The opinion of the court was delivered by: Michael J. Seng United States Magistrate Judge
BENJAMIN B. WAGNER United States Attorney ALYSON A. BERG Assistant United States Attorney United States Courthouse 2500 Tulare Street, Suite 4401 Fresno, California 93721 Telephone: (559) 497-4000 Facsimile: (559) 497-4099 Attorneys for Defendant UNITED STATES OF AMERICA
STIPULATION FOR PROTECTIVE ORDER; ORDER
Plaintiff Tony Richardson("Plaintiff") and Defendant United States of America ("United States") (collectively "the parties") stipulate, by and through the undersigned counsel, as follows:
WHEREAS the parties seek to use confidential information relating to the operation of the United States Penitentiary at Atwater, personal identifier information of Plaintiff and Brian King Humphreys, as well as medical and/or psychological records of Plaintiff in this action (collectively "Confidential Information");
WHEREAS, such Confidential Information is arguably protected from disclosure pursuant to confidential security rights and/or privacy rights;
WHEREAS, the parties wish to protect the rights of the United States, Plaintiff and Brian King Humphreys, from unauthorized and/or unnecessary disclosure of the Confidential Information;
WHEREAS, the parties also wish to prevent the possibility of any misuse or unnecessary disclosure of the Confidential Information, regardless of any security and/or privacy rights;
THE PARTIES THEREFORE STIPULATE, and pending further order of the Court, that the following procedures designed to ensure the protection of this Confidential Information shall govern all forthcoming pre-trial discovery proceedings:
1. All information designated as "Confidential Information" that is privy to security and/or rights of privacy is subject to this stipulated Protective Order.
2. Confidential Information may be shown, or its contents disclosed only to the following persons:
(a) Counsel of record in this action and counsel's agents and employees; and
(b) Any expert used as a consultant or intended to be called as a witness who is retained by counsel of record to assist in the preparation and/or trial of this case.
Confidential Information designated as subject to this Protective Order shall not be disclosed or shown to any other person or entity.
3. Confidential Information designated as subject to this stipulated Protective Order or any information derived therefrom shall be used solely for the purpose of the disputed claims and defenses in ...