AMENDED STIPULATION FOR PROTECTIVE ORDER AND PROTECTIVE ORDER

KENDALL J. NEWMAN, Magistrate Judge.

Subject to the approval of this Court, the parties hereby stipulate to the following protective order:

1. In connection with discovery proceedings in this action the United States Attorney's Office (USA), and defense counsel hereby agree to designate documents as "confidential" under the terms of this Stipulation for Protective Order (hereinafter "Order"). The documents protected pursuant to this Order have not been made public and the disclosure of said documents would have the effect of causing harm.

2. The documents eligible for protection under this Order include:

A. Chapters 1, 2, 4, 8, 11, 17, 18, and 21 of the CHP Officer Safety Manual will be produce pursuant to the subpoena issued by the USA on January 21, 2015. All of these chapters will be subject to this Order.

3. A signed Protective Order is required because production of the CHP Manual would compromise the safety and security of CHP officers in the field.

4. The CHP Manual and its contents are protected under this Order, including any information contained in the Manual, and any summaries, copies, abstracts, or other documents derived in whole or in part from this manual. The information disclosed in this manual shall be used only for the purpose of prosecuting or defending this action, and no other purpose.

5. The CHP Manual produced pursuant to this Order may be disclosed or made available to the USA or defense counsel only; no other persons will have the right to review this document. Only the chapters noted above in Item 2A will be disclosed. Any disclosure or inspection of the CHP Manual shall be limited to an in-person review at the USA's Office, on a date and at a time when the CHP's legal representative from the California Department of Justice can be available to supervise inspection of the CHP Manual. In no event will any party be authorized to retain a copy of the CHP Manual, or photograph, photocopy, record, or otherwise duplicate the CHP Manual by use of a duplicating machine, camera, dictaphone, or other technology.

6. Nothing in this Order, or the production of any document under the terms of this Order, shall be deemed to have the effect of an admission or waiver by either party or of altering the confidentiality of the CHP Manual.

7. If the CHP Manual, or any part thereof, is produced in accordance with this Order is disclosed to any person other than in the manner authorized by this Order, the party responsible for the disclosure shall immediately bring all pertinent facts relating to such disclosure to the attention of all counsel of record and, without prejudice to other rights and remedies available to the producing party, make every effort to obtain the return of the disclosed the CHP Manual and prevent further disclosure of it by the person who was the recipient of such information.

8. This Order shall survive through the final termination of this action. Once this action has been terminated, no party will have the right to see, review, or inspect the CHP Manual. Moreover, the parties agree to destroy any notes they took regarding the contents of the CHP Manual.

IT IS SO STIPULATED.

IT IS SO ORDERED.