Robles v. Kaiser Permanente Medical Group

Filing 22

STIPULATED PROTECTIVE ORDER signed by Judge Morrison C. England, Jr on 8/18/2010. (Matson, R)

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MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP
CENTRE PLAZA OFFICE TOWER 1150 NINTH STREET, SUITE 1200

Matthew K. Hawkins, # 131117 Loura Erickson, # 258371 McCormick, Barstow, Sheppard, Wayte & Carruth LLP Centre Plaza Office Tower 1150 Ninth Street, Suite 1200 Modesto, CA 95354 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant THE PERMANENTE MEDICAL GROUP, INC. (sued erroneously herein as KAISER PERMANENTE)

(SPACE BELOW FOR FILING STAMP ONLY)

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

DINA ROBLES, Plaintiff, v. KAISER PERMANENTE, KATHY THOMAS, RONNIE COOK, Defendants.

Case No. 2:09-cv-2171-MCE-DAD STIPULATION FOR PROTECTIVE ORDER; ORDER

The parties hereto, through their respective counsel, stipulate to the following protective order. The parties agree that a copy of this Stipulation shall be sent to all counsel via facsimile, and counsel may sign and return the signed document to counsel for defendant The Permanente Medical Group, Inc. for attachment to the original of this Stipulation, and that said signature shall represent the original signature of the party. 1. CONFIDENTIAL INFORMATION. The parties consider any and all records or

documents produced in response to discovery requests in this case to be Confidential Information. /////
85124/00023-1592376.v1

STIPULATION TO PROTECTIVE ORDER AND [PROPOSED] ORDER 2:09-CV-2171

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MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP
CENTRE PLAZA OFFICE TOWER 1150 NINTH STREET, SUITE 1200

2.

PRODUCTION OF CONFIDENTIAL INFORMATION.

Promptly upon this

order being entered, filed, and served on the parties, all records produced since the inception of this litigation and any further document production, will be subject to this protective order. 3. LIMITATION ON DISCLOSURE OF CONFIDENTIAL INFORMATION.

Except with the prior written consent of all the other parties, or upon order of this Court, Confidential Information must not be disclosed to any person other than: a. b. c. d. e. the Court and Court personnel; the court reporter and videographer (if any) present at any hearing or deposition; counsel for the respective parties to this litigation, including employees and associates of counsel; persons who authored, prepared, or received the Confidential Information in a context outside this litigation; the named parties to this litigation, to include any officer or employee of the TPMG, to the extent deemed necessary by counsel for the prosecution or defense of this litigation; percipient witnesses; consultants or expert witnesses retained for the prosecution or defense of this litigation. Persons

f. g. 4.

LIMITATION ON USE OF CONFIDENTIAL INFORMATION.

receiving Confidential Information must not reveal or discuss that information to or with any person who is not entitled to receive the information, except as set forth in this order. 5. COPIES OF CONFIDENTIAL INFORMATION. This order does not restrict a

person who is properly in the possession of Confidential Information from (1) making working copies, abstracts, digests, and analyses of Confidential Information for use in connection with this litigation or (2) converting or translating Confidential Information into machine readable form for incorporation in a data retrieval system used in connection with this litigation. Any such copies, abstracts, digests, analyses, or data compilations have the same level of protection under the terms of this order as the Confidential Information from which they are derived. 85124/00023-1592376.v1 2
STIPULATION TO PROTECTIVE ORDER AND [PROPOSED] ORDER 2:09-CV-2171

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MCCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP
CENTRE PLAZA OFFICE TOWER 1150 NINTH STREET, SUITE 1200

6. CASE.

ALL CONFIDENTIAL INFORMATION TO BE USED ONLY FOR THIS All Confidential Information must be used by the party or parties to whom the

Confidential Information is produced solely for the purpose of this case. 7. CONCLUSION OF LITIGATION. The conclusion of this action is defined as 30

days after the expiration of the time to appeal or challenge any final judgment or settlement. All provisions of this order restricting the communication or use of Confidential Information continue to be binding after the conclusion of this action, unless otherwise agreed or ordered. Dated: August _____, 2010 McCORMICK, BARSTOW, SHEPPARD, WAYTE & CARRUTH LLP

By: /s/ Loura Erickson Matthew K. Hawkins Loura Erickson Attorneys for Defendant THE PERMANENTE MEDICAL GROUP, INC. (sued erroneously herein as KAISER PERMANENTE) Dated: August _____, 2010 RANDY J. HARVEY, P.C.

By: /s/ Randy Harvey____________________ Randy J. Harvey Attorneys for Plaintiff DINA ROBLES IT IS SO ORDERED.

DATED: August 18, 2010 __________________________________ MORRISON C. ENGLAND, JR UNITED STATES DISTRICT JUDGE

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STIPULATION TO PROTECTIVE ORDER AND [PROPOSED] ORDER 2:09-CV-2171

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