The opinion of the court was delivered by: Hon. Elizabeth D. Laporte United States Magistrate Judge
CHARLES F. BOURDON, State Bar #84782 Law Offices of Charles F. Bourdon 179 - 11th Street, 2nd Floor San Francisco, CA 94103 3 415-864-5100 415-865-0376 (fax) 4 BARON J. DREXEL, State Bar #132529 Law Offices of Baron J. Drexel 212 Ninth Street, Suite 401 6 5 Oakland, CA 94607 510-444-3184 (phone) 7 510-444-3181 (fax) Attorneys for Plaintiff 9
MARK A. JONES, State Bar #96494 KRISTEN K. PRESTON, State Bar #125455 10 JONES & DYER A Professional Corporation 11 1800 J Street Sacramento, California 95811 12 Telephone: (916) 552-5959 Fax: (916) 442-5959 13 Attorneys for: Defendants County of Lake, County of Lake Sheriff's Department, 14 Sheriff Rodney Mitchell and Deputy Richard Ward 15 TERENCE J. CASSIDY, State Bar #99180 JOHN R. WHITEFLEET, State Bar #213301 PORTER | SCOTT 17 16 350 University Avenue, Suite 200 Sacramento, California 95825 18 Telephone: (916) 929-1481 Fax: (916) 927-3706 19 Attorneys for: Defendant Deputy Paul DeShong 20
STIPULATION AND PROTECTIVE ORDER
It is hereby stipulated by and between all the parties to this action by and through their
2 respective attorneys of record, that in order to protect the confidentiality of the records described 3 below, any of said records disclosed pursuant to court order following the court's in camera review 4 are subject to a protective order (and designated as "Confidential Material") as follows: 5
1. The following records are designated as "Confidential Material":
a. County of Lake employment records of Richard Ward and/or Paul DeShong to the extent such records are ordered by the court to be produced after completion of the court's in camera review of the records submitted by Defendant County of Lake.
2. Confidential Material shall be used solely in connection with this litigation, the 11 preparation of trial, and trial in this case, subject to the rules of admissibility, or any related appellate 12 proceedings, and not for any other purpose, including any other litigation. 13
3. Confidential Material may not be disclosed except as set forth in paragraphs 4 and 5.
4. Confidential Material may be disclosed only to the following persons:
a. Counsel for any party to this action.
b. Paralegal, stenographic, clerical and secretarial personnel regularly employed by counsel referred to in 4(a);
c. Court personnel including stenographic reporters engaged in such proceedings as are necessarily incidental to preparation for the trial of this action;
d. Any outside expert or consultant retained in connection with this action, and not otherwise ...