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Reynaga Hernandez v. Skinner

United States District Court, D. Montana, Billings Division

January 8, 2019

MIGUEL ANGEL REYNAGA HERNANDEZ, Plaintiff,
v.
DERREK SKINNER, in his individual capacity; and PEDRO HERNANDEZ, in his individual capacity, Defendants.

          Presented by: Attorneys for Plaintiff Matt Adams, Leila Kang, Anne Recinos, Aaron Korthuis, Shahid Hague

          Attorney for Defendants Kevin Gillen Deputy Yellowstone County Attorney

          STIPULATION AND ORDER

          SUSAN P. WATTERS United States District Judge.

         IT IS HEREBY STIPULATED and agreed by and between counsel for the parties that the terms and conditions of this Stipulation and Order shall govern the handling of certain information contained in documents, discovery responses, depositions, pleadings, exhibits, and all other information or things produced or disclosed by any party ("Producing Party") in this litigation.

         1. Designation of Materials Subject to Protective Order. A Producing Party shall have the right to designate documents and information it produces as "CONFIDENTIAL" pursuant to this Stipulation and Order and materials designated as such will be referred to as "Designated Materials." Any information relating to an individual's immigration status will be designated as CONFIDENTIAL. Such information includes place of birth, national origin, passports, visas, social security No. or statements, tax identification No. or other tax information, information regarding entry into the United States, and information regarding any proceeding or application before the Department of Homeland Security (DHS), Department of Justice (DOJ), or any agency within DHS or DOJ.

         2. Designation of Information Produced. A Producing Party shall designate information and/or records as CONFIDENTIAL by marking the applicable designation thereon in a size and location which makes the designation readily apparent. In the case of depositions, any party will have thirty (30) calendar days after receipt of the deposition transcript and exhibits to designate, in writing, to the other parties and to the court reporter, whether the transcript or any portion thereof, is to be designated as CONFIDENTIAL. During this thirty-day period, the transcript must be treated as CONFIDENTIAL. If no such designation is made at the time of the deposition or within this thirty-day period, the entire transcript will be considered devoid of CONFIDENTIAL information. Each party and the court reporter must attach a copy of any final and timely written designation notice to the transcript and each copy of the transcript in their possession, custody, or control, and the portions designated in such notice must thereafter be treated in accordance with this Order.

a. Inadvertent Failure to Designate CONFIDENTIAL Information. An inadvertent failure to designate qualified information as CONFIDENTIAL at the time of its disclosure, does not, standing alone, waive the Producing Party's right to secure protection under this Stipulation and Order for such materials. If material is designated as CONFIDENTIAL after it is initially produced, the receiving parties, on timely notification of the designation, must make reasonable efforts to assure that the Designated Materials are treated in accordance with the provisions of this Order.
b. Designation of Previously Produced CONFIDENTIAL Information. Within thirty (30) calendar days of this order, each party shall designate any previously produced documents, files, or materials as CONFIDENTIAL by marking it in accordance with Paragraph 2.
c. Maintenance of CONFIDENTIAL Information. It is the responsibility of counsel for each party to maintain materials containing CONFIDENTIAL information in a secure manner and appropriately identified so as to allow access to such information only to such persons and under such terms as permitted under this Stipulation and Order. The parties shall cooperate to the extent reasonable to segregate Designated Material with transcripts (and exhibits, if applicable) into a separate document or transcript.

         3. CONFIDENTIAL Restrictions. Information designated as CONFIDENTIAL shall be used by the receiving parties solely for the purposes of this litigation, and may be disclosed only to the following persons:

a. Any employee or former employee of a party to whom it is deemed necessary that the designated materials be shown for purpose of the litigation, provided that such employee or former employee shall be advised that he or she is subject to the terms of this Stipulation and Order before being provided designated materials;
b. Counsel for the respective parties, and employees and independent contractors for counsel that are engaged in work necessary to assist in this litigation. "Counsel" shall mean the attorneys and their firms who have entered an appearance in this case as of the date this Stipulation and Order is executed by the parties;
c. Third-party experts or consultants, and the employees of such experts and consultants who are assisting them, engaged by counsel or a party to assist in this litigation;
d. A witness in the course of a deposition, hearing, or trial testimony where counsel has a reasonable and good faith belief that examination with respect to the designated material is necessary, provided that the witness agrees to be bound by the terms of this Stipulation and Order and that the ...

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