STIPULATED AGREEMENT RE PRODUCTION OF "PERSONNEL RECORDS"; ORDER

KENDALL J. NEWMAN, Magistrate Judge.

INTRODUCTION

On October 1, 2014, Plaintiff Juan Antonio Ruiz, Jr. served Defendants City of Stockton, City of Stockton Police Department, Eric Jones, Alejandro Guerrero, and Thomas Quinones (collectively, "Defendants") with Requests for Production of Documents, Set One. On November 24, 2014, Defendants responded to the discovery requests but withheld production of all "personnel records" implicated by Plaintiff Juan Antonio Ruiz, Jr.'s discovery requested.

Following meet and confer efforts between the parties' counsel, the following stipulated agreement has been reached.

STIPULATION

1. Defendants agree to provide Plaintiffs with all documents responsive to Plaintiff Juan Antonio Ruiz, Jr.'s Request for Production of Documents, Set One, subject to any attorney-client privileged information and/or information protected under the work-product doctrine.

2. These documents will be specially-designated, and may only be disclosed to counsel, parties, and experts within this litigation.

3. If Plaintiffs intend to disclose these specially-designated documents to anyone outside of the litigation, Plaintiffs' counsel will notify Defendants' counsel as to the particular document(s) they intend to disclose.

4. In response, Defendants' counsel will determine whether or not to seek a protective order, pursuant to Federal Rule of Civil Procedure 26(c), regarding the particular document(s). Defendants' counsel will advise Plaintiffs' counsel and file a motion for protective order within five (5) calendar days after Plaintiffs' counsel provides notification, if Defendants' counsel intends to subject the document(s) to court-ordered protection.

5. If Plaintiffs' counsel does not receive notification from Defendants' counsel regarding intent to seek a protective order within five (5) calendar days, the document(s) is no longer subject to this stipulated agreement and Plaintiffs' counsel may distribute the document(s) without limitation.

6. After Plaintiffs' counsel has provided Defendants' counsel notification of intent to distribute a document(s), Plaintiffs' counsel agrees that if Defendants' counsel informs Plaintiffs' counsel that a protective order will be sought within five (5) calendar days and files a motion for protective order, Plaintiffs' counsel will not distribute the document(s) at issue until after the Court has issued a ruling regarding whether the document(s) is properly subject to protection under Federal Rule of Civil Procedure 26(c).

ORDER

IT IS SO ORDERED. Additionally, the parties are ordered to meet and confer in good faith (either in person, or at a minimum, by telephone) prior to the filing of a motion for a protective order. The court expects the parties to stipulate to a reasonable extension(s) of the five-day period to file a motion for a protective order, contemplated above, should it prove necessary to exhaust good faith informal meet-and-confer efforts.