Bonilla-Chirinos, et al. v. City of West Sacramento, et al.

Filing 13

PROTECTIVE ORDER signed by Magistrate Judge Edmund F. Brennan on 4/21/2016 ORDERING the Court hereby GRANTS the parties' foregoing stipulation for a protective order over all documents produced in this case. (Reader, L)

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AMIE McTAVISH (SB No. 242371)
Email: [e-mail]
SEAN D. O’DOWD (SB No. 296320)
Email: [e-mail]
ANGELO, KILDAY & KILDUFF, LLP
Attorneys at Law
601 University Avenue, Suite 150
Sacramento, CA 95825
Telephone: [phone]

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Telecopier: [phone]

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Attorneys for Defendants CITY OF WEST SACRAMENTO and KENNETH FELLOWS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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) Case No.: 2:15-cv-02564-WBS-EFB
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)
) STIPULATION FOR PROTECTIVE
) ORDER AND PROPOSED ORDER
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Plaintiffs,
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vs.
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CITY OF WEST SACRAMENTO,
KENNETH FELLOWS (BADGE #151) AND )
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DOES 1 THROUGH 99,
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Defendants.
______________________________________ )
GUILLERMO BONILLA-CHIRINOS,
SANDRA HERNANDEZ, INDIVIDUALLY
AND AS GUARDIANS AD LITEM OF J B,
A MINOR

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IT IS HEREBY AGREED AND STIPULATED BETWEEN THE PLAINTIFFS, AND

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DEFENDANTS CITY OF WEST SACRAMENTO AND KENNETH FELLOWS, 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. The documents shall not be duplicated, reproduced,

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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 plaintiffs’ case;

-1STIPULATION 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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Dated: April 21, 2016

ANGELO, KILDAY & KILDUFF, LLP
/s/ Sean D. O’Dowd
By:_________________________________
AMIE McTAVISH
SEAN D. O’DOWD
Attorneys for Defendants
CITY OF WEST SACRAMENTO and
KENNETH FELLOWS

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Dated: April 14, 2016

LAW OFFICE OF ARMANDO S.
MENDEZ
/s/ Armando S. Mendez (as authorized on
4/14/2016)
By:_________________________________
ARMANDO S. MENDEZ
Attorney for Plaintiffs

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-2STIPULATION 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.
Dated: April 21, 2016

________________________________________
EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE

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-3STIPULATION FOR PROTECTIVE ORDER AND PROPOSED ORDER