Peinado v. City and County of San Francisco et al
Filing
97
STIPULATION AND ORDER re 96 STIPULATION WITH PROPOSED ORDER Protective Order filed by Rene Peinado, PROTECTIVE ORDER. Signed by Judge Edward M. Chen on 10/22/14. (bpf, COURT STAFF) (Filed on 10/22/2014)
1
2
3
4
PAMELA Y. PRICE, ESQ. (STATE BAR NO. 107713)
LAW OFFICES OF PAMELA Y. PRICE
A Professional Law Corporation
901 Clay Street
Oakland, CA 94607
Telephone: (510) 452-0292
Facsimile: (510 452-5625
E-mail: pamela.price@pypesq.com
5
6
7
8
9
10
11
12
Attorneys for Plaintiff
RENE PEINADO
DENNIS J. HERRERA, State Bar #139669
City Attorney
CHERYL ADAMS, State Bar #164194
Chief Trial Deputy
MICHAEL A. GERCHOW, State Bar #245706
Deputy City Attorney
Fox Plaza
1390 Market Street, Sixth Floor
San Francisco, California 94102-5408
Telephone: (415) 554-3936
Facsimile:
(415) 554-3837
E-Mail:
michael.gerchow@sfgov.org
13
14
Attorney for Defendant
CITY AND COUNTY OF SAN FRANCISCO
15
16
UNITED STATES DISTRICT COURT
17
NORTHERN DISTRICT OF CALIFORNIA
18
19
RENE PEINADO,
Plaintiff,
20
21
v.
22
CITY AND COUNTY OF SAN
FRANCISCO, et al.,
23
Defendants.
24
) NO. C11-01799 EMC
)
) STIPULATED PROTECTIVE ORDER
)
)
)
)
)
)
)
)
25
26
27
28
13018P215D-PYP
STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
1
1.
PURPOSES AND LIMITATIONS
2
Disclosure and discovery activity in this action are likely to involve production of
3
confidential, proprietary, or private information for which special protection from public
4
disclosure and from use for any purpose other than prosecuting this litigation may be warranted.
5
Accordingly, the parties hereby stipulate to and petition the court to enter the following
6
Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket
7
protections on all disclosures or responses to discovery and that the protection it affords from
8
public disclosure and use extends only to the limited information or items that are entitled to
9
confidential treatment under the applicable legal principles. The parties further acknowledge, as
10
set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file
11
confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
12
followed and the standards that will be applied when a party seeks permission from the court to
13
file material under seal.
14
2.
15
16
DEFINITIONS
2.1
Challenging Party: a Party or Non-Party that challenges the designation of
information or items under this Order.
17
2.2
“CONFIDENTIAL” Information or Items: information (regardless of how it is
18
generated, stored or maintained) or tangible things that qualify for protection under Federal Rule
19
of Civil Procedure 26(c).2
20
21
2.3
well as their support staff).
22
23
Counsel (without qualifier): Outside Counsel of Record and House Counsel (as
2.4
Designating Party: a Party or Non-Party that designates information or items that
it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
24
2.5
Disclosure or Discovery Material: all items or information, regardless of the
25
medium or manner in which it is generated, stored, or maintained (including, among other things,
26
testimony, transcripts, and tangible things), that are produced or generated in disclosures or
27
responses to discovery in this matter.
28
///
13018P215D-PYP
-1STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
1
2.6
Expert: a person with specialized knowledge or experience in a matter pertinent to
2
the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
3
consultant in this action.
4
5
2.7
Counsel does not include Outside Counsel of Record or any other outside counsel.
6
7
2.8
Non-Party: any natural person, partnership, corporation, association, or other legal
entity not named as a Party to this action.
8
9
House Counsel: attorneys who are employees of a party to this action. House
2.9
Outside Counsel of Record: attorneys who are not employees of a party to this
action but are retained to represent or advise a party to this action and have appeared in this
10
action on behalf of that party or are affiliated with a law firm which has appeared on behalf of
11
that party.
12
13
2.10
consultants, retained experts, and Outside Counsel of Record (and their support staffs).
14
15
Party: any party to this action, including all of its officers, directors, employees,
2.11
Producing Party: a Party or Non-Party that produces Disclosure or Discovery
Material in this action.
16
2.12
Professional Vendors: persons or entities that provide litigation support services
17
(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
18
organizing, storing, or retrieving data in any form or medium) and their employees and
19
subcontractors.
20
21
2.13
Protected Material: any Disclosure or Discovery Material that is designated as
“CONFIDENTIAL.”
22
2.14
Receiving Party: a Party that receives Disclosure or Discovery Material from a
23
Producing Party.
24
3.
SCOPE
25
The protections conferred by this Stipulation and Order cover not only Protected Material
26
(as defined above), but also (1) any information copied or extracted from Protected Material; (2)
27
all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
28
conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
-2STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
13018P215D-PYP
1
However, the protections conferred by this Stipulation and Order do not cover the following
2
information: (a) any information that is in the public domain at the time of disclosure to a
3
Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as
4
a result of publication not involving a violation of this Order, including becoming part of the
5
public record through trial or otherwise; and (b) any information known to the Receiving Party
6
prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who
7
obtained the information lawfully and under no obligation of confidentiality to the Designating
8
Party. Any use of Protected Material at trial shall be governed by a separate agreement or order.
9
4.
DURATION
10
Even after final disposition of this litigation, the confidentiality obligations imposed by
11
this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court
12
order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all
13
claims and defenses in this action, with or without prejudice; and (2) final judgment herein after
14
the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this
15
action, including the time limits for filing any motions or applications for extension of time
16
pursuant to applicable law.
17
5.
18
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection. Each Party
19
or Non-Party that designates information or items for protection under this Order must take care
20
to limit any such designation to specific material that qualifies under the appropriate standards.
21
The Designating Party must designate for protection only those parts of material, documents,
22
items, or oral or written communications that qualify – so that other portions of the material,
23
documents, items, or communications for which protection is not warranted are not swept
24
unjustifiably within the ambit of this Order.
25
Mass, indiscriminate, or routinized designations are prohibited. Designations that are
26
shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
27
unnecessarily encumber or retard the case development process or to impose unnecessary
28
expenses and burdens on other parties) expose the Designating Party to sanctions.
-3STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
13018P215D-PYP
1
If it comes to a Designating Party’s attention that information or items that it designated
2
for protection do not qualify for protection, that Designating Party must promptly notify all other
3
Parties that it is withdrawing the mistaken designation.
4
5.2
Manner and Timing of Designations. Except as otherwise provided in this Order
5
(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
6
Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
7
designated before the material is disclosed or produced.
8
Designation in conformity with this Order requires:
9
(a) for information in documentary form (e.g., paper or electronic documents, but
10
excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing
11
Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a
12
portion or portions of the material on a page qualifies for protection, the Producing Party also
13
must clearly identify the protected portion(s) (e.g., by making appropriate markings in the
14
margins).
15
A Party or Non-Party that makes original documents or materials available for inspection
16
need not designate them for protection until after the inspecting Party has indicated which
17
material it would like copied and produced. During the inspection and before the designation, all
18
of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the
19
inspecting Party has identified the documents it wants copied and produced, the Producing Party
20
must determine which documents, or portions thereof, qualify for protection under this Order.
21
Then, before producing the specified documents, the Producing Party must affix the
22
“CONFIDENTIAL” legend to each page that contains Protected Material. If only a portion or
23
portions of the material on a page qualifies for protection, the Producing Party also must clearly
24
identify the protected portion(s) (e.g., by making appropriate markings in the margins).
25
(b) for testimony given in deposition or in other pretrial or trial proceedings, that
26
the Designating Party identify on the record, before the close of the deposition, hearing, or other
27
proceeding, all protected testimony.
28
13018P215D-PYP
(c) for information produced in some form other than documentary and for any
-4STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
1
other tangible items, that the Producing Party affix in a prominent place on the exterior of the
2
container or containers in which the information or item is stored the legend
3
“CONFIDENTIAL.” If only a portion or portions of the information or item warrant protection,
4
the Producing Party, to the extent practicable, shall identify the protected portion(s).
5
5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
6
designate qualified information or items does not, standing alone, waive the Designating Party’s
7
right to secure protection under this Order for such material. Upon timely correction of a
8
designation, the Receiving Party must make reasonable efforts to assure that the material is
9
treated in accordance with the provisions of this Order.
10
11
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Any Party or Non-Party may challenge a designation of
12
confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
13
designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic
14
burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to
15
challenge a confidentiality designation by electing not to mount a challenge promptly after the
16
original designation is disclosed.
17
6.2
Meet and Confer. The Challenging Party shall initiate the dispute resolution
18
process by providing written notice of each designation it is challenging and describing the basis
19
for each challenge. To avoid ambiguity as to whether a challenge has been made, the written
20
notice must recite that the challenge to confidentiality is being made in accordance with this
21
specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in
22
good faith and must begin the process by conferring directly (in voice to voice dialogue; other
23
forms of communication are not sufficient) within 14 days of the date of service of notice. In
24
conferring, the Challenging Party must explain the basis for its belief that the confidentiality
25
designation was not proper and must give the Designating Party an opportunity to review the
26
designated material, to reconsider the circumstances, and, if no change in designation is offered,
27
to explain the basis for the chosen designation. A Challenging Party may proceed to the next
28
stage of the challenge process only if it has engaged in this meet and confer process first or
-5STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
13018P215D-PYP
1
establishes that the Designating Party is unwilling to participate in the meet and confer process in
2
a timely manner.
3
6.3
Judicial Intervention. If the Parties cannot resolve a challenge without court
4
intervention, the Designating Party shall file and serve a motion to retain confidentiality under
5
Civil Local Rule 7 (and in compliance with Civil Local Rule 79-5, if applicable) within 21 days
6
of the initial notice of challenge or within 14 days of the parties agreeing that the meet and confer
7
process will not resolve their dispute, whichever is earlier. Each such motion must be
8
accompanied by a competent declaration affirming that the movant has complied with the meet
9
and confer requirements imposed in the preceding paragraph. Failure by the Designating Party to
10
make such a motion including the required declaration within 21 days (or 14 days, if applicable)
11
shall automatically waive the confidentiality designation for each challenged designation. In
12
addition, the Challenging Party may file a motion challenging a confidentiality designation at any
13
time if there is good cause for doing so, including a challenge to the designation of a deposition
14
transcript or any portions thereof. Any motion brought pursuant to this provision must be
15
accompanied by a competent declaration affirming that the movant has complied with the meet
16
and confer requirements imposed by the preceding paragraph.
17
The burden of persuasion in any such challenge proceeding shall be on the Designating
18
Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
19
unnecessary expenses and burdens on other parties) may expose the Challenging Party to
20
sanctions. Unless the Designating Party has waived the confidentiality designation by failing to
21
file a motion to retain confidentiality as described above, all parties shall continue to afford the
22
material in question the level of protection to which it is entitled under the Producing Party’s
23
designation until the court rules on the challenge.
24
7.
25
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is disclosed
26
or produced by another Party or by a Non-Party in connection with this case only for prosecuting,
27
defending, or attempting to settle this litigation. Such Protected Material may be disclosed only
28
to the categories of persons and under the conditions described in this Order. When the litigation
-6STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
13018P215D-PYP
1
has been terminated, a Receiving Party must comply with the provisions of section 13 below
2
(FINAL DISPOSITION).
3
Protected Material must be stored and maintained by a Receiving Party at a location and in a
4
secure manner that ensures that access is limited to the persons authorized under this Order.
5
7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered
6
by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
7
information or item designated “CONFIDENTIAL” only to:
8
(a) the Receiving Party’s Outside Counsel of Record in this action, as well as
9
employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the
10
information for this litigation and who have signed the “Acknowledgment and Agreement to Be
11
Bound” that is attached hereto as Exhibit A;
12
(b) the officers, directors, and employees (including House Counsel) of the
13
Receiving Party to whom disclosure is reasonably necessary for this litigation and who have
14
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
15
(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
16
reasonably necessary for this litigation and who have signed the “Acknowledgment and
17
Agreement to Be Bound” (Exhibit A);
18
(d) the court and its personnel;
19
(e) court reporters and their staff, professional jury or trial consultants, mock
20
jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation
21
and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22
(f) during their depositions, witnesses in the action to whom disclosure is
23
reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound”
24
(Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of
25
transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be
26
separately bound by the court reporter and may not be disclosed to anyone except as permitted
27
under this Stipulated Protective Order.
28
13018P215D-PYP
(g) the author or recipient of a document containing the information or a custodian
-7STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
1
or other person who otherwise possessed or knew the information.
2
8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
LITIGATION
3
If a Party is served with a subpoena or a court order issued in other litigation that compels
4
disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
5
must:
6
(a) promptly notify in writing the Designating Party. Such notification shall
7
include a copy of the subpoena or court order;
8
(b) promptly notify in writing the party who caused the subpoena or order to issue
9
in the other litigation that some or all of the material covered by the subpoena or order is subject
10
to this Protective Order. Such notification shall include a copy of this Stipulated Protective
11
Order; and
12
(c) cooperate with respect to all reasonable procedures sought to be pursued by the
13
Designating Party whose Protected Material may be affected.
14
If the Designating Party timely seeks a protective order, the Party served with the
15
subpoena or court order shall not produce any information designated in this action as
16
“CONFIDENTIAL” before a determination by the court from which the subpoena or order
17
issued, unless the Party has obtained the Designating Party’s permission. The Designating Party
18
shall bear the burden and expense of seeking protection in that court of its confidential material –
19
and nothing in these provisions should be construed as authorizing or encouraging a Receiving
20
Party in this action to disobey a lawful directive from another court.
21
22
9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
LITIGATION
23
(a) The terms of this Order are applicable to information produced by a Non-Party
24
in this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties
25
in connection with this litigation is protected by the remedies and relief provided by this Order.
26
Nothing in these provisions should be construed as prohibiting a Non-Party from seeking
27
additional protections.
28
13018P215D-PYP
(b) In the event that a Party is required, by a valid discovery request, to produce a
-8STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
1
Non-Party’s confidential information in its possession, and the Party is subject to an agreement
2
with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
3
(1) promptly notify in writing the Requesting Party and the Non-Party that
4
some or all of the information requested is subject to a confidentiality agreement with a Non-
5
Party;
6
(2) promptly provide the Non-Party with a copy of the Stipulated
7
Protective Order in this litigation, the relevant discovery request(s), and a reasonably specific
8
description of the information requested; and
9
10
(3) make the information requested available for inspection by the NonParty.
11
(c) If the Non-Party fails to object or seek a protective order from this court within
12
14 days of receiving the notice and accompanying information, the Receiving Party may produce
13
the Non-Party’s confidential information responsive to the discovery request. If the Non-Party
14
timely seeks a protective order, the Receiving Party shall not produce any information in its
15
possession or control that is subject to the confidentiality agreement with the Non-Party before a
16
determination by the court. Absent a court order to the contrary, the Non-Party shall bear the
17
burden and expense of seeking protection in this court of its Protected Material.
18
10.
19
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material
20
to any person or in any circumstance not authorized under this Stipulated Protective Order, the
21
Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized
22
disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material,
23
(c) inform the person or persons to whom unauthorized disclosures were made of all the terms of
24
this Order, and (d) request such person or persons to execute the “Acknowledgment and
25
Agreement to Be Bound” that is attached hereto as Exhibit A.
26
11.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
MATERIAL
27
When a Producing Party gives notice to Receiving Parties that certain inadvertently
28
13018P215D-PYP
-9STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
1
produced material is subject to a claim of privilege or other protection, the obligations of the
2
Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
3
provision is not intended to modify whatever procedure may be established in an e-discovery
4
order that provides for production without prior privilege review. Pursuant to Federal Rule of
5
Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a
6
communication or information covered by the attorney-client privilege or work product
7
protection, the parties may incorporate their agreement in the stipulated protective order
8
submitted to the court.
9
12.
10
11
MISCELLANEOUS
12.1
Right to Further Relief. Nothing in this Order abridges the right of any person to
seek its modification by the court in the future.
12
12.2
Right to Assert Other Objections. By stipulating to the entry of this Protective
13
Order no Party waives any right it otherwise would have to object to disclosing or producing any
14
information or item on any ground not addressed in this Stipulated Protective Order. Similarly,
15
no Party waives any right to object on any ground to use in evidence of any of the material
16
covered by this Protective Order.
17
12.3
Filing Protected Material. Without written permission from the Designating Party
18
or a court order secured after appropriate notice to all interested persons, a Party may not file in
19
the public record in this action any Protected Material. A Party that seeks to file under seal any
20
Protected Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
21
under seal pursuant to a court order authorizing the sealing of the specific Protected Material at
22
issue. Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request
23
establishing that the Protected Material at issue is privileged, protectable as a trade secret, or
24
otherwise entitled to protection under the law. If a Receiving Party's request to file Protected
25
Material under seal pursuant to Civil Local Rule 79-5(d) is denied by the court, then the
26
Receiving Party may file the information in the public record pursuant to Civil Local Rule 79-
27
5(e) unless otherwise instructed by the court.
28
///
13018P215D-PYP
-10STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
1
2
13.
FINAL DISPOSITION
Within 60 days after the final disposition of this action, as defined in paragraph 4, each
3
Receiving Party must return all Protected Material to the Producing Party or destroy such
4
material. As used in this subdivision, “all Protected Material” includes all copies, abstracts,
5
compilations, summaries, and any other format reproducing or capturing any of the Protected
6
Material. Whether the Protected Material is returned or destroyed, the Receiving Party must
7
submit a written certification to the Producing Party (and, if not the same person or entity, to the
8
Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all
9
the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has
10
not retained any copies, abstracts, compilations, summaries or any other format reproducing or
11
capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to
12
retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
13
legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work
14
product, and consultant and expert work product, even if such materials contain Protected
15
Material. Any such archival copies that contain or constitute Protected Material remain subject to
16
this Protective Order as set forth in Section 4 (DURATION).
17
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
18
Dated: October 10, 2014
19
LAW OFFICES OF PAMELA Y. PRICE
/s/ Pamela Y . Price
20
PAMELA Y. PRICE, Attorneys for Plaintiff
RENE PEINADO
21
Dated: October 10, 2014
22
UNIT
ED
S
24
FO
N
A
H
-11ER
STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
LI
RT
13018P215D-PYP
__________________________________
en
HON. EDWARD warCHENh
M. d M. C
dge Ed DISTRICT COURT
UNITED Ju
STATES
NO
28
October 22, 2014
DATED: ________________________
O ORD
IT IS S
R NIA
PURSUANT TO THE FOREGOING STIPULATION, IT IS SO ORDERED. RED
E
26
27
RT
U
O
/s/ Michael A. Gerchow
MICHAEL A. GERCHOW,TRICT City Attorney
S DIS Deputy
TE CITY AND COUNTY OF
C
Counsel for Defendants
TA
SAN FRANCISCO, ELIAS GEORGOPOULOS
23
25
OFFICE OF THE CITY ATTORNEY
F
D IS T IC T O
R
C
1
EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4
I, _____________________________ [print or type full name], of _________________
5
[print or type full address], declare under penalty of perjury that I have read in its entirety and
6
understand the Stipulated Protective Order that was issued by the United States District Court for
7
the Northern District of California in the case of Peinado v. City and County of San Francisco, et
8
al., Case No. C11-01799 EMC. I agree to comply with and to be bound by all the terms of this
9
Stipulated Protective Order and I understand and acknowledge that failure to so comply could
10
expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will
11
not disclose in any manner any information or item that is subject to this Stipulated Protective
12
Order to any person or entity except in strict compliance with the provisions of this Order.
13
I further agree to submit to the jurisdiction of the United States District Court for the
14
Northern District of California for the purpose of enforcing the terms of this Stipulated Protective
15
Order, even if such enforcement proceedings occur after termination of this action.
16
I hereby appoint __________________________ [print or type full name] of
17
_______________________________________ [print or type full address and telephone
18
number] as my California agent for service of process in connection with this action or any
19
proceedings related to enforcement of this Stipulated Protective Order.
20
Date: ______________________________________
21
City and State where sworn and signed: _________________________________
22
Printed name: _______________________________
23
Signature: __________________________________
24
25
26
27
28
13018P215D-PYP
-12STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
1
2
CERTIFICATION
I hereby certify my understanding that Confidential Information is being provided to me
3
pursuant to the terms and restrictions of the Protective Order dated June 25, 2014, in Peinado v.
4
City and County of San Francisco, Case No. C11-01799 EMC. I have been given a copy of that
5
Order and read it. I agree to be bound by the Order. I will not reveal the Confidential
6
Information to anyone, except as allowed by the Order. I will maintain all such Confidential
7
Information -- including copies, notes, or other transcriptions made therefrom -- in a secure
8
9
10
11
manner to prevent unauthorized access to it. No later than thirty (30) days after the conclusion of
this action, I will return the Confidential Information -- including copies, notes, or other
transcriptions made therefrom --to the counsel who provided me with the Confidential
Information. I hereby consent to the jurisdiction of the United States District Court of the
Northern District of California for the purpose of enforcing the Protective Order.
12
13
Dated:___________
______________________________
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
13018P215D-PYP
-13STIPULATED PROTECTIVE ORDER (C11-01799 EMC)
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?