Cruz et al v. City of Rocklin et al

Filing 9

STIPULATION AND PROTECTIVE ORDER signed by District Judge Morrison C. England, Jr on 1/3/18. (Mena-Sanchez, L)

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BRUCE A. KILDAY (S.B. 066415)
Email: [e-mail]
JOHN A. WHITESIDES (S.B. 125611)
Email: [e-mail]
SEAN D. O’DOWD (S.B. 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 ROCKLIN, CHRIS OSBORN, JOHN CONSTABLE and
BREANNA ADAMS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CHERYL CRUZ, et al.,

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Plaintiffs,

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vs.
CITY OF ROCKLIN, et al.,

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Defendants.

) Case No.: 2:17-cv-01628-MCE-EFB
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) STIPULATION FOR PROTECTIVE
) ORDER; ORDER THEREON
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IT IS HEREBY AGREED AND STIPULATED BETWEEN THE PLAINTIFF, AND

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DEFENDANTS CITY OF ROCKLIN, CHRIS OSBORN, JOHN CONSTABLE, AND

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BREANNA ADAMS (hereinafter collectively referred to as “the Parties”), that all documents

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produced in this case pursuant to Fed. Rules Civ. Proc., rules 26, 30, 34 & 45 shall be governed

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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
-1STIPULATION FOR PROTECTIVE ORDER; ORDER THEREON

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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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-2STIPULATION FOR PROTECTIVE ORDER; ORDER THEREON

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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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IT IS SO STIPULATED.

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Dated: January 3, 2018

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ANGELO, KILDAY & KILDUFF, LLP
/s/ Sean D. O’Dowd
By:_________________________________
BRUCE A. KILDAY
SEAN D. O’DOWD
Attorneys for Defendants
CITY OF ROCKLIN, CHRIS OSBORN,
JOHN CONSTABLE and BREANNA
ADAMS

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Dated: December 20, 2017

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LAW OFFICE OF KELLAN PATTERSON
/s/ Kellan Patterson [as authorized
12/20/17]
By:_________________________________
KELLAN PATTERSON
Attorneys for Plaintiffs

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IT IS SO ORDERED.
Dated: January 3, 2018

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-3STIPULATION FOR PROTECTIVE ORDER; ORDER THEREON