Opinion
2:22-cv-09179-JFW-AJRx
04-30-2024
A.G., a minor child; by and through his guardian ad litem Jennifer Reeder, Plaintiff, v. Santa Maria Joint Union High School District, Laurie Ramirez, and Does 1-10, Defendants.
Molly Thurmond, Cyrus Khosh-Chashm MC LAW GROUP, APC Attorneys for Defendant Santa Maria Joint Union High School District Daniel R. Shaw, Colleen A. Snyder SNYDER & SHAW, LLP San Luis Obispo Attorneys for Plaintiff Nicholas J. Street ZIMMER & MELTON, LLP Attorneys for Defendant, Laurie Fee Exempt Pursuant to Govt. Code § 6103
Molly Thurmond, Cyrus Khosh-Chashm MC LAW GROUP, APC Attorneys for Defendant Santa Maria Joint Union High School District
Daniel R. Shaw, Colleen A. Snyder SNYDER & SHAW, LLP San Luis Obispo Attorneys for Plaintiff
Nicholas J. Street ZIMMER & MELTON, LLP Attorneys for Defendant, Laurie Fee Exempt Pursuant to Govt. Code § 6103
Hon. John F. Walter, District Court Judge
[PROPOSED] PROTECTIVE ORDER RE: PRIVATE AND CONFIDENTIAL INFORMATION
A. Joel Richlin United States Magistrate Judge
Pursuant to the stipulation of all parties, and finding good cause therefor, IT IS HEREBY ORDERED:
1. The parties by counsel shall be bound by the terms of this Protective Order.
2. Subject to any limitations provided in this Protective Order, private and confidential records and information relevant to this proceeding, and requested by any Party, will be produced in its entirety, subject to objections that are not based on confidentiality or privacy.
3. Any and all information disclosed pursuant to this Order shall be used for the sole purpose of preparing for and conducting litigation of this action.
4. If any Party files with the Court or otherwise makes public any of the documents or information disclosed pursuant to this Order, that party's counsel shall redact private and confidential information, or file said documents under seal.
5. Any and all information disclosed pursuant to this Order shall not be disclosed, directly or indirectly, to persons other than:
(a) an attorney employed by a party for the purpose of working on this action;
(b) an employee of such attorney who is working on this action;
(c) a person who is hired to provide administrative, clerical, or support functions that require access to such documents;
(d) with respect to a particular document, a person who is named on the face of such document as having been its author or one of its recipients, or who appears from other documents or testimony to have been the author or recipient of such document(s);
(e) an independent consultant or expert retained by a party or attorney to prepare for or conduct this litigation;
(f) a person to whom it is otherwise reasonably essential that the material be shown for purposes of that person giving testimony or making litigation decisions in this action;
(g) a stenographer, court reporter, or videographer present in his or her official capacity at any hearing, deposition, or proceeding in this action; and
(h) any court before which this action is pending, including court personnel who are authorized by the judges of the court to review such information.
6. Before any document produced pursuant to this Order is disclosed to any person described in 6 (e) or (f), the party providing the documents will make reasonable efforts to ensure that the person to whom the disclosure is made understands and will abide by the terms of this Order, and will provide that person with a copy of this Order.
7. Even after the termination of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until and unless a court order otherwise directs.
IT IS SO ORDERED.