Cabral v. SaveMart Supermarkets, Inc.
Filing
16
STIPULATED PROTECTIVE ORDER signed by Judge John A. Mendez on 10/13/2015 ORDERING 15 Stipulated Protective Order is APPROVED. (Reader, L)
1
2
3
4
5
McCORMACK AND ERLICH, LLP
JASON M. ERLICH (SBN 203661)
150 Post Street, Suite 742
San Francisco, California 94108
Telephone: (415) 296-8420
Facsimile: (415) 296-8552
Email: jason@mcelawfirm.com
Attorneys for Plaintiff
RHONDA CABRAL
6
7
8
9
10
11
12
JACKSON LEWIS P.C.
CARY G. PALMER (SBN 186601)
HEATH A. HAVEY (SBN 244087)
801 K Street, Suite 2300
Sacramento, California 95814
Telephone: (916) 341-0404
Facsimile: (916) 341-0141
Email: PalmerC@jacksonlewis.com
Email: HaveyH@jacksonlewis.com
Attorneys for Defendant
SAVE MART SUPERMARKETS, INC.
13
14
UNITED STATES DISTRICT COURT
15
EASTERN DISTRICT OF CALIFORNIA
16
17
RHONDA CABRAL,
Plaintiff,
18
19
20
21
Case No. 2:15-CV-00994-JAM-KJN
STIPULATED PROTECTIVE ORDER
v.
SAVE MART SUPERMARKETS, INC; and
DOES 1 to 25,
Defendants.
22
23
24
25
26
27
28
1
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
1.
PURPOSES AND LIMITATIONS
2
Disclosure and discovery activity in this action are likely to involve production of
3
confidential, proprietary, or private information for which special protection from public
4
disclosure and from use for any purpose other than prosecuting this litigation may be warranted.
5
Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated
6
Protective Order. The parties acknowledge that this Order does not confer blanket protections on
7
all disclosures or responses to discovery and that the protection it affords from public disclosure
8
and use extends only to the limited information or items that are entitled to confidential treatment
9
under the applicable legal principles. The parties further acknowledge, as set forth in Section
10
12.3, below, that this Stipulated Protective Order does not entitle them to file confidential
11
information under seal; Civil Local Rules 141 (sealing) and 140 (redaction) sets forth the
12
procedures that must be followed and the standards that will be applied when a party seeks
13
permission from the court to file material under seal.
14
2.
15
16
DEFINITIONS
2.1
Challenging Party:
a Party or Non-Party that challenges the designation of
information or items under this Order.
17
2.2
“CONFIDENTIAL” Information or Items: information (regardless of how it is
18
generated, stored or maintained) or tangible things that qualify for protection under Federal Rule
19
of Civil Procedure 26(c); or private medical, therapeutic, or other patient information or records.
20
21
2.3
well as their support staff).
22
23
Counsel (without qualifier): Outside Counsel of Record and House Counsel (as
2.4
Designating Party: a Party or Non-Party that designates information or items that
it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
24
2.5
Disclosure or Discovery Material: all items or information, regardless of the
25
medium or manner in which it is generated, stored, or maintained (including, among other things,
26
testimony, transcripts, and tangible things), that are produced or generated in disclosures or
27
responses to discovery in this matter.
28
///
2
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
2.6
Expert: a person with specialized knowledge or experience in a matter pertinent to
2
the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
3
consultant in this action.
4
5
2.7
House Counsel: attorneys who are employees of a party to this action. House
Counsel does not include Outside Counsel of Record or any other outside counsel.
6
7
8
2.8
Non-Party: any natural person, partnership, corporation, association, or other legal
entity not named as a Party to this action.
9
2.9
Outside Counsel of Record: attorneys who are not employees of a party to this
10
action but are retained to represent or advise a party to this action and have appeared in this action
11
on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
12
13
2.10
consultants, retained experts, and Outside Counsel of Record (and their support staffs).
14
15
Party: any party to this action, including all of its officers, directors, employees,
2.11
Producing Party: a Party or Non-Party that produces Disclosure or Discovery
Material in this action.
16
2.12
Professional Vendors: persons or entities that provide litigation support services
17
(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
18
organizing, storing, or retrieving data in any form or medium) and their employees and
19
subcontractors.
20
21
2.13
Protected Material: any Disclosure or Discovery Material that is designated as
“CONFIDENTIAL.”
22
2.14
Receiving Party: a Party that receives Disclosure or Discovery Material from a
23
Producing Party.
24
3.
25
SCOPE
A.
The protections conferred by this Stipulation and Order cover not only Protected
26
Material (as defined above), but also (1) any information copied or extracted from Protected
27
Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any
28
testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected
3
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
Material. However, the protections conferred by this Stipulation and Order do not cover the
2
following information: (a) any information that is in the public domain at the time of disclosure to
3
a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as
4
a result of publication not involving a violation of this Order, including becoming part of the
5
public record through trial or otherwise; and (b) any information known to the Receiving Party
6
prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who
7
obtained the information lawfully and under no obligation of confidentiality to the Designating
8
Party. Any use of Protected Material at trial shall be governed by a separate agreement or order.
9
4.
10
DURATION
B.
Even after final disposition of this litigation, the confidentiality obligations
11
imposed by this Order shall remain in effect until a Designating Party agrees otherwise in writing
12
or a court order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal
13
of all claims and defenses in this action, with or without prejudice; and (2) final judgment herein
14
after the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this
15
action, including the time limits for filing any motions or applications for extension of time
16
pursuant to applicable law.
17
5.
18
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection. Each Party
19
or Non-Party that designates information or items for protection under this Order must take care
20
to limit any such designation to specific material that qualifies under the appropriate standards.
21
The Designating Party must designate for protection only those parts of material, documents,
22
items, or oral or written communications that qualify – so that other portions of the material,
23
documents, items, or communications for which protection is not warranted are not swept
24
unjustifiably within the ambit of this Order.
25
Mass, indiscriminate, or routinized designations are prohibited. Designations that are
26
shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
27
unnecessarily encumber or retard the case development process or to impose unnecessary
28
expenses and burdens on other parties) expose the Designating Party to sanctions.
4
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
If it comes to a Designating Party’s attention that information or items that it designated
2
for protection do not qualify for protection, that Designating Party must promptly notify all other
3
Parties that it is withdrawing the mistaken designation.
4
5.2
Manner and Timing of Designations. Except as otherwise provided in this Order
5
(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
6
Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
7
designated before the material is disclosed or produced.
8
Designation in conformity with this Order requires:
9
(a) for information in documentary form (e.g., paper or electronic documents, but
10
excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party
11
affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a
12
portion or portions of the material on a page qualifies for protection, the Producing Party also
13
must clearly identify the protected portion(s) (e.g., by making appropriate markings in the
14
margins).
15
A Party or Non-Party that makes original documents or materials available for inspection
16
need not designate them for protection until after the inspecting Party has indicated which
17
material it would like copied and produced. During the inspection and before the designation, all
18
of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the
19
inspecting Party has identified the documents it wants copied and produced, the Producing Party
20
must determine which documents, or portions thereof, qualify for protection under this Order.
21
Then, before producing the specified documents, the Producing Party must affix the
22
“CONFIDENTIAL” legend to each page that contains Protected Material. If only a portion or
23
portions of the material on a page qualifies for protection, the Producing Party also must clearly
24
identify the protected portion(s) (e.g., by making appropriate markings in the margins).
25
(b) for testimony given in deposition or in other pretrial or trial proceedings, that
26
the Designating Party identify on the record, before the close of the deposition, hearing, or other
27
proceeding, all protected testimony.
28
5
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
(c) for information produced in some form other than documentary and for any
2
other tangible items, that the Producing Party affix in a prominent place on the exterior of the
3
container or containers in which the information or item is stored the legend “CONFIDENTIAL.”
4
If only a portion or portions of the information or item warrant protection, the Producing Party, to
5
the extent practicable, shall identify the protected portion(s).
6
(d) for information produced by a Non-Party or in response to a subpoena, within a
7
reasonable period of time after receipt of the copies, a Party may designate the material or
8
information as “CONFIDENTIAL.”
9
5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
10
designate qualified information or items does not, standing alone, waive the Designating Party’s
11
right to secure protection under this Order for such material. Upon timely correction of a
12
designation, the Receiving Party must make reasonable efforts to assure that the material is
13
treated in accordance with the provisions of this Order.
14
6.
15
CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Any Party or Non-Party may challenge a designation of
16
confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
17
designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic
18
burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to
19
challenge a confidentiality designation by electing not to mount a challenge promptly after the
20
original designation is disclosed.
21
6.2
Meet and Confer. The Challenging Party shall initiate the dispute resolution
22
process by providing written notice of each designation it is challenging and describing the basis
23
for each challenge. To avoid ambiguity as to whether a challenge has been made, the written
24
notice must recite that the challenge to confidentiality is being made in accordance with this
25
specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in
26
good faith and must begin the process by conferring directly (in voice to voice dialogue; other
27
forms of communication are not sufficient) within 14 days of the date of service of notice. In
28
conferring, the Challenging Party must explain the basis for its belief that the confidentiality
6
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
designation was not proper and must give the Designating Party an opportunity to review the
2
designated material, to reconsider the circumstances, and, if no change in designation is offered,
3
to explain the basis for the chosen designation. A Challenging Party may proceed to the next stage
4
of the challenge process only if it has engaged in this meet and confer process first or establishes
5
that the Designating Party is unwilling to participate in the meet and confer process in a timely
6
manner.
7
6.3
Judicial Intervention.
If the Parties cannot resolve a challenge without court
8
intervention, the Designating Party shall file and serve a motion to retain confidentiality under
9
Civil Local Rule 141.1 within 21 days of the initial notice of challenge or within 14 days of the
10
parties agreeing that the meet and confer process will not resolve their dispute, whichever is
11
earlier. Each such motion must be accompanied by a competent declaration affirming that the
12
movant has complied with the meet and confer requirements imposed in the preceding paragraph.
13
Failure by the Designating Party to make such a motion including the required declaration within
14
21 days (or 14 days, if applicable) shall automatically waive the confidentiality designation for
15
each challenged designation. In addition, the Challenging Party may file a motion challenging a
16
confidentiality designation at any time if there is good cause for doing so, including a challenge to
17
the designation of a deposition transcript or any portions thereof. Any motion brought pursuant to
18
this provision must be accompanied by a competent declaration affirming that the movant has
19
complied with the meet and confer requirements imposed by the preceding paragraph.
20
The burden of persuasion in any such challenge proceeding shall be on the Designating
21
Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
22
unnecessary expenses and burdens on other parties) may expose the Challenging Party to
23
sanctions. Unless the Designating Party has waived the confidentiality designation by failing to
24
file a motion to retain confidentiality as described above, all parties shall continue to afford the
25
material in question the level of protection to which it is entitled under the Producing Party’s
26
designation until the court rules on the challenge.
27
///
28
///
7
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
2
7.
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is disclosed or
3
produced by another Party or by a Non-Party in connection with this case only for prosecuting,
4
defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to
5
the categories of persons and under the conditions described in this Order. When the litigation has
6
been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
7
DISPOSITION).
8
9
10
Protected Material must be stored and maintained by a Receiving Party at a location and in
a secure manner that ensures that access is limited to the persons authorized under this Order.
7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered
11
by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
12
information or item designated “CONFIDENTIAL” only to:
13
(a) the Receiving Party’s Outside Counsel of Record in this action, as well as
14
employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the
15
information for this litigation and who have signed the “Acknowledgment and Agreement to Be
16
Bound” that is attached hereto as Exhibit A;
17
(b)
the officers, directors, and employees (including House Counsel) of the
18
Receiving Party to whom disclosure is reasonably necessary for this litigation and who have
19
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20
(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
21
reasonably necessary for this litigation and who have signed the “Acknowledgment and
22
Agreement to Be Bound” (Exhibit A);
23
(d) the court and its personnel;
24
(e) court reporters and their staff, professional jury or trial consultants, mock
25
jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation
26
and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27
28
(f)
during their depositions, witnesses in the action to whom disclosure is
reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound”
8
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
(Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of
2
transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be
3
separately bound by the court reporter and may not be disclosed to anyone except as permitted
4
under this Stipulated Protective Order.
5
(g) the author or recipient of a document containing the information or a custodian
6
or other person who otherwise possessed or knew the information.
7
8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
8
LITIGATION
9
If a Party is served with a subpoena or a court order issued in other litigation that compels
10
disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
11
must:
12
13
(a)
promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order;
14
(b) promptly notify in writing the party who caused the subpoena or order to issue
15
in the other litigation that some or all of the material covered by the subpoena or order is subject
16
to this Protective Order. Such notification shall include a copy of this Stipulated Protective Order;
17
and
18
19
(c) cooperate with respect to all reasonable procedures sought to be pursued by the
Designating Party whose Protected Material may be affected.
20
If the Designating Party timely seeks a protective order, the Party served with the
21
subpoena or court order shall not produce any information designated in this action as
22
“CONFIDENTIAL” before a determination by the court from which the subpoena or order
23
issued, unless the Party has obtained the Designating Party’s permission. The Designating Party
24
shall bear the burden and expense of seeking protection in that court of its confidential material –
25
and nothing in these provisions should be construed as authorizing or encouraging a Receiving
26
Party in this action to disobey a lawful directive from another court.
27
///
28
///
9
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
9.
2
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
LITIGATION
3
(a) The terms of this Order are applicable to information produced by a Non-Party
4
in this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties
5
in connection with this litigation is protected by the remedies and relief provided by this Order.
6
Nothing in these provisions should be construed as prohibiting a Non-Party from seeking
7
additional protections.
8
(b) In the event that a Party is required, by a valid discovery request, to produce a
9
Non-Party’s confidential information in its possession, and the Party is subject to an agreement
10
with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
11
(1) promptly notify in writing the Requesting Party and the Non-Party that
12
some or all of the information requested is subject to a confidentiality agreement with a Non-
13
Party;
14
(2)
promptly provide the Non-Party with a copy of the Stipulated
15
Protective Order in this litigation, the relevant discovery request(s), and a reasonably specific
16
description of the information requested; and
17
18
(3) make the information requested available for inspection by the NonParty.
19
(c) If the Non-Party fails to object or seek a protective order from this court within
20
14 days of receiving the notice and accompanying information, the Receiving Party may produce
21
the Non-Party’s confidential information responsive to the discovery request. If the Non-Party
22
timely seeks a protective order, the Receiving Party shall not produce any information in its
23
possession or control that is subject to the confidentiality agreement with the Non-Party before a
24
determination by the court. Absent a court order to the contrary, the Non-Party shall bear the
25
burden and expense of seeking protection in this court of its Protected Material.
26
10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
27
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
28
Material to any person or in any circumstance not authorized under this Stipulated Protective
10
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the
2
unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
3
Protected Material, (c) inform the person or persons to whom unauthorized disclosures were made
4
of all the terms of this Order, and (d) request such person or persons to execute the
5
“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A.
6
11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
7
MATERIAL
8
When a Producing Party gives notice to Receiving Parties that certain inadvertently
9
produced material is subject to a claim of privilege or other protection, the obligations of the
10
Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
11
provision is not intended to modify whatever procedure may be established in an e-discovery
12
order that provides for production without prior privilege review. Pursuant to Federal Rule of
13
Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a
14
communication or information covered by the attorney-client privilege or work product
15
protection, the parties may incorporate their agreement in the stipulated protective order
16
submitted to the court.
17
12.
18
19
20
MISCELLANEOUS
12.1
Right to Further Relief. Nothing in this Order abridges the right of any person to
seek its modification by the court in the future.
12.2
Right to Assert Other Objections. By stipulating to the entry of this Protective
21
Order no Party waives any right it otherwise would have to object to disclosing or producing any
22
information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
23
Party waives any right to object on any ground to use in evidence of any of the material covered
24
by this Protective Order.
25
12.3
Filing Protected Material. Without written permission from the Designating Party
26
or a court order secured after appropriate notice to all interested persons, a Party may not file in
27
the public record in this action any Protected Material. A Party that seeks to file under seal any
28
Protected Material must comply with Civil Local Rule 141. Protected Material may only be filed
11
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
under seal pursuant to a court order authorizing the sealing of the specific Protected Material at
2
issue. Pursuant to Civil Local Rule 141, a sealing order will issue only upon a request establishing
3
that the Protected Material at issue is entitled to protection under the law. If a Receiving Party's
4
request to file Protected Material under seal pursuant to Civil Local Rule 141 is denied by the
5
court, then the Receiving Party may file the information in the public record unless otherwise
6
instructed by the court.
7
13.
FINAL DISPOSITION
8
Within 60 days after the final disposition of this action, as defined in paragraph 4, each
9
Receiving Party must return all Protected Material to the Producing Party or destroy such
10
material. As used in this subdivision, “all Protected Material” includes all copies, abstracts,
11
compilations, summaries, and any other format reproducing or capturing any of the Protected
12
Material.
13
Whether the Protected Material is returned or destroyed, the Receiving Party must submit
14
a written certification to the Producing Party (and, if not the same person or entity, to the
15
Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all
16
the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has
17
not retained any copies, abstracts, compilations, summaries or any other format reproducing or
18
capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to
19
retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
20
legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work
21
product, and consultant and expert work product, even if such materials contain Protected
22
Material. Any such archival copies that contain or constitute Protected Material remain subject to
23
this Protective Order as set forth in Section 4 (DURATION).
24
25
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: _______________, 2015
McCORMACK & ERLICH, LLP
26
By:
27
Jason M. Erlich
Attorneys for Plaintiff
RHONDA CABRAL
28
12
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
1
Dated: _______________, 2015
2
JACKSON LEWIS P.C.
By:
Heath A. Havey
Attorneys for Defendant
SAVE MART SUPERMARKETS, INC.
3
4
5
6
PURSUANT TO THE FOREGOING STIPULATION, IT IS SO ORDERED.
7
8
Dated: 10/13/2015
/s/ John A. Mendez_____________
United States District Court Judge
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
13
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
EXHIBIT A
1
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
I,
___________________________
[print
or
type
full
name],
of
______________________________________________ [print or type full address], declare
under penalty of perjury that I have read in its entirety and understand the Stipulated Protective
Order that was issued by the United States District Court for the Eastern District of California on
_____________ [date] in the case of Rhonda Cabral v. Save Mart Supermarkets, Inc., Case No.
2:15-CV-00994-JAM-KJN. I agree to comply with and to be bound by all the terms of this
Stipulated Protective Order and I understand and acknowledge that failure to so comply could
expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will
not disclose in any manner any information or item that is subject to this Stipulated Protective
Order to any person or entity except in strict compliance with the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court for the
Eastern District of California for the purpose of enforcing the terms of this Stipulated Protective
Order, even if such enforcement proceedings occur after termination of this action.
I hereby appoint __________________________ [print or type full name] of
_______________________________________________ [print or type full address and
telephone number] as my California agent for service of process in connection with this action or
any proceedings related to enforcement of this Stipulated Protective Order.
20
21
22
23
24
25
Date: ______________________________________
City and State where sworn and signed: _________________________________
Printed name: _______________________________
Signature: __________________________________
4852-5228-9577, v. 1
26
27
28
14
STIPULATED PROTECTIVE ORDER
2:15-CV-00994-JAM-KJN
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?