S.T. v. City of Ceres et al

Filing 19

ORDER on Stipulated PROTECTIVE ORDER, signed by Magistrate Judge Barbara A. McAuliffe on 3/2/2017. (Herman, H)

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1 2 3 4 5 6 7 9 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 8 11 12 13 14 DALE L. ALLEN, JR., State Bar No. 145279 dallen@aghwlaw.com PHILIP J. DOWNS, JR., State Bar No. 302939 pdowns@aghwlaw.com ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 180 Montgomery Street, Suite 1200 San Francisco, CA 94104 Telephone: (415) 697-2000 Facsimile: (415) 813-2045 Attorneys for Defendants CITY OF CERES; JUSTIN CANATSY and JESUS SALINAS DARRELL J. YORK, State Bar No. djylaw@gmail.com SARAH L. GARVEY, State Bar No. sarahgarvey@yahoo.com YORK & GARVEY 137 N. Larchmont Boulevard, #506 Los Angeles, CA 90004 Telephone: (866) 908-2121 Facsimile: (877) 221-3306 Attorneys for Plaintiffs S.T., a minor by and through his guardian ad litem JESSICA NIBLETT, individually and as successor in interest of ALBERT B. THOMPSON, deceased 15 16 UNITED STATES DISTRICT COURT 17 EASTERN DISTRICT OF CALIFORNIA 18 19 S.T., a minor by and through his guardian Case No.: 1:16-cv-01713-LJO-BAM ad litem Jessica Niblett, individually and as successor in interest of Albert B. ORDER ON STIPULATED PROTECTIVE Thompson, deceased, ORDER 20 Plaintiff, 21 v. 22 23 CITY OF CERES; JUSTIN CANATSY; JESUS SALINAS; and DOES 1-10, inclusive, 24 Defendants. 25 26 1. PURPOSES AND LIMITATIONS 27 Disclosure and discovery activity in this action are likely to involve production of 28 confidential, proprietary, or private information for which special protection from public 1 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM disclosure and from use for any purpose other than prosecuting this litigation may be warranted. 2 Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated 3 Protective Order. The parties acknowledge that this Order does not confer blanket protections on 4 all disclosures or responses to discovery and that the protection it affords from public disclosure 5 and use extends only to the limited information or items that are entitled to confidential treatment 6 under the applicable legal principles. The parties further acknowledge, as set forth in Section 7 12.3, below, that this Stipulated Protective Order does not entitle them to file confidential 8 information under seal; Civil Local Rule 141 sets forth the procedures that must be followed and 9 the standards that will be applied when a party seeks permission from the court to file material 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 1 under seal. 11 2. 12 13 14 DEFINITIONS 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is 15 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule 16 of Civil Procedure 26(c). 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 pertinent to 26 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 27 consultant in this action. 28 2.7 House Counsel: attorneys who are employees of a party to this action. House 2 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM 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 this 5 action but are retained to represent or advise a party to this action and have appeared in this action 6 on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party. 7 10 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs). 9 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 8 2.10 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 11 2.12 Professional Vendors: persons or entities that provide litigation support services 12 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and 13 organizing, storing, or retrieving data in any form or medium) and their employees and 14 subcontractors. 15 16 2.13 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 17 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 18 Producing Party. 19 3. SCOPE 20 The protections conferred by this Stipulation and Order cover not only Protected Material 21 (as defined above), but also (1) any information copied or extracted from Protected Material; (2) 22 all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 23 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 24 However, the protections conferred by this Stipulation and Order do not cover the following 25 information: (a) any information that is in the public domain at the time of disclosure to a 26 Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as 27 a result of publication not involving a violation of this Order, including becoming part of the 28 public record through trial or otherwise; and (b) any information known to the Receiving Party 3 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM 1 prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who 2 obtained the information lawfully and under no obligation of confidentiality to the Designating 3 Party. Any use of Protected Material at trial shall be governed by a separate agreement or order. 4 4. DURATION Even after final disposition of this litigation, the confidentiality obligations imposed by 6 this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court 7 order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all 8 claims and defenses in this action, with or without prejudice; and (2) final judgment herein after 9 the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 5 including the time limits for filing any motions or applications for extension of time pursuant to 11 applicable law. 12 5. 13 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party 14 or Non-Party that designates information or items for protection under this Order must take care 15 to limit any such designation to specific material that qualifies under the appropriate standards. 16 The Designating Party must designate for protection only those parts of material, documents, 17 items, or oral or written communications that qualify – so that other portions of the material, 18 documents, items, or communications for which protection is not warranted are not swept 19 unjustifiably within the ambit of this Order. 20 Mass, indiscriminate, or routinized designations are prohibited. Designations that are 21 shown to be clearly unjustified or that have been made for an improper purpose (e.g., to 22 unnecessarily encumber or retard the case development process or to impose unnecessary 23 expenses and burdens on other parties) expose the Designating Party to sanctions. 24 If it comes to a Designating Party’s attention that information or items that it designated 25 for protection do not qualify for protection, that Designating Party must promptly notify all other 26 Parties that it is withdrawing the mistaken designation. 27 28 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 4 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM 1 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 2 designated before the material is disclosed or produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic documents, but excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing 6 Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a 7 portion or portions of the material on a page qualifies for protection, the Producing Party also 8 must clearly identify the protected portion(s) (e.g., by making appropriate markings in the 9 margins). 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 5 A Party or Non-Party that makes original documents or materials available for inspection 11 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 13 of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the 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. 16 Then, before producing the specified documents, the Producing Party must affix the 17 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a portion or 18 portions of the material on a page qualifies for protection, the Producing Party also must clearly 19 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 20 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 21 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 other 24 tangible items, that the Producing Party affix in a prominent place on the exterior of the container 25 or containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a 26 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 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 5 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM 1 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. Upon timely correction of a 3 designation, the Receiving Party must make reasonable efforts to assure that the material is 4 treated in accordance with the provisions of this Order. 5 6. 6 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1. Timing of Challenges. Any Party or Non-Party may challenge a designation of designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic 9 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 8 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 7 challenge a confidentiality designation by electing not to mount a challenge promptly after the 11 original 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 14 for each challenge. To avoid ambiguity as to whether a challenge has been made, the written 15 notice must recite that the challenge to confidentiality is being made in accordance with this 16 specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in 17 good faith and must begin the process by conferring directly (in voice to voice dialogue; other 18 forms of communication are not sufficient) within 14 days of the date of service of notice. In 19 conferring, the Challenging Party must explain the basis for its belief that the confidentiality 20 designation was not proper and must give the Designating Party an opportunity to review the 21 designated material, to reconsider the circumstances, and, if no change in designation is offered, 22 to explain the basis for the chosen designation. A Challenging Party may proceed to the next 23 stage of the challenge process only if it has engaged in this meet and confer process first or 24 establishes that the Designating Party is unwilling to participate in the meet and confer process in 25 a timely manner. 26 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 27 intervention, the Designating Party shall file and serve a motion to retain confidentiality (and in 28 compliance with Civil Local Rule 141, if applicable) within 21 days of the initial notice of 6 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM challenge or within 14 days of the parties agreeing that the meet and confer process will not 2 resolve their dispute, whichever is earlier. Each such motion must be accompanied by a 3 competent declaration affirming that the movant has complied with the meet and confer 4 requirements imposed in the preceding paragraph. Failure by the Designating Party to make such 5 a motion including the required declaration within 21 days (or 14 days, if applicable) shall 6 automatically waive the confidentiality designation for each challenged designation. In addition, 7 the Challenging Party may file a motion challenging a confidentiality designation at any time if 8 there is good cause for doing so, including a challenge to the designation of a deposition 9 transcript or any portions thereof. Any motion brought pursuant to this provision must be 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 1 accompanied by a competent declaration affirming that the movant has complied with the meet 11 and confer requirements imposed by the preceding paragraph. 12 The burden of persuasion in any such challenge proceeding shall be on the Designating 13 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 14 unnecessary expenses and burdens on other 141parties) may expose the Challenging Party to 15 sanctions. Unless the Designating Party has waived the confidentiality designation by failing to 16 file a motion to retain confidentiality as described above, all parties shall continue to afford the 17 material in question the level of protection to which it is entitled under the Producing Party’s 18 designation 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 disclosed or 21 produced by another Party or by a Non-Party in connection with this case only for prosecuting, 22 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to 23 the categories of persons and under the conditions described in this Order. When the litigation has 24 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 25 DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a location and 27 in a secure manner that ensures that access is limited to the persons authorized under this Order. 28 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered 7 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM 1 by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any 2 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 Receiving Party to whom disclosure is reasonably necessary for this litigation and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 8 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 11 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 jurors, 15 and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who 16 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 18 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 19 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed 20 deposition testimony or exhibits to depositions that reveal Protected Material must be separately 21 bound by the court reporter and may not be disclosed to anyone except as permitted under this 22 Stipulated Protective Order. 23 (g) the author or recipient of a document containing the information or a custodian or 24 other person who otherwise possessed or knew the information. 25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 26 OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation that compels 28 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party 8 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM 1 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 in 5 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; 7 and 9 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 8 If the Designating Party timely seeks a protective order, the Party served with the 11 subpoena or court order shall not produce any information designated in this action as 12 “CONFIDENTIAL” before a determination by the court from which the subpoena or order 13 issued, unless the Party has obtained the Designating Party’s permission. The Designating Party 14 shall bear the burden and expense of seeking protection in that court of its confidential material – 15 and nothing in these provisions should be construed as authorizing or encouraging a Receiving 16 Party in this action to disobey a lawful directive from another court. 17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN 18 THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced by a Non-Party in 20 this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 21 connection with this litigation is protected by the remedies and relief provided by this Order. 22 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking 23 additional protections. 24 (b) In the event that a Party is required, by a valid discovery request, to produce a 25 Non-Party’s confidential information in its possession, and the Party is subject to an agreement 26 with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 27 28 (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; 9 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM 1 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in 2 this litigation, the relevant discovery request(s), and a reasonably specific description of the 3 information requested; and 4 (3) make the information requested available for inspection by the Non-Party. 5 (c) If the Non-Party fails to object or seek a protective order from this court within 14 days of receiving the notice and accompanying information, the Receiving Party may produce the 7 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely 8 seeks a protective order, the Receiving Party shall not produce any information in its possession 9 or control that is subject to the confidentiality agreement with the Non-Party before a 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 6 determination by the court. Absent a court order to the contrary, the Non-Party shall bear the 11 burden and expense of seeking protection in this court of its Protected Material. 12 10. 13 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 14 Material to any person or in any circumstance not authorized under this Stipulated Protective 15 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the 16 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 17 Protected Material, (c) inform the person or persons to whom unauthorized disclosures were 18 made of all the terms of this Order, and (d) request such person or persons to execute the 19 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A. 20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 21 PROTECTED MATERIAL 22 When a Producing Party gives notice to Receiving Parties that certain inadvertently 23 produced material is subject to a claim of privilege or other protection, the obligations of the 24 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This 25 provision is not intended to modify whatever procedure may be established in an e-discovery 26 order that provides for production without prior privilege review. Pursuant to Federal Rule of 27 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a 28 communication or information covered by the attorney-client privilege or work product 10 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM 1 protection, the parties may incorporate their agreement in the stipulated protective order 2 submitted to the court. 3 12. 4 5 MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order no Party waives any right it otherwise would have to object to disclosing or producing any 8 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 9 Party waives any right to object on any ground to use in evidence of any of the material covered 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 7 by this Protective Order. 11 12.3 Filing Protected Material. Without written permission from the Designating Party or 12 a court order secured after appropriate notice to all interested persons, a Party may not file in the 13 public record in this action any Protected Material. A Party that seeks to file under seal any 14 Protected Material must comply with Civil Local Rule 141. Protected Material may only be filed 15 under seal pursuant to a court order authorizing the sealing of the specific Protected Material at 16 issue. Pursuant to Civil Local Rule 141, a sealing order will issue only upon a request establishing 17 that the Protected Material at issue is privileged, protectable as a trade secret, or otherwise 18 entitled to protection under the law. If a Receiving Party's request to file Protected Material 19 under seal is denied by the court, then the Receiving Party may file the information in the public 20 record pursuant to Civil Local Rule 141 unless otherwise instructed by the court. 21 13. 22 FINAL DISPOSITION Within 60 days after the final disposition of this action, as defined in paragraph 4, each 23 Receiving Party must return all Protected Material to the Producing Party or destroy such 24 material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, 25 compilations, summaries, and any other format reproducing or capturing any of the Protected 26 Material. Whether the Protected Material is returned or destroyed, the Receiving Party must 27 submit a written certification to the Producing Party (and, if not the same person or entity, to the 28 Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all 11 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has 2 not retained any copies, abstracts, compilations, summaries or any other format reproducing or 3 capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to 4 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 5 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work 6 product, and consultant and expert work product, even if such materials contain Protected 7 Material. Any such archival copies that contain or constitute Protected Material remain subject to 8 this Protective Order as set forth in Section 4 (DURATION). 9 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 1 11 12 DATED: ________________________ /s/ Sarah L. Garvey Attorneys for Plaintiff DATED: ________________________ /s/ Dale L. Allen, Jr. Attorneys for Defendant 13 14 15 ORDER 16 The parties’ stipulated protective order filed on March 1, 2017 (Doc. 18) complies with 17 the requirements of Local Rules 141 and 141.1. Accordingly, IT IS HEREBY ORDERED that 18 the parties’ Stipulated Protective Order is APPROVED in its entirety. 19 20 21 22 IT IS SO ORDERED. Dated: /s/ Barbara March 2, 2017 A. McAuliffe _ UNITED STATES MAGISTRATE JUDGE 23 24 25 26 27 28 12 159932.1 ORDER ON STIPULATED PROT. ORDER 1:16-CV-01713-LJO-BAM

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