STIPULATED ORDER OF PROTECTION

LONNY R. SUKO, Senior District Judge.

I. BASIS

On April 20, 2015, Defendants served a Notice of FRCP 34 Inspection on Plaintiffs seeking to inspect Minor Child A's cell phone activity on the 18th and 19th of October 2014. The purpose of the inspection is to retrieve text messages and other information related to the October 18, 2014 motor vehicle accident and the events giving rise to this lawsuit. Defendants now seek to expand the search to the months of October-November 2014 and to search for certain key words. Plaintiffs do not object.

The parties recognize that there may be information contained on Minor Child A's cell phone that is "private" or "sensitive" to Minor Child A and has no relevance to these proceedings. In order to give Defendants access to discoverable and relevant information, and at the same time protect Minor Child A's privacy, the parties have agreed to the following procedure for the inspection of Minor Child A's cell phone.

II. STIPULATION

IT IS HEREBY STIPULATED BY THE PARTIES, by and through their attorneys, that the following procedure shall apply to the inspection of Minor Child A's cell phone:

1. Plaintiffs will produce Minor Child A's cell phone, along with any applicable passwords, to Global CompuSearch;

2. Global CompuSearch will conduct two searches of the content on Minor Child A's cell phone, including any information stored in "the cloud;"

3. The first search will be a search for all of the information, social media posts, data, texts, images retrieved from Minor Child A's phone for the months of October-November 2014;

4. The second search will be a search for the following key words that is not limited to a date range: suicide; suicidal; kill; die; accident; lawsuit; court; rape; accident; crash; Anthony; Cucinotti; Marcus; Kindra; Maddy; Northwest Boulevard; Bowdish; and sexual abuse.

5. Global CompuSearch will produce a report for each of the above searches in accordance with their normal procedures;

6. Said reports will be delivered to counsel for Plaintiffs. Global CompuSearch will not provide a copy of the report to anyone else, but will keep a copy of the report in its file;

7. Counsel for Plaintiffs will redact portions of the reports that counsel believes is not relevant and would invade the privacy interests of Minor Child A. Counsel will then provide counsel for Defendants with a copy of the redacted report, along with a "redaction log" identifying the general nature of what has been redacted. The redaction log will be sufficiently detailed so as to allow the Defendants to challenge the redactions with the Court, should Defendants believe that any redaction is improper;

8. The report produced by Global CompuSearch shall remain confidential, meaning that Global CompuSearch will not produce a copy of the file to anyone other than counsel for Plaintiffs. The redacted report produced to counsel for Defendants shall be subject to the same protections as Minor Child A's medical records and school records in this litigation.

9. If the documents produced by Global CompuSearch are sufficiently voluminous such that it would impose an undue burden on Plaintiffs' counsel to make the redactions referenced in Paragraph 7, the parties will confer in an effort to identify an alternative method of producing relevant information to the defense without imposing an undue burden on Plaintiffs.

10. Defendants will pay the costs of having Global CompuSearch perform the foregoing inspection and produce the report.

ORDER

Based on the parties' foregoing Stipulation, the Court, having considered the files and records herein, finds that good cause exists to grant the parties' Stipulated Order of Protection.

Now, therefore, it is hereby ORDERED, ADJUDGED AND DECREED that the parties' Stipulated Order of Protection is GRANTED. The inspection of Minor Child A's cell phone shall be conducted pursuant to the protocols as set forth above.