Juan Francisco Martinez v. County of Los Angeles, et al

Filing 84

STIPULATION and PROTECTIVE ORDER signed by Magistrate Judge Allison Claire on 5/17/2019 re: Production Pursuant to Subpoena Duces Tecum Issued 4/24/19. (York, M)

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DONALD W. COOK, SBN 116666
ATTORNEY AT LAW
3435 Wilshire Blvd., Suite 2910
Los Angeles, CA 90010
[phone] / [phone] facsimile
E-mail: [e-mail]

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Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Case No. 2:18-cv-00964-TLNAC

JUAN FRANCISCO MARTINEZ, an
individual,

PROTECTIVE ORDER RE
PRODUCTION PURSUANT
TO SUBPOENA DUCES
TECUM ISSUED 4/24/19

Plaintiff,

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vs.

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CITY OF STOCKTON; COUNTY OF
SAN JOAQUIN; SAN JOAQUIN
COUNTY SHERIFF’S DEPARTMENT;
and DOES 1-10, both their individual &
official capacities,

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Defendants.

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Upon the stipulation filed by Plaintiff and non-party California Department of

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Justice and good cause appearing therefor, the California Department of Justice shall

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produce the items sought by subpoena duces tecum issued April 24, 2019 (production

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date 5/10/19) and issued by Plaintiff’s counsel), except that the production shall be

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subject to a protective order under the following terms:

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1.

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Plaintiff, the items may only be disclosed to the Court hearing this matter, the

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parties’ attorneys, investigators and/or consultants or experts, and

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representatives, in this lawsuit, for defendant the City of Stockton. The items,

DONALD W. COOK.
Attorney at Law
3435 Wilshire Blvd., Ste. 2910
Los Angeles, CA 90010
([phone]

To the extent subpoenaed items pertain to an individual who is NOT the

Protective Order Re Production Pursuant to Subpoena
duces tecum (Case No. 2:18-cv-00964-TLN-AC)

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mart0964.third party stip PO_2.ajnw.docx

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however, shall not be disclosed to Plaintiff (unless the item(s) pertain(s) to

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Plaintiff and not another individual);

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2.

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thereof to any person other than those listed in Paragraph 1, that party shall

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give written notice by mail and email to counsel for the California Department

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of Justice so that the Department can make a motion to prevent the disclosure.

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The notice shall inform the Department to whom disclosure is requested and

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If any party wishes to disclose the subpoenaed items, or any portion

the purpose thereof. The party wishing to disclose the information will not to
do so unless and until agreement with the Department is reached, or the
Department’s motion is ruled on by the court. If, however, the Department,
does not file its motion within two weeks of the notice, the party wishing to
disclose the information may deem the issue to have been abandoned.
3.

This Order makes no finding of the relevancy, if any, of the subpoenaed

items to the proof of claims and/or defenses asserted by any party in this case.

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DATED: May 17, 2019

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DONALD W. COOK.
Attorney at Law
3435 Wilshire Blvd., Ste. 2910
Los Angeles, CA 90010
([phone]

Protective Order Re Production Pursuant to Subpoena
duces tecum (Case No. 2:18-cv-00964-TLN-AC)

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mart0964.third party stip PO_2.ajnw.docx