Stanislav Petrov v. Alameda County et al
Filing
49
STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION [*AS MODIFIED BY THE COURT*] re 47 STIPULATION WITH PROPOSED ORDER FOR PROTECTIVE ORDER filed by Paul Wieber, Alameda County, Luis Santamaria, Stanislav Petrov, Gregory J. Ahern. Signed by Judge Yvonne Gonzalez Rogers on 11/3/16. (fs, COURT STAFF) (Filed on 11/3/2016)
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Timothy P. Murphy, State Bar No. 120920
EDRINGTON, SCHIRMER & MURPHY LLP
2300 Contra Costa Boulevard, Suite 450
Pleasant Hill, CA 94523-3936
Telephone: (925) 827-3300
Facsimile: (925) 827-3320
Attorneys for Defendants
ALAMEDA COUNTY and SHERIFF
GREGORY J. AHERN
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA – OAKLAND COURTHOUSE
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) Case No.: 4:16-cv-04323-YGR
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) STIPULATED PROTECTIVE ORDER FOR
Plaintiff,
) STANDARD LITIGATION
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vs.
) *AS MODIFIED BY THE COURT*
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ALAMEDA COUNTY, a public entity;
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SHERIFF GREGORY J. AHERN; ACSO
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DEPUTIES PAUL WIEBER, LUIS
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SANTAMARIA, SHAWN OSBORNE,
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MALIZIA, MILLER, SHELTON, GRIFFITH, )
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SERGEANT TAYLOR, and DOES 1-10,
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Jointly and Severally,
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Defendants.
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STANISLAV PETROV, individually,
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1.
PURPOSES AND LIMITATIONS
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Disclosure and discovery activity in this action are likely to involve production of
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confidential, proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may be warranted.
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Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated
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Protective Order. The parties acknowledge that this Order does not confer blanket protections on
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all disclosures or responses to discovery and that the protection it affords from public disclosure
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and use extends only to the limited information or items that are entitled to confidential treatment
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under the applicable legal principles. The parties further acknowledge, as set forth in Section 12.3,
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below, that this Stipulated Protective Order does not entitle them to file confidential information
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under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards
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that will be applied when a party seeks permission from the court to file material under seal.
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2.
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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
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generated, stored or maintained) or tangible things that qualify for protection under Federal Rule
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of Civil Procedure 26(c), and for which public disclosure is likely to result in particularized harm
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and violate privacy interests recognized by law. This information may include:
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a.
personnel file records of any peace officer;
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b.
medical records;
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c.
social security numbers and similar sensitive identifying information
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(unless redacted by order or by agreement of all parties).
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
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medium or manner in which it is generated, stored, or maintained (including, among other things,
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testimony, transcripts, and tangible things), that are produced or generated in disclosures or
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responses to discovery in this matter.
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2.6
Expert: a person with specialized knowledge or experience in a matter pertinent to
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the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
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consultant in this action.
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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.
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2.8
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Non-Party: any natural person, partnership, corporation, association, or other legal
entity not named as a Party to this action.
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Outside Counsel of Record: attorneys who are not employees of a party to this
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action but are retained to represent or advise a party to this action and have appeared in this action
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on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
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consultants, retained experts, and Outside Counsel of Record (and their support staffs).
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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.
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Professional Vendors: persons or entities that provide litigation support services
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(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
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organizing, storing, or retrieving data in any form or medium) and their employees and
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subcontractors.
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Protected Material: any Disclosure or Discovery Material that is designated as
“CONFIDENTIAL.”
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Receiving Party: a Party that receives Disclosure or Discovery Material from a
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Producing Party.
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3.
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SCOPE
The protections conferred by this Stipulation and Order cover not only Protected Material
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(as defined above), but also (1) any information copied from Protected Material; (2) all copies,
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excerpts, summaries, or compilations of Protected Material that reveal the source of the Protected
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Material or that reveal specific information entitled to confidentiality as a matter of law; and (3)
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any testimony, conversations, or presentations by Parties or their Counsel that might reveal
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Protected Material. However, the protections conferred by this Stipulation and Order do not cover
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the following information: (a) any information that is in the public domain at the time of
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disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a
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Receiving Party as a result of publication not involving a violation of this Order, including
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becoming part of the public record through trial or otherwise; and (b) any information known to
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the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure
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from a source who obtained the information lawfully and under no obligation of confidentiality to
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the Designating Party. Any use of Protected Material at trial shall be governed by a separate
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agreement or order.
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4.
DURATION
Even after final disposition of this litigation, the confidentiality obligations imposed by this
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Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order
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otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims
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and defenses in this action, with or without prejudice; and (2) final judgment herein after the
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completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
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including the time limits for filing any motions or applications for extension of time pursuant to
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applicable law.
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5.
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DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection. Each Party
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or Non-Party that designates information or items for protection under this Order must take care to
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limit any such designation to specific material that qualifies under the appropriate standards. The
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Designating Party must designate for protection only those parts of material, documents, items, or
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oral or written communications that qualify – so that other portions of the material, documents,
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items, or communications for which protection is not warranted are not swept unjustifiably within
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the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations that are
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shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
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unnecessarily encumber or retard the case development process or to impose unnecessary
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expenses and burdens on other parties) expose the Designating Party to sanctions.
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If it comes to a Designating Party’s attention that information or items that it designated
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for protection do not qualify for protection, that Designating Party must promptly notify all other
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Parties that it is withdrawing the mistaken designation.
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5.2
Manner and Timing of Designations. Except as otherwise provided in this Order
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(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
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Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
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designated before the material is disclosed or produced.
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Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic documents, but
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excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party
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affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a
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portion or portions of the material on a page qualifies for protection, the Producing Party also must
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clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). A
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Party or Non-Party that makes original documents or materials available for inspection need not
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designate them for protection until after the inspecting Party has indicated which material it would
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like copied and produced. During the inspection and before the designation, all of the material
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made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
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identified the documents it wants copied and produced, the Producing Party must determine which
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documents, or portions thereof, qualify for protection under this Order. Then, before producing the
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specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page
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that contains Protected Material. If only a portion or portions of the material on a page qualifies
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for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by
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making appropriate markings in the margins).
(b) for testimony given in deposition or in other pretrial or trial proceedings, that the
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Designating Party identify on the record, before the close of the deposition, hearing, or other
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proceeding, all protected testimony.
(c) for information produced in some form other than documentary and for any other
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tangible items, that the Producing Party affix in a prominent place on the exterior of the container
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or containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a
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portion or portions of the information or item warrant protection, the Producing Party, to the
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extent practicable, shall identify the protected portion(s).
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5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
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designate qualified information or items does not, standing alone, waive the Designating Party’s
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right to secure protection under this Order for such material. Upon timely correction of a
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designation, the Receiving Party must make reasonable efforts to assure that the material is treated
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in accordance with the provisions of this Order.
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6.
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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Any Party or Non-Party may challenge a designation of
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confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
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designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic
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burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to
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challenge a confidentiality designation by electing not to mount a challenge promptly after the
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original designation is disclosed.
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6.2
Meet and Confer. The Challenging Party shall initiate the dispute resolution
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process by providing written notice of each designation it is challenging and describing the basis
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for each challenge. To avoid ambiguity as to whether a challenge has been made, the written
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notice must recite that the challenge to confidentiality is being made in accordance with this
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specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in
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good faith and must begin the process by conferring directly (in voice to voice dialogue; other
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forms of communication are not sufficient) within 14 days of the date of service of notice. In
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conferring, the Challenging Party must explain the basis for its belief that the confidentiality
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designation was not proper and must give the Designating Party an opportunity to review the
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designated material, to reconsider the circumstances, and, if no change in designation is offered, to
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explain the basis for the chosen designation. A Challenging Party may proceed to the next stage of
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the challenge process only if it has engaged in this meet and confer process first or establishes that
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the Designating Party is unwilling to participate in the meet and confer process in a timely
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manner.
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6.3
Judicial Intervention.
If the Parties cannot resolve a challenge without court
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intervention, the parties shall follow the Court’s Standing Order in Civil Cases regarding
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Discovery and Discovery Motions. The parties may file a joint letter brief regarding retaining
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confidentiality within 21 days of the initial notice of challenge or within 14 days of the parties
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agreeing that the meet and confer process will not resolve their dispute, whichever is earlier.
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Failure by a Designating Party to file such discovery dispute letter within the applicable 21 or 14
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day period (set forth above) with the Court shall automatically waive the confidentiality
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designation for each challenged designation. If, after submitting a joint letter brief, the Court
allows that a motion may be filed, any 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. The Court, in its discretion, may elect to transfer the
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discovery matter to a Magistrate Judge.
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In addition, the parties may file a joint letter brief regarding a challenge to 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. If, after submitting a joint letter brief, the Court
allows that a motion may be filed, any motion brought pursuant to this provision must be
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accompanied by a competent declaration affirming that the movant has complied with the meet
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and confer requirements imposed by the preceding paragraph. The Court, in its discretion, may
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elect to refer the discovery matter to a Magistrate Judge.
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The burden of persuasion in any such challenge proceeding shall be on the Designating
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Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
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unnecessary expenses and burdens on other parties) may expose the Challenging Party to
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sanctions. Unless the Designating Party has waived the confidentiality designation by failing to
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file a letter brief to retain confidentiality as described above, all parties shall continue to afford the
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material in question the level of protection to which it is entitled under the Producing Party’s
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designation until the court rules on the challenge.
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7.
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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is disclosed or
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produced by another Party or by a Non-Party in connection with this case only for prosecuting,
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defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to
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the categories of persons and under the conditions described in this Order. When the litigation has
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been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
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DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a location and in
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a secure manner that ensures that access is limited to the persons authorized under this Order.
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Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered
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by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
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information or item designated “CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this action, as well as
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employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the
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information for this litigation (counsel and law firms appearing in this action are deemed to have
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agreed to be bound by this Protective Order);
(b) the officers, directors, and employees (including House Counsel) of the Receiving
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Party to whom disclosure is reasonably necessary for this litigation and who have signed the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
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reasonably necessary for this litigation and who have signed the “Acknowledgment and
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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,
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and Professional Vendors to whom disclosure is reasonably necessary for this litigation;
(f) during their depositions, witnesses in the action to whom disclosure is reasonably
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necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
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unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed
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deposition testimony or exhibits to depositions that reveal Protected Material must be separately
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bound by the court reporter and may not be disclosed to anyone except as permitted under this
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Stipulated Protective Order or as agreed by the Designating Party.
(g) the author or recipient of a document containing the information or a custodian or
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other person who otherwise possessed or knew the information.
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8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
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LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation that compels
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disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
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must:
(a) promptly notify in writing the Designating Party. Such notification shall include a
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copy of the subpoena or court order;
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(b) promptly notify in writing the party who caused the subpoena or order to issue in
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the other litigation that some or all of the material covered by the subpoena or order is subject to
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this Protective Order. Such notification shall include a copy of this Stipulated Protective Order;
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and
(c) cooperate with respect to all reasonable procedures sought to be pursued by the
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Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with the subpoena
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or court order shall not produce any information designated in this action as “CONFIDENTIAL”
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before a determination by the court from which the subpoena or order issued, unless the Party has
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obtained the Designating Party’s permission. The Designating Party shall bear the burden and
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expense of seeking protection in that court of its confidential material – and nothing in these
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provisions should be construed as authorizing or encouraging a Receiving Party in this action to
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disobey a lawful directive from another court.
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9.
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A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
LITIGATION
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(a) The terms of this Order are applicable to information produced by a Non-Party in
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this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in
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connection with this litigation is protected by the remedies and relief provided by this Order.
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Nothing in these provisions should be construed as prohibiting a Non-Party from seeking
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additional protections.
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(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
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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
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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
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in this litigation, the relevant discovery request(s), and a reasonably specific description of the
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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
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days of receiving the notice and accompanying information, the Receiving Party may produce the
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Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely
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seeks a protective order, the Receiving Party shall not produce any information in its possession or
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control that is subject to the confidentiality agreement with the Non-Party before a determination
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by the court. Absent a court order to the contrary, the Non-Party shall bear the burden and
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expense of seeking protection in this court of its Protected Material.
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10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
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Material to any person or in any circumstance not authorized under this Stipulated Protective
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Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the
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unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected
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Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the
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terms of this Order, and (d) request such person or persons to execute the “Acknowledgment and
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Agreement to Be Bound” that is attached hereto as Exhibit A.
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11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
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MATERIAL
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When a Producing Party gives notice to Receiving Parties that certain inadvertently
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produced material is subject to a claim of privilege or other protection, the obligations of the
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Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
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provision is not intended to modify whatever procedure may be established in an e-discovery order
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that provides for production without prior privilege review. Pursuant to Federal Rule of Evidence
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502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a
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communication or information covered by the attorney-client privilege or work product protection,
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the parties may incorporate their agreement in the stipulated protective order submitted to the
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court.
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12.
12.1
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MISCELLANEOUS
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
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Right to Assert Other Objections. By stipulating to the entry of this Protective
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Order no Party waives any right it otherwise would have to object to disclosing or producing any
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information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
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Party waives any right to object on any ground to use in evidence of any of the material covered
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by this Protective Order.
12.3
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Filing Protected Material. Without written permission from the Designating Party
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or a court order secured after appropriate notice to all interested persons, a Party may not file in
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the public record in this action any Protected Material. A Party that seeks to file under seal any
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Protected Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
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under seal pursuant to a court order authorizing the sealing of the specific Protected Material at
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issue. Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request
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establishing that the Protected Material at issue is privileged, protectable as a trade secret, or
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otherwise entitled to protection under the law. If a Receiving Party's request to file Protected
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Material under seal pursuant to Civil Local Rule 79-5(d) is denied by the court, then the Receiving
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Party may file the information in the public record pursuant to Civil Local Rule 79-5(e) unless
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otherwise instructed by the court.
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13.
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FINAL DISPOSITION
Within 60 days after the final disposition of this action, as defined in paragraph 4, upon
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written notification served by Producing or Designating Party, each Receiving Party must return
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all Protected Material to the Producing Party or destroy such material. As used in this subdivision,
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“all Protected Material” includes all copies, abstracts, compilations, summaries, and any other
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format reproducing or capturing any of the Protected Material. Whether the Protected Material is
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returned or destroyed, the Receiving Party must submit a written certification to the Producing
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Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline that
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(1) identifies (by category, where appropriate) all the Protected Material that was returned or
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destroyed and (2)affirms that the Receiving Party has not retained any copies, abstracts,
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compilations, summaries or any other format reproducing or capturing any of the Protected
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Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
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pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
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correspondence, deposition and trial exhibits, expert reports, attorney work product, and
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consultant and expert work product, even if such materials contain Protected Material. Any such
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archival copies that contain or constitute Protected Material remain subject to this Protective Order
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as set forth in Section 4 (DURATION).
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: October 31, 2016
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/s/
Michael J. Haddad, Esq.
Attorney for Plaintiff
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HADDAD & SHERWIN LLP
Dated: October 31, 2016
EDRINGTON, SCHIRMER & MURPHY LLP
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/s/
Timothy P. Murphy
Attorneys for Defendants
ALAMEDA COUNTY and SHERIFF
GREGORY J. AHERN
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Dated: October 31, 2016
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/s/
Jeffrey M. Vucinich, Esq.
Attorneys for Defendant PAUL WEIBER
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CLAPP MORONEY BELLAGAMBA
VUCINICH BEEMAN & SCHELEY
Dated: October 31, 2016
MCNAMARA, NEY, BEATTY, SLATTERY,
BORGES & AMBACHER LLP
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/s/
Noah G. Blechman, Esq.
Attorneys for Defendant LUIS SANTAMARIA
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Dated: October 31, 2016
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LAW OFFICE OF VINCENT P. HURLEY
/s/
Vincent P. Hurley, Esq.
Attorneys for Defendant SHAWN OSBORNE
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Dated: October 31, 2016
/s/
Mark E. Berry, Esq.
Attorneys for Defendants
JOHN MALIZIA and ROBERT GRIFFITH
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Dated: October 31, 2016
HOWARD ROME MARTIN & RIDLEY LLP
/s/
Todd H. Master, Esq.
Attorneys for Defendants
JOSHUA MILLER and DARRIN SHELTON
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MAYALL HURLEY, PC
Dated: October 31, 2016
SENNEFF FREEMAN & BLUESTONE, LLP
/s/
Bonnie A. Freeman, Esq.
Attorneys for Defendant
DAVID TAYLOR
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: ________________________
November 3, 2016
_____________________________________
Yvonne Gonzalez Rogers
United States District Court Judge
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, _____________________________ [print or type full name], of _________________
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[print or type full address], declare under penalty of perjury that I have read in its entirety and
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understand the Stipulated Protective Order that was issued by the United States District Court for the
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Northern District of California on
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et al., 4:16-cv-04323 YGR. I agree to comply with and to be bound by all the terms of this
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Stipulated Protective Order and I understand and acknowledge that failure to so comply could
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expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not
[date] in the case of Petrov v. Alameda County,
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disclose in any manner any information or item that is subject to this Stipulated Protective Order to
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any person or entity except in strict compliance with the provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District Court for the
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Northern District of California for the purpose of enforcing the terms of this Stipulated Protective
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Order, even if such enforcement proceedings occur after termination of this action.
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I hereby appoint __________________________ [print or type full name] of
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_______________________________________ [print or type full address and telephone number] as
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my California agent for service of process in connection with this action or any proceedings related
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to enforcement of this Stipulated Protective Order.
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Date: ______________________________________
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City and State where sworn and signed: _________________________________
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Printed name: _______________________________
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Signature: __________________________________
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Stipulated Protective Order For Standard Litigation
No. 4:16-cv-04323-YGR
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CERTIFICATION BY TIMOTHY P. MURPHY PURSUANT TO LOCAL RULE NO.5-1,
SECTION (i)(3). RE E-FILING ON BEHALF OF MULTIPLE SIGNATORIES
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1.
I am an attorney licensed to practice law in the State of California, and am an
attorney in the law firm of Edrington, Schirmer & Murphy, counsel for Defendants ALAMEDA
COUNTY and SHERIFF GREGORY J. AHERN.
The statements herein are made on my
personal knowledge, and if called as a witness, I could and would testify thereto.
2.
The above e-filed document contains multiple signatures.
I declare that
concurrence has been obtained from each of the other signatories to file this jointly prepared
document with the Court. Pursuant to Local Rule 5-1, section (i)(3), I shall maintain records to
support this concurrence for subsequent production for the Court if so ordered, or for inspection
upon request by a party until one year after final resolution of the action (including appeal, if any).
I declare under penalty of perjury under the laws of the United States of California that the
foregoing is true and correct on October 31, 2016.
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/s/
Timothy P. Murphy
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Stipulated Protective Order For Standard Litigation
No. 4:16-cv-04323-YGR
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