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Allison v. Johanson

May 19, 2009

JARED ALLISON AND HAZEL ALLISON, PLAINTIFFS,
v.
STEPHEN JOHANSON, IN HIS INDIVIDUAL CAPACITY; STEVE DAWSON, IN HIS INDIVIDUAL CAPACITY, AND DOES 1 THROUGH 50, DEFENDANTS.



The opinion of the court was delivered by: John A. Mendez United States District Judge

STIPULATED REQUEST FOR A PROTECTIVE ORDER AND PROPOSED ORDER

Plaintiffs JARED ALLISON and HAZEL ALLISON by and through their attorney, Andrew C. Schwartz, individually and on behalf of CASPER, MEADOWS, SCHWARTZ & COOK and Defendants STEPHEN JOHANSON, by and through his attorney of Robert Johnson, individually and on behalf of JOHNSON, SCHACHTER & LEWIS, and defendant STEVEN DAWSON by and through his attorney, Claudia Leed, individually and on behalf of STUBBS & LEONE, hereby stipulate to the following protective order:

1. DEFINITIONS

1.1 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and outside counsel (and their support staff).

1.2 Disclosure or Discovery Material: all items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

1.3 "Confidential" Information or Items: information (regardless of how generated, stored or maintained) or tangible things that qualify for protection under standards developed under F.R.Civ.P. 26(c). The material subject to this protective order is the following:

a. Documents produced by Defendant Dawson in response to Plaintiff's First Request for the Production of Documents;

b. Documents produced by the parties pursuant to FRCP Rule 26;

c. Any depositions taken in this matter and exhibits attached thereto;

d. Any medical records regarding the plaintiffs;

e. Any medical records regarding Stephen Johanson;

f. Any psychological records regarding the plaintiffs;

g. Any psychological records and psychological screening records regarding Stephen Johanson;

h. Commission of Peace Officer Standards and Training Confidential Profile Report re: Stephen Johanson;

i. Classified Employment Information form re: Stephen Johanson;

j. Classified Employment Application for Stephen Johanson;

k. Sacramento Police Academy Certification for Stephen Johanson;

l. Stephen Johanson's Resume;

m. North Bay Occupational Health, Fitness for Duty Examination of Stephen Johanson;

n. POST Background Investigative File Regarding Stephen Johanson

o. Patrick Lawson-Background Investigative Report regarding Stephen Lawson, dated August 26, 2007;

p. Voice Stress Analysis of Stephen Johanson, dated August 26, 2007;

q. Personal History Questionnaire, Stephen Johanson;

r. Application for Employment form completed by Stephen Johanson dated July 19, 2007;

s. California Department of Justice Criminal History background check on Stephen Johanson;

t. City of Dixon personnel records regarding Stephen Johanson available to Chief Dawson at the time Johanson was hired by the Solano Community College District;

u. Credit report regarding Stephen Johanson;

v. Stephen Johanson's California State University Diploma;

w. Stephen Johanson's California State University--Sacramento transcript;

x. Stephen Johanson's Sierra College transcript;

y. Stephen Johanson's Sacramento City ...


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