Alger v. FCA US LLC

Filing 40

AMENDED ADDENDUM to 19 Stipulated Protective Order signed by Magistrate Judge Edmund F. Brennan on 10/25/18. (Kastilahn, A)

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KERSHAW, COOK & TALLEY PC
William A. Kershaw (State Bar No. 057486)
Stuart C. Talley (State Bar No. 180374)
Ian J. Barlow (State Bar No. 262213)
401 Watt Avenue
Sacramento, California 95864
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Plaintiff and the putative Class

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DYKEMA GOSSETT LLP
James P. Feeney (State Bar No. 219045)
Dommond E. Lonnie (State Bar No. 142662)
Abirami Gnanadesigan (State Bar No. 263375)
333 South Grand Ave., Suite 2100
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Defendant
FCA US LLC f/k/a Chrysler Group LLC
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Case No.: 2:18-cv-00360-MCE-EFB

SHAWN ALGER as an individual and on
behalf of all others similarly situated,

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AMENDED ADDENDUM TO
STIPULATED PROTECTIVE ORDER

Plaintiff,
v.
FCA US LLC f/k/a CHRYSLER GROUP
LLC, a Delaware Corporation, and DOES 1
through 100, inclusive,

Assigned to Hon. Morrison C. England, Jr.
Courtroom 7, 14th Floor
Complaint Filed: February 16, 2018

Defendants.

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AMENDED ADDENDUM TO STIP PROTECTIVE ORDER

2:18-cv-00360-MCE-EFB

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WHEREAS, on July 25, 2018 the court entered a Protective Order in this case to protect
from disclosure various documents produced by the Parties to this litigation;

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WHEREAS, after the issuance of the Protective Order, plaintiff served third party subpoenas
seeking documents and testimony from third parties;

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WHEREAS, the Parties desire to allow confidential documents and testimony produced by

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such third parties to be protected from disclosure pursuant to the Protective Order entered int his

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case.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD, that Section 2.7 of the

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Protective Order is hereby amended to read as follows: “Party: any party to this action, or any third

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party producing documents or deposition testimony in response to a subpoena served in this action,

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including all of its officer, directors, employees, consultants, retained experts, and Counsel (and

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their support staffs).”

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IT IS FURTHER STIPULATED, THROUGH COUNSEL OF RECORD, that Section 7.2(f)

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of the Protective Order is hereby amended to read as follows: any actual or anticipated witnesses in

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the action to whom disclosure is reasonably necessary and who have signed the “Acknowledgment

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and Agreement to Be Bound” (Exhibit A), and their Counsel, unless otherwise agreed by the

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Designating Part or ordered by the court. Pages of transcribed deposition testimony or exhibits to

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depositions that reveal Protected Material must be separately bound by the court reporter and may

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not be disclosed to anyone except as permitted under this Stipulated Protective Order.

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Dated: October 23, 2018.

Respectfully submitted,
KERSHAW, COOK & TALLEY PC

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By: /s/ Stuart C. Talley
STUART C. TALLEY
WILLIAM A. KERSHAW
IAN J. BARLOW
Attorneys for Plaintiff and the putative Class

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AMENDED ADDENDUM TO STIP PROTECTIVE ORDER

2:18-cv-00360-MCE-EFB

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Dated: October 23, 2018.

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DYKEMA GOSSETT LLP

By: /s/ Fred J. Fresard
DOMMOND E. LONNIE
JAMES P. FEENEY
FRED J. FRESARD
ABIRAMI GNANADESIGAN
BRITTANY MOUSOURAKIS
Attorneys for Defendant
FCA US LLC f/k/a/ Chrysler Group LLC

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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: October 25, 2018.
EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE

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AMENDED ADDENDUM TO STIP PROTECTIVE ORDER

2:18-cv-00360-MCE-EFB