Logan v. Patriot National, Inc., et al.

Filing 19

STIPULATED PROTECTIVE ORDER signed by District Judge Morrison C. England, Jr., on 11/8/17. (Kastilahn, A)

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1 2 3 4 5 6 7 8 9 10 11 JOANNA L. BROOKS, Bar No. 182986 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard, Suite 600 Walnut Creek, CA 94597 Telephone: 925.932.2468 Fax No.: 925.946.9809 BRITNEY N. TORRES, Bar No. 287019 LITTLER MENDELSON, P.C. 500 Capitol Mall, Suite 500 Sacramento, CA 95814 Telephone: 916.830.7200 Fax No.: 916.561.0828 Attorneys for Defendants PATRIOT NATIONAL, INC., PATRIOT RISK SERVICES, INC., PATRIOT CLAIM SERVICES, INC., AND PATRIOT RISK MANAGEMENT, INC. 12 UNITED STATES DISTRICT COURT 13 EASTERN DISTRICT OF CALIFORNIA 14 TAMMY LYNN LOGAN, an individual, 15 16 17 18 19 20 21 22 Plaintiff, Case No. 2:16-cv-01407-MCE-CKD STIPULATED PROTECTIVE ORDER v. PATRIOT NATIONAL, INC., A Delaware Corporation; PATRIOT RISK SERVICES, INC., A Delaware Corporation; PATRIOT CLAIM SERVICES, INC., A Delaware Corporation; PATRIOT RISK MANAGEMENT, INC., A Delaware Corporation; and DOES 1 through 50, inclusive, Defendants. 23 24 25 26 27 28 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 Case No. 2:16-CV-01407-MCE-CKD Firmwide:148707466.2 068868.1009 STIPULATED PROTECTIVE ORDER 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 disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, 5 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective 6 Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures 7 or responses to discovery and that the protection it affords from public disclosure and use extends 8 only to the limited information or items that are entitled to confidential treatment under the 9 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, below, that 10 this Stipulated Protective Order does not entitle them to file confidential information under seal; 11 Civil Local Rule 141 sets forth the procedures that must be followed and the standards that will be 12 applied when a party seeks permission from the court to file material under seal. 13 2. 14 15 16 DEFINITIONS 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it 17 is generated, stored or maintained) or tangible things that qualify for protection under Federal Rule 18 of Civil Procedure 26(c). 19 20 21 22 23 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their support staff). 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.” 2.5 Disclosure or Discovery Material: all items or information, regardless of the 24 medium or manner in which it is generated, stored, or maintained (including, among other things, 25 testimony, transcripts, and tangible things), that are produced or generated in disclosures or 26 responses to discovery in this matter. 27 28 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert Firmwide:148707466.2 068868.1009 Case No. 2:16-CV-01407-MCE-CKD 2. STIPULATED PROTECTIVE ORDER 1 witness or as a consultant in this action. 2 3 2.7 Counsel does not include Outside Counsel of Record or any other outside counsel. 4 5 House Counsel: attorneys who are employees of a party to this action. House 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 6 2.9 Outside Counsel of Record: attorneys who are not employees of a party to 7 this action but are retained to represent or advise a party to this action and have appeared in this 8 action on behalf of that party or are affiliated with a law firm which has appeared on behalf of that 9 party. 10 11 2.10 any party to this action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs). 12 13 Party: 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 14 2.12 Professional Vendors: persons or entities that provide litigation support 15 services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and 16 organizing, storing, or retrieving data in any form or medium) and their employees and 17 subcontractors. 18 19 2.13 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 20 2.14 21 a Producing Party. 22 3. Receiving Party: a Party that receives Disclosure or Discovery Material from SCOPE 23 The protections conferred by this Stipulation and Order cover not only Protected 24 Material (as defined above), but also (1) any information copied or extracted from Protected 25 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any 26 testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected 27 Material. However, the protections conferred by this Stipulation and Order do not cover the 28 following information: (a) any information that is in the public domain at the time of disclosure to a Firmwide:148707466.2 068868.1009 Case No. 2:16-CV-01407-MCE-CKD 3. LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 STIPULATED PROTECTIVE ORDER 1 Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a 2 result of publication not involving a violation of this Order, including becoming part of the public 3 record through trial or otherwise; and (b) any information known to the Receiving Party prior to the 4 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 5 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 6 Protected Material at trial shall be governed by a separate agreement or order. 7 4. DURATION 8 Even after final disposition of this litigation, the confidentiality obligations imposed 9 by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court 10 order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims 11 and defenses in this action, with or without prejudice; and (2) final judgment herein after the 12 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 13 including the time limits for filing any motions or applications for extension of time pursuant to 14 applicable law. 15 5. 16 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 17 Party or Non-Party that designates information or items for protection under this Order must take 18 care to limit any such designation to specific material that qualifies under the appropriate standards. 19 The Designating Party must designate for protection only those parts of material, documents, items, 20 or oral or written communications that qualify – so that other portions of the material, documents, 21 items, or communications for which protection is not warranted are not swept unjustifiably within 22 the ambit of this Order. 23 Mass, indiscriminate, or routinized designations are prohibited. Designations that are 24 shown to be clearly unjustified or that have been made for an improper purpose (e.g., to 25 unnecessarily encumber or retard the case development process or to impose unnecessary expenses 26 and burdens on other parties) expose the Designating Party to sanctions. 27 If it comes to a Designating Party’s attention that information or items that it 28 designated for protection do not qualify for protection, that Designating Party must promptly notify Firmwide:148707466.2 068868.1009 Case No. 2:16-CV-01407-MCE-CKD 4. LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 STIPULATED PROTECTIVE ORDER 1 2 all other Parties that it is withdrawing the mistaken designation. 5.2 Manner and Timing of Designations. Except as otherwise provided in this 3 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 4 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 5 designated before the material is disclosed or produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic documents, but 8 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 9 affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion 10 or portions of the material on a page qualifies for protection, the Producing Party also must clearly 11 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 12 A Party or Non-Party that makes original documents or materials available for 13 inspection need not designate them for protection until after the inspecting Party has indicated which 14 material it would like copied and produced. During the inspection and before the designation, all of 15 the material made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting 16 Party has identified the documents it wants copied and produced, the Producing Party must 17 determine which documents, or portions thereof, qualify for protection under this Order. Then, 18 before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL” 19 legend to each page that contains Protected Material. If only a portion or portions of the material on 20 a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) 21 (e.g., by making appropriate markings in the margins). 22 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 23 Designating Party identify on the record, before the close of the deposition, hearing, or other 24 proceeding, all protected testimony. 25 (c) for information produced in some form other than documentary and for any other 26 tangible items, that the Producing Party affix in a prominent place on the exterior of the container or 27 containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a 28 portion or portions of the information or item warrant protection, the Producing Party, to the extent Firmwide:148707466.2 068868.1009 Case No. 2:16-CV-01407-MCE-CKD 5. LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 STIPULATED PROTECTIVE ORDER 1 practicable, shall identify the protected portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 3 to designate qualified information or items does not, standing alone, waive the Designating Party’s 4 right to secure protection under this Order for such material. Upon timely correction of a 5 designation, the Receiving Party must make reasonable efforts to assure that the material is treated in 6 accordance with the provisions of this Order. 7 6. 8 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 9 of confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 10 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, 11 or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a 12 confidentiality designation by electing not to mount a challenge promptly after the original 13 designation is disclosed. 14 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 15 process by providing written notice of each designation it is challenging and describing the basis for 16 each challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 17 recite that the challenge to confidentiality is being made in accordance with this specific paragraph 18 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must 19 begin the process by conferring directly (in voice to voice dialogue; other forms of communication 20 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging 21 Party must explain the basis for its belief that the confidentiality designation was not proper and 22 must give the Designating Party an opportunity to review the designated material, to reconsider the 23 circumstances, and, if no change in designation is offered, to explain the basis for the chosen 24 designation. A Challenging Party may proceed to the next stage of the challenge process only if it 25 has engaged in this meet and confer process first or establishes that the Designating Party is 26 unwilling to participate in the meet and confer process in a timely manner. 27 28 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court intervention, the Designating Party shall file and serve a motion to retain confidentiality under Civil Firmwide:148707466.2 068868.1009 Case No. 2:16-CV-01407-MCE-CKD 6. STIPULATED PROTECTIVE ORDER 1 Local Rule 141.1 (and in compliance with Civil Local Rule 141, if applicable) within 21 days of the 2 initial notice of challenge or within 14 days of the parties agreeing that the meet and confer process 3 will not resolve their dispute, whichever is earlier. Each such motion must be accompanied by a 4 competent declaration affirming that the movant has complied with the meet and confer 5 requirements imposed in the preceding paragraph. Failure by the Designating Party to make such a 6 motion including the required declaration within 21 days (or 14 days, if applicable) shall 7 automatically waive the confidentiality designation for each challenged designation. In addition, the 8 Challenging Party may file a motion challenging a confidentiality designation at any time if there is 9 good cause for doing so, including a challenge to the designation of a deposition transcript or any 10 portions thereof. Any motion brought pursuant to this provision must be accompanied by a 11 competent declaration affirming that the movant has complied with the meet and confer 12 requirements imposed by the preceding paragraph. 13 The burden of persuasion in any such challenge proceeding shall be on the 14 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or 15 impose unnecessary expenses and burdens on other parties) may expose the Challenging Party to 16 sanctions. Unless the Designating Party has waived the confidentiality designation by failing to file a 17 motion to retain confidentiality as described above, all parties shall continue to afford the material in 18 question the level of protection to which it is entitled under the Producing Party’s designation until 19 the court rules on the challenge. 20 7. 21 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 22 disclosed or produced by another Party or by a Non-Party in connection with this case only for 23 prosecuting, defending, or attempting to settle this litigation. Such Protected Material may be 24 disclosed only to the categories of persons and under the conditions described in this Order. When 25 the litigation has been terminated, a Receiving Party must comply with the provisions of section 13 26 below (FINAL DISPOSITION). 27 28 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 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. Firmwide:148707466.2 068868.1009 Case No. 2:16-CV-01407-MCE-CKD 7. STIPULATED PROTECTIVE ORDER 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 2 ordered by the court or permitted in writing by the Designating Party, a Receiving Party may 3 disclose any information or item designated “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 5 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the 6 information for this litigation and who have signed the “Acknowledgment and Agreement to Be 7 Bound” that is attached hereto as Exhibit A; 8 9 10 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 12 reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement 13 to Be Bound” (Exhibit A); 14 (d) the court and its personnel; 15 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, 16 and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who 17 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 19 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 20 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material must be separately 22 bound by the court reporter and may not be disclosed to anyone except as permitted under this 23 Stipulated Protective Order. 24 (g) the author or recipient of a document containing the information or a custodian or 25 other person who otherwise possessed or knew the information. 26 8. 27 28 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION If a Party is served with a subpoena or a court order issued in other litigation that Firmwide:148707466.2 068868.1009 8. STIPULATED PROTECTIVE ORDER Case No. 2:16-CV-01407-MCE-CKD 1 compels disclosure of any information or items designated in this action as “CONFIDENTIAL,” that 2 Party must: 3 4 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 5 (b) promptly notify in writing the party who caused the subpoena or order to issue in 6 the other litigation that some or all of the material covered by the subpoena or order is subject to this 7 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 8 9 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 10 If the Designating Party timely seeks a protective order, the Party served with the 11 subpoena or court order shall not produce any information designated in this action as 12 “CONFIDENTIAL” before a determination by the court from which the subpoena or order issued, 13 unless the Party has obtained the Designating Party’s permission. The Designating Party shall bear 14 the burden and expense of seeking protection in that court of its confidential material – and nothing 15 in these provisions should be construed as authorizing or encouraging a Receiving Party in this 16 action to disobey a lawful directive from another court. 17 9. 18 19 20 21 22 23 24 25 26 27 28 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION (a) The terms of this Order are applicable to information produced by a Non-Party in this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional protections. (b) In the event that a Party is required, by a valid discovery request, to produce a Non-Party’s confidential information in its possession, and the Party is subject to an agreement with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; Firmwide:148707466.2 068868.1009 9. STIPULATED PROTECTIVE ORDER Case No. 2:16-CV-01407-MCE-CKD 1 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in 2 this litigation, the relevant discovery request(s), and a reasonably specific description of the 3 information requested; and 4 (3) make the information requested available for inspection by the Non-Party. 5 (c) If the Non-Party fails to object or seek a protective order from this court within 6 14 days of receiving the notice and accompanying information, the Receiving Party may produce the 7 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely 8 seeks a protective order, the Receiving Party shall not produce any information in its possession or 9 control that is subject to the confidentiality agreement with the Non-Party before a determination by 10 the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of 11 seeking protection in this court of its Protected Material. 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this Stipulated 15 Protective Order, the Receiving Party must immediately (a) notify in writing the Designating Party 16 of the unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 17 Protected Material, (c) inform the person or persons to whom unauthorized disclosures were made of 18 all the terms of this Order, and (d) request such person or persons to execute the “Acknowledgment 19 and Agreement to Be Bound” that is attached hereto as Exhibit A. 20 11. 21 22 23 24 25 26 27 28 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL When a Producing Party gives notice to Receiving Parties that certain inadvertently produced material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure may be established in an e-discovery order that provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a communication or information covered by the attorney-client privilege or work product protection, the parties may Firmwide:148707466.2 068868.1009 10. STIPULATED PROTECTIVE ORDER Case No. 2:16-CV-01407-MCE-CKD 1 incorporate their agreement in the stipulated protective order submitted to the court. 2 12. 3 4 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. 5 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 6 Order no Party waives any right it otherwise would have to object to disclosing or producing any 7 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 8 Party waives any right to object on any ground to use in evidence of any of the material covered by 9 this Protective Order. 10 12.3 Filing Protected Material. Without written permission from the Designating 11 Party or a court order secured after appropriate notice to all interested persons, a Party may not file 12 in the public record in this action any Protected Material. A Party that seeks to file under seal any 13 Protected Material must comply with Civil Local Rule 141. Protected Material may only be filed 14 under seal pursuant to a court order authorizing the sealing of the specific Protected Material at 15 issue. Pursuant to Civil Local Rule 141, a sealing order will issue only upon a request establishing 16 that the Protected Material at issue is privileged, protectable as a trade secret, or otherwise entitled to 17 protection under the law. If a Receiving Party's request to file Protected Material under seal pursuant 18 to Civil Local Rule 141(b) is denied by the court, then the Receiving Party may not file the 19 information in the public record. 20 13. FINAL DISPOSITION 21 Within 60 days after the final disposition of this action, as defined in paragraph 4, 22 each Receiving Party must return all Protected Material to the Producing Party or destroy such 23 material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, 24 compilations, summaries, and any other format reproducing or capturing any of the Protected 25 Material. Whether the Protected Material is returned or destroyed, the Receiving Party must submit a 26 written certification to the Producing Party (and, if not the same person or entity, to the Designating 27 Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected 28 Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained any Firmwide:148707466.2 068868.1009 Case No. 2:16-CV-01407-MCE-CKD 11. LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 STIPULATED PROTECTIVE ORDER 1 copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the 2 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of 3 all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 4 correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant 5 and expert work product, even if such materials contain Protected Material. Any such archival copies 6 that contain or constitute Protected Material remain subject to this Protective Order as set forth in 7 Section 4 (DURATION). 8 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 10 Dated: October 18, 2017 ARIAS SANGUINETTI STAHLE & TORRIJOS, LLP 11 By: /s/ Alfredo Torrijos Mike Arias, Esq. Alfredo Torrijos, Esq. 12 13 14 Attorneys for Plaintiff Tammy Lynn Logan 15 16 Dated: October 18, 2017 LITTLER MENDELSON 17 By: /s/ Britney N. Torres JoAnna L. Brooks, Esq. Britney N. Torres, Esq., 18 19 20 . Attorneys for Defendant Patriot National, Inc., Patriot Risk Services, Inc., Patriot Claim Services, Inc., and Patriot Risk Consultants, Inc. 21 22 23 24 25 PURSUANT TO STIPULATION, IT IS SO ORDERED. Dated: November 8, 2017 26 27 28 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard Suite 600 Walnut Creek, CA 94597 925.932.2468 Firmwide:148707466.2 068868.1009 12. STIPULATED PROTECTIVE ORDER Case No. 2:16-CV-01407-MCE-CKD

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