McKeon et al v. Central Valley Community Sports Foundation et al

Filing 74

Stipulated Protective ORDER Re: Use of Video Recorded Deposition, signed by Magistrate Judge Barbara A. McAuliffe on 5/17/19. (Martin-Gill, S)

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DAVID J. WEILAND #160447
[e-mail]
KEITH M. WHITE #188536
[e-mail]
COLEMAN & HOROWITT, LLP
Attorneys at Law
499 West Shaw, Suite 116
Fresno, California 93704
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
CENTRAL VALLEY COMMUNITY
SPORTS FOUNDATION, a non-profit
corporation, dba GATEWAY ICE CENTER; and
JEFF BLAIR

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MEGAN MCKEON; LAILA NEAL, A
MINOR BY AND THROUGH HER
GUARDIAN AD LITEM, TINA NEAL; and
TINA NEAL,

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Case No. 1:18-CV-00358-DAD-BAM
STIPULATED PROTECTIVE ORDER
RE: USE OF VIDEO RECORDED
DEPOSITIONS

Plaintiffs,
v.
CENTRAL VALLEY COMMUNITY
SPORTS FOUNDATION, a Non-Profit
Corporation, dba GATEWAY ICE CENTER;
and JEFF BLAIR, an individual; and DOES 1
through 50, Inclusive,
Defendants.

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Defendants CENTRAL VALLEY COMMUNITY SPORT FOUNDATATION, a Non-

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Profit Corporation, dba GATEWAY ICE CENTER (“CVCSF”) and JEFF BLAIR (“Blair”)

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(CVCSF and Blair are collectively “Defendants”) and Plaintiffs, MEGAN MCKEON, LAILA

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NEAL by and through her Guardian Ad Litem, Tina Neal, and TINA NEAL (“collectively

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“Plaintiffs”) by and through their counsel of record, hereby agree and stipulate that the Court enter

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an order prohibiting the use and distribution of any video recording of depositions taken in this
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STIPULATED PROTECTIVE ORDER

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matter in any manner outside of the direct litigation without prior approval of the Court. If either

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party wants to use any video recording of depositions for any purpose outside of this litigation,

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they shall file a motion with the Court requesting prior approval for such a use. Counsel for the

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parties shall retain control of any such video recordings of depositions to prevent unapproved use

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or distribution.

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Dated: May 16, 2019

COLEMAN & HOROWITT, LLP

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By:

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/s/ Keith M. White
KEITH M. WHITE
Attorneys for Defendants, CENTRAL
VALLEY COMMUNITY
SPORTS FOUNDATION, a Non-Profit
Corporation, dba GATEWAY ICE
CENTER; and
JEFF BLAIR

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Dated: May 16, 2019

HATMAKER LAW GROUP

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By_ /s/ Rachelle Taylor Golden__________
RACHELLE TAYLOR GOLDEN
Attorney for Plaintiffs, MEGAN
MCKEON, TINA NEAL and
LAILA NEAL

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STIPULATED PROTECTIVE ORDER

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ORDER
Pursuant to the stipulation of the parties through their counsel of record, IT IS HEREBY
ORDERED that:

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The use and distribution of any video recording of depositions taken in this matter in any

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manner outside of the direct litigation without prior approval of the Court is PROHIBITED. If

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either party wants to use any video recording of depositions for any purpose outside of this

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litigation, they shall file a motion with the Court requesting prior approval for such a use. Counsel

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for the parties shall retain control of any such video recordings of depositions to prevent

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unapproved use or distribution.

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IT IS SO ORDERED.

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Dated:

May 17, 2019

/s/ Barbara

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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STIPULATED PROTECTIVE ORDER