G.F. et al v. Contra Costa County et al
Filing
107
ORDER by Judge Saundra Brown Armstrong Granting 106 Stipulated PROTECTIVE ORDER. (ndr, COURT STAFF) (Filed on 1/14/2014)
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SIDNEY M. WOLINSKY (CA BAR NO. 33716) (swolinsky@dralegal.org)
MARY-LEE K. SMITH (CA BAR NO. 239086) (msmith@dralegal.org)
REBECCA WILLIFORD (CA BAR NO. 269977 ) (rwilliford@dralegal.org)
KARA JANSSEN (CA BAR NO. 274762) (kjanssen@dralegal.org)
DISABILITY RIGHTS ADVOCATES
2001 Center Street, Fourth Floor
Berkeley, CA 94704-1204
Telephone:
(510) 665-8644
Facsimile:
(510) 665-8511
HERNAN VERA (CA BAR NO. 175149) (hvera@publiccounsel.org)
LAURA FAER (CA BAR NO. 233846) (lfaer@publiccounsel.org)
PUBLIC COUNSEL
2001 Center Street, Fourth Floor
Berkeley, CA 94704-1204
Telephone:
(510) 529-3419
Facsimile:
(213) 385-9089
GRACE A. CARTER (CA BAR NO. 101610) (gracecarter@paulhastings.com)
GINA COOK (CA BAR NO. 245611 ) (ginacook@paulhastings.com)
PAUL HASTINGS LLP
55 Second Street, Twenty-Fourth Floor
San Francisco, CA 94105-3441
Telephone:
(415) 856-7000
Facsimile:
(415) 856-7100
Attorneys for Plaintiffs
(Additional Counsel Listed on Next Page)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
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G.F., by and through her guardian ad litem,
Gail F.; W.B., by and through his guardian ad
litem, CiCi C.; Q.G., by and through his
guardian ad litem, Barbara C.; and on behalf of
themselves and a class of those similarly
situated,
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Case No. C 13-3667-SBA
STIPULATED PROTECTIVE ORDER
Plaintiffs,
v.
CONTRA COSTA COUNTY; CONTRA
COSTA COUNTY OFFICE OF
EDUCATION.
Defendants.
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. Cal., No. C 13-3667-SBA
LEGAL_US_W # 76278399.7
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SHARON L. ANDERSON (SBN 94814)
County Counsel
D. CAMERON BAKER (SBN 154432)
Deputy County Counsel
COUNTY OF CONTRA COSTA
651 Pine Street, Ninth Floor
Martinez, California 94553
Telephone: (925) 335-1800
Facsimile: (925) 335-1866
Electronic Mail: cameron.baker@cc.cccounty.us
Attorneys for Defendant Contra Costa County
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Kimberly A. Smith, SBN 176659
ksmith@fagenfriedman.com
David Mishook, SBN 273555
dmishook@fagenfriedman.com
FAGEN FRIEDMAN & FULFROST, LLP
70 Washington Street, Suite 205
Oakland, California 94607
Phone: 510-550-8200
Fax: 510-550-8211
Attorneys for Defendant Contra Costa County
Office of Education
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. Cal., No. C 13-3667-SBA
LEGAL_US_W # 76278399.7
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PURPOSES AND LIMITATIONS
Disclosure and discovery activity in this action are likely to involve
production of confidential, proprietary, or private information for which special
protection from public disclosure and from use for any purpose other than
prosecuting this litigation may be warranted. Accordingly, the parties hereby
stipulate to and petition the court to enter the following Stipulated Protective Order.
The parties acknowledge that this Order does not confer blanket protections on all
disclosures or responses to discovery and that the protection it affords from public
disclosure and use extends only to the limited information or items that are entitled
to confidential treatment under the applicable legal principles. The parties further
acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective
Order does not entitle them to file confidential information under seal; Civil Local
Rule 79-5 and General Order 62 set forth the procedures that must be followed and
the standards that will be applied when a party seeks permission from the court to
file material under seal.
2.
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 generated, stored or maintained) or tangible things that qualify for
protection under Federal Rule of Civil Procedure 26(c) or that implicate a party or
non-party’s constitutional right to privacy or other statutory privacy right. Such
documents include but are not limited to medical records, psychological or
psychiatric records, juvenile court records, and educational records protected by the
Family Educational Rights and Privacy Act.
2.3
Counsel (without qualifier): Outside Counsel of Record and House
Counsel (as well as their support staff).
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. CAL., NO. C 13-3667-SBA
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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 medium or manner in which it is generated, stored, or maintained (including,
among other things, testimony, transcripts, and tangible things), that are produced
or generated in disclosures or responses to discovery in this matter.
2.6
Expert: a person with specialized knowledge or experience in a matter
pertinent to the litigation who has been retained by a Party or its counsel to serve as
an expert witness or as a consultant in this action.
2.7
House Counsel: attorneys who are employees of a party to this action.
House Counsel does not include Outside Counsel of Record or any other outside
counsel.
2.8
Non-Party: any natural person, partnership, corporation, association,
or other legal entity not named as a Party to this action.
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 action on behalf of that party or are affiliated with a law firm
which has appeared on behalf of that party. Outside Counsel of Record specifically
includes attorneys from the Contra Costa County Counsel’s Office.
2.10 Party: any party to this action, including all of its officers, directors,
employees, consultants, retained experts, and Outside Counsel of Record (and their
support staffs).
2.11 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this action.
2.12 Professional Vendors: persons or entities that provide litigation
support services (e.g., photocopying, videotaping, translating, preparing exhibits or
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. CAL., NO. C 13-3667-SBA
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demonstrations, and organizing, storing, or retrieving data in any form or medium)
and their employees and subcontractors.
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2.13 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”
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2.14 Receiving Party: a Party that receives Disclosure or Discovery
Material from a Producing Party.
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SCOPE
The protections conferred by this Stipulation and Order cover not only
Protected Material (as defined above), but also (1) any information copied or
extracted from Protected Material; (2) all copies, excerpts, summaries, or
compilations of Protected Material; and (3) any testimony, conversations, or
presentations by Parties or their Counsel that might reveal Protected Material.
However, the protections conferred by this Stipulation and Order do not cover the
following information: (a) any information that is in the public domain at the time
of disclosure to a Receiving Party or becomes part of the public domain after its
disclosure to a Receiving Party as a result of publication not involving a violation
of this Order, including becoming part of the public record through trial or
otherwise; and (b) any information known to the Receiving Party prior to the
disclosure or obtained by the Receiving Party after the disclosure from a source
who obtained the information lawfully and under no obligation of confidentiality to
the Designating Party. Any use of Protected Material at trial shall be governed by a
separate agreement or order.
4.
DURATION
Even after final disposition of this litigation, the confidentiality obligations
imposed by this Order shall remain in effect until a Designating Party agrees
otherwise in writing or a court order otherwise directs. Final disposition shall be
deemed to be the later of (1) dismissal of all claims and defenses in this action, with
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. CAL., NO. C 13-3667-SBA
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or without prejudice; and (2) final judgment herein after the completion and
exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
including the time limits for filing any motions or applications for extension of time
pursuant to applicable law.
5.
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection.
Each Party or Non-Party that designates information or items for protection under
this Order must take care to limit any such designation to specific material that
qualifies under the appropriate standards. The Designating Party must designate for
protection only those parts of material, documents, items, or oral or written
communications that qualify - so that other portions of the material, documents,
items, or communications for which protection is not warranted are not swept
unjustifiably within the ambit of this Order.
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 unnecessarily encumber or retard the case development process or
to impose unnecessary expenses and burdens on other parties) expose the
Designating Party to sanctions.
If it comes to a Designating Party’s attention that information or items that it
designated for protection do not qualify for protection, that Designating Party must
promptly notify all other Parties that it is withdrawing the mistaken designation.
5.2
Manner and Timing of Designations. Except as otherwise provided in
this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
under this Order must be clearly so designated before the material is disclosed or
produced.
Designation in conformity with this Order requires:
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. CAL., NO. C 13-3667-SBA
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(a) for information in documentary form (e.g., paper or electronic
documents, but excluding transcripts of depositions or other pretrial or trial
proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each
page that contains protected material. If only a portion or portions of the material
on a page qualifies for protection, the Producing Party also must clearly identify the
protected portion(s) (e.g., by making appropriate markings in the margins). A Party
or Non-Party that makes original documents or materials available for inspection
need not designate them for protection until after the inspecting Party has indicated
which material it would like copied and produced. During the inspection and
before the designation, all of the material made available for inspection shall be
deemed “CONFIDENTIAL.” After the inspecting Party has identified the
documents it wants copied and produced, the Producing Party must determine
which documents, or portions thereof, qualify for protection under this Order.
Then, before producing the specified documents, the Producing Party must affix the
“CONFIDENTIAL” legend to each page that contains Protected Material. If only a
portion or portions of the material on a page qualifies for protection, the Producing
Party also must clearly identify the protected portion(s) (e.g., by making
appropriate markings in the margins).
(b) for testimony given in deposition or in other pretrial or trial
proceedings, that the Designating Party identify on the record, before the close of
the deposition, hearing, or other proceeding, all protected testimony.
(c) for information produced in some form other than documentary and
for any other tangible items, that the Producing Party affix in a prominent place on
the exterior of the container or containers in which the information or item is stored
the legend “CONFIDENTIAL.” If only a portion or portions of the information or
item warrant protection, the Producing Party, to the extent practicable, shall identify
the protected portion(s).
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. CAL., NO. C 13-3667-SBA
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5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent
failure to designate qualified information or items does not, standing alone, waive
the Designating Party’s right to secure protection under this Order for such
material. Upon timely correction of a designation, the Receiving Party must make
reasonable efforts to assure that the material is treated in accordance with the
provisions of this Order.
6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Any Party or Non-Party may challenge a
designation of confidentiality at any time. Unless a prompt challenge to a
Designating Party’s confidentiality designation is necessary to avoid foreseeable,
substantial unfairness, unnecessary economic burdens, or a significant disruption or
delay of the litigation, a Party does not waive its right to challenge a confidentiality
designation by electing not to mount a challenge promptly after the original
designation is disclosed.
6.2
Meet and Confer. The Challenging Party shall initiate the dispute
resolution process by providing written notice of each designation it is challenging
and describing the basis for each challenge. To avoid ambiguity as to whether a
challenge has been made, the written notice must recite that the challenge to
confidentiality is being made in accordance with this specific paragraph of the
Protective Order. The parties shall attempt to resolve each challenge in good faith
and must begin the process by conferring directly (in voice to voice dialogue; other
forms of communication are not sufficient) within 14 days of the date of service of
notice. In conferring, the Challenging Party must explain the basis for its belief that
the confidentiality designation was not proper and must give the Designating Party
an opportunity to review the designated material, to reconsider the circumstances,
and, if no change in designation is offered, to explain the basis for the chosen
designation. A Challenging Party may proceed to the next stage of the challenge
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process only if it has engaged in this meet and confer process first or establishes
that the Designating Party is unwilling to participate in the meet and confer process
in a timely manner.
6.3
Judicial Intervention. If the Parties cannot resolve a challenge without
court intervention, the Designating Party shall file and serve a motion to retain
confidentiality under Civil Local Rule 7 (and in compliance with Civil Local Rule
79-5 and General Order 62, if applicable) within 21 days of the initial notice of
challenge or within 14 days of the parties agreeing that the meet and confer process
will not resolve their dispute, whichever is earlier. Each such motion must be
accompanied by a competent declaration affirming that the movant has complied
with the meet and confer requirements imposed in the preceding paragraph. Failure
by the Designating Party to make such a motion including the required declaration
within 21 days (or 14 days, if applicable) shall automatically waive the
confidentiality designation for each challenged designation. In addition, the
Challenging Party may file a motion challenging a confidentiality designation at
any time if there is good cause for doing so, including a challenge to the
designation of a deposition transcript or any portions thereof. Any motion brought
pursuant to this provision must be accompanied by a competent declaration
affirming that the movant has complied with the meet and confer requirements
imposed by the preceding paragraph.
The burden of persuasion in any such challenge proceeding shall be on the
Designating Party. Frivolous challenges, and those made for an improper purpose
(e.g., to harass or impose unnecessary expenses and burdens on other parties) may
expose the Challenging Party to sanctions. Unless the Designating Party has
waived the confidentiality designation by failing to file a motion to retain
confidentiality as described above, all parties shall continue to afford the material in
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STIPULATED PROTECTIVE ORDER
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question the level of protection to which it is entitled under the Producing Party’s
designation until the court rules on the challenge.
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case only for prosecuting, defending, or attempting to settle this litigation. Such
Protected Material may be disclosed only to the categories of persons and under the
conditions described in this Order. When the litigation has been terminated, a
Receiving Party must comply with the provisions of section 13 below (FINAL
DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a
location and in a secure manner that ensures that access is limited to the persons
authorized under this Order.
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7.2
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Receiving Party may disclose any information or item designated
“CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this action, as well
as employees of said Outside Counsel of Record to whom it is reasonably necessary
to disclose the information for this litigation and who have signed the
“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
A;
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Disclosure of “CONFIDENTIAL” Information or Items. Unless
otherwise ordered by the court or permitted in writing by the Designating Party, a
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Basic Principles. A Receiving Party may use Protected Material that is
disclosed or produced by another Party or by a Non-Party in connection with this
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ACCESS TO AND USE OF PROTECTED MATERIAL
(b) the officers, directors, and employees (including House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this litigation
and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
A);
(c) Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this litigation and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d) the court and its personnel;
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(e) court reporters and their staff, professional jury or trial consultants,
mock jurors, and Professional Vendors to whom disclosure is reasonably necessary
for this litigation and who have signed the “Acknowledgment and Agreement to Be
Bound” (Exhibit A);
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(f) during their depositions, witnesses in the action to whom disclosure is
reasonably necessary and who have signed the “Acknowledgment and Agreement
to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
ordered by the court. Pages of transcribed deposition testimony or exhibits to
depositions that reveal Protected Material must be marked “CONFIDENTIAL
PURSUANT TO PROTECTIVE ORDER” by the court reporter and may not be
disclosed to anyone except as permitted under this Stipulated Protective Order.
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(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information.
8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
IN OTHER LITIGATION
If a Party is served with a subpoena or a court order issued in other litigation
that compels disclosure of any information or items designated in this action as
“CONFIDENTIAL,” that Party must:
(a) promptly notify in writing the Designating Party. Such notification
shall include a copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or order
to issue in the other litigation that some or all of the material covered by the
subpoena or order is subject to this Protective Order. Such notification shall
include a copy of this Stipulated Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be
pursued by the Designating Party whose Protected Material may be affected.
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If the Designating Party timely seeks a protective order, the Party served with
the subpoena or court order shall not produce any information designated in this
action as “CONFIDENTIAL” before a determination by the court from which the
subpoena or order issued, unless the Party has obtained the Designating Party’s
permission. The Designating Party shall bear the burden and expense of seeking
protection in that court of its confidential material - and nothing in these provisions
should be construed as authorizing or encouraging a Receiving Party in this action
to disobey a lawful directive from another court.
9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a
Non-Party in this action and designated as “CONFIDENTIAL.” Such information
produced by Non-Parties in connection with this litigation is protected by the
remedies and relief provided by this Order. Nothing in these provisions should be
construed as prohibiting a Non-Party from seeking additional protections.
(b) In the event that a Party is required, by a valid discovery request, to
produce a Non-Party’s confidential information in its possession, and the Party is
subject to an agreement with 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 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 Order in this litigation, the relevant discovery request(s), and a
reasonably specific description of the information requested; and
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(3) make the information requested available for inspection by the
Non-Party.
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(c) If the Non-Party fails to object or seek a protective order from this
court within 14 days of receiving the notice and accompanying information, the
Receiving Party may produce the Non-Party’s confidential information responsive
to the discovery request. If the Non-Party timely seeks a protective order, the
Receiving Party shall not produce any information in its possession or control that
is subject to the confidentiality agreement with the Non-Party before a
determination by the court. Absent a court order to the contrary, the Non-Party
shall bear the burden and expense of seeking protection in this court of its Protected
Material.
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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
Protected Material to any person or in any circumstance not authorized under this
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
writing the Designating Party of the unauthorized disclosures, (b) use its best
efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
person or persons to whom unauthorized disclosures were made of all the terms of
this Order, and (d) request such person or persons to execute the “Acknowledgment
and Agreement to Be Bound” that is attached hereto as Exhibit A.
11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain
inadvertently produced material is subject to a claim of privilege or other
protection, the obligations of the Receiving Parties are those set forth in Federal
Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
whatever procedure may be established in an e-discovery order that provides for
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production without prior privilege review. Pursuant to Federal Rule of Evidence
502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
of a communication or information covered by the attorney-client privilege or work
product protection, the parties may incorporate their agreement in the stipulated
protective order submitted to the court.
12.
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 Order no Party waives any right it otherwise would have to object to
disclosing or producing any information or item on any ground not addressed in
this Stipulated Protective Order. Similarly, no Party waives any right to object on
any ground to use in evidence of any of the material covered by this Protective
Order.
12.3 Filing Protected Material. Without written permission from the
Designating Party or a court order secured after appropriate notice to all interested
persons, a Party may not file in the public record in this action any Protected
Material. A Party that seeks to file under seal any Protected Material must comply
with Civil Local Rule 79-5 and General Order 62. Protected Material may only be
filed under seal pursuant to a court order authorizing the sealing of the specific
Protected Material at issue. Pursuant to Civil Local Rule 79-5 and General Order
62, a sealing order will issue only upon a request establishing that the Protected
Material at issue is privileged, protectable as a trade secret, or otherwise entitled to
protection under the law. If a Receiving Party’s request to file Protected Material
under seal pursuant to Civil Local Rule 79-5(d) and General Order 62 is denied by
the court, then the Receiving Party may file the information in the public record
pursuant to Civil Local Rule 79-5(e) unless otherwise instructed by the court.
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13.
FINAL DISPOSITION
Within 60 days after the final disposition of this action, as defined in
paragraph 4, each Receiving Party must return all Protected Material to the
Producing Party or destroy such material. As used in this subdivision, “all
Protected Material” includes all copies, abstracts, compilations, summaries, and any
other format reproducing or capturing any of the Protected Material. Whether the
Protected Material is returned or destroyed, the Receiving Party must submit a
written certification to the Producing Party (and, if not the same person or entity, to
the Designating Party) by the 60 day deadline that (1) identifies (by category, where
appropriate) all the Protected Material that was returned or destroyed and (2)affirms
that the Receiving Party has not retained any copies, abstracts, compilations,
summaries or any other format reproducing or capturing any of the Protected
Material. Notwithstanding this provision, Counsel are entitled to retain an archival
copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
work product, and consultant and expert work product, even if such materials
contain Protected Material. Any such archival copies that contain or constitute
Protected Material remain subject to this Protective Order as set forth in Section 4
(DURATION).
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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Respectfully submitted,
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DATED: January 13, 2014
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MARY-LEE K. SMITH
REBECCA WILLIFORD
KARA JANSSEN
DISABILITY RIGHTS ADVOCATES
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/s/
Mary-Lee K. Smith
Attorneys for Plaintiffs
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LEGAL_US_W # 77113834.1
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. CAL., NO. C 13-3667-SBA
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DATED: January 13, 2014
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LAURA FAER
PUBLIC COUNSEL
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/s/
Laura Faer
Attorneys for Plaintiffs
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5
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DATED: January 13, 2014
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GRACE A. CARTER
GINA GUARIENTI COOK
PAUL HASTINGS LLP
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/s/
Grace A. Carter
Attorneys for Plaintiffs
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DATED: January 13, 2014
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/s/
D. Cameron Baker
Attorneys for Defendant CONTRA COSTA
COUNTY
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DATED: January 13, 2014
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FAGEN FRIEDMAN & FULFROST, LLP
/s/
Kimberly Smith
Attorneys for Defendant CONTRA COSTA
COUNTY OFFICE OF EDUCATION
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COUNTY COUNSEL FOR THE COUNTY OF
CONTRA COSTA
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: 1/14/2014
_______________________
Judge Saundra B. Armstrong
United States District Judge
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LEGAL_US_W # 77113834.1
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. CAL., NO. C 13-3667-SBA
1
EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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 [date] in the case of G.F., et al. v. Contra Costa County, et al., Case
No. C 13-3667-SBA. 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: __________________________________
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Printed name: ______________________________
Signature: _________________________________
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LEGAL_US_W # 77113834.1
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. CAL., NO. C 13-3667-SBA
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2
I, Mary-Lee K. Smith, am the ECF User whose ID and password are being used to file this
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STIPULATED PROTECTIVE ORDER. In compliance with General Order 45, X.B., I hereby
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attest that Laura Faer, Grace A. Carter, Kimberly Smith and D. Cameron Baker have concurred in
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this filing and the use of their electronic signatures above.
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DATED: January 13, 2014
Respectfully submitted,
DISABILITY RIGHTS ADVOCATES
PUBLIC COUNSEL
PAUL HASTINGS LLP
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/s/
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Mary-Lee K. Smith
Attorneys for Plaintiffs
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LEGAL_US_W # 77113834.1
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STIPULATED PROTECTIVE ORDER
U.S.D.C., N.D. CAL., NO. C 13-3667-SBA
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