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Shepherd v. Crawford

September 2, 2008

MARGARET A. SHEPHERD, PLAINTIFF,
v.
OFFICER GARRETT CRAWFORD, OFFICER D. GRIEPP, OFFICER DAVID ANGAROLE, OFFICER T. MUSTARO, OFFICER JOSEPH PIMENTAL, OFFICER SCOPESI, OFFICER YAIR OAXACA, DOE OFFICER ONE, DOE OFFICER TWO, DOE OFFICER THREE, DOE OFFICER FOUR, CITY OF MODESTO, THE COPPER RHINO, LLC, LESLIE R. KNOLL, GRIFFIN ALLEN DYE, AND DOES 5-20, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Dennis L. Beck United States Magistrate Judge

STIPULATION AND ORDER TO PROTECT CONFIDENTIAL INFORMATION

STIPULATION

Plaintiff MARGARET A. SHEPHERD and Defendants CITY OF MODESTO, and OFFICERS GARRETT CRAWFORD, DOUGLAS GRIEPP, DAVID ANGAROLE, TODD MUSTARO, JOSEPH PIMENTAL, TONY SCOPESI, YAIR OAXACA, LESLIE R. KNOLL, GRIFFIN ALLEN DYE and THE COPPER RHINO, LLC by and through their undersigned counsel of record, and subject to the approval of the court, stipulate to the following Protective Order as set forth below:

1. In connection with any discovery proceedings in this action, the parties may agree or the Court may direct that any document, thing, material, testimony or other information derived therefrom, be designated as "Confidential" under the terms of this Stipulated Protective Order ("Order"). Confidential information is information which has not been made public and is privileged and confidential and protected from public disclosure under applicable Federal or California State law.

2. Confidential documents shall be so designated by stamping copies of the document produced to a party with the legend "CONFIDENTIAL." Stamping the legend "CONFIDENTIAL" on the cover of any multi-page document shall designate all pages of the document as confidential, unless otherwise indicated by the producing party.

3. Material designated as confidential under this Order, the information contained therein, and any summaries, copies, abstracts, or documents derived in whole or in part from material designated as confidential ("confidential material") shall be used only for the purpose of the prosecution, defense, or settlement of this action and for no other purpose.

4. Confidential material produced pursuant to this Order may be disclosed or made available only to the Court, to counsel for a party (including the paralegal, clerical, and secretarial staff employed by such counsel) and to the "qualified persons" designated below:

a. Experts or consultants (together with their clerical staff) retained by such counsel to assist in the prosecution, defense or settlement of this action;

b. Court reporters employed in this action; and

c. A witness at any deposition or proceedings in this action.

d. Any other person as to whom the parties in writing agree.

Prior to receiving any confidential material, each "qualified person" shall be provided with a copy of this Order and shall execute a non-disclosure agreement in the form of Attachment A, a copy of which shall be maintained by the counsel who is providing the materials.

5. The portion of any deposition in which confidential materials are discussed shall be taken only in the presence of qualified persons, as defined above.

6. Nothing herein shall impose any restrictions on the use or disclosure by a party of material obtained by such party independent of discovery in this action, whether or not such material is also obtained through discovery in this action, or from ...


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