Clifford et al v. Placer County et al

Filing 19

STIPULATED PROTECTIVE ORDER signed by Magistrate Judge Carolyn K. Delaney on 3/6/12. (Becknal, R)

1
2
3
4
5
6

PLACER COUNTY COUNSEL’S OFFICE
David K. Huskey (SBN 109329)
175 Fulweiler Avenue
Auburn, California 95603
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants PLACER COUNTY
and the PLACER COUNTY SHERIFF’S DEPARTMENT

7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11
12
13
14
15
16
17
18
19
20
21
22

THE ESTATE OF ROBERT (BOBBY)
S. CLIFFORD, LINDA K. CLIFFORD,
individually with right of survivorship
and in her capacity as the personal
representative of THE ESTATE OF
ROBERT (BOBBY) S. CLIFFORD;
MICHAEL HUTHMAN, individually
with right of survivorship,

)
)
)
)
)
)
)
)
)
Plaintiffs,
)
vs.
)
)
PLACER COUNTY, the PLACER
)
COUNTY SHERIFF’S DEPARTMENT, )
DEFENDANT OFFICER JOHN DOE, )
individually and in his official capacity as )
a police officer, DOES 2-50, Inclusive, )
)
Defendants.
)

Case No. 2:11-CV-02591-LKK-CKD
STIPULATION FOR PROTECTIVE
ORDER RE DOCUMENTS
DISCLOSED IN CLIFFORD v.
PLACER COUNTY, ET AL.

23
24

I.

25

INTRODUCTION

26

The parties through their attorneys of record have agreed to the following protective

27

order to govern the handling of the documents turned over from the Placer County Sheriff’s

28
1

Stipulation for Protective Order

1

Dept. in the Clifford v. Placer County case referenced above. The documents subject to the

2

protective order will hereinafter be referred to as “documents.”

3

II.

4

DOCUMENTS SUBJECT TO THE PROTECTIVE ORDER

5

All documents must be Bates stamped, marked “subject to protective order,” and

6

marked “Clifford.” Counsel for defendants may decide what Placer County documents to

7

designate as subject to the protective order, and shall have them marked as described above.

8

III.

9

PROCEDURE FOR MODIFYING SCOPE OF THIS PROTECTIVE ORDER

10

If plaintiffs’ counsel wishes to modify the scope of this protective order, he must

11

obtain the written agreement of defendants’ counsel. If defendants’ counsel will not agree

12

in writing to the request, then plaintiffs' counsel must bring a noticed motion to the

13

magistrate assigned to hear discovery matters in this case.

14

IV.

15

RESTRICTIONS IMPOSED BY THIS PROTECTIVE ORDER

16

Plaintiffs’ counsel, their law office staff and their experts may use and copy the

17

documents subject to the protective order for purposes of the Clifford v. Placer County

18

litigation, and for no other purpose. While plaintiffs may view these documents at the

19

discretion of their counsel, plaintiffs may not make, receive or keep copies of these

20

documents.

21

If plaintiffs' counsel wishes for experts to receive a copy of the documents in

22

question, he must have them sign an acknowledgement that they received a copy of the

23

protective order and agree to abide by its terms before turning over the documents or copies

24

thereof. Plaintiffs’ counsel will be responsible for keeping all such acknowledgements of

25

the terms and conditions of the protective order until the conclusion of the case noted above.

26
27

All persons receiving documents pursuant to this protective order agree to return all
copies of the documents to the counsel for defendants at the conclusion of this case.

28
2

Stipulation for Protective Order

1
2

I have read the foregoing protective order and agree to abide by its terms and
conditions.

3
4

Dated: _____________

WALSTON CROSS, P.C.

5
6
7

By:

8

ORESTES A. CROSS

9

Attorney for Plaintiffs the ESTATE OF
ROBERT CLIFFORD, LINDA
CLIFFORD, individually with right of
survivorship and in her capacity as the
personal representative of the Estate of
Robert Clifford, Michael Huthman,
individually with right of survivorship

10
11
12
13
14
15

Dated: March 2, 2012

PLACER COUNTY COUNSEL’S OFFICE

16
17

By:

/s/ DAVID K. HUSKEY
DAVID K. HUSKEY

18

Attorneys for Defendants PLACER
COUNTY and the PLACER COUNTY
SHERIFF’S DEPARTMENT

19
20
21
22
23
24
25
26
27
28
3

Stipulation for Protective Order

1

ORDER

2
3
4

Having read and considered the foregoing stipulation for a protective order, and good
cause appearing therefore, it is hereby ordered that the stipulation for a protective order will
be enforced as an order of this court.

5

IT IS SO ORDERED.

6
7

Dated: March 6, 2012

8

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

9
10
11
12
13
14
15
16
17

DEAC_Signature-END:

18
19
20
21
22
23
24

234b0d4o

25
26
27
28
4

Stipulation for Protective Order