Ramos v. Los Rios Community College District

Filing 44

STIPULATION and PROTECTIVE ORDER signed by Magistrate Judge Kendall J. Newman on 6/29/2018. (Hunt, G)

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Attorneys for Plaintiff ANGELA RAMOS

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TELEPHONE: [phone] / FACSIMILE: [phone]

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

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2180 HARVARD STREET, SUITE 560
SACRAMENTO, CA 95815

Attorneys for DEFENDANT LOS RIOS COMMUNITY COLLEGE DISTRICT
Alexis S. McKenna, Esq., SBN: 197120
Elana R. Jacobs, Esq., SBN: 303178
WINER, McKENNA & BURRITT, LLP
1999 HARRISON STREET, SUITE 600
OAKLAND, CALIFORNIA 94612
Tel [phone]
Fax [phone]
[e-mail]

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JOHNSON SCHACHTER & LEWIS

ALESA SCHACHTER, ESQ. (SBN 102542)
[e-mail]
JASON M. SHERMAN, ESQ. (SBN 245190)
[e-mail]
JOHNSON SCHACHTER & LEWIS
A Professional Law Corporation
Harvard Square
2180 Harvard Street, Suite 560
Sacramento, CA 95815
Telephone: [phone]
Facsimile: [phone]

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

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ANGELA RAMOS, an individual,

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Plaintiff,
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v.
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LOS RIOS COMMUNITY COLLEGE
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DISTRICT, a public entity, THOMAS
KLOSTER dba METRO-MATH TUTORING )
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SERVICES, a company, THOMAS
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KLOSTER, an individual, DOES 1-50,
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inclusive,
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Defendants.
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CASE NO. 2:17-cv-01458-WBS-KJN
STIPULATION AND PROTECTIVE
ORDER
State Court Complaint Filed: June 13, 2017
Removed:
July 13, 2017
Date:
June 28, 2018
Time:
10:00 a.m.
Courtroom: 25
Before: The Hon. Kendall J. Newman
Trial Date:

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STIPULATION AND PROTECTIVE ORDER

September 24, 2019

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Disclosure and discovery in this action will involve production of confidential,

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proprietary, and/or private information for which the parties seek special protection from public

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disclosure and from use for any purpose other than in connection with the instant litigation.

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Accordingly, the parties hereby stipulate to the following protective order.

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2.

The parties acknowledge that this stipulated protective order creates no

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entitlement to file confidential information under seal. Civil Local Rule 141 sets forth the

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procedures that must be followed when a party seeks permission from the Court to file material

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under seal.

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3.

The following “Confidential Documents” are protected under the terms and

conditions of this stipulated protective order:
•

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TELEPHONE: [phone] / FACSIMILE: [phone]

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

2180 HARVARD STREET, SUITE 560
SACRAMENTO, CA 95815

JOHNSON SCHACHTER & LEWIS

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Personnel records regarding Thomas Kloster, including but not limited to, his

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personnel file, any other documents related to his job performance, any

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complaints, and any personnel action regarding him.

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Los Rios Community College District Police Department investigation files.

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•

Plaintiff’s academic, student, DSPS and financial aid files.

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4.

It is agreed that these Confidential Documents, and any part of them, shall be used

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solely in connection with this litigation and the preparation and trial of this case, or any related

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appellate proceeding, and not for any other purpose.

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5.

Confidential Documents may not be disclosed except as set forth in paragraph 6.

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“Disclosed” means that the documents themselves, or copies of the documents, or the substance

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of the documents are disseminated to any person by any means.

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6.

The Confidential Documents shall be retained by counsel for the parties to this

lawsuit and shall not be disclosed to anyone other than:
(a)

proceeds to trial;

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The court, its clerks and research attorneys and the jury, if this matter

(b)

Attorneys actively involved in the representation of a Party (as used herein,

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“Party” refers to an individual party, party representatives, guardian ad

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litem, and current and former employees of an entity party), their

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STIPULATION AND PROTECTIVE ORDER

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secretaries, paralegal, assistants, and other staff actively involved in

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assisting in the litigation;
(c)

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Any expert or consultant who is retained by any of the parties or their

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counsel of record to assist counsel in the litigation, and any employee of

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such an expert assisting in the litigation;
(d)

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Any person called to testify as a witness either at a deposition or court

also only if such persons are informed of the terms of this Protective Order;
(e)

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Deposition and court reporters and their support personnel, for purposes of
preparing transcripts;

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(f)

TELEPHONE: [phone] / FACSIMILE: [phone]

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

purposes of assisting in the preparation or examination of the witness, and

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2180 HARVARD STREET, SUITE 560
SACRAMENTO, CA 95815

proceeding in the litigation, but only to the extent necessary for the

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JOHNSON SCHACHTER & LEWIS

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Employees of outside copying services and other vendors retained by

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counsel to assist in the copying, imaging, handling or computerization of

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documents, but only to the extent necessary to provide such services in

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connection with the litigation and only after being informed of the

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provisions of this Protective Order and agreeing to abide by its terms;
(g)

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Mediators or other Alternative Dispute Resolution neutrals (including their

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employees, agents, and contractors) to whom disclosure is reasonably

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necessary to their involvement in the litigation;

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(h)

Any person who created a document or was the recipient thereof; and

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(i)

The Parties and their Insurance Carriers or claims representatives

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7.

At the conclusion of the Trial and any appeal, or upon other termination of this

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litigation, all confidential materials obtained by counsel for plaintiff, and all parts of such

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material, in possession of counsel for plaintiff, shall at the request of defense counsel return or

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destroy all Confidential Documents and all copies thereof made by or on behalf of other parties,

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and the other parties shall comply with such request unless otherwise ordered by the Court.

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Notwithstanding this provision, the attorneys for any Party are entitled to retain an archival copy

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STIPULATION AND PROTECTIVE ORDER

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of confidential materials and any copies with work product provided that such material is

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maintained in a manner designed to preserve its confidentiality.

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8.

The provisions of this Protective Order are without prejudice to the right of any

To apply to the court for an order compelling production of documents or modification of this

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Order or for any order permitting disclosure of confidential material beyond the terms of this

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Order.

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TELEPHONE: [phone] / FACSIMILE: [phone]

TELEPHONE: [phone] / FACSIMILE: [phone]

confidential material designation from any documents; (c) To object to a discovery request; (d)

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A PROFESSIONAL LAW CORPORATION

or relating to discovery in this litigation; (b) To apply to the court for an order removing the

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2180 HARVARD STREET, SUITE 560
SACRAMENTO, CA 95815

party: (a) To apply to the court for a further Protective Order relating to any confidential material

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JOHNSON SCHACHTER & LEWIS

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IT IS SO STUPULATED, THROUGH COUNSEL OF RECORD
Dated: June 11, 2018

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JOHNSON SCHACHTER & LEWIS
A Professional Law Corporation

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By:__/s/ Jason M. Sherman_______________
ALESA SCHACHTER
JASON M. SHERMAN
Attorney for Defendant LOS RIOS
COMMUNITY COLLEGE DISTRICT

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Dated: June 11, 2018

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WINER, McKENNA & BURRITT, LLP

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By:__/s/ Elana R. Jacobs (as auth. on 6/11/18)
ALEXIS S. McKENNA
ELANA R. JACOBS
Attorney for Plaintiff ANGELA RAMOS

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: June 29, 2018

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STIPULATION AND PROTECTIVE ORDER