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Robert Arredondo v. Calnet

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA


July 28, 2011

ROBERT ARREDONDO, PLAINTIFF,
v.
CALNET, INC., A VIRGINIA CORPORATION NOT REGISTERED IN CALIFORNIA; AND DOES 1 THROUGH 30, INCLUSIVE, DEFENDANTS.

The opinion of the court was delivered by: Hon. David T. Bristow Magistrate Judge OF The District Court

[PROPOSED] PROTECTIVE ORDER FOR HANDLING OF DOCUMENTS PRODUCED BY FEIZAL MOHIDEEN IN RESPONSE TO PARTIES' SUBPOENAS [DISCOVERY MATTER]

Courtroom: 840

Judge: Hon. Dale S. Fischer Magistrate Judge: David T. Bristow

Trial Date: December 6, 2011

Calnet, Inc. filed an ex parte application for a protective order on July 20, 2011 of the above-entitled Court to request a Protective Order relating to the handling of attorney-client privileged and/or confidential material produced by Feizal Mohideen, a former employee of Calnet. Following a telephonic discovery conference with the Court on July 22, 2011, counsel for the parties met and conferred further and, as a result, have agreed to the terms of a protective order for handling of documents produced by Feizal Mohideen in response to the parties' subpoenas issued to him. This Order does not effect any objections or relief that Mr. Mohideen may have regarding the subpoena issued to him by Calnet.

NOW, THEREFORE, with respect to Plaintiff's subpoena to Mr. Mohideen and Calnet's subpoena to Mr. Mohideen, the Court finds that good cause exists for the following relief:

1. All documents in Mr. Mohideen's possession that are responsive to the subpoenas will be produced to Knox Attorney Service or such other vendor as the parties may mutually agree ("Knox");

2. Knox will assign consecutive control numbers to each of the documents produced by Mr. Mohideen, beginning with "FM000001";

3. As soon as possible, Knox will provide defense counsel only with a copy of the documents for review, and counsel for both parties with the number range for the document production;

4. No later than 5 p.m. on the second court day following the date of Knox's receipt of the documents from Mr. Mohideen, defense counsel will do all of the following:

a. Remove all attorney-client privileged documents and provide a privilege log to plaintiff's counsel identifying the control number(s), date(s), author(s), recipient(s), document type (email, letter, memo, etc.) and general subject matter of any documents so removed;

b. Mark any documents that it contends is a "Confidential" document under section 4 of the Protective Order in this action (Docket No. 20); and

c. Produce to plaintiff's counsel all documents produced by Mr. Mohideen to Knox, excluding any documents identified on Calnet's privilege log, but including all documents designated by Calnet as confidential pursuant to the Protective Order.

5. Calnet shall be responsible for any fees or costs charged by Knox for its services as described above.

6. If the parties are unable to resolve any issues that may arise regarding documents produced by Mr. Mohideen, the Court will entertain any motions regarding such documents on an expedited basis.

IT IS SO ORDERED:

Dated:

20110728

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