(PROPOSED) ORDER FOR EXCHANGE OF DOCUMENTS AND INFORMATION PURSUANT TO PROTECTIVE ORDER

JOSEPH C. SPERO, Chief Magistrate Judge.

The Court, having reviewed Plaintiffs' Notice Re: Denial of County Defendants' Motion to Stay, the Court's Order Denying County Defendants' Motion to Stay (Dkt. 99), and the record in this matter, and good cause appearing, this Court hereby Orders as follows:

1) All parties shall receive a complete copy of all Coroner's, Autopsy, and Toxicology reports; complete Coroner's Office investigative files related to the death of Kayleigh Slusher; all photographs of any kind related to the death of Kayleigh Slusher, including but not limited to all autopsy photographs; all recordings, whether by audio or video, related to the death of Kayleigh Slusher; and all statements, interviews, notes, correspondence, or records of any kind related to the death of Kayleigh Slusher.

2) The documents and information to be produced specifically includes all records and information in the possession, custody, or control of A) the City of Napa and its police department, concerning Kayleigh Slusher's death and the claims and defenses made in this case, regardless of the source; B) the City of Napa and its police department, concerning all calls for service to Kayleigh Slusher's apartment (2060 Wilkins Avenue, Apt. 7, Napa, CA) prior to February 3, 2014, regardless of the source; C) Napa County concerning Kayleigh Slusher's death and the claims and defenses made in this case, regardless of the source; and D) Plaintiffs, concerning Kayleigh Slusher's death and the claims and defenses made in this case, regardless of the source.

3) No party waives any legal right to assert appropriate privileges, with a privilege log.

4) All documents and information produced pursuant to this Order shall be deemed confidential and subject to the Protective Order in this matter. (Dkt. 33).

5) Should any party need to file any of the documents and information produced pursuant to this Order in court during the pendency of criminal proceedings against Sara Krueger or Ryan Warner, that party shall file the documents and information under seal.

6) Plaintiffs and the Napa County Defendants shall produce the documents and information within ten days of this Court's Order. The City of Napa Defendants shall produce the documents and information no later than August 15, 2016, given their counsel's travel outside the country.

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.