STIPULATION AND [PROPOSED] ORDER TO AMEND STIPULATED PROTECTIVE ORDER, DKT. 51

YVONNE GONZALEZ ROGERS, District Judge.

Plaintiffs J.P., by and through his Guardian Ad Litem, Shannon Villanueva ("Plaintiff") and Defendants TRIAD FAMILY SERVICES, MARIA REFUGIO MOORE, COUNTY OF ALAMEDA, DIANE DAVIS MAAS, SUE MAY (collectively "Defendants"), jointly submit this Stipulation and [Proposed] Order seeking additional relief as permitted by Section 12.1 in the Stipulated Protective Order, Dkt. 51, as follows.

1. The parties stipulated to and this Court entered a Stipulated Protective Order, Dkt. 51, on March 16, 2018.

2. Defendants TRIAD and MOORE deposed the plaintiff on September 5, 2018 during which time the parties met and conferred and realized that the Stipulated Protective Order did not include several before-believed proper recipients of confidential information and documents if they were to agree to and execute Attachment A to Dkt. 51.

3. For example, plaintiff will be deposing a former employee of TRIAD on September 13, 2018. Yet the Stipulated Protective Order does not include the parties or former employees of the parties who agree to be subject to the Protective Order by executing Attachment A to Dkt. 51.

4. Another example relates to the parties' agreement to participate in a settlement conference with Magistrate Judge Laurel Beeler on September 25, 2018. The parties will need to share confidential information and documents including exhibits and testimony relating to the plaintiff's damages with claims adjusters, parties, insureds, and other decision makers.

5. The parties agree that, by consenting to the filing of this stipulation, the County Defendants are not violating the stay (Docket #68) or otherwise submitting to the jurisdiction of the district court on Plaintiff's claims against them.

6. Accordingly, the parties hereby stipulate and jointly request this Court expand the scope of the Protective Order to grant further relief to allow confidential information and documents be shared with parties, former employees of the parties, claims adjusters, insureds, and settlement decision makers who agree to be subject to the Protective Order by executing Attachment A to Dkt. 51.

ELECTRONIC CASE FILING ATTESTATION

I, Lizabeth N. de Vries, am the ECF user whose identification and password are being used to file the foregoing documents. Pursuant to Civil Local Rule 5.1(i), I hereby attest that concurrence in the filing of these documents has been obtained from each of its signatories.

PURSUANT TO STIPULATION,

The Court hereby finds good cause and hereby orders that the Stipulated Protective Order at Dkt. 51 is expanded to allow confidential information and documents be shared with the parties, former employees of the parties, claims adjusters, insureds, and settlement decision makers who agree to be subject to the Protective Order by executing Attachment A to Dkt. 51, e-filed in this matter on March 16, 2018.