UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION
February 8, 2011
TERRY SANDRES, AN INDIVIDUAL,
CORRECTIONS CORPORATION OF AMERICA, A MARYLAND CORPORATION; AND DOES 1THROUGH 50, INCLUSIVE,
The opinion of the court was delivered by: Jennifer L. Thurston United States Magistrate Judge
STIPULATED PROTECTIVE ORDER FOR CONTACT INFORMATION OF DEFENDANTS' EMPLOYEES
Assigned to: Hon. Oliver W. Wanger/Room
District Judge: Oliver W. Wanger Magistrate Judge: Jennifer L. Thurston Action filed: July 24, 2009
Trial Date: August 30, 2011
WHEREAS, on February 4, 2011, the Court ordered that Defendants CCA of Tennessee, LLC ("Defendants") provide Plaintiff Terry Sandres ("Plaintiff") with the last known contact information for certain employees and former employees of Defendants;
WHEREAS, as a condition of this disclosure, the Court ordered that the parties submit a stipulated protective order to the Court limiting the disclosure of this contact information;
THE PARTIES THEREFORE STIPULATE AND AGREE AS FOLLOWS:
1. For the purposes of this Stipulation and Order the term CONFIDENTIAL INFORMATION shall mean: the last known addresses and telephone numbers for all employees and former employees of Defendants ("CCA Employees") which have been requested through special interrogatories and produced pursuant to the court's order.
2. Defendants shall provide the CONFIDENTIAL INFORMATION within one court day of the Court's order on this Stipulation.
3. The CONFIDENTIAL INFORMATION shall not be disclosed to any person except:
a. the parties' respective counsel of record;
b. other persons employed, consulted or retained by the parties' respective counsel of record;
c. court reporters; and
d. the Court or court personnel.
Disclosure may be made subject to the terms and conditions set forth in the Stipulation only. The parties' respective counsel of record shall assure that the persons enumerated above shall strictly maintain the confidentiality of the CONFIDENTIAL INFORMATION. Moreover, the parties specifically agree that the CONFIDENTIAL INFORMATION shall not be used or disclosed by the parties' counsel of record other than in connection with this litigation and shall not be used by the parties' counsel of record in any other proceeding, except as compelled by legal process.
4. Upon final determination of this litigation, any party that has received from the other party CONFIDENTIAL INFORMATION shall promptly destroy the CONFIDENTIAL INFORMATION and notify the producing party thereof.
5. Neither this Stipulation, nor any action taken by any attorney pursuant to this Stipulation, shall be deemed to have the effect of any admission or waiver by any party hereto or of altering the confidentiality of the CONFIDENTIAL INFORMATION.
6. The court reporter or any other person preparing either full deposition transcripts or portions of deposition transcripts in which CONFIDENTIAL INFORMATION are marked as exhibits shall be instructed not to furnish copies of the CONFIDENTIAL INFORMATION to any person not authorized under the terms of this Stipulation to have access to CONFIDENTIAL INFORMATION.
7. This Stipulation shall be without prejudice to the right of the parties to bring before the Court at any time the question of whether any information is confidential, relevant and/or protected by a right of privacy or whether its use should be restricted.
8. In addition, Plaintiff's counsel (including his partners or employees) may use this CONFIDENTIAL INFORMATION for the purpose of directly contacting such CCA employees.
Dated: February 7, 2011 APPELL | HILAIRE | BENARDO LLP
Barry Appell Attorney for Plaintiff
Dated: February 7, 2011 GLEASON & FAVAROTE, LLP
Attorney for Defendants
IT IS SO ORDERED.
© 1992-2011 VersusLaw Inc.