JOINT SUPPLEMENTAL STIPULATED [PROPOSED] PROTECTIVE ORDER

RICHARD SEEBORG, District Judge.

WHEREAS Plaintiff Gena Hanson, individually and on behalf of others similarly situated, as a part of the discovery process and in preparation for mediation, has requested that Defendant, JQD, LLC, d/b/a/ Pro Solutions, (collectively, the "Parties") produce its database of collection information for all putative class members (hereafter the "Database");

WHEREAS Defendant believes that the outstanding discovery requests are overbroad and call for the production of confidential private information;

WHEREAS Plaintiff believes that the existing protective order, signed by the Court on September 22, 2014, is sufficient to protect any privacy rights of the putative class members that may be put at issue;

WHEREAS Defendant believes that the existing protective order signed by the Court on September 22, 2014, is insufficient to protect the privacy rights of class members that may be put at issue and it may be prohibited from producing the information plaintiff seeks without a court order;

WHEREAS Defendant is concerned about its limited insurance coverage and the fact that the amount of coverage is reduced by the cost of the defense, and, therefore, desires to attempt to settle this matter, and has proposed that the parties participate in a mediation,

WHEREAS Plaintiff has stated it cannot participate in a mediation without the information it sought through discovery

NOW, THEREFORE, the Parties hereby STIPULATE that the Court enter a supplemental protective order directing Defendant to provide the Database to Plaintiff, and order that (1) Plaintiff shall treat the Database as "Attorney's Eyes Only" information; (2) Plaintiff shall not contact any putative class members prior to class certification or without the express permission of Defendant or the Court (this does not preclude Plaintiff from discussing the case with any putative class members who affirmatively contact Plaintiff); (3) production of the information requested does not constitute a wavier of any privilege which would otherwise apply; (4) Plaintiff shall not contact any Homeowner's Association identified in the Database without the express permission of Defendant or the Court; and, (5) within 30 days of the conclusion of the case Plaintiff will return to Pro Solutions' counsel all copies of the database and destroy all copies of documents obtained from it.

PROPOSEDl ORDER

Pursuant to the STIPULATION of the Parties, it is hereby ordered that Defendant shall provide the requested Database to Plaintiff, and that (1) Plaintiff shall treat the Database as "Attorney's Eyes Only" information; (2) Plaintiff shall not contact any putative class members prior to class certification or without the express permission of Defendant or the Court (this does not preclude Plaintiff from discussing the case with any putative class members who affirmatively contact Plaintiff); (3) production of the information requested does not constitute a wavier of any privilege which would otherwise apply; (4) Plaintiff shall not contact any Homeowner's Association identified in the Database without the express permission of Defendant or the Court; and, (5) within 30 days of the conclusion of the case Plaintiff will destroy the copy of the database and all copies of documents obtained from it.

IT IS SO ORDERED.