Free Protective Order - District Court of California - California

Case 3:07-cv-02295-JAH-CAB

Document 13

Filed 06/04/2008

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendant. __________________________________________ Whereas on May 29, 2008 the Honorable Cathy Ann Bencivengo entered an Order directing the parties to file a joint motion for the entry of a protective order, the parties hereby request that the Court Order as follows: 1. On or before June 16, 2008, Defendant shall supplements his Rule 26(a)(1)(A) Initial v. ORDER THEREON DONALD C. WINTER in his official capacity as SECRETARY OF THE NAVY, LONNIE J. JONES, Plaintiff, Civil Case No.: 07cv2295 JAH (CAB) JOINT MOTION FOR ENTRY OF A PROTECTIVE ORDER and UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

Disclosure to provide Plaintiff with the "the name and, if known, the address and telephone number of each individual likely to have discoverable information ..." 2. The contact information (i.e. addresses and phone numbers) produced by Defendant

to Plaintiff concerning current and former employees of the United States Government shall not be used for any purpose other than litigation of this case or in connection with proceedings concerning

07cv2295

Case 3:07-cv-02295-JAH-CAB

Document 13

Filed 06/04/2008

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

settlement. For those purposes, the materials may be disclosed to the following persons only: a. b. c. this matter. Such disclosures may be made only while such persons are assisting in the accomplishment of the foregoing purposes, with disclosure only to the extent necessary to enable them to perform the same. 3. Unless the United States Attorney's Office consents in writing to further disclosure, The signatories and their staff; Bona fide employees and agents of the signatories for any of the parties; and, The Court, including any jurors that may be empaneled in connection with any trial of

the signatories shall not further disclose the information to persons or entities not listed in subparts 1a through 1c. above without first obtaining from the Court an Order. 4. The Court may change this stipulated Protective Order in the interests of justice or for

public policy reasons. 5. The plaintiff shall notify the United States Attorney's Office of his intent to contact

any government employee for whom contact information was provided by defendant at least (3) days prior to initiating contact with such employee. DATED: June 3, 2008 KAREN P. HEWITT United States Attorney s/ Timothy C. Stutler TIMOTHY C. STUTLER Assistant U.S. Attorney Attorneys for the United States of America LAW OFFICE OF PAUL D. JACKSON

22 23 24 25 26 27 28 /// /// /// /// DATED: June 3, 2008 s/ Paul D. Jackson PAUL D. JACKSON, ESQ. Attorneys for Plaintiff

07cv2295

2

Case 3:07-cv-02295-JAH-CAB

Document 13

Filed 06/04/2008

Page 3 of 3

1 2 3 4 5 6 7 8 9 DATED: June 4, 2008 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

ORDER Pursuant to the stipulation of the parties for entry of the protective order described above, IT IS SO ORDERED. IT IS FURTHER ORDERED, subject to public policy, and further court order, nothing shall be filed under seal, and the court shall not be required to take any action, without separate prior order by the Judge before whom the hearing or proceeding will take place, after application by the affected party with appropriate notice to opposing counsel.

______________________________ CATHY ANN BENCIVENGO United States Magistrate Judge

07cv2295

3