Free Motion for Protective Order - District Court of California - California

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

Document 12

Filed 06/03/2008

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PAUL D. JACKSON (SBN 059542) Law Offices of Paul D. Jackson 10951 Sorrento Valley Road, Suite 1-G San Diego, CA. 92121 Telephone: (858) 552-4900 Facsimile: (858) 552-4904 KAREN P. HEWITT United States Attorney Southern District of California TIMOTHY C. STUTLER Assistant U.S. Attorney California State Bar No. 131794 880 Front St., Rm. 6293 San Diego, California 92101-8893 Telephone: (619) 557-7387

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

LONNIE J. JONES, Plaintiff, v.

Civil Case No.: 07cv2295 JAH (CAB) JOINT MOTION FOR ENTRY OF A PROTECTIVE ORDER and ORDER THEREON

DONALD C. WINTER in his official capacity as SECRETARY OF THE NAVY, 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

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

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

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Filed 06/03/2008

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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 DATED: ___________________ 28 _______________________________________ CATHY ANN BENCIVENGO United States Magistrate Judge
Civil Case No.: 07cv2295 JAH (CAB) Page 2

DATED: June 3, 2008

s/ Paul D. Jackson PAUL D. JACKSON, ESQ. Attorneys for Plaintiff

// IT IS SO ORDERED

THE PARTIES' JOINT MOTION FOR A PROTECTIVE ORDER AND ORDER THEREON 2