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City of Lindsay v. Sociedad Quimica Y Minera De Chile

June 6, 2012

CITY OF LINDSAY,
PLAINTIFF,
v.
SOCIEDAD QUIMICA Y MINERA DE CHILE, S.A.; SQM NORTH AMERICA CORPORATION; AND DOES 1 THROUGH 200, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Sandra M. Snyder United States Magistrate Judge

STIPULATED PROTECTIVE ORDER REGARDING WATER SUPPLY / QUALITY DOCUMENTS FROM CDPH (Doc. 61)

IT IS HEREBY STIPULATED by defendant SQM North America Corporation ("SQMNA") and the California Department of Public Health ("CDPH"), by and through their undersigned attorneys of record, that a Protective Order be entered by this Court with regard to records produced by CDPH as follows:

1. When used in this Protective Order ("Order"), the word "Litigants" means all parties and their attorneys of record in the following matter: City of ("Action"). The term "Parties" means the Litigants and the CDPH.

2. The Court recognizes that: (1) there exists the very real possibility of damage to or destruction of the nation's water supply and water quality infrastructure by terrorist activities thereby threatening public health and the environment, or possibly causing loss of life; (2) since the terrorist activities of September 11, 2001, water utilities have been under heightened security conditions; (3) threats resulting in physical destruction to any of these systems could include disruption of operating or distribution system components and actual damage to reservoirs and pumping stations; (4) a loss of flow and pressure would cause problems for customers and would hinder firefighting efforts; and, (5) bioterrorism or chemical threats could result in the distribution of microbiological agents or toxic chemicals to households across the state, which could endanger the public health of thousands. The Court recognizes that under the laws, regulations, and the policies of the State of California and the United States of America, certain precautions relative to certain information regarding various water systems are necessary to protect the security of those systems. The Court also recognizes that the purpose of this Order is to assure that production of this information in the Action will not create a threat to public health and safety.

3. The Court finds that some of the information with respect to water supply and water quality infrastructure demanded pursuant to a subpoena served on CDPH and certain information being sought or which may be sought in the future in discovery is sensitive, confidential, and related to public safety. Such information includes any and all information which is deemed confidential under law and all water system operating infrastructure and locational information, including:

a. Water System schematics and facility maps;

b. Pipeline maps;

c. Facility plans and specifications;

d. Consultant and internally generated reports that analyze water system vulnerabilities; //

e. Documents that explain water system hydraulics or operation practices;

f. Emergency operations and response plans;

g. Operation and maintenance manuals;

h. Security related documents;

i. Distribution related documents;

j. Water source related documents;

k. Water quality related documents;

l. Personal information about employees and customers, such as their individual identities, phone numbers, or addresses;

m. Pumping levels of wells;

n. Production records ...


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