Carefoot et al v. County of Kern et al
Filing
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STIPULATED PROTECTIVE ORDER, signed by Magistrate Judge Jennifer L. Thurston on 8/31/2017. (Hall, S)
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MARK L. NATIONS, COUNTY COUNSEL
By: ANDREW C. THOMSON, DEPUTY (SBN 149057)
Kern County Administrative Center
1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 93301
Telephone 661-868-3800
Fax 661-868-3805
Attorneys for Defendants County of Kern,
Duckworth, Stephens and Edwards
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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PRISCILLA CAREFOOT; J.H., a
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minor by and through his Guardian Ad )
Litem, Priscilla Carefoot,
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Plaintiff,
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vs.
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COUNTY OF KERN, by and through )
THE KERN COUNTY DEPARTMENT )
OF HUMAN SERVICES; KIM
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DUCKWORTH, an Individual; ANNIE )
STEPHENS, an Individual; KENISHA )
EDWARDS, an Individual; and DOES )
1 through 50, inclusive,
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Defendants.
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CASE NO. 1: 17-CV-00456-AWI-JLT
STIPULATION FOR A PROTECTIVE
ORDER; EXHIBIT A; PROPOSED ORDER
(Doc. 24)
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This Stipulation for a Protective Order (hereinafter the “Stipulation”) is agreed to by Plaintiffs
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J.H, a minor, by and through his guardian Plaintiff Priscilla Carefoot (hereinafter collectively
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“Plaintiffs”), and Defendants, County of Kern, Kim Duckworth, Annie Stephens and Kenisha
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Edwards (hereinafter collectively “Defendants”), (hereinafter Plaintiff and Defendants are
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collectively referred to as the “Parties”), by and through their respective attorneys of record.
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PROTECTIVE ORDER
1. PURPOSES AND LIMITATIONS
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Disclosure and discovery activity in this action are likely to involve production of
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confidential, proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may be warranted.
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STIPULATION FOR A PROTECTIVE ORDER AND PROPOSED ORDER
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Accordingly, the Parties in J.H., et al. v. County of Kern et al., USDC Eastern District of
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California Case No. 1:17-CV-00456-AWI-JLT petition the Court to enter the following
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Protective Order, with good cause appearing therefore:
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This Order does not confer blanket protections on all disclosures or responses to
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discovery and that the protection it affords from public disclosure and use extends only to the
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limited information or items that are entitled to confidential treatment under the applicable legal
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principles. As set forth in Section 12.3, below, this Protective Order does not entitle the Parties to
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file confidential information under seal.
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2. DEFINITIONS
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2.1
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Challenging Party:
a Party or Non-Party that challenges the designation of
information or items under this Order.
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2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is
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generated, stored or maintained) or tangible things that qualify for protection under Federal Rule
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of Civil Procedure 26(c).
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2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well
as their support staff).
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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.”
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2.5 Disclosure or Discovery Material: all items or information, regardless of the medium
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or manner in which it is generated, stored, or maintained (including, among other things,
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testimony, transcripts, and tangible things), that are produced or generated in disclosures or
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responses to discovery in this matter.
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2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to
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the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
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consultant in this action.
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2.7 House Counsel: attorneys who are employees of a Party to this action. House
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Counsel does not include Outside Counsel of Record or any other outside counsel.
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STIPULATION FOR A PROTECTIVE ORDER AND PROPOSED ORDER
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2.8 Non-Party: any natural person, partnership, corporation, association, or other legal
entity not named as a Party to this action.
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2.9 Outside Counsel of Record: attorneys who are not employees of a party to this
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action but are retained to represent or advise a party to this action and have appeared in this
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action on behalf of that party or are affiliated with a law firm which has appeared on behalf of
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that party.
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2.10 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).
2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
Material in this action.
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2.12 Professional Vendors: persons or entities that provide litigation support services
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(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
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organizing, storing, or retrieving data in any form or medium) and their employees and
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subcontractors.
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2.13 Protected Material: any Disclosure or Discovery Material that is designated as
“CONFIDENTIAL.”
2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a
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Producing Party.
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3. SCOPE
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The protections conferred by this Order cover not only Protected Material (as defined
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above), but also (1) any information copied or extracted from Protected Material; (2) all copies,
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excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
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conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
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However, the protections conferred by this Order do not cover the following information: (a) any
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information that is in the public domain at the time of disclosure to a Receiving Party or becomes
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part of the public domain after its disclosure to a Receiving Party as a result of publication not
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involving a violation of this Order, including becoming part of the public record through trial or
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otherwise; and (b) any information known to the Receiving Party prior to the disclosure or
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STIPULATION FOR A PROTECTIVE ORDER AND PROPOSED ORDER
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obtained by the Receiving Party after the disclosure from a source who obtained the information
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lawfully and under no obligation of confidentiality to the Designating Party. Any use of
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Protected Material at trial shall be governed by a separate agreement or order.
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4. DURATION
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Even after final disposition of this litigation, the confidentiality obligations imposed by
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this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court
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order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all
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claims and defenses in this action, with or without prejudice; and (2) final judgment herein after
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the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this
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action, including the time limits for filing any motions or applications for extension of time
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pursuant to applicable law.
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5. DESIGNATING PROTECTED MATERIAL
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5.1 Exercise of Restraint and Care in Designating Material for Protection
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Each Party or Non-Party that designates information or items for protection under this
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Order must take care to limit any such designation to specific material that qualifies under the
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appropriate standards. The Designating Party must designate for protection only those parts of
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material, documents, items, or oral or written communications that qualify – so that other
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portions of the material, documents, items, or communications for which protection is not
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warranted are not swept unjustifiably within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations that are
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shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
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unnecessarily encumber or retard the case development process or to impose unnecessary
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expenses and burdens on other Parties) expose the Designating Party to sanctions.
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If it comes to a Designating Party’s attention that information or items that it designated
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for protection do not qualify for protection, the Designating Party must promptly notify all other
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Parties that it is withdrawing the mistaken designation.
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STIPULATION FOR A PROTECTIVE ORDER AND PROPOSED ORDER
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5.2 Manner and Timing of Designations
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Except as otherwise provided in this Order (see, e.g., second paragraph of section 5.2(a)
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below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for
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protection under this Order must be clearly so designated before the material is disclosed or
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produced. Designation in conformity with this Order requires:
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(a)
for information in documentary form (e.g., paper or electronic documents, but
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excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing
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Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only
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a portion or portions of the material on a page qualifies for protection, the Producing Party also
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must clearly identify the protected portion(s) (e.g., by making appropriate markings in the
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margins).A Party or Non-Party that makes original documents or materials available for
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inspection need not designate them for protection until after the inspecting Party has indicated
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which 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 wants copied and
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produced, the Producing Party must determine which documents, or portions thereof, qualify for
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protection under this Order. Then, before producing the specified documents, the Producing
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Party must affix the “CONFIDENTIAL” legend to each page that contains Protected Material.
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If only a portion or portions of the material on a page qualifies for protection, the
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Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate
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markings in the margins).
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(b) for testimony given in deposition or in other pretrial or trial proceedings, that the
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Designating Party identify on the record, before the close of the deposition, hearing, or other
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proceeding, all protected testimony.
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(c) for information produced in some form other than documentary and for any other
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tangible items, that the Producing Party affix in a prominent place on the exterior of the
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container[s] in which the information or item is stored the legend \“CONFIDENTIAL.” If only a
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portion or portions of the information or item warrant protection, the Producing Party, to the
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extent practicable, shall identify the protected portion(s).
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5.3 Inadvertent Failure to Designate
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If timely corrected, an inadvertent failure to designate qualified information or items does
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not, standing alone, waive the Designating Party’s right to secure protection under this Order for
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such material. Upon timely correction of a designation, the Receiving Party must make
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reasonable efforts to assure that the material is treated in accordance with the provisions of this
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Order.
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6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
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6.1 Timing of Challenges
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Any Party may challenge a designation of confidentiality at any time. Unless a prompt
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challenge to a Designating Party’s confidentiality designation is necessary to avoid foreseeable,
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substantial unfairness, unnecessary economic burdens, or a significant disruption or delay of the
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litigation, the challenge must be brought within a reasonable time or it is waived.
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6.2 Meet and Confer
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The Challenging Party shall initiate the dispute resolution process by providing written
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notice of each designation it is challenging and describing the basis for each challenge. To avoid
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ambiguity as to whether a challenge has been made, the written notice must recite that the
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challenge to confidentiality is being made in accordance with this specific paragraph of the
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Protective Order. The Parties shall attempt to resolve each challenge in good faith and must
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begin the process by conferring directly (in voice to voice dialogue; other forms of
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communication are not sufficient) within 14 days of the date of service of notice. In conferring,
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the Challenging Party must explain the basis for its belief that the confidentiality designation was
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not proper and must give the Designating Party an opportunity to review the designated material,
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to reconsider the circumstances, and, if no change in designation is offered, to explain the basis
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for the chosen designation. A Challenging Party may proceed to the next stage of the challenge
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process only if it has engaged in this meet and confer process first or establishes that the
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Designating Party is unwilling to participate in the meet and confer process in a timely manner.
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STIPULATION FOR A PROTECTIVE ORDER AND PROPOSED ORDER
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6.3 Judicial Intervention
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If the Parties cannot resolve a challenge after meeting and conferring, the Challenging
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Party SHALL initiate an informal, telephonic conference with the assigned Magistrate Judge as
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required by the scheduling order. At that conference, the Court will attempt to resolve the matter
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without need for formal motion practice. If, in the Court’s view, the matter can only be resolved
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through formal motion practice, the Court will authorize the Challenging Party to file a motion
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which SHALL comply with Local Rule 251(c).
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As with motions to compel, the Challenging Party SHALL bear the initial burden of
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demonstrating that the Designating Party has improperly marked the material as confidential. If
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this showing is made, the burden will shift and as with motions for protective orders under
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Federal Rules of Civil Procedure 26(c), the burden of establishing the need for the
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confidentiality—as with any evidentiary privilege—must be borne by the Designating Party who
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is asserting it. Frivolous challenges, and those made for an improper purpose (e.g., to harass or
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impose unnecessary expenses and burdens on other Parties) may expose the Challenging Party to
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sanctions. All Parties shall continue to afford the material in question the level of protection to
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which it is entitled under the Producing Party’s designation until the court rules on the challenge.
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7. ACCESS TO AND USE OF PROTECTED MATERIAL
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7.1 Basic Principles
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A Receiving Party may use Protected Material that is disclosed or produced by another
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Party or by a Non-Party in connection with this case only for prosecuting, defending, or
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attempting to settle this litigation. Such Protected Material may be disclosed only to the
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categories of persons and under the conditions described in this Order. When the litigation has
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been terminated, a Receiving Party must comply with the provisions of section 13 below
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(FINAL DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a location and
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in a secure manner that ensures that access is limited to the persons authorized under this Order.
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7.2 Disclosure of “CONFIDENTIAL” Information or Items
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Unless otherwise ordered by the court or permitted in writing by the Designating Party, a
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
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of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information
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for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that
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is attached hereto as Exhibit A;
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(b) the officers, directors, and employees (including House Counsel) of the Receiving
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Party to whom 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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(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
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reasonably necessary for this litigation and who have signed the “Acknowledgment and
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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 jurors, and
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Professional Vendors 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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(f) during their depositions, witnesses in the action to whom disclosure is reasonably
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necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
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A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of
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transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be
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separately bound by the court reporter and may not be disclosed to anyone except as permitted
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under this Protective Order.
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(g) the author or recipient of a document containing the information or a custodian or
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other person who otherwise possessed or knew the information.
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STIPULATION FOR A PROTECTIVE ORDER AND PROPOSED ORDER
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8. PROTECTED MATERIAL SUBPOENAED AND/OR ORDERED PRODUCED IN
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OTHER LITIGATION
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If a Party is served with a subpoena/court order issued in other litigation that compels
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disclosure of information/items designated in this action as “CONFIDENTIAL,” that Party must:
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(a) promptly notify in writing the Designating Party. Such notification shall include a
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copy of the subpoena or court order;
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(b) promptly notify in writing the party who caused the subpoena or order to issue in the
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other litigation that some or all of the material covered by the subpoena or order is subject to this
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Protective Order. Such notification shall include a copy of this Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be pursued by the
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Designating Party whose Protected Material may be affected. If the Designating Party timely
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seeks a protective order, the Party served with the subpoena or court order shall not produce any
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information designated in this action as “CONFIDENTIAL” before a determination by the court
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from which the subpoena or order issued, unless the Party has obtained the Designating Party’s
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permission. The Designating Party shall bear the burden and expense of seeking protection in
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that court of its confidential material – and nothing in these provisions should be construed as
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authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from
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another court.
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9.
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THIS LITIGATION
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN
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(a) The terms of this Order are applicable to information produced by a Non-Party in this
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action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in
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connection with this litigation is protected by the remedies and relief provided by this Order.
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Nothing in these provisions should be construed as prohibiting a Non-Party from seeking
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additional protections.
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(b) In the event that a Party is required, by a valid discovery request, to produce a Non-
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Party’s confidential information in its possession, and the Party is subject to an agreement with
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the Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
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(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;
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(2) promptly provide the Non-Party with a copy of the Protective Order in this litigation,
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the relevant discovery request(s), and a reasonably specific description of the information
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requested; and
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(3) make the information requested available for inspection by the Non-Party.
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(c) If the Non-Party fails to object or seek a protective order from this court within 14
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days of receiving the notice and accompanying information, the Receiving Party may produce
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the Non-Party’s confidential information responsive to the discovery request. If the Non-Party
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timely seeks a protective order, the Receiving Party shall not produce any information in its
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possession or control that is subject to the confidentiality agreement with the Non-Party before a
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determination by the court. Absent a court order to the contrary, the Non-Party shall bear the
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burden and expense of seeking protection in this court of its Protected Material.
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10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
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If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
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Material to any person or in any circumstance not authorized under this Protective Order, the
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Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized
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disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material,
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(c) inform the person or persons to whom unauthorized disclosures were made of all the terms of
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this Order, and (d) request such person or persons to execute the “Acknowledgment and
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Agreement to Be Bound” that is attached hereto as Exhibit A.
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11.
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PROTECTED MATERIAL
INADVERTENT
PRODUCTION
OF
PRIVILEGED
OR
OTHERWISE
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When a Producing Party gives notice to Receiving Parties that certain inadvertently
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produced material is subject to a claim of privilege or other protection, the obligations of the
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Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
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provision is not intended to modify whatever procedure may be established in an e-discovery
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order that provides for production without prior privilege review. Pursuant to Federal Rule of
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Evidence 502(d) and (e), insofar as the Parties reach an agreement on the effect of disclosure of a
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communication or information covered by the attorney-client privilege or work product
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protection, the Parties may incorporate their agreement in the stipulated protective order
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submitted to the court.
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12. MISCELLANEOUS
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12.1 Right to Further Relief
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Nothing in this Order abridges the right of any person to seek its modification by the
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court in the future.
12.2 Right to Assert Other Objections
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The entry of this Protective Order does not imply any Party’s waiver of any right it
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otherwise would have to object to disclosing or producing any information or item on any
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ground not addressed in this Protective Order. Similarly, no Party waives any right to object on
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any ground to use in evidence of any of the material covered by this Protective Order.
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12.3 Filing Protected Material
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Without written permission from the Designating Party or a court order secured after
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appropriate notice to all interested persons, a Party may not file in the public record in this action
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any Protected Material. A Party that seeks to file under seal any Protected Material must comply
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with the applicable local rules. Protected Material may only be filed under seal pursuant to a
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court order authorizing the sealing of the specific Protected Material at issue. A sealing order
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will issue only upon a request establishing that the Protected Material at issue is privileged,
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protectable as a trade secret, or otherwise entitled to protection under the law. If a Receiving
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Party's request to file Protected Material under seal is denied by the court, then the Receiving
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Party may file the information in the public record unless otherwise instructed by the court.
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13. FINAL DISPOSITION
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Within 60 days after the final disposition of this action, as defined in paragraph 4, each
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Receiving Party must return all Protected Material to the Producing Party or destroy such
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material. As used in this subdivision, “all Protected Material” includes all copies, abstracts,
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compilations, summaries, and any other format reproducing or capturing any of the Protected
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Material. Whether the Protected Material is returned or destroyed, the Receiving Party must
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submit a written certification to the Producing Party (and, if not the same person or entity, to the
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Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all
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the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has
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not retained any copies, abstracts, compilations, summaries or any other format reproducing or
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capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to
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retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
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legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work
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product, and consultant and expert work product, even if such materials contain Protected
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Material. Any such archival copies that contain or constitute Protected Material remain subject
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to this Protective Order as set forth in Section 4 (DURATION).
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Dated: August 31, 2017
MARK L. NATIONS, COUNTY COUNSEL
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By /s/ Andrew C. Thomson
Andrew C. Thomson, Deputy
Attorneys for Defendants County of Kern,
Duckworth, Stephens and Edwards
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Dated: August 31, 2017
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By /s/ Daniel Sharpe
Daniel Sharpe, Esq.
Attorneys for Plaintiffs
J.H., a minor and Priscilla Carefoot
ORDER
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LAW OFFICE OF VINCENT W. DAVIS
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IT IS SO ORDERED.
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Dated:
August 31, 2017
/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, _____________________________ [print or type full name], of _________________ [print
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or type full address], declare under penalty of perjury that I have read in its entirety and
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understand the Protective Order that was issued by the United States District Court for the
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Eastern District of California on [date] in the case of M.M., a minor, et al v. County of Kern et
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al., USDC Eastern District of California Case No. 1:16-CV-00376-DAD-JLT.
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I agree to comply with and to be bound by all the terms of this Protective Order and I
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understand and acknowledge that failure to so comply could expose me to sanctions and
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punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner
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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 Eastern
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District of California for the purpose of enforcing the terms of this Protective Order, even if
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such enforcement proceedings occur after termination of this action.
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I hereby appoint ____________________________________________ [print/type full name]
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of ________________________________________ [print/type full address and telephone
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number] as my California agent for service of process in connection with this action or any
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proceedings related to enforcement of this Protective Order.
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Date: ______________________________________
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City and State where sworn and signed: _________________________________
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Printed name: _______________________________
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Signature: __________________________________
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