragraph of the Protective Order. The parties shall attempt to resolve each challenge in good faith

17

and must begin the 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 conferring, the

19

Challenging Party must explain the basis for its belief that the confidentiality designation was not

20

proper and must give the Designating Party an opportunity to review the designated material, to

21

reconsider the circumstances, and, if no change in designation is offered, to explain the basis for the

22

chosen designation. A Challenging Party may proceed to the next stage of the challenge process

23

only if it has engaged in this meet and confer process first or establishes that the Designating Party is

24

unwilling to participate in the meet and confer process in a timely manner.

25

6.3

Judicial Intervention. If the Parties cannot resolve a challenge without court

26

intervention and they have complied with the scheduling order (Doc. 9 at 3), the Designating Party

27

shall file and serve a motion to retain confidentiality under Civil Local Rule 7 (and in compliance

28

with Civil Local Rule 79-5, if applicable) Local Rule 251 within 21 days of the initial notice of

LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

(NO. 1:16-CV-01484-JLT)

6.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

challenge or within 14 days of the parties agreeing that the meet and confer process will not resolve

2

their dispute, whichever is earlier.

3

declaration affirming that the movant has complied with the meet and confer requirements imposed

4

in the preceding paragraph. Failure by the Designating Party to make such a motion including the

5

required declaration within 21 days (or 14 days, if applicable) shall automatically waive the

6

confidentiality designation for each challenged designation. In addition, the Challenging Party may

7

file a motion challenging a confidentiality designation at any time if there is good cause for doing so,

8

including a challenge to the designation of a deposition transcript or any portions thereof. Any

9

motion brought pursuant to this provision must be accompanied by a competent declaration

10

affirming that the movant has complied with the meet and confer requirements imposed by the

11

preceding paragraph.

Each such motion must be accompanied by a competent

12

The burden of persuasion in any such challenge proceeding shall be on the

13

Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or

14

impose unnecessary expenses and burdens on other parties) may expose the Challenging Party to

15

sanctions. Unless the Designating Party has waived the confidentiality designation by failing to file

16

a motion to retain confidentiality as described above, all parties shall continue to afford the material

17

in question the level of protection to which it is entitled under the Producing Party’s designation

18

until the court rules on the challenge.

19

7.

20

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is

21

disclosed or produced by another Party or by a Non-Party in connection with this case only for

22

prosecuting, defending, or attempting to settle this litigation. Such Protected Material may be

23

disclosed only to the categories of persons and under the conditions described in this Order. When

24

the litigation has been terminated, a Receiving Party must comply with the provisions of section 13

25

below (FINAL DISPOSITION).

26
27
28
LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

Protected Material must be stored and maintained by a Receiving Party at a location
and in a secure manner that ensures that access is limited to the persons authorized under this Order.
7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

(NO. 1:16-CV-01484-JLT)

7.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

ordered by the court or permitted in writing by the Designating Party, a Receiving Party may

2

disclose any information or item designated “CONFIDENTIAL” only to:

3

(a)

the Receiving Party’s Outside Counsel of Record in this action, as well as

4

employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the

5

information for this litigation and who have signed the “Acknowledgment and Agreement to Be

6

Bound” that is attached hereto as Exhibit A;

7

(b)

the officers, directors, and employees (including House Counsel) of the

8

Receiving Party to whom disclosure is reasonably necessary for this litigation and who have signed

9

the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

10

(c)

Experts (as defined in this Order) of the Receiving Party to whom disclosure

11

is reasonably necessary for this litigation and who have signed the “Acknowledgment and

12

Agreement to Be Bound” (Exhibit A);

13

(d)

the court and its personnel;

14

(e)

court reporters and their staff, professional jury or trial consultants, mock

15

jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation and

16

who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

17

(f)

during their depositions, witnesses in the action to whom disclosure is

18

reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound”

19

(Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of

20

transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be

21

separately bound by the court reporter and may not be disclosed to anyone except as permitted under

22

this Stipulated Protective Order.

23

(g)

the author or recipient of a document containing the information or a

24

custodian or other person who otherwise possessed or knew the information.

25

8.

26

LITIGATION

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER

27

If a Party is served with a subpoena or a court order issued in other litigation that

28

compels disclosure of any information or items designated in this action as “CONFIDENTIAL,” that

LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

(NO. 1:16-CV-01484-JLT)

8.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

Party must:

2
3

(a)

promptly notify in writing the Designating Party.

Such notification shall

include a copy of the subpoena or court order;

4

(b)

promptly notify in writing the party who caused the subpoena or order to issue

5

in the other litigation that some or all of the material covered by the subpoena or order is subject to

6

this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and

7
8

(c)

cooperate with respect to all reasonable procedures sought to be pursued by

the Designating Party whose Protected Material may be affected.

9

If the Designating Party timely seeks a protective order, the Party served with the

10

subpoena or court order shall not produce any information designated in this action as

11

“CONFIDENTIAL” before a determination by the court from which the subpoena or order issued,

12

unless the Party has obtained the Designating Party’s permission. The Designating Party shall bear

13

the burden and expense of seeking protection in that court of its confidential material – and nothing

14

in these provisions should be construed as authorizing or encouraging a Receiving Party in this

15

action to disobey a lawful directive from another court.

16

9.

17

LITIGATION

18

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS

(a)

The terms of this Order are applicable to information produced by a Non-

19

Party in this action and designated as “CONFIDENTIAL.” Such information produced by Non-

20

Parties in connection with this litigation is protected by the remedies and relief provided by this

21

Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking

22

additional protections.

23

(b)

In the event that a Party is required, by a valid discovery request, to produce a

24

Non-Party’s confidential information in its possession, and the Party is subject to an agreement with

25

the Non-Party not to produce the Non-Party’s confidential information, then the Party shall:

26
27
28
LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

(1)

promptly notify in writing the Requesting Party and the Non-Party that some

or all of the information requested is subject to a confidentiality agreement with a Non-Party;
(2)

promptly provide the Non-Party with a copy of the Stipulated Protective

(NO. 1:16-CV-01484-JLT)

9.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

Order in this litigation, the relevant discovery request(s), and a reasonably specific description of the

2

information requested; and

3

(3)

make the information requested available for inspection by the Non-Party.

4

(c)

If the Non-Party fails to object or seek a protective order from this court

5

within 14 days of receiving the notice and accompanying information, the Receiving Party may

6

produce the Non-Party’s confidential information responsive to the discovery request. If the Non-

7

Party timely seeks a protective order, the Receiving Party shall not produce any information in its

8

possession or control that is subject to the confidentiality agreement with the Non-Party before a

9

determination by the court. Absent a court order to the contrary, the Non-Party shall bear the burden

10

and expense of seeking protection in this court of its Protected Material.

11

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

12

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

13

Protected Material to any person or in any circumstance not authorized under this Stipulated

14

Protective Order, the Receiving Party must immediately (a) notify in writing the Designating Party

15

of the unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the

16

Protected Material, (c) inform the person or persons to whom unauthorized disclosures were made of

17

all the terms of this Order, and (d) request such person or persons to execute the “Acknowledgment

18

and Agreement to Be Bound” that is attached hereto as Exhibit A.

19

11.

20

MATERIAL

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED

21

When a Producing Party gives notice to Receiving Parties that certain inadvertently

22

produced material is subject to a claim of privilege or other protection, the obligations of the

23

Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision

24

is not intended to modify whatever procedure may be established in an e-discovery order that

25

provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d)

26

and (e), insofar as the parties reach an agreement on the effect of disclosure of a communication or

27

information covered by the attorney-client privilege or work product protection, the parties may

28

incorporate their agreement in the stipulated protective order submitted to the court.

LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

(NO. 1:16-CV-01484-JLT)

10.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

12.

MISCELLANEOUS

2
3

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.

4

12.2

Right to Assert Other Objections. By stipulating to the entry of this Protective

5

Order no Party waives any right it otherwise would have to object to disclosing or producing any

6

information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no

7

Party waives any right to object on any ground to use in evidence of any of the material covered by

8

this Protective Order.

9

12.3

Filing Protected Material. Without written permission from the Designating

10

Party or a court order secured after appropriate notice to all interested persons, a Party may not file

11

in the public record in this action any Protected Material. A Party that seeks to file under seal any

12

Protected Material must comply with Local Rule 141 Civil Local Rule 79-5. Protected Material may

13

only be filed under seal pursuant to a court order authorizing the sealing of the specific Protected

14

Material at issue. Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request

15

establishing that the Protected Material at issue is privileged, protectable as a trade secret, or

16

otherwise entitled to protection under the law. If a Receiving Party's request to file Protected

17

Material under seal pursuant to Civil Local Rule 79-5(d) is denied by the court, then the Receiving

18

Party may file the information in the public record pursuant to Civil Local Rule 79-5(e) unless

19

otherwise instructed by the court.

20

13.

FINAL DISPOSITION

21

Within 60 days after the final disposition of this action, as defined in paragraph 4,

22

each Receiving Party must return all Protected Material to the Producing Party or destroy such

23

material.

24

compilations, summaries, and any other format reproducing or capturing any of the Protected

25

Material. Whether the Protected Material is returned or destroyed, the Receiving Party must submit

26

a written certification to the Producing Party (and, if not the same person or entity, to the

27

Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all the

28

Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has not

LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

As used in this subdivision, “all Protected Material” includes all copies, abstracts,

(NO. 1:16-CV-01484-JLT)

11.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing

2

any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

3

archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal

4

memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and

5

consultant and expert work product, even if such materials contain Protected Material. Any such

6

archival copies that contain or constitute Protected Material remain subject to this Protective Order

7

as set forth in Section 4 (DURATION).

8

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

9

DATED: ________________________

KRING & CHUNG, LLP

10
11

_____________________________________
ALLYSON K. THOMPSON
Attorneys for Plaintiff

12
13
14

DATED: ________________________

LITTLER MENDELSON, P.C.

15
_________________________________
MATTHEW E. FARMER
Attorneys for Defendant

16
17

ORDER

18
19
20
21

Based upon the stipulation of counsel, the stipulated protective order, as modified by the Court
in paragraphs 1, 6.3 and 12.3 is GRANTED.
IT IS SO ORDERED.

22
Dated:
23

February 16, 2017

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

24
25
26
27
28
LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

(NO. 1:16-CV-01484-JLT)

12.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19

I,

_____________________________

[print

or

type

full

name],

_________________ [print or type full address], declare under penalty of perjury that I have read in
its entirety and understand the Stipulated Protective Order that was issued by the United States
District Court for the Eastern District of California on [date] in the case of Christine Taylor v. The
Geo Group, Inc., and Geo Corrections and Detention, LLC I hereby agree to comply with and to be
bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that
failure to so comply could expose me to sanctions and punishment in the nature of contempt. I
solemnly promise that I will not disclose in any manner any information or item that is subject to this
Stipulated Protective Order to any person or entity except in strict compliance with the provisions of
this Order.
I further agree to submit to the jurisdiction of the United States District Court for the
Eastern District of California for the purpose of enforcing the terms of this Stipulated Protective
Order, even if such enforcement proceedings occur after termination of this action.
I hereby appoint __________________________ [print or type full name] of
_______________________________________ [print or type full address and telephone number] as
my California agent for service of process in connection with this action or any proceedings related
to enforcement of this Stipulated Protective Order.

20
Date: ______________________________________
21
City and State where sworn and signed: _________________________________
22
Printed name: _______________________________
23
Signature: __________________________________
24
25
26
27
28
LITTLER MENDELSON, P.C.
5200 North Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

of

(NO. 1:16-CV-01484-JLT)

13.

STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION