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Vasquez v. Rackauckas

January 22, 2010

MANUEL VASQUEZ, ET AL., PLAINTIFF-PETITIONERS,
v.
TONY RACKAUCKAS, ET AL., DEFENDANT-RESPONDENTS.



The opinion of the court was delivered by: The Honorable Valerie B. Fairbank

[PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER CLASS ACTION Complaint Filed: Sept. 23, 2009 Trial Date: November 9, 2010

The Court accepts the Stipulated Protective Order ("Protective Order") and hereby orders:

1. The following information shall be deemed CONFIDENTIAL INFORMATION for purposes of this Protective Order: Any information, if any exists, that is otherwise protected from public disclosure under the law, including but not limited to California Welfare & Institutions Code §825, et seq., regarding Plaintiffs-Petitioners MANUEL VASQUEZ, MIGUEL BERNAL LARA, GABRIEL BASTIDA, and RANDY BASTIDA.

2. Defendants-Respondents shall not publicly disclose any CONFIDENTIAL INFORMATION. Defendants-Respondents are not restricted from disclosing the information with their clients to the extent that such disclosure does not violate the law.

3. All documents filed with the Court containing CONFIDENTIAL INFORMATION shall be filed under seal.

4. All documents containing CONFIDENTIAL INFORMATION shall be produced in a sealed envelope labeled with a statement that substantially conforms to the following form:

CONFIDENTIAL

This envelope contains CONFIDENTIAL INFORMATION subject to a Protective Order issued in this action that governs the use and disclosure of the enclosed documents.

5. Any portions of transcripts of the deposition of Plaintiffs-Petitioners MANUEL VASQUEZ, MIGUEL BERNAL LARA, GABRIEL BASTIDA, RANDY BASTIDA, or LORRAINE NEWHOUSE, Gabriel Bastida's and Randy Bastida's mother, that contains CONFIDENTIAL INFORMATION shall be deemed "CONFIDENTIAL." Any reference to CONFIDENTIAL INFORMATION in this Protective Order shall also include any CONFIDENTIAL deposition testimony Plaintiffs-Petitioners and/or LORRAINE NEWHOUSE.

6. In the event that counsel for any party files with or submits to the Court any CONFIDENTIAL INFORMATION by way of pleadings, motions, or other papers containing or making reference to such CONFIDENTIAL INFORMATION, such documents shall be filed in a sealed envelope labeled with a statement that conforms substantially to the following:

CONFIDENTIAL

This envelope contains CONFIDENTIAL INFORMATION subject to a Protective Order issued in this action that governs the use and disclosure of the enclosed documents.

All such documents filed with the Court shall be maintained by the Clerk of the Court separate from the public records in this action and shall be released only upon further order of the Court.

7. If any party desires the release of any CONFIDENTIAL INFORMATION that party may move the Court in accordance with the rules of the Court for an order that the CONFIDENTIAL INFORMATION shall not be subject to this ...


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