Frank v. County of Humboldt et al

Filing 172

STIPULATION AND ORDER RE: IDENTIFICATION, NONUSE AND RETURN AND/OR CONFIRMED DESTRUCTION OF DOCUMENTS SUBJECT TO THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ("HIPAA") PROTECTIONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECTION 1157 AND EXHIBIT A - C. Signed by Judge Maxine M. Chesney on May 22, 2014. (mmclc2, COURT STAFF) (Filed on 5/22/2014)

1 GENESE K. DOPSON (SBN 108333)
Email: [e-mail]
2 LENORE C. KELLY (SBN 170891)
Email: [e-mail]
3 WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
4 525 Market Street, 1th Floor
San Francisco, California 94105
5 Telephone: [phone]
Facsimile: [phone]
6

Attorneys for Defendants
7 BHC SIERRA VISTA HOSPITAL and
PAUL HYPPOLITE
8
9

UNITED STATES DISTRICT COURT

10

NORTHERN DISTRICT OF CALIFORNIA

11
12
13
14
15
16
17
18
19
20
21

MINNY FRANK

)
)
Plaintiff,
)
)
v.
)
)
)
COUNTY OF HUMBOLDT, COUNTY OF)
HUMBOLDTDEPARTMENTOF
)
HEALTH AND HUMAN SERVICES,
)
JAMES BRAGG, CHRISTYREIHM,
)
KATHERINE YOUNG, KERI SCHROCK, )
DAVID WILLIAMS, JENNIFER
)
WILLIAMS, BHC SIERRA VISTA
)
HOSPITAL, INC., PAUL HYPPOLITE,
)
ROXANNE HALZCAK, ABDUL QADIR, )
M.D., individually and in their official
)
)
capacities; DOES 2-50, inclusive,
)
Defendants.
)
)
)

Case No.: C13-00089 MMC

STIPULATION AND [PROPOSED]
ORDER RE: IDENTIFICATION, NON
USE AND RETURN AND/OR
CONFIRMED DESTRUCTION OF
DOCUMENTS SUBJECT TO THE
HEALTH INSURANCE PORTABILITY
AND ACCOUNTABILITY ("HIP AA")
PROTECTIONS AND PRIVILEGED
UNDER CALIFORNIA EVIDENCE CODE
SECTION 1157 AND EXHIBIT A - C
Judge: Maxine M. Chesney
Referred: Magistrate Judge Elizabeth D.
LaPorte
Action Filed: January 8, 2013
Trial Date: October 6, 2014

22
23

WHEREAS, certain information that has been inadvertently disclosed during discovery in

24 this action constitutes privileged private information or information of a sensitive nature that is not
25

generally known or readily accessible to the general public and that may cause harm to one or

26 more of the parties if such information is disclosed to the general public; and
27
28
STIPULATION AND [PROPOSED] ORDER RE: IDENTIFICATION, NON USE AND RETURN AND/OR CONFIRMED
DESTRUCTION OF DOCUMENTS SUBJECT TO THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ("HIPAA")
PROTECTIONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECTION 1157

Case No.: C13-00089 MMC
1208539v.l

1

WHEREAS, all parties to the action have agreed to return or destroy said sensitive

2 information.
3

WHEREAS, on June 4, 2014, a Motion to Compel Plaintiff to return or to destroy said

4 sensitive information is set for hearing.
5

WHEREAS, Defendant, County of Humboldt and all named County individuals and

6 entities have agreed to enter into this Stipulation in lieu of filing a motion.
7

WHEREAS, Defendants, David Williams and Jennifer Williams have agreed to enter into

8 this Stipulation in lieu of filing a motion.

9

WHEREAS, Defendant, Dr. Qadir has agreed to enter into this Stipulation in lieu of filing a

10 motion.
11

The Parties, by and through their counsel of record, enter into this Stipulation.

12
1.

13
14
15

The Parties acknowledge that on March 24, 2014 Defendants Paul Hyppolite and BHC
Sierra Vista Hospital ("Designating Defendants") notified Plaintiff and counsel for all other parties
in this action of inadvertently disclosed and produced writings/documents 1 in discovery.

16
17

18
19
20
21

Said writings/documents are Protected Material, and are subject to protections of The
Health Insurance Portability and Accountability Act of 1996 (HIPAA)- particularly Title II ,2
defining policies, procedures and guidelines for maintaining the privacy and security of
individually identifiable health information and to the protections of California Evidence Code
Section 1157 privilege (Proceedings and Records of Certain Health Care Professional Review
committees).

22
23

PURPOSE OF STIPULATION

The Protected Material inadvertently disclosed by Designating Defendants Hyppolite and
BHC Sierra Vista Hospital, as set forth below in Section 2 constitute private and privileged

24
1

25
26

"Writings" as defined by California Evidence Code Section 250.

2

Covered entities within the meaning of Title II include health care providers that transmit health
care data in a way that is regulated by HIPAA and has been extended by the DHHS rule to
27 independent contractors of covered entities who fit within the definition of "business associates."

28

2
STIPULATION AND [PROPOSED] ORDER RE: IDENTIFICATION, NON USE AND RETURN AND/OR CONFIRMED
DESTRUCTION OF DOCUMENTS SUBJECT TO THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ("HIPAA")
PROTECTIONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECTION 1157

Case No.: Cl3-00089 MMC
1208539v.l

1 information pertaining to Paul Hyppolite- Case Worker and Employee ofBHC Sierra Vista
2 Hospital, and to Dr. Abdul Qadir - Independent Contractor and treating psychiatrist at BHC Sierra
3 Vista Hospital.
4

The Designating Defendants requested Plaintiff and counsel for all other parties to

5 immediately return or confirm destruction of the subject privileged/protected covered records
6 including all copies of same. All parties have agreed to do so except Plaintiff, which necessitated
7 Designating Defendants to file a Motion to Compel seeking the issuance of an Order compelling
8 Plaintiff to identify, agree to non use and return and/or confirm destruction of the subject
9 documents.
10

This Stipulation is entered into as a result of the agreement by Defendant County of

11

Humboldt and all named County individuals and entities; Defendant Jennifer and David Williams;

12 and Defendant Abdul Qadir, M.D., to comply with Designating Defendants' request.

13 2.
14

15
16
17
18
19
20

IDENTIFICATION OF THE INADVERTENTLY DISCLOSED PROTECTED AND
PRIVILEGED WRITINGS
The writings/documents that are Protected Material, and subject to protections of The

Health Insurance Portability and Accountability Act of 1996 (HIP AA) - particularly Title II,
defining policies, procedures and guidelines for maintaining the privacy and security of
individually identifiable health information and to the protections of California Evidence Code
Section 1157 privilege(Proceedings and Records of Certain Health Care Professional Review
committees) are identified in the Designating Defendants' inadvertent production as follows:
1. Batestamps SVH00429 through SVH00529 inclusive (Personnel file of Dr. Abdul Qadir
and Peer Review documents;

21

22

2. Bate stamps HYPPOLITE000006-9 (Univ. of Phoenix Official Academic Transcript);
HYPPOLITE000052-63 (Performance Evaluation Social Worker);

23
24

3. Batestamps HYPPOLITE000065-70 (Sierra Vista Hospital Performance Evaluation Case
Manager);

25
4. Batestamps HYPPOLITE000073 (Employee Withholding Allowance Certificate);

26

5. Batestamps HYPPOLITE000074-000080 (Background Check);

27
6. BatestampsHYPPOLITE000096 (Employee Updated Information Sheet)

28

3
STIPULATION AND [PROPOSED) ORDER RE: IDENTIFICATION, NON USE AND RETURN AND/OR CONFIRMED
DESTRUCTION OF DOCUMENTS SUBJECT TO THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ("HIPAA")
PROTECTIONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECTION 1157

Case No.: CB-00089 MMC
1208539v.l

1

2

The above-referenced writings, items 1 through 6, were inadvertently produced in

3 Batestamped numbers referenced above and they were also produced in non-Batestamped format.
4 This Stipulation applies to both Batestamped and non-Batestamped writings.
5

Defendant County of Humboldt and all named County individuals and entities; Defendant

6 Jennifer and David Williams; and Defendant Abdul Qadir, M.D., hereby stipulate and agree that
7 all originals and all copies of the writings referenced above, whether batestamped or not, shall be
8 located and identified to the Designating Defendants as having been isolated and destroyed or,
9 alternatively, all of such writings shall be returned to Designating Defendants.
10

3.

11

SCOPE
The protections conferred by this Stipulation and Order cover not only Protected Material

12 (as defined above in paragraph 2), but also (1) any information (writings) copied or extracted from
13

said Material; (2) all copies, excerpts, summaries, or compilations of said Protected Material

14 (writings); and (3) any testimony, conversations, or presentations Defendants, and any
15 conversations, or presentations by Defendants to any attorney such Protected Material (writings).
16 Defendants understand that pursuant to this Stipulation they are to retrieve any and all such
17 writings whether Batestamped or not, and Defendants understands they are to send back any disks
18 to confirm retrieval and return such writings to Designating Defendants or, alternatively, confirm
19 the destruction of said writings. Defendants have indicated they will send back the said Protected
20 Material (writings).
21

4.

22
23

DURATION
Even after final disposition of this litigation, the confidentiality obligations imposed by this

Order shall remain in effect.

24

5.
25

PLAINTIFF'S AFFIRMATIVE AGREEMENT TO BE BOUND BY THE TERMS
OF THIS STIPULATION

26

Defendants County of Humboldt and all named County individuals and entities; Defendant

27 Jennifer and David Williams; and Defendant Abdul Qadir, M.D., expressly agree to date, sign and

28

4
STIPULATION AND [PROPOSED) ORDER RE: IDENTIFICATION, NON USE AND RETURN AND/OR CONFIRMED
DESTRUCTION OF DOCUMENTS SUBJECT TO THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ("HIPAA")
PROTECTIONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECTION 1157

Case No.: Cl3-00089 MMC
1208539v.I

1 return to Designating Defendants the .. Acknowledgment and Agreement to Be Bound" that is

2 attached hereto as Exhibit A-C.

3 6.

DESIGNATING DEFENDANTS WITHDRAWAL OF MOTION TO COMPEL

4

Once Defendants County of Humboldt and all named County individuals and entities;

5 Defendant Jennifer and David Williams; and Defendant Abdul Qadir, M.D., date, sign and return

6 to Designating Defendants the "Acknowledgment and Agreement to Be Bound" that is attached
7 hereto as Exhibit A-C, Designating Defendants will withdraw their pending M~tion to Compel.
8 Designating Defendants shall present the executed Exhibit A-C to the Court with this Stipulation

9 and Proposed Order.
10

IT IS SO STIPULATED.

11

12
DATED:

13

"5'

l ~1 1'\

WILSON, ELSER, MOSKOWITZ, EDELMAN &
DICKERLL

14
15
16 DATED:
Nancy Delaney
Attorneys for Defendants
COUNTY OF HUMBOLDT and all named
County individuals and entities

17
18

19

DATED:

5(ct{ttf

20

~

Attorneys for Defendant
ABDUL QADIR, M.D.

21
22

~«~

Ann H. Larson

DATED:
DAVID WILLIAMS and
JENNIFER WILLIAMS
In Pro Per

23
24

25 PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

26
27

DATED: _ _ _ _ _ _ _ __
United States District Judge

28

s
STIPULATION AND (PROPOSED] ORDER RE: IDENTIFICATION, NON USE AND RETURN AND/OR CONFIRMED
DESTRUCfiON OF DOCUMENTS SUBJECT TO THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ("HIPAA ")
PROTECfiONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECfiON 1157

Case No.: CB-00089 MMC
1208539v.l

return to Designating Defendants the "Acknowledgment and Agreement to Be Bound.. that is
2 attached hereto as Exhibit A-C .

..

·' 6.

DESIGNATING DEFENDANTS WITHDRAWAL Of" MOTION TO COMPEL

4

Once Defendants County of Humboldt and all named County individuals and entities;

5 Defendant Jennifer and David Williams; and Defendant Abdul Qadir, M.D., date, sign and return
6 to Designating Defendants the "Acknowledgment and Agreement to Be Bound" that is attached
7 hereto as Exhibit A-C, Designating Defendants will withdraw their pending Motion to CompeL
8 Designating Defendants shall present the executed Exhibit A-C to the Court with this Stipulation
9 and Proposed Order.
10

IT IS SO STIPULATED.
WILSON, ELSER, MOSKOWITZ, EDELMAN &
DICKER LLP

11

12

I DATED:

:: I

----~---------------

Genese K. Dopson
Lenore C. Kelly
Attorneys for Defendants
BHC SIERRA VISTA HOSPITAL and
PAUL HYPPOUTE

16 DATED:
"'Nancy Delancy
Attorneys for Defendants
COUNTY OF HUMBOLDT and all named
County individuals and entities

17
18

Ann H. Larson

24

25

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

26
n"""i-te-=d""'s=-t-at_e_s-=o:-:-i-st'"""ri:-c-tJ:::-u_,d,_g_c___,,,,,.,,,,,,_,

"~--,~1.-,-J

28

1

5
STIPliLATION AND IPROPOSED! ORDER RE: IDENTIFICATION, NON USE ,\NO RETURN AND/OR CONFIRMED
DE.STRIJCTION OF DOClJMENTS SUBJECT TO THE HF.,\l.TH INSURANCE PORTABJLlTY AND :\CCOUNTAIUI JTY ("llii'A.\."1
PROTECTIONS AND PRIVILEGED t:NDER <:ALJFORNIA EVIDENCE COO.E SECTION 11$7

Case No.: CIJ-00089 MMC
1208539v,l

1 retum to Designating Defendants the ''Acknowledgment and Agreement to Be Bound" that is
2 attached hereto as Exhibit A-C.

3 6.

DESIGNATING DEFENDANTS WITHDRAWAL OF MOTION TO COMPEL

4

Once Defendants County of Humboldt and all named County individuals and entities;

5 Defendant Jennifer and David Williams; and Defendant Abdul Qadir, M.D., date, sign and return
6 to Designating Defendants the "Acknowledgment and Agreement to Be Bound" that is attached

7 hereto as Exhibit A-C, Designating Defendants will withdraw their pending Motion to Compel.

8 Designating Defendants shall present the executed Exhibit A-Cto the Court with this Stipulation

WILSON, ELSER, MOSKOWITZ, EDELMAN &
DICKE LL

Nancy laney
Attorneys for Defendants
COUNTY OF HUMBOLDT and all named
County individuals and entities
Ann H. Larson
Attorneys for Defendant
ABDUL QADIR, M.D.

DAVID WILLIAMS and
JENNIFER WILLIAMS
In Pro Per
25

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

26

27

DATED: _________________
May 22, 2014
United States District Judge

28

5

STIPULATION AND (PROPOSED I ORDER nE: ll>Jo:NTIFlCATION, NON USE AND RETURN AND/OR CONFIRMED
DE..'iTRliCTION OF DOCUMENTS SliBJECT TO THE HEALTH INSURANCE PORTAUil.lTY AND ACCOUNTABILITY ("HIPAA ")
PROTECTIONS AND PRIVILEGED lJNDER CALIFORNIA EVIDENCE CODE SECTION 1157

Case No.: C 13-00089 MMC
1208539v.l

1

EXHIBIT A

2
3

Acknowledgment and Agreement to Be Bound

4

Defendant Humboldt County and all named County individuals and entities herein,

5
stipulate, acknowledge and agree to be bound as follows:
6
The inadvertently produced writings/documents that are Protected Material, and subject to
7
protections of The Health Insurance Portability and Accountability Act of 1996 (HIPAA)-

8
particularly Title II, defining policies, procedures and guidelines for maintaining the privacy and
9
security of individually identifiable health information and to the protections of California
10
Evidence Code Section 1157 privilege (Proceedings and Records of Certain Health Care

11
Professional Review committees) are identified in the Designating Defendants' production as:

12
13
1. Batestamps SVH00429 through SVH00529 inclusive (Personnel file of Dr. Abdul Qadir
and Peer Review documents;

14
15

2. Batestamps HYPPOLITE000006-9 (Univ. of Phoenix Official Academic Transcript);
HYPPOLITE000052-63 (Performance Evaluation Social Worker);

16

3. Batestamps HYPPOLITE000065-70 (Sierra Vista Hospital Performance Evaluation Case
Manager);

17

18

4. Batestamps HYPPOLITE000073 (Employee Withholding Allowance Certificate);

19
5. Batestamps HYPPOLITE000074-000080 (Background Check);

20
6. BatestampsHYPPOLITE000096 (Employee Updated Information Sheet)

21

22
This Stipulation applies to both Batestamped and non-Batestamped originals and/or copies

23
of said writings.
24

Defendant Humboldt County and all named County individuals and entities herein, hereby

25
stipulate and agree under penalty of perjury that all originals and/or all copies of the writings

26
referenced above are protected, privileged, whether batestamped or not, and said documents shall

27

28

6
STIPULATION AND [PROPOSED] ORDER RE: IDENTIFICATION, NON USE AND RETURN AND/OR CONFIRMED
DESTRUCTION OF DOCUMENTS SUBJECT TO THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ("HIPAA")
PROTECTIONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECTION 1157

Case No.: C13-00089 MMC
1208539v.l

not be made public, that said documents have been located and identified, and I represent to the
2

Designating Defendants that said documents have been retumed, isolated and destroyed.

3
4

.

Signed

_y

this~ day, May, 2014, in ---=----=~r---

5
6

7
8
9

10
ll
12

13
14
15

16
17
18

19
20
2l

22
23

24
25

26

27

28

7
STIPULATION AND tpROJ>OSEDI ORDER RE: IDENTIFICATION, l'\ON USE AND RETllRN AND/OR CONFIRMED
DESTRUCTION OF DOCUI\IENTS SUBJECT TO TUE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY {''IIIPAA~I
PROTECTIONS r\1'~0 I'RlVILEGED lJNDI::R CALifORNIA EVIDEI'iCE CODE SECTION I 157

Case No.: C 13-00089 MMC
1208539v.l

1

EXHIBITB

2

Acknowledgment and Agreement to Be Bound

3
4

Defendant Abdul Qadir M.D., stipulates, acknowledges and agrees to be bound as follows:

5

The inadvertently produced writings/documents that are Protected Material, and subject to

6 protections of The Health Insurance Portability and Accountability Act of 1996 (HIPAA)7 particularly Title II, defining policies, procedures and guidelines for maintaining the privacy and
8 security of individually identifiable health information and to the protections of California
9 Evidence Code Section 1157 privilege (Proceedings and Records of Certain Health Care
10 Professional Review committees) are identified in the Designating Defendants' production as:
11

12

1. Batestamps SVH00429 through SVH00529 inclusive (Personnel file of Dr. Abdul Qadir
and Peer Review documents;

13

2. Batestamps HYPPOLITE000006-9 (Univ. of Phoenix Official Academic Transcript);
HYPPOLITE000052-63 (Performance Evaluation Social Worker);

14
15
16

3. Batestamps HYPPOLITE000065-70 (Sierra Vista Hospital Performance Evaluation Case
Manager);

17

4. Bate stamps HYPPOLITE000073 (Employee Withholding Allowance Certificate);

18

5. Batestamps HYPPOLITE000074-000080 (Background Check);

19

6. BatestampsHYPPOLITE000096 (Employee Updated Information Sheet)

20
21

This Stipulation applies to both Batestamped and non-Batestamped originals and/or copies

22 of said writings.
23
24
25

Defendant Abdul Qadir M.D hereby stipulates and agrees under penalty of perjury that all
originals and/or all copies of the writings referenced above are protected, privileged, whether

26 batestamped or not, and said documents shall not be made public, that said documents have been
27

28

8
STIPULATION AND [PROPOSED) ORDER RE: IDENTIFICATION, NON USE AND RETURN AND/OR CONFIRMED
DESTRUCTION OF DOCUMENTS SUBJECT TO THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ("HIPAA")
PROTECTIONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECTION 1157

Case No.: Cl3-00089 MMC
1208539v.l

1 located and identified, and I represent to the Designating Defendants that said documents have
2 been returned, isolated and destroyed.

3

4

Signed this

--.9.!!_ day, May, 2014, in /J~, M

(City and State.)

5
6

Ann H. Larson
Attorneys for Defendant
ABDUL QADIR, M.D.

7

"""'""'

8
9
10
11
12

13
14
15

16
17
18
19
20
21
22

23
24

25

26
27
28

9
STIPULATION AND (PROPOSEDJ ORDER RE: IDENTIFICATION, NON USE AND RETURN ANDIOR CONFIRMED
DESTRUCOON OF DOCUMENTS SUBJECT TO THE HEALm INSURANCE PORTABILITY AND ACCOUNTABILITY ("IDPAA")
PROTECTIONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECTION 1157

Case No.: CI3-00089 MMC
1208539v.l

1

EXHIBIT C

2

Acknowledgment and Agreement to Be Bound

3

4

Defendants Jennifer and David Williams stipulate, acknowledge and agree to be bound as

5 follows:
6

The inadvertently produced writings/documents that are Protected Material, and subject to

7 protections of The Health Insurance Portability and Accountability Act of 1996 (HIPAA)8 particularly Title II, defining policies, procedures and guidelines for maintaining the privacy and
9

security of individually identifiable health information and to the protections of California

10 Evidence Code Section 1157 privilege (Proceedings and Records of Certain Health Care
11

Professional Review committees) are identified in the Designating Defendants' production as:

12
13

1. Batestamps SVH00429 through SVH00529 inclusive (Personnel file of Dr. Abdul Qadir
and Peer Review documents;

14

2. Batestamps HYPPOLITE000006-9 (Univ. of Phoenix Official Academic Transcript);
HYPPOLITE000052-63 (Performance Evaluation Social Worker);

15
16
17

3. Batestamps HYPPOLITE000065-70 (Sierra Vista Hospital Performance Evaluation Case
Manager);

18

4. Batestamps HYPPOLITE000073 (Employee Withholding Allowance Certificate);

19

5.

20

6. BatestampsHYPPOLITE000096 (Employee Updated Information Sheet)

Batestamps HYPPOLITE000074-000080 (Background Check);

21
22
23
24
25

This Stipulation applies to both Batestamped and non-Batestamped originals and/or copies
of said writings.
Defendants Jennifer and David Williams hereby stipulate and agree under penalty of
perjury that all originals and/or all copies of the writings referenced above are protected,

26 privileged, whether batestamped or not, and said documents shall not be made public, that said
27

28

10
STIPULATION AND [PROPOSED) ORDER RE: IDENTIFICATION, NON USE AND RETURN AND/OR CONFIRMED
DESTRUCTION OF DOCUMENTS SUBJECT TO THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ("HIPAA")
PROTECTIONS AND PRIVILEGED UNDER CALIFORNIA EVIDENCE CODE SECTION 1157

Case No.: Cl3-00089 MMC
1208539v.l

documents have been located and identified, and I represent to the Designating Defendants that
2 said documents have been returned, isolated and destroyed.
3
4

5
6

lLLIAMS and
WILLIAMS

7
R

9
10

II
12
13
14
15

16
17

18
19

20
21

22
23
24

25
26

27
28

II
STlPlil.J\TION t\J•m IPIWPOSE:DI ORDER Rt:; IDF.NTJFICATION, NON lJSE AND RE'flJRN ANOJOR CONFIRMED
Ot:STRUCflON OF DOClJ.l\.U:J'II~l'S Sl!BJECJ' TO THE JU:At:Tll INSURANCE PORTABILITY ANU ACCO\JNT:\Bil.IT\' ("IIII'A,\''1
PROTEn'IONS 1\.~U PRIVU.EGED UNDER CALIFORNIA EVIDENCE {'ODf: SE(TION 11!'7

Case No.: CI3-00089 MMC
I 2UR5J9v. I