STIPULATION FOR PROTECTIVE ORDER AND PROPOSED ORDER

EDMUND F. BRENNAN, District Judge.

It is hereby agreed and stipulated between the Plaintiff, JONATHAN EARL DANNER and Defendants COUNTY OF SAN JOAQUIN and MANUEL ANDRADE that all documents produced in this case pursuant to Fed. Rules Civ. Proc., rules 26, 30, 34 & 45 shall be governed by this protective order.

The documents shall be used by the parties solely for the purpose of prosecuting and defending the above captioned case. The documents shall not be duplicated, reproduced, transmitted, or communicated to any person for any reason other than counsel; clients; experts retained for the purpose of furthering the defense of or prosecution of the plaintiff's case; deposition and trial witnesses; mediator or third party neutral; or the court. The copying of produced documents is to be conducted in-house and shall not be done by outside third party vendors.

All copies of protected documents distributed by counsel to any party for purpose of prosecuting or defending the litigation shall be returned to counsel at the conclusion of the litigation.

This Order shall constitute a protective order pursuant to Fed. Rules Civ. Proc., rule 26(c) and shall be enforceable as set forth therein.

STIPULATED AND AGREED.

ORDER

Having considered the stipulation of the parties and good cause appearing, the court hereby GRANTS the parties' foregoing stipulation for a protective order over all documents produced in this case.

IT IS SO ORDERED.