Trevino v. Golden State FC LLC et al

Filing 19

ORDER on Stipulated Federal Rule of Evidence 502(D), signed by Magistrate Judge Michael J. Seng on 3/12/2018. (Hellings, J)

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MORGAN, LEWIS & BOCKIUS LLP
Barbara J. Miller, Bar No. 167223
Roberta H. Kuehne, Bar No. 225067
Joel M. Purles, Bar No. 266208
600 Anton Boulevard, Suite 1800
Costa Mesa, CA 92626-7653
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants
GOLDEN STATE FC LLC and AMAZON.COM, INC.

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Peter R. Dion-Kindem, Bar No. 95267
The Dion-Kindem Law Firm
Peter R. Dion-Kindem, P.C.
21550 Oxnard Street, Suite 900
Woodland Hills, CA 91367
Tel: [phone]
Fax: [phone]
[e-mail]
Lonnie C. Blanchard, III, Bar No. 93530
The Blanchard Law Group, APC
3311 East Pico Boulevard
Los Angeles, CA 90023
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
JUAN TREVINO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JUAN TREVINO, an individual, on behalf of
himself and all others similarly situated,

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Case No. 1:18-cv-00120-DAD-MJS
[PROPOSED] STIPULATED FEDERAL
RULE OF EVIDENCE 502(D) ORDER

Plaintiff,
vs.

Complaint Filed: July 12, 2017

GOLDEN STATE FC, LLC, a Delaware
Limited Liability Company; AMAZON.COM,
INC., a Delaware Corporation, and DOES 1
through 10,
Defendants.

MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

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[PROPOSED] STIPULATED RULE 502(d) ORDER

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff Juan Trevino on

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behalf of himself and all others similarly situated (“Plaintiff”) and Defendants Golden State FC

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LLC and Amazon.com, Inc. (“Defendants”) (collectively, the “Parties”), by and through their

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respective counsel of record, in order to allow the Parties to respond to discovery expeditiously

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while limiting discovery costs, hereby stipulate for an order pursuant to Federal Rule of Evidence

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502(d) that states:

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Pursuant to Federal Rule of Evidence 502(d), neither the attorney-client privilege nor the

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work product protection is waived by disclosure of such information in this litigation. The

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production of privileged or work product protected documents, whether in electronically stored

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information or other materials, is not a waiver of the privilege or protection in this case or in any

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other federal or state proceeding. If any privileged or work product protected documents are

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produced, the party receiving produced documents (“Receiving Party”) shall, at the request of the

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party producing those documents (“Producing Party”), promptly return such documents (and all

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copies thereof), including all later created excerpts, summaries, compilations, and other

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documents or records that include, communicate, or reveal the information claimed to be

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privileged or protected. A Receiving Party who receives a document that it knows or reasonably

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should know is privileged shall notify the Producing Party within 3 business days of discovery of

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the document.

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Nothing in this Order overrides any attorney’s ethical responsibilities to refrain from

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examining or disclosing materials that the attorney knows or reasonably should know to be

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privileged and to inform the Producing Party that such materials have been produced.

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Nothing in this Order is intended to or shall serve to limit a party’s right to conduct a

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review of documents, ESI or information (including metadata) for relevance, responsiveness

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and/or segregation of privileged and/or protected information before production.

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The provisions of Federal Rule of Evidence 502(b)(2) are inapplicable to the production
of protected information under this Order.
This Order shall be interpreted to provide the maximum protection allowed by Federal
Rule of Evidence 502(d).

MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

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[PROPOSED] STIPULATED RULE 502(d) ORDER

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The obligations imposed by this Rule 502(d) Order shall survive the termination of this
action.
IT IS SO STIPULATED.

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PETER R. DION-KINDEM, P.C.
Dated: March 12, 2018

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By /s/ Peter R. Dion-Kindem
Peter R. Dion-Kindem
Attorney for Plaintiff
JUAN TREVINO

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Dated: March 12, 2018

MORGAN, LEWIS & BOCKIUS LLP

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By /s/ Roberta H. Kuehne
Barbara J. Miller
Roberta H. Kuehne
Joel M. Purles
Attorneys for Defendants
GOLDEN STATE FC LLC and AMAZON.COM, INC.

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I attest that I have obtained Peter R. Dion-Kindem’s concurrence in the filing of this
document.
/s/ Roberta H. Kuehne
Roberta H. Kuehne

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PURSUANT TO STIPULATION,
IT IS SO ORDERED.

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Dated:

March 12, 2018

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

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[PROPOSED] STIPULATED RULE 502(d) ORDER