PROTECTIVE ORDER [Proposed]

ARTHUR NAKAZATO, Magistrate Judge.

PROTECTIVE ORDER

Pursuant to the parties' Stipulation for Protective Order, IT IS HEREBY ORDERED as follows:

(1) The parties shall have the right to use records and information produced by Federal Defendant Patrick R. Donahoe, Postmaster General ("Federal Defendant"), in conducting or responding to further discovery in this case, including depositions;

(2) The parties shall have the right to use records and information produced by Federal Defendant in all law and motion proceedings. However, the parties agree that any records or information designated as "Confidential" will be filed under seal;

(3) The parties shall have the right to use records produced by Federal Defendant in all preparations for trial. If a party wishes to disclose records protected by the Privacy Act to persons requested to furnish expert or litigation services, other than their counsel, then said person(s) shall execute a written declaration substantially in the form of Exhibit "A" attached hereto. Nothing herein shall prohibit the parties or counsel from disclosing a document or its contents which constitute or contains information protected under the Privacy Act to the person the document identifies as an author or addressee of such document;

(4) The parties shall have the right to use records produced by Federal Defendant at trial in this action, including without limitation, in the examination of any witnesses, and in the presentation of all types of evidence, in the making and defending of trial motions, in trial briefs, and in argument;

(5) The parties shall have the right to use records produced by Federal Defendant in any appellate proceedings, including without limitation, in trial briefs and in argument;

(6) Upon completion of this action, Plaintiff and her counsel shall certify to the Court that they have irretrievably destroyed or returned all documents that have been produced pursuant to this Protective Order. They shall further certify that they have destroyed or returned all copies and/or duplicates, as defined by Rule 1001(4) of the Federal Rules of Evidence, that they have made of such documents; and

(7) This Order is not intended to compromise the rights of any party to object to discovery pursuant to the Federal Rules of Civil Procedure or any other governing authority nor is it intended to alter any burden of proof regarding any assertion of privilege in this matter.

EXHIBIT "A"

_____ I have read and I understand the Stipulation For Protective Order and Protective Order entered by the Court in the case Laura Arroyo v. Patrick R. Donahoe, Postmaster General, SA CV 13-200-AG(ANx), and I agree to be bound by its terms.