Merino et al v. El Dorado Hills County Water District

Filing 43

STIPULATED PROTECTIVE ORDER signed by Magistrate Judge Dale A. Drozd on 2/17/12. (Kaminski, H)

1
2
3
4
5
6

WILLIAM J. GORHAM III, SB No. 151773
MAYALL HURLEY
A Professional Corporation
2453 Grand Canal Boulevard, Second Floor
Stockton, California 95207-8253
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant,
El Dorado Hills County Water District

7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11
12

DAVID MERINO; STEVE MARANVILLE;
KARA MERINO; BRENDA
MARANVILLE,

13
14
15
16
17

No. 2:10-CV-02152-LKK-DAD
STIPULATED PROTECTIVE ORDER

Plaintiffs,
vs.
EL DORADO HILLS COUNTY WATER
DISTRICT; and DOES 1-50,
Defendants.

18
19

In order to preserve and maintain the confidentiality of documents consisting of or

20

related to privacy rights of employees of El Dorado Hills County Water District, counsel

21

for El Dorado Hills County Water District and counsel for Plaintiffs David Merino and

22

Steve Maranville agree and stipulate to the following. (Plaintiffs and Defendant are

23

individually referred to as a “Party.” Plaintiffs and Defendant are collectively referred to

24

as the “Parties.”)

25

1.

This Stipulated Protective Order governs the production and handling of

26

internal documents that refer, relate to, or name present and past employees of Defendant

27

El Dorado Hills County Water District who are not named in this action.

28

_______________________
Stipulated Protective Order
Page 1 of 3

2.

1

All documents that refer, relate to, or name present and past employees of

2

Defendant who are not named in this action produced to the Parties shall be used only in

3

the litigation of the lawsuit entitled David Merino; et al. v. El Dorado Hills County Water

4

District; et al., Case No. 2:10-CV-02152-LKK-DAD, and in no other action, civil,

5

administrative, or for any improper purpose.
3.

6

All documents that refer, relate to, or name present and past employees

7

produced to the Parties shall not, without leave of court, be communicated, in any way, to

8

anyone other than this Court, the Parties in this action and their counsel, paralegals and

9

secretaries, except as produced herein. Each party in this action and its counsel shall be

10

advised of, and bound, by the terms of this Order.
4.

11

The Parties and their counsel agree that counsel may show the documents

12

referenced in paragraph 1 to the Parties and may use them at deposition, in motions, and

13

at trial. However, the Parties’ counsel shall not give the Parties, or anyone else, copies of

14

any such document, except to experts, investigators, and/or consultants who agree to the

15

terms of this Order and the return of the documents at the conclusion of this case.
5.

16

Communication of the contents of the documents pursuant thereto to

17

persons who are assisting counsel in the preparation and trial of this action, and to persons

18

who may be called upon to testify in the action with respect to the documents or

19

information contained therein, shall be permitted, provided that, before obtaining access

20

to such documents or information, each such person shall be advised that the matters in

21

those documents should not be discussed outside the context of the action.
6.

22

The Parties and their counsel agree that the documents referenced in

23

paragraph 1 will be used only for purposes of this litigation and that all such documents,

24

and any copies of them, will be returned to Defendant El Dorado Hills County Water

25

District’s counsel at the end of this litigation.

26
27

//

28

_______________________
Stipulated Protective Order
Page 2 of 3

1

Dated: 2/17/12

MAYALL HURLEY, P.C.

2

By

3
4

/s/
WILLIAM J. GORHAM III, Attorneys for
Defendant, El Dorado Hills County Water District

5
6

Dated: 2/17/12

CHOUDHARY LAW OFFICE

7

By
8
9

/s/
JOEL RAPAPORT, Attorneys for Plaintiffs,
DAVID MERINO and STEVE MARANVILLE

10

ORDER

11
12
13

IT IS SO ORDERED.
Dated: February 17, 2012

14
15
16
17
18
19

DDAD1\orders.civil\merino2152.stip.protord

20
21
22
23
24
25
26
27
28

_______________________
Stipulated Protective Order
Page 3 of 3