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Hoa v. Cate

United States District Court, Ninth Circuit

July 3, 2013

PAUL HOA, an individual. Plaintiff,
MATHEW CATE, in his official capacity as the Secretary for California Department of Corrections and Rehabilitations and as an individual; CALIFORNIA, a state; CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATION, a state agency; SAN QUENTIN STATE PRISON, a state facility; DAVID F. LOPEZ, an individual; T. GREGORY STAGNITTO, an individual; MICHAEL MARTEL, an individual; BRIDGE TRANSPORT, an entity of unknown form; STAG LEASING, INC., a California corporation; and DOES 1 to 20, Inclusive. Defendants.

Gene H. Shioda Bar No. 186780, James A. Kim Bar No. 220763, Jason Y. Lie Bar No. 233614, LAW OFFICE OF GENE H. SHIODA, Los Angeles, California, Attorneys for Plaintiff PAUL HOA.

John F. Geary (SBN 13777), Raymond J. Fullerton (SBN 219264), Robert W. Henkels (SBN 255410), GEARY, SHEA, O'DONNELL, GRATTAN, AND MITCHELL, Santa Rosa, CA, Attorneys for David F. Lopez, T. Gregory Stagnitto, Bridge Transport Stag Leasing, Inc.

KAMALA D. HARRIS, Attorney General of California, JAY M. GOLDMAN, Supervising Deputy Attorney General, MANEESH SHARMA, Deputy Attorney General, State Bar No. 280084, San Francisco, CA, Attorneys for Matthew Cate.



The undersigned parties hereby agree to the terms of this Stipulated Protective Order (hereafter, "Protective Order"), as set forth below, and submit it to the Court for adoption as an Order upon full execution by counsel on behalf of their respective clients:

Pursuant to this stipulation, the Court finds that good cause exists for the entry of this Protective Order in that the preparation and trial of this action will require the discovery of documents, testimony, information, or things claimed by one or more of the parties to this stipulation to contain confidential personal, business, or commercial information or private personal information, and the ends of justice will be served by entry of an order setting forth procedures for and rules governing discovery, copying, use and return of documents, deposition transcripts, interrogatory answers and other materials. Accordingly,


1. Irrespective of the form in which discovery materials are produced, including printed or electronically recorded documents, in connection with the discovery process in the above-entitled case, including but not limited to, deposition testimony, answers to interrogatories, documents produced in response to requests for production, responses to requests for admissions, medical records and any documents recorded on computer disks, the parties to this stipulation may designate any such materials as "confidential" or "confidential discovery material, " under the terms of this stipulated order.

2. The parties to this stipulation and order may designate as "Confidential" or "Trade Secret, " pursuant to the terms of this order, documents or other discovery material to the extent they consist of or include medical records, business records, personal private information including financial records, trade secret or confidential research, development, or commercial information and may include financial information, information relating to ownership or control of any non-public company or public company, and any information protected from disclosure by any privacy law, as well as any other type of information given confidential status by the court.

3. Any person subject to this order who receives any confidential discovery material in the course of discovery in this action shall not disclose such confidential discovery material to anyone else except as expressly permitted by this order.

4. With respect to the confidential or trade secret portion of any documents or material, other than deposition transcripts and exhibits, the producing party may designate the portion as confidential discovery material by stamping or otherwise clearly marking the protected page, passage, or item as "Confidential" or "Privacy" in such a manner that will not interfere with legibility or audibility.

5. With respect to deposition transcripts and exhibits, a party to this stipulation may indicate on the record that a question calls for confidential discovery material, in which case the text in the transcript where these questions or answers occur shall be specially marked as a separate page stamped "Confidential Information Governed By Protective Order" by the court reporter. For convenience, the parties to this stipulation may agree that entire deposition transcripts shall be treated as confidential discovery material.

6. Notwithstanding the provisions of paragraphs 2-4 above, a producing party may redact from any Confidential Document any: (i) social security number, (ii) bank account statements or numbers.

7. If at any time prior to the trial of this action a party to this stipulation realizes that previously undesignated documents or other material should be designated as confidential discovery material, that party may so designate by advising all other parties to this stipulation in writing. The designated documents or material will thereafter be treated as confidential discovery material pursuant to this order. However, no party to this ...

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