Trabakoolas et al v. Watts Water Technologies, Inc. et al

Filing 120

STIPULATION AND PROTECTIVE ORDER. Signed by Judge Yvonne Gonzalez Rogers on 4/10/13. (fs, COURT STAFF) (Filed on 4/10/2013)

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1 2 3 4 5 6 7 8 DAVID S. MacCUISH (SBN 054024) TODD BENOFF (SBN 192983) LINDSAY G. CARLSON (SBN 235999) ALSTON & BIRD LLP 333 South Hope Street, Sixteenth Floor Los Angeles, California 90071 Telephone: (213) 576-1000 Facsimile: (213) 576-1100 David.MacCuish@alston.com Todd.Benoffgalston.com Lindsay.Carlson@alston.com Attorneys for Defendants WATTS REGULATOR CO., WATTS WATER TECHNOLOGIES, INC. and WOLVERINE BRASS, INC. 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 OAKLAND COURTHOUSE 12 13 14 JASON TRABAKOOLAS and SHEILA STETSON, individually and on behalf of all others similarly situated, 15 16 17 18 19 20 21 Plaintiffs, v. WATTS WATER TECHNOLOGIES, INC., WATTS REGULATOR CO., WATTS ANDERSON-BARROWS METAL CORP., WATTS PLUMBING TECHNOLOGIES (TAIZHO) CO., LTD., SAVARD PLUMBING COMPANY, WOLVERINE BRASS, INC., AND JOHN DOES 1-100, Case No.: 4:12-cv-01172-YGR STIPULATION AND [PROPOSED] PROTECTIVE ORDER RE PRODUCTION OF TECHNICAL REPORTS ON ALLEGED FAILURES OF CONNECTORS The Honorable Yvonne Gonzalez Rogers Defendants, 22 23 24 25 26 27 28 1 STIPULATION AND [PROPOSED} PROTECTIVE ORDER RE PRODUCTION OF TECHNICAL. REPORTS ON ALLEGED FAILURES OF CONNECTORS LEGAL02/34029703v2 CASE NO. C12-01172 YGR 1 Defendant Watts Regulator Co.'s ("Watts") has proposed to produce certain technical 2 reports, which it represents were prepared in anticipation of litigation and which relate to the 3 alleged failure of toilet connector coupling nuts, under the terms of a protective order, The 4 parties here STIPULATE AND AGREE that the production of such reports shall have the 5 following legal effect: 6 7 (1) The waiver of work product by Watts shall be limited to the reports themselves and shall not extend to any other work product of Watts or its counsel. 8 (2) The production of the reports shall not constitute a waiver of any attorney- 9 client privilege. 10 (3) Nothing in this order precludes Plaintiffs from deposing the authors of the 11 reports or his employees and associates with firsthand knowledge of the analyses of alleged 12 failures that are the subject of the reports. 13 (4) The parties agree that any technical report previously produced in arbitration or 14 other litigation does not constitute work product. This protective order shall also not apply 15 to any of those other reports that do not constitute work product. (5) 16 Plaintiffs have not seen the technical reports which are the subject of this 17 protective order, Plaintiffs may seek relief from the terms of this protective order for good 18 cause shown. 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 2 STIPULATION AND [PROPOSED] PROTECTIVE ORDER RE PRODUCTION OF TECHNICAL. REPORTS ON ALLEGED FAILURES OF CONNECTORS LEGAL02/34029703v2 CASE NO. C12-01172 YGR 1 (6) This protective order applies to this action only and shall not be construed to 2 require the production of the reports, or the waiver of work product, in any other legal 3 proceeding. 4 5 Dated: April , 2013 6 7 DAVID S. MacCUISH TODD BENOFF LINDSAY CARLSON ALSTON & BIRD LLP 1.0,,a 8 A litt,L4 David S. MacCuish Attorneys for Defendants WATTS REGULATOR CO., WATTS WATER TECHNOLOGIES, INC. and WOLVERINE BRASS, INC. 9 10 11 12 Dated: April( , 2013 ) 13 14 SIMON BAHNE PARIS PATRICK HOWARD CHARLES J. KOCHER SALTZ, MONGELUZZI, BARRETT & BENDESKY, P.C. 15 ) — 16 7 7„— - Simon Bahne Paris Interim Class Counsel 17 18 19 IT IS SO ORDERED: A party wishing to file any document subject to this protective order must comply with Civ. L.R. 79-5. This Order terminates Dkt. No. 118. 20 21 Dated: April 10, 2013 Honorable Yvonne Gonzalez Rogers United States District Court Judge 22 23 24 25 26 27 28 3 STIPULATION AND [PROPOSED] PROTECTIVE ORDER RE PRODUCTION OF TECHNICAL REPORTS ON ALLEGED FAILURES OF CONNECTORS LEGAL02/34029703v2 CASE NO, C12-01172 YGR

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