Smith v. City of Stockton, et al

Filing 86

ORDER signed by Magistrate Judge Carolyn K. Delaney on 3/3/2016. Court hereby GRANTS parties' 85 Stipulation for Protective Order over all documents produced in case. (Marciel, M)

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MAYALL, HURLEY, P.C.
A Professional Corporation
2453 Grand Canal Boulevard, Second Floor
Stockton, California 95207-8253
Telephone [phone]
MARK E. BERRY, ESQ.
CA State Bar No. 155091
DERICK E. KONZ, ESQ.
CA State Bar No. 286902

Attorneys for Defendant,
Deputy Sheriff JOHN NESBITT

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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) No. 2:10-CV-02495-MCE-CKD
)
) STIPULATION FOR PROTECTIVE
) ORDER AND PROPOSED ORDER
)
Plaintiffs,
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vs.
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Police Officer ERIC AZARVAND; Police
)
Officer GREGORY DUNN; Deputy Sheriff )
JOHN NESBITT
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)
Defendants.
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)
DIONNE SMITH-DOWNS and JAMES E.
RIVERA, SR., both individually and as
Successors-In-Interest to the Estate of
JAMES E. RIVERA, JR.

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IT IS HEREBY AGREED AND STIPULATED BETWEEN THE PLAINTIFFS, and

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DEFENDANTS ERIC AZARVAND, GREGORY DUNN and JOHN NESBITT, that all

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documents produced in this case pursuant to Fed. Rules Civ. Proc., rules 26, 30, 34 & 45 shall be

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governed by this protective order.

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The documents shall be used by the parties solely for the purpose of prosecuting and

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defending the above captioned case.

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transmitted, or communicated to any person for any reason other than counsel; clients; experts

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retained for the purpose of furthering the defense of or prosecution of the plaintiff’s case;

The documents shall not be duplicated, reproduced,

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STIPULATION FOR PROTECTIVE ORDER AND PROPOSED ORDER
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deposition and trial witnesses; mediator or third party neutral; or the court. The copying of

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produced documents is to be conducted in-house and shall not be done by outside third party

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vendors.

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All copies of protected documents distributed by counsel to any party for purpose of

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prosecuting or defending the litigation shall be returned to counsel at the conclusion of the

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litigation and counsel shall store and ultimately destroy the documents consistent with individual

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firm policy.

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This Order shall constitute a protective order pursuant to Fed. Rules Civ. Proc., rule 26(c)
and shall be enforceable as set forth therein.

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STIPULATED AND AGREED.
MAYALL HURLEY, P.C.

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DATED: March 1, 2016

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/s/ Mark E. Berry
__________________________________________
MARK E. BERRY, ESQ.
Attorney for Defendant, JOHN NESBITT

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ANGELO, KILDAY & KILDUFF, LLP

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DATED: March 1, 2016

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/s/ Amie McTavish (as authorized on 2/22/16)
__________________________________________
AMIE MCTAVISH, ESQ.
Attorney for Defendants, ERIC AZARVAND and
GREGORY DUNN

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LAW OFFICES OF JOHN L. BURRIS

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DATED: March 1, 2016

/s/ Benjamin Nisenbaum (as authorized on 2/29/16)
__________________________________________
BENJAMIN NISENBAUM, ESQ.
Attorney for Plaintiffs, DIONNE SMITH-DOWNS and
JAMES E. RIVERA, SR., both individually and as
Successors-In-Interest to the Estate of JAMES E. RIVERA,
JR.,

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_____________________________________________
STIPULATION FOR PROTECTIVE ORDER AND PROPOSED ORDER
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ORDER

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Having considered the stipulation of the parties and good cause appearing, the court

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hereby GRANTS the parties’ foregoing stipulation for a protective order over all documents

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produced in this case.

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IT IS SO ORDERED.
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Dated: March 3, 2016

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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STIPULATION FOR PROTECTIVE ORDER AND PROPOSED ORDER
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