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Tarek Hamdi v. United States Citizenship

March 7, 2011


The opinion of the court was delivered by: Hon. David T. Bristow United States Magistrate Judge

Proposed Stipulated Protective Order

Plaintiff and Defendants (collectively, "the Parties"), by and through counsel, stipulate and agree that they will produce documents and other discovery subject to the instant Protective Order. Such disclosure is subject to the following conditions:

1. As used in this Protective Order, the term "Confidential Information" includes any information that is disclosed by the Parties in this action and which at or before the time of disclosure has been designated as "Confidential" by the Parties in one or more of the following ways:

a. Information set forth in a response to an interrogatory may be so designated by including the word "Confidential" in the response.

b. Information contained in any document or part thereof may be so designated by marking the word "Confidential" on the document or by giving written notice to the other party describing the document or part thereof either specifically or by category.

c. Information contained in any statement made during an oral deposition may be so designated through a statement made on the record. When producing documents, the Producing Party shall mark each page containing confidential information as "Confidential."

d. The parties may designate as "Confidential" documents which contain personal, private information about Plaintiff Hamdi or other individuals such as, but not limited to: Plaintiff's Alien file, in its entirety; financial information; phone records; birth dates, social security numbers, home addresses, work addresses, and email addresses.

2. All discovery produced or exchanged labeled "Confidential" that is pursuant to this Protective Order shall be used solely for the purposes of litigating this Action or Related Actions and for no other purpose whatsoever and shall not be disclosed, disseminated, or transmitted to any person, entity, or organization except in accordance with the terms hereof.

3. For purposes of this Protective Order, "Qualified Persons" means (i) Plaintiff Tarek Hamdi, (ii) attorneys for the parties in this litigation, and employees of such attorneys at the U.S. Department of Justice, Civil Division and the ACLU Foundation of Southern California to whom it is necessary that the discovery be shown for purposes of litigating the above-captioned proceeding, and (iii) judges and court personnel involved in this Action or any of the Related Actions, including certified court reporters appearing at depositions, provided that the deposition court reporters are advised that the materials have been designated as "Confidential" and shall agree to keep such information confidential;

4. All discovery labeled "Confidential" shall be disclosed or made available only to Qualified Persons and shall be restricted in circulation to said Qualified Persons. All copies of such discovery shall be maintained in the offices of counsel for the parties.

5. Nothing herein shall prevent disclosure beyond the terms of this Protective Order, if all parties consent to such disclosure, or if the Court, after notice to all affected parties, orders such disclosure. Further, nothing in this Protective Order precludes any person from disclosing or using in any manner its own information, or information not obtained under this Protective Order, even if the same information is also produced under this Protective Order.

6. If Plaintiff's counsel is required by law or court order to disclose, disseminate, or transmit "Confidential Information" produced under this Protective Order to any person or entity not identified herein as a Qualified Person, the name of that person or entity and the reason access is required shall be provided to counsel for Defendants no less than 21 days prior to disclosure/dissemination/transmittal to enable Defendants to object and seek a protective order as necessary. There shall be no disclosure after an objection has been made until the matter has been resolved unless disclosure, dissemination, or transmission is required by law or court order. Any person, entity or organization not identified herein as a Qualified Person who receives"Confidential Information" shall be provided with a photocopy of theProtective Order and shall abide by all terms and conditions set forth herein unless otherwise permitted by court order.

7. The Parties may modify this Protective Order through a written agreement signed by counsel for all parties. In the event that all parties do not agree to a proposed modification, each party reserves the right to seek leave of the Court to modify this Protective Order.

8. In the event a party wishes to use any "Confidential Information" produced under this Protective Order to move the Court to resolve a matter arising from litigating the above-captioned proceeding only, or to oppose such motion, such pleadings shall be filed in accordance with Local ...

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