[PROPOSED] STIPULATED PROTECTIVE ORDER

DAVID T. BRISTOW, Magistrate Judge.

Plaintiffs ALFREDO TRUJILLO and JOSEPH STONGLE, and the Defendant CONTINENTAL AIRLINES submit this [Proposed] Stipulated Protective Order Governing Confidential Material and respectfully request that the Court enter the [Proposed] Protective Order.

PARTIES TO THE PROTECTIVE ORDER

This Stipulated Protective Order (hereinafter "Protective Order") governs the Parties in Alfredo Trujillo and Joseph Stongle v. Continental Airlines, Case No. 2:12-CV-04300 (the "Action"). All references to "Party" or "Designating Party" throughout this order are intended to include non-parties.

SCOPE AND PURPOSE OF THE PROTECTIVE ORDER

This Order shall govern the use of Confidential Information produced pursuant to this Protective Order. The purpose of the Protective Order is to ensure that Plaintiffs are provided personal information that may be necessary to personally serve deposition subpoenas on witnesses identified below, and to secure their attendance at their depositions. Confidential Information shall be used by Plaintiffs solely for this purpose.

DEFINITION OF "CONFIDENTIAL INFORMATION"

For purposes of this Order, "Confidential Information" shall mean the "personal identifying information" pertaining to the "identified deposition witnesses" whom Defendant, CONTINENTAL AIRLINES has alleged are not managing agents. The "personally identifying information" shall be defined as the home address, home telephone number of record, and work schedules of the "identified deposition witnesses." The schedules shall include the starting and ending times for each trip, and identifying flight numbers. The "identified deposition witnesses" are:

KEITH THIBODEAUX

GEORGE KONDOS

ROSARIO SONNETT

LORIE BROWN FROMMER

"QUALIFIED PERSONS"

Confidential Information may be disclosed only to the following "Qualified Persons": the Court and court staff; counsel of record for the Parties and their staff; and process servers retained for the purpose of serving subpoenas in this case.

DUTY TO DISCLOSE CONFIDENTIAL INFORMATION

Upon entry of this Order, Defendant, CONTINENTAL AIRLINES, shall be under an ongoing duty to provide to Plaintiff's counsel, the "personal identifying information" of the "identified deposition witnesses." CONTINENTAL's ongoing obligation shall include supplementing disclosure of Confidential Information if that information has changed since the previous disclosure, and such supplemental disclosure shall be made within one business day of CONTINENTAL receiving a request for such information. For each "identified deposition witness," CONTINENTAL's ongoing duty shall end upon the commencement of the deposition of that individual "identified deposition witness."

EXECUTING THE NON-DISCLOSURE AGREEMENT

Each person to whom Confidential Information is disclosed, except the persons identified in above, shall execute a non-disclosure agreement in the form annexed hereto as Exhibit A before receiving Confidential Information. Copies of the executed Exhibit A shall be retained by counsel disclosing Confidential Information to such person.

SUBPOENA FOR CONFIDENTIAL INFORMATION

If any Party has obtained Confidential Information under the terms of this Order and receives a request to produce such Confidential Information by subpoena or other compulsory process commanding the production of such Confidential Information, the Party receiving such a request or subpoena shall promptly notify the Party from which it received the Confidential Information, including in such notice the date set for the production of such subpoenaed information and, unless prohibited by applicable law, enclosing a copy of the subpoena (or other form of process).

FILING CONFIDENTIAL INFORMATION

The Parties acknowledge that this Order creates no entitlement to file Confidential Information under seal. No document shall be filed under seal unless counsel complies with Local Rule 79-5.1 of the United States District Court for the Central District of California, and any other applicable statute or court rule.

Nothing herein shall impose any restriction on the use or disclosure by a Party of its own information or of information that lawfully came into the possession of the Party independent of any disclosure of information in this litigation.

IT IS SO STIPULATED.

ORDER

NOW THEREFORE, Having read the above Stipulated Protective Order and good cause appearing, IT IS SO ORDERED.

EXHIBIT A

I, the undersigned, hereby declare that I have read the attached Stipulated Protective Order entered in the above-captioned case. I understand the terms of, will comply with, and agree to be bound by all of the provisions of the Stipulated Protective Order.