Narog v. City of Redwood City et al

Filing 55

Order by Magistrate Judge Donna M. Ryu granting 53 Stipulation.(dmrlc2, COURT STAFF) (Filed on 4/22/2014)

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Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page1 of 14 1 2 3 4 JIVAKA CANDAPPA (SBN 225919) 739 East Walnut Street, Suite 204 Pasadena, CA 91101 Telephone: (626) 345-5334 jcandappa@candappalaw.com Attorney for Plaintiff CORY NAROG 5 6 7 8 9 10 11 12 JOSEPH C. HOWARD, JR. (SBN 050784) jhoward@hrmrlaw.com TODD H. MASTER (SBN 185881) tmaster@hrmrlaw.com HOWARD ROME MARTIN & RIDLEY LLP 1775 Woodside Road, Suite 200 Redwood City, CA 94061 Telephone: (650) 365-7715 Facsimile: (650) 364-529 Attorneys for Defendants CITY OF REDWOOD CITY, KENNETH FALJEAN, JOHN PAUL GARY, and VICTOR F. FIGUEROA 13 14 UNITED STATES DISTRICT COURT 15 FOR THE NORTHERN DISTRICT OF CALIFORNIA 16 17 18 19 20 21 22 23 24 CORY NAROG, Plaintiff, vs. CITY OF REDWOOD CITY, OFFICER FIGUEROA (#387), OFFICER FALJEAN (#309), OFFICER GARY, DOE 1 through DOE 40, in their official and individual capacities, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. C13-3237 DMR AMENDED [PROPOSED] STIPULATED PROTECTIVE ORDER: PRODUCTION OF CONFIDENTIAL RECORDS Judge: Hon. Donna M. Ryu Location: 1301 Clay Street, Oakland, CA Courtroom: 4, 3rd Floor, Complaint Filed: July 12, 2013 25 26 Plaintiff Cory Narog (“Plaintiff”) and Defendants City of Redwood City, Victor 27 Figueroa, Kenneth Faljean and John Gary (collectively “Defendants”), through their respective 28 attorneys of record, stipulate to the following protective order: Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -1- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page2 of 14 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 11 file confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that 12 must be followed and the standards that will be applied when a party seeks permission from the 13 court to file material under seal. 14 2. 15 16 17 DEFINITIONS 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 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 19 Rule of Civil Procedure 26(c). 20 21 22 23 24 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their support staff). 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.” 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 26 things, testimony, transcripts, and tangible things), that are produced or generated in disclosures 27 or responses to discovery in this matter. 28 Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -2- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page3 of 14 1 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent 2 to the litigation who has been retained by a Party or its counsel to serve as an expert witness or 3 as a consultant in this action. 2.7 4 5 Counsel does not include Outside Counsel of Record or any other outside counsel. 2.8 6 7 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.9 8 9 House Counsel: attorneys who are employees of a party to this action. House 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. 2.10 12 13 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 2.11 14 15 Party: any party to this action, including all of its officers, directors, employees, Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 2.12 16 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. 2.13 20 21 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.14 22 Receiving Party: a Party that receives Disclosure or Discovery Material from a 23 Producing Party. 24 3. 25 SCOPE The protections conferred by this Stipulation and Order cover not only Protected 26 Material (as defined above), but also (1) any information copied or extracted from Protected 27 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any 28 testimony, conversations, or presentations by Parties or their Counsel that might reveal Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -3- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page4 of 14 1 Protected Material. However, the protections conferred by this Stipulation and Order do not 2 cover the following information: (a) any information that is in the public domain at the time of 3 disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a 4 Receiving Party as a result of publication not involving a violation of this Order, including 5 becoming part of the public record through trial or otherwise; and (b) any information known to 6 the Receiving Party prior to the disclosure or obtained by the Receiving Party after the 7 disclosure from a source who obtained the information lawfully and under no obligation of 8 confidentiality to the Designating Party. Any use of Protected Material at trial shall be governed 9 by a separate agreement or order. 10 4. DURATION 11 Even after final disposition of this litigation, the confidentiality obligations imposed by 12 this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court 13 order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all 14 claims and defenses in this action, with or without prejudice; and (2) final judgment herein after 15 the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this 16 action, including the time limits for filing any motions or applications for extension of time 17 pursuant to applicable law. 18 5. 19 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party 20 or Non-Party that designates information or items for protection under this Order must take care 21 to limit any such designation to specific material that qualifies under the appropriate standards. 22 The Designating Party must designate for protection only those parts of material, documents, 23 items, or oral or written communications that qualify – so that other portions of the material, 24 documents, items, or communications for which protection is not warranted are not swept 25 unjustifiably within the ambit of this Order. 26 27 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper purpose (e.g., to 28 Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -4- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page5 of 14 1 unnecessarily encumber or retard the case development process or to impose unnecessary 2 expenses and burdens on other parties) expose the Designating Party to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it designated 4 for protection do not qualify for protection, that Designating Party must promptly notify all 5 other Parties that it is withdrawing the mistaken designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 7 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 8 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly 9 so designated before the material is disclosed or produced. 10 Designation in conformity with this Order requires: 11 (a) for information in documentary form (e.g., paper or electronic documents, but 12 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing 13 Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only 14 a portion or portions of the material on a page qualifies for protection, the Producing Party also 15 must clearly identify the protected portion(s) (e.g., by making appropriate markings in the 16 margins). 17 A Party or Non-Party that makes original documents or materials available for 18 inspection need not designate them for protection until after the inspecting Party has indicated 19 which material it would like copied and produced. During the inspection and before the 20 designation, all of the material made available for inspection shall be deemed 21 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied 22 and produced, the Producing Party must determine which documents, or portions thereof, 23 qualify for protection under this Order. Then, before producing the specified documents, the 24 Producing Party must affix the “CONFIDENTIAL” legend to each page that contains Protected 25 Material. If only a portion or portions of the material on a page qualifies for protection, the 26 Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate 27 markings in the margins). 28 Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -5- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page6 of 14 1 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 2 Designating Party identify on the record, before the close of the deposition, hearing, or other 3 proceeding, all protected testimony. (c) for information produced in some form other than documentary and for any other 4 5 tangible items, that the Producing Party affix in a prominent place on the exterior of the 6 container or containers in which the information or item is stored the legend 7 “CONFIDENTIAL.” If only a portion or portions of the information or item warrant protection, 8 the Producing Party, to the extent practicable, shall identify the protected portion(s). 5.3 9 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 10 designate qualified information or items does not, standing alone, waive the Designating Party’s 11 right to secure protection under this Order for such material. Upon timely correction of a 12 designation, the Receiving Party must make reasonable efforts to assure that the material is 13 treated in accordance with the provisions of this Order. 14 6. 15 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 16 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 17 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic 18 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to 19 challenge a confidentiality designation by electing not to mount a challenge promptly after the 20 original designation is disclosed. 21 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 22 process by providing written notice of each designation it is challenging and describing the 23 basis for each challenge. To avoid ambiguity as to whether a challenge has been made, the 24 written notice must recite that the challenge to confidentiality is being made in accordance with 25 this specific paragraph of the Protective Order. The parties shall attempt to resolve each 26 challenge in good faith and must begin the process by meeting and conferring within 14 days of 27 the date of service of notice, and such meet and confer must comply with the process set forth in 28 the Standing Order for Magistrate Hon. Donna M. Ryu addressing discovery disputes. In Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -6- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page7 of 14 1 conferring, the Challenging Party must explain the basis for its belief that the confidentiality 2 designation was not proper and must give the Designating Party an opportunity to review the 3 designated material, to reconsider the circumstances, and, if no change in designation is offered, 4 to explain the basis for the chosen designation. A Challenging Party may proceed to the next 5 stage of the challenge process only if it has engaged in this meet and confer process, as set forth 6 in the Standing Order for Magistrate Hon. Donna M. Ryu addressing discovery disputes, or if 7 the Challenging Party establishes that the Designating Party is unwilling to participate in the 8 meet and confer process in a timely manner. 6.3 9 Judicial Intervention. If the Parties cannot resolve a challenge without court 10 intervention, the Parties shall file a joint letter brief under the Standing Order for Magistrate 11 Hon. Donna M. Ryu addressing discovery disputes (and in compliance with Civil Local Rule 12 79-5, if applicable). Lead trial counsel for both parties must sign the letter and the joint letter 13 must comply with the Standing Order for Magistrate Hon. Donna M. Ryu addressing discovery 14 disputes. In the rare instance that a joint letter is not possible, each side may submit a letter not 15 to exceed four pages, which shall include an explanation of why a joint letter was not possible. . 16 The burden of persuasion in any such challenge proceeding shall be on the Designating 17 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 18 unnecessary expenses and burdens on other parties) may expose the Challenging Party to 19 sanctions. All parties shall continue to afford the material in question the level of protection to 20 which it is entitled under the Producing Party’s designation until the court rules on the 21 challenge. 22 7. 23 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed 24 or produced by another Party or by a Non-Party in connection with this case only for 25 prosecuting, defending, or attempting to settle this litigation. Such Protected Material may be 26 disclosed only to the categories of persons and under the conditions described in this Order. 27 When the litigation has been terminated, a Receiving Party must comply with the provisions of 28 section 13 below (FINAL DISPOSITION). Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -7- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page8 of 14 1 Protected Material must be stored and maintained by a Receiving Party at a location and 2 in a secure manner that ensures that access is limited to the persons authorized under this Order. 3 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 4 ordered by the court or permitted in writing by the Designating Party, a Receiving Party may 5 disclose any information or item designated “CONFIDENTIAL” only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 7 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the 8 information for this litigation and who have signed the “Acknowledgment and Agreement to Be 9 Bound” that is attached hereto as Exhibit A; 10 (b) the officers, directors, and employees (including House Counsel) of the Receiving 11 Party to whom disclosure is reasonably necessary for this litigation and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 14 reasonably necessary for this litigation and who have signed the “Acknowledgment and 15 Agreement to Be Bound” (Exhibit A); 16 (d) the court and its personnel;(e) court reporters and their staff, professional jury or 17 trial consultants, mock jurors, and Professional Vendors to whom disclosure is reasonably 18 necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be 19 Bound” (Exhibit A); 20 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 21 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 22 A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of 23 transcribed deposition testimony or exhibits to depositions that reveal Protected Material must 24 be separately bound by the court reporter and may not be disclosed to anyone except as 25 permitted under this Stipulated Protective Order. 26 27 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information. 28 Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -8- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page9 of 14 1 7.3 Documents designated “CONFIDENTIAL ATTORNEYS’ EYES ONLY” or 2 “CONFIDENTIAL AEO” shall not be disclosed to Plaintiff. In the event Mr. Candappa 3 withdraws or is terminated as counsel for Plaintiff, documents designated “CONFIDENTIAL 4 ATTORNEYS’ EYES ONLY” or “CONFIDENTIAL AEO” shall not be disclosed to Plaintiff 5 or Plaintiff’s new attorney of record without such new attorney of record or Plaintiff first 6 obtaining leave to do so from this Court. 7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 8 LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation that 10 compels disclosure of any information or items designated in this action as 11 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification shall include a 12 13 copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to issue in the 14 15 other litigation that some or all of the material covered by the subpoena or order is subject to 16 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; 17 and (c) cooperate with respect to all reasonable procedures sought to be pursued by the 18 19 Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the 20 21 subpoena or court order shall not produce any information designated in this action as 22 “CONFIDENTIAL” before a determination by the court from which the subpoena or order 23 issued, unless the Party has obtained the Designating Party’s permission. The Designating Party 24 shall bear the burden and expense of seeking protection in that court of its confidential material 25 - and nothing in these provisions should be construed as authorizing or encouraging a Receiving 26 Party in this action to disobey a lawful directive from another court. 27 /// 28 Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -9- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page10 of 14 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN 2 THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non-Party in 4 this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties 5 in connection with this litigation is protected by the remedies and relief provided by this Order. 6 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking 7 additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to produce a Non- 9 Party’s confidential information in its possession, and the Party is subject to an agreement with 10 the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non-Party that some 11 12 or all of the information requested is subject to a confidentiality agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated Protective 13 14 Order in this litigation, the relevant discovery request(s), and a reasonably specific description 15 of the information requested; and 16 (3) make the information requested available for inspection by the Non-Party. 17 (c) If the Non-Party fails to object or seek a protective order from this court within 14 18 days of receiving the notice and accompanying information, the Receiving Party may produce 19 the Non-Party’s confidential information responsive to the discovery request. If the Non-Party 20 timely seeks a protective order, the Receiving Party shall not produce any information in its 21 possession or control that is subject to the confidentiality agreement with the Non-Party before a 22 determination by the court. Absent a court order to the contrary, the Non-Party shall bear the 23 burden and expense of seeking protection in this court of its Protected Material. 24 10. 25 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 26 Material to any person or in any circumstance not authorized under this Stipulated Protective 27 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the 28 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -10- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page11 of 14 1 Protected Material, (c) inform the person or persons to whom unauthorized disclosures were 2 made of all the terms of this Order, and (d) request such person or persons to execute the 3 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A. 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 5 MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain inadvertently 7 produced material is subject to a claim of privilege or other protection, the obligations of the 8 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This 9 provision is not intended to modify whatever procedure may be established in an e-discovery 10 order that provides for production without prior privilege review. Pursuant to Federal Rule of 11 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of 12 a communication or information covered by the attorney-client privilege or work product 13 protection, the parties may incorporate their agreement in the stipulated protective order 14 submitted to the court. 15 12. 16 17 18 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. 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 19 Order no Party waives any right it otherwise would have to object to disclosing or producing 20 any information or item on any ground not addressed in this Stipulated Protective Order. 21 Similarly, no Party waives any right to object on any ground to use in evidence of any of the 22 material covered by this Protective Order. 23 12.3 Filing Protected Material. Without written permission from the Designating 24 Party or a court order secured after appropriate notice to all interested persons, a Party may not 25 file in the public record in this action any Protected Material. A Party that seeks to file under 26 seal any Protected Material must comply with Civil Local Rule 79-5. Protected Material may 27 only be filed under seal pursuant to a court order authorizing the sealing of the specific 28 Protected Material at issue. Pursuant to Civil Local Rule 79-5, a sealing order will issue only Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -11- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page12 of 14 1 upon a request establishing that the Protected Material at issue is privileged, protectable as a 2 trade secret, or otherwise entitled to protection under the law. If a Receiving Party's request to 3 file Protected Material under seal pursuant to Civil Local Rule 79-5(d) is denied by the court, 4 then the Receiving Party may file the information in the public record pursuant to Civil Local 5 Rule 79-5(e) unless otherwise instructed by the court. 6 13. FINAL DISPOSITION Within 60 days after the final disposition of this action, as defined in paragraph 4, each 7 8 Receiving Party must return all Protected Material to the Producing Party or destroy such 9 material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, 10 compilations, summaries, and any other format reproducing or capturing any of the Protected 11 Material. Whether the Protected Material is returned or destroyed, the Receiving Party must 12 submit a written certification to the Producing Party (and, if not the same person or entity, to the 13 Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all 14 the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party 15 has not retained any copies, abstracts, compilations, summaries or any other format reproducing 16 or capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled 17 to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 18 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, 19 attorney work product, and consultant and expert work product, even if such materials contain 20 Protected Material. Any such archival copies that contain or constitute Protected Material 21 remain subject to this Protective Order as set forth in Section 4 (DURATION). 22 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 23 24 DATED: April 21, 2014 25 26 /// 27 /// 28 LAW OFFICE OF JIVAKA CANDAPPA /s/ Jivaka Candappa By: _________________________________________ Jivaka Candappa, Attorney for Plaintiff /// Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -12- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page13 of 14 HOWARD ROME MARTIN & RIDLEY, LLP 6 10 S . Ryu onna M Judge D HON. DONNA M. RYU E C UNITED R N STATES MAGISTRATE JUDGE F H 9 Dated: April 22, 2014 IT RT 8 RED RD PURSUANT TO STIPULATION, IT IS SO ORDERED. E IS SO O NO 7 UNIT ED 5 RT U O 4 R NIA 3 By: /s/ Melissa M. Holmes Joseph C. Howard,STR I Jr. IC ES D Todd H. Master TC AT Melissa M. Holmes T Attorneys for Defendants FO DATED: April 21, 2014 A 2 LI 1 D IS T IC T O R 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -13- Case4:13-cv-03237-DMR Document53 Filed04/21/14 Page14 of 14 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 I, ______________________________________________ [print or type full name], of ______________________________________________________ [print or type full address], declare under penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that was issued by the United States District Court for the Northern District of California on ________________ in the case of Cory Narog v. City of Redwood City et al., Case No. C13-3237 DMR. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any person or entity except in strict compliance with the provisions of this Order. I further agree to submit to the jurisdiction of the United States District Court for the Northern District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after termination of this action. I hereby appoint ________________________________________ [print or type full name] of _____________________________________________________________________ [print or type full address and telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. Date: ______________________________________ City and State where sworn and signed: _________________________________ Printed name: _______________________________ Signature: __________________________________ 28 Amended [Proposed] Stipulated Protective Order: Production of Confidential Records: Narog v. Redwood City C13-3237 DMR -14-

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