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Jose Bermudez v. City of Berkeley; Officer Roderick Roe In His Capacity As An Individual

January 14, 2011

JOSE BERMUDEZ, PLAINTIFF,
v.
CITY OF BERKELEY; OFFICER RODERICK ROE IN HIS CAPACITY AS AN INDIVIDUAL;
OFFICER JOHN JONES IN HIS CAPACITY AS AN INDIVIDUAL; FORMER CHIEF OF POLICE DOUGLAS N. HAMBLETON IN HIS OFFICIAL CAPACITY AND IN HIS CAPACITY AS AN INDIVIDUAL; BERKELEY BOWL PRODUCE, INC.; TOSHA ANDERSON IN HER CAPACITY AS AN INDIVIDUAL;
DAVID CRAIB IN HIS CAPACITY AS AN INDIVIDUAL; AND DOES 1-100, DEFENDANTS.



The opinion of the court was delivered by: Claudia Wilken Judge, United States District Court

CHRISTOPHER R.A. MORRAY-JONES (SB # 256726) LAW OFFICES OF C. MORRAY-JONES 1611 Telegraph Avenue, Suite 910 Oakland, CA 94612 Telephone: (510) 444-0151 Facsimile: (510) 444-0150 Email: cm-j@m-jlaw.com Attorney for Plaintiff JOSE BERMUDEZ Zach Cowan, City Attorney, SBN 96372 Matthew J. Orebic, Deputy City Attorney, SBN 124491 BERKELEY CITY ATTORNEY'S OFFICE 2180 Milvia Street, Fourth Floor Berkeley, CA 94704 Telephone: (510) 981-6998 Facsimile: (510) 981-6960 Morebic@ci.berkeley.ca.us Attorneys for Defendants City of Berkeley, Former Officer Roderick Roe, Officer Matthew Meredith, and Former Chief Douglas Hambleton

# 81

# 5

STIPULATION AND PROTECTIVE ORDER

The above-captioned plaintiff and defendants, by and through their attorneys, hereby stipulate to, and respectfully ask the Court to issue, the following Protective Order:

1. DEFINITIONS

1.1 Party: any party to this action, including all of its elected and appointed officials, officers, employees, consultants, retained experts, and outside counsel, together with their support staff.

1.2 Disclosure or Discovery Material: all items or information, regardless of the medium or manner generated, stored, or maintained, and including, but not limited to, paper records and electronically stored data.

1.3 "Confidential" Information or Items: information, however generated, stored or maintained, and/or tangible things qualified for protection under standards developed pursuant to Fed. R. Civ. P. 26(c).

1.4 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

1.5 Producing Party: a Party or non-party that produces Disclosure or Discovery Material in this action.

1.6 Designating Party: a Party or non-party that designates information or items that it produces in disclosures or in responses to discovery as "Confidential."

1.7 Challenging Party: a party or non-party who challenges the designation of any Disclosure or Discovery Material as "Confidential."

1.8 Protected Material: any Disclosure or Discovery Material that is designated as "Confidential" or as "Highly Confidential-Attorneys' Eyes Only."

1.9 Outside Counsel: attorneys who are not employees of a Party but who are retained to represent or advise a Party in this action.

1.10 House Counsel: attorneys who are employees of a Party. support staffs.

1.11 Counsel (without qualifier): Outside Counsel and House Counsel, and their 1.12 Expert: a person with specialized knowledge or experience in a matter pertinent to witness or consultant in this action, and who is not a past or a current employee of a Party and, at the time of retention, is not anticipated to become an employee of a Party. This definition includes a professional jury or trial consultant retained in connection with this litigation.

the litigation who has been retained by a Party or its counsel to serve as an expert

1.13 Professional Vendors: person or entities that provide litigation support services 11 organizing, storing, retrieving data in any form or medium, etc.) and their employees and subcontractors.

(e.g., photocopying: videotaping; translating; preparing exhibits or demonstrations;

2. SCOPE

The protections conferred by this Stipulation and Order cover not only Protected

Material (as defined above), but also any information copied or extracted therefrom, as 17 well as all copies, excerpts, summaries, or compilations thereof, plus testimony, 18 conversations, or presentations by parties or counsel to or in court or in other settings that 19 might reveal Protected Material. 20

this Order shall remain in effect until a Designating Party agrees otherwise in writing or a 23 ...


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