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Alfredo Trujillo, An Individual, and Joseph Stongle, An Individual v. Continental Airlines

February 27, 2013

ALFREDO TRUJILLO, AN INDIVIDUAL, AND JOSEPH STONGLE, AN INDIVIDUAL, PLAINTIFFS,
v.
CONTINENTAL AIRLINES, A CORPORATION; AND DOES 1-50, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Magis. Judge David T. Bristow

[PROPOSED] STIPULATED PROTECTIVE ORDER

Plaintiffs ALFREDO TRUJILLO and JOSEPH STONGLE, and the Defendant CONTINENTAL AIRLINES submit this [Proposed] Stipulated Protective Order Governing Confidential Material and respectfully request that the Court enter the [Proposed] Protective Order.

PARTIES TO THE PROTECTIVE ORDER

This Stipulated Protective Order (hereinafter "Protective Order") governs the Parties in Alfredo Trujillo and Joseph Stongle v. Continental Airlines, Case No. 2:12-CV-04300 (the "Action"). All references to "Party" or "Designating Party" throughout this order are intended to include non-parties.

SCOPE AND PURPOSE OF THE PROTECTIVE ORDER

This Order shall govern the use of Confidential Information produced pursuant to this Protective Order. The purpose of the Protective Order is to ensure that Plaintiffs are provided personal information that may be necessary to personally serve deposition subpoenas on witnesses identified below, and to secure their attendance at their depositions. Confidential Information shall be used by Plaintiffs solely for this purpose.

DEFINITION OF "CONFIDENTIAL INFORMATION"

For purposes of this Order, "Confidential Information" shall mean the "personal identifying information" pertaining to the "identified deposition witnesses" whom Defendant, CONTINENTAL AIRLINES has alleged are not managing agents. The "personally identifying information" shall be defined as the home address, home telephone number of record, and work schedules of the "identified deposition witnesses." The schedules shall include the starting and ending times for each trip, and identifying flight numbers. The "identified deposition witnesses" are:

KEITH THIBODEAUX GEORGE KONDOS ROSARIO SONNETT LORIE BROWN FROMMER

"QUALIFIED PERSONS"

Confidential Information may be disclosed only to the following "Qualified Persons": the Court and court staff; counsel of record for the Parties and their staff; and process servers retained for the purpose of serving subpoenas in this case.

DUTY TO DISCLOSE CONFIDENTIAL INFORMATION

Upon entry of this Order, Defendant, CONTINENTAL AIRLINES, shall be under an ongoing duty to provide to Plaintiff's counsel, the "personal identifying information" of the "identified deposition witnesses." CONTINENTAL's ongoing obligation shall include supplementing disclosure of Confidential Information if that information has changed since the previous disclosure, and such supplemental disclosure shall be made within one business day of CONTINENTAL receiving a request for such information. For each "identified deposition ...


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