Porter v. Munoz et al

Filing 27

STIPULATION FOR PROTECTIVE ORDER and ORDER signed by District Judge Leslie E. Kobayashi on 10/11/17. (Kastilahn, A)

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BRUCE A. KILDAY, ESQ., SB No. 66415
Email: [e-mail]
SEAN D. O’DOWD, ESQ., 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 SERGEANT MUNOZ and CITY OF DAVIS (also sued herein as
CITY OF DAVIS POLICE DEPARTMENT)

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KELLAN STEVEN PATTERSON, SBN 307190
Email: [e-mail]
LAW OFFICES OF KELLAN PATTERSON
P.O. BOX 5042
Sacramento, CA 95814
Telephone: [phone]
Fax: [phone]

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA

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LASONJA PORTER,

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Plaintiff,
vs.

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SERGEANT MUNOZ in his individual
capacity, DOES 1-10 in their individual
capacities, CITY OF DAVIS POLICE
DEPARTMENT, CITY OF DAVIS,

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Defendants.

) Case No.: 2:16-01702-LEK-EFB
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) STIPULATION FOR PROTECTIVE
) ORDER AND ORDER
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IT IS HEREBY AGREED AND STIPULATED BETWEEN THE PLAINTIFF, AND

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DEFENDANTS SERGEANT MUNOZ and CITY OF DAVIS (also sued herein as CITY OF

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DAVIS POLICE DEPARTMENT) (hereinafter collectively referred to as “the Parties”), 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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Absent a separate agreement between the Parties, in writing, all documents produced in

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this case shall be used by the Parties solely for the purpose of prosecuting and defending the

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above-captioned case. The documents shall not be duplicated, reproduced, transmitted, or

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communicated to any person for any reason other than counsel; clients; experts retained for the

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purpose of furthering the defense of or prosecution of the Plaintiff’s case; deposition and trial

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witnesses; mediator or third party neutral; or the Court. The copying of produced documents is to

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be conducted in-house and shall not be done by outside third party 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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Nothing in this agreement shall be interpreted to limit Plaintiff’s ability to obtain and

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disseminate documents procured outside this litigation, including, but not limited to, documents

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obtained pursuant to a request under the California Public Records Act (Gov. Code § 6250 et.

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seq.).

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This Order shall constitute a protective order pursuant to Fed. Rules Civ. Proc., rule 26(c)

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and shall be enforceable as set forth therein.

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The above is stipulated to by the respective counsel for the parties as follows:

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Dated: October 11, 2017

ANGELO, KILDAY & KILDUFF, LLP
/s/ Sean D. O’Dowd
By:_________________________________
BRUCE A. KILDAY
SEAN D. O’DOWD
Attorneys for Defendants
SERGEANT MUNOZ and CITY OF
DAVIS (also sued herein as CITY OF
DAVIS POLICE DEPARTMENT)

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Dated: October 11, 2017

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LAW OFFICE OF KELLAN PATTERSON
/s/ Kellan Patterson (as authorized on
9/29/2017)
By:_________________________________
KELLAN STEVEN PATTERSON
Attorney for Plaintiff
LASONJA PORTER

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ORDER
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IT IS SO ORDERED.
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Dated: October 11, 2017

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/s/ Leslie E. Kobayashi
Leslie E. Kobayashi
United States District Judge

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STIPULATION FOR PROTECTIVE ORDER AND PROPOSED ORDER