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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1 2 3 4 5 6 7 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: +1.714.830.0600 Fax: +1.714.830.0700 Attorneys for Defendants GOLDEN STATE FC LLC and AMAZON.COM, INC. 8 9 10 11 12 13 14 15 16 17 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: +1.818.883.4900 Fax: +1.714.830.0700 Lonnie C. Blanchard, III, Bar No. 93530 The Blanchard Law Group, APC 3311 East Pico Boulevard Los Angeles, CA 90023 Tel: +1.213.599.8255 Fax: +1.213.402.3949 Attorneys for Plaintiff JUAN TREVINO 18 19 UNITED STATES DISTRICT COURT 20 EASTERN DISTRICT OF CALIFORNIA 21 22 JUAN TREVINO, an individual, on behalf of himself and all others similarly situated, 23 24 25 26 27 28 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 1 [PROPOSED] STIPULATED RULE 502(d) ORDER 1 IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff Juan Trevino on 2 behalf of himself and all others similarly situated (“Plaintiff”) and Defendants Golden State FC 3 LLC and, Inc. (“Defendants”) (collectively, the “Parties”), by and through their 4 respective counsel of record, in order to allow the Parties to respond to discovery expeditiously 5 while limiting discovery costs, hereby stipulate for an order pursuant to Federal Rule of Evidence 6 502(d) that states: 7 Pursuant to Federal Rule of Evidence 502(d), neither the attorney-client privilege nor the 8 work product protection is waived by disclosure of such information in this litigation. The 9 production of privileged or work product protected documents, whether in electronically stored 10 information or other materials, is not a waiver of the privilege or protection in this case or in any 11 other federal or state proceeding. If any privileged or work product protected documents are 12 produced, the party receiving produced documents (“Receiving Party”) shall, at the request of the 13 party producing those documents (“Producing Party”), promptly return such documents (and all 14 copies thereof), including all later created excerpts, summaries, compilations, and other 15 documents or records that include, communicate, or reveal the information claimed to be 16 privileged or protected. A Receiving Party who receives a document that it knows or reasonably 17 should know is privileged shall notify the Producing Party within 3 business days of discovery of 18 the document. 19 Nothing in this Order overrides any attorney’s ethical responsibilities to refrain from 20 examining or disclosing materials that the attorney knows or reasonably should know to be 21 privileged and to inform the Producing Party that such materials have been produced. 22 Nothing in this Order is intended to or shall serve to limit a party’s right to conduct a 23 review of documents, ESI or information (including metadata) for relevance, responsiveness 24 and/or segregation of privileged and/or protected information before production. 25 26 27 28 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 2 [PROPOSED] STIPULATED RULE 502(d) ORDER 1 2 3 The obligations imposed by this Rule 502(d) Order shall survive the termination of this action. IT IS SO STIPULATED. 4 5 PETER R. DION-KINDEM, P.C. Dated: March 12, 2018 6 By /s/ Peter R. Dion-Kindem Peter R. Dion-Kindem Attorney for Plaintiff JUAN TREVINO 7 8 9 Dated: March 12, 2018 MORGAN, LEWIS & BOCKIUS LLP 10 11 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. 12 13 14 15 16 17 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 18 19 20 21 PURSUANT TO STIPULATION, IT IS SO ORDERED. 22 23 24 Dated: March 12, 2018 /s/ Michael J. Seng UNITED STATES MAGISTRATE JUDGE 25 26 27 28 MORGAN, LEWIS & BOCKIUS LLP ATTORNEYS AT LAW COSTA MESA 3 [PROPOSED] STIPULATED RULE 502(d) ORDER

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