STIPULATED PROTECTIVE ORDER REGARDING PRODUCTION OF CONFIDENTIAL RECORDS

ALLISON CLAIRE, Magistrate Judge.

Following meet and confer discussions, and pursuant to the Plaintiffs' May 12, 2015 correspondence, IT IS HEREBY AGREED AND STIPULATED between all parties that the following documents contained within Defendant SCOTT BRATTON's Manteca Police Department personnel file shall be governed by protective order:

It is understood that these documents contain private and personal information regarding SCOTT BRATTON's pre-employment psychological testing by a licensed professional.

The produced documents shall be used by the parties solely for the purpose of prosecuting and defending the above captioned case. The documents shall not be duplicated, reproduced, transmitted, or communicated to any person or entity for any reason whatsoever excepting Plaintiff's counsel; Plaintiffs; declared experts pursuant to the Plaintiffs' Rule 26 disclosure; deposition witnesses at the time of deposition; trial witnesses at the time of trial; mediator or third party neutral; or the court.

The copying of the documents is to be conducted in-house and shall not be done by outside third party vendors.

Even after the termination of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until SCOTT BRATTON agrees otherwise in writing or a court order otherwise directs.

If any party learns that, by inadvertence or otherwise, it has disclosed documents protected pursuant to this protective order to any person or in any circumstance not authorized under this Stipulated Protective Order, that party must immediately (a) notify in writing SCOTT BRATTON of the unauthorized disclosures, (b) use its best efforts to retrieve all copies of the protected material, (c) inform the person or persons to whom unauthorized disclosures were made of all the terms of this Order, and (d) request such person or persons to execute the "Acknowledgement and Agreement to Be Bound" that is attached hereto as Exhibit A.

This Order shall constitute a protective order pursuant to Federal Rules of Civil Procedure 26(c) and shall be enforceable as set forth therein. Plaintiffs' counsel shall advise the Plaintiffs, experts and others of this Protective Order and its effect.

STIPULATED AND AGREED:

PURSUANT TO STIPULATION, IT IS SO ORDERED.

EXHIBIT A

ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND

I, __________________________________________________[print or type full name] of ________________________________________________________________________ [print or type full address], declare under penalty of perjury that I have read in its entirety and understood the Stipulated Protective Order that was issued by the United States District Court for the Eastern District of California on _____________________[date] in the case of KAUR, et al. v. CITY OF LODI, et al.. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any person or entity except in strict compliance with the provisions of this Order.

I further agree to submit to the jurisdiction of the United States District Court for the Eastern District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after termination of this action.

I hereby appoint ______________________________________[print or type full name] of ________________________________________________________________________ [print or type full address and telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of the Stipulated Protective Order.