Stipulation and OrderCal. Super. - 6th Dist.November 24, 2020ZOCV373984 Santa Clara - Civil EFS-oznvnner ATTORNEY 0R PARTY WITHOUT ATTORNEY: STATE BAR N0: FOR coun-r usE ONLY NAME: Tyler A. Brown (SBN 121350) / Kate L. Brown (SBN 308134) FIRM NAME: Jackson Lewis P.C. STREET ADDRESS: 5O California Street, 9th Floor CITY: San Francisco STATE: CA ZIP CODE: 94111 TELEPHONE No.: (415) 394-9400 FAX “0-5 (415) 394'9401 on 7/23/2021 5:06 PM E.MAIL ADDRESS: kate.brown@jacksonlewis.com Reviewed By: F. Miller ATTORNEY FOR (name): Defendants SUPERIOR COURT 0F CALIFORNIA, COUNTY OF SANTA CLARA E:\slzlfiioe?\6,931763§28; STREET ADDRESS; 191 N. First Street MAILING ADDRESS; CITYAND ZIP CODE: San Jose, CA 951 13 BRANCH NAME: CASE NUMBER: PLAINTIFF/PETITIONER: JANE DOE 200V373984 DEFENDANT/RESPONDENT: RURAL/METRO OF CALIFORNIA, |NC., et al. JUDICIAL OFFICER: OTHER: PROPOSED ORDER (COVER SHEET) [1)?“ NOTE: This cover sheet is to be used to electronically file and submit to the court a proposed order. The proposed order sent electronically to the court must be in PDF format and must be attached to this cover sheet. In addition, a version of the proposed order in an editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed order in PDF format are filed. 1- Name of the party submitting the proposed order: Rural/Metro of California, |nc.; American Medical Response West; American Medical Response, |nc.; Christopher Garvin 2- Title of the proposed order: Proposed Stipulated Protective Order 3. The proceeding to which the proposed order relates is: a. Description of proceeding: b. Date and time: c. Place: 4. The proposed order was served on the other parties in the case. Kate L. Brown rim (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR A'I'I'ORNEY) Page 1 of 2 Form Adopted for Mandaiory Use PROPOSED ORDER (COVER SHEET) Cal. Rules of Court, Judicial Council of California _ _ _ rules 2.252, 3.1312 EFs-ozo [Rev. February 1, 201 7] (Electronlc Flllng) www.couns.ca.gov EFS-OZO CASE NAME: CASE NUMBER: JANE DOE v. RURAL/METRO 0F CALIFORNIA, INC., et aI. 200V373984 PROOF OF ELECTRONIC SERVICE PROPOSED ORDER 1. | am at least 18 years old and not a party to this action. 3- My residence or business address is (specify): 5O California Street, 9th Floor, San Francisco, CA 941 11 b. My electronic service address is (specify): 2_ | electronically served the Proposed Order (Cover Sheet) with a proposed order in PDF format attached, and a proposed order in an editable word-processing format as follows: a. On (name ofperson served) (If the person served is an attorney, the party or pan‘ies represented should also be stated): See Proof of Service b. To (electronic service address ofperson served): c. 0n (date): July 23, 2021 E Electronic service of the Proposed Order (Cover Sheet) with the attached proposed order in PDF format and service of the proposed order in an editable word-processing format on additional persons are described in an attachment. | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: July 23, 2021 fwfl Fatimah Sikin ’ (TYPE 0R PRINT NAME 0F DECLARANT) (SIGNATURE 0F DECLARANT) EFs-ozo [Rev. February 1, 2017] pRQPQSED ORDER (COVER SHEET) Pagez or2 (Electronic Filing) \OOOflQM-DUJNH NNNNNNNNNHr-Ih-tr-lr-tr-tr-tr-AHH OOQQM-PUJNi-‘OKOOOQQM-BWNi-‘O Maria Boum (State Bar No. 269322) Michael Brooks (State Bar N0. 272052) Law Office ofTanya Gomerman, APC 825 Van Ness Avenue, Suite 502 San Francisco, CA 94109 Tel. (415) 545-8608 Fax (855) 545-8608 Filed E-mail: mgria@attomevtanva.com July 28 2021 E-ma11: m1chael@attornevtanva.com Clerk Of the Court Attorneys for Plaintiff SUper'Or court Of CA JANE DOE County of Santa Clara 20CV373984 Tyler A. Brown (State Bar No. 121350) By: rburc'aga Kate L. Brown (StatC Bar NO. 308134) Signed; 7/23/2021 09;45 AM JACKSON LEWIS P.C. ‘ 50 California Street, 9th Floor r WW San Francisco, California 941 1 1-461 5 Telephone: (415) 394-9400 Facsimile: (415) 394-9401 E-mail: Tyler.Brown@iacksonlewis.com E-mail: Kate.Brown@iacksonlewis.com Attorneys for Defendants RURAL/METRO OF CALIFORNIA, INC; AMERICAN MEDICAL RESPONSE WEST; AMERICAN MEDICAL RESPONSE, INC; and CHRISTOPHER GARVIN *See nextpagefor additional attorneys SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA JANE DOE, an individual, Case N0. 20CV373984 Plaintiff, [PR STIPULATED PROTECTIVE ORDER V. RURAL/METRO OF CALIFORNIA, INC, a California corporation; AMERICAN Complaint Filed: 11/24/2020 MEDICAL RESPONSE WEST, a California Trial Date: None set corporation; AMERICAN MEDICAL RESPONSE, INC, a Delaware corporation; ALBERT J CHAVEZ, an individual; CHRISTOPHER GARVIN, an individual; and DOES 1 TO 50, inclusive, Defendants. _“-\ AhAA-rwn-u nmm-r-r-r A rnw-v-x “1x Amfimmvv 71a Ahh-r-vr‘ A ‘v Anny ya-ann 4 \DOONONUI-PUJNH NNNNNNNNNHr-dr-tb-th-db-IHr-tr-tr-d mfiom-PWNHOKOOOQONm-waHO Edward A. Kraus (State Bar No. 162043) Kathryn E. Barrett (State Bar No. 162100) Marc G. van Niekerk (State Bar N0. 201329) Silicon Valley Law Group One North Market Street, Suite 200 San Jose, CA 951 13 Tel. (408) 573-5700 Fax (408) 573-5701 E-mail: eak@sv1g.com E-mail: keb@svlg.com E-mail: mvn@svlg.com Attorneys for Defendant ALBERT J. CHAVEZ -hn Ahnnrfifi-I nmmv" A r-nw“ “1s Amw-anmflm Ahhu-‘h AAmva-Ann A \DOOQONU‘I-RUJNr-t NNNNNNNNNHr-tt-tv-Ir-tr-AHHHr-t ooflO‘xUI-hUJNr-tOKOooflmm-PUJNI-O IT IS HEREBY STIPULATED by and among the parties t0 Jane Doe V. Rural/Metro Of California, Inc., et a1., Case N0. 20CV373984 (“the Litigation”), Plaintiff Jane Doe and Defendants Rural/Metro Of California, Ina, American Medical Response West, American Medical Response, Inc., Albert J. Chavez and Christopher Garvin (the “Parties”), by and through their respective counsel 0frecord, that in order t0 facilitate the exchange ofinformation and documents t0 be used for purposes of this litigation only that may be confidential or proprietary due t0 federal laws, state laws, privacy rights, and/or trade secret protections, the Parties stipulate as follows: 1. In this Stipulation and Protective Order, the words set forth below shall have the following meanings: a. “Proceeding” means the above-entitled proceeding, Jane Doe V. Rural/Metro of California, 1110., et a1., California Superior Court for the County 0f Santa Clara, Case N0. 20CV3 73984. b. “Court” means the any judge to Which this Proceeding may be assigned, including Court staff participating in such proceedings. c. “Confidential” means any Documents, Testimony, 0r Information which is in the possession 0f a Designating Party Who believes in good faith that such Documents, Testimony, or Information is entitled t0 confidential treatment under applicable law. d. “Confidential Materials” means any Documents, Testimony, 0r Information as defined below designated as “Confidential” pursuant to the provisions 0f this Stipulation and Protective Order. e. “Designating Party” means the Party that designates Documents, Testimony, or Information, as defined below, as “Confidential.” f. “Disclose” or “Disclosed” 0r “Disclosure” means to reveal, divulge, give, or make available Materials, or any part thereof, 0r any information contained therein. g. “Documents” means (i) any “Writing,” “Original,” and “Duplicate” as those terms are defined by California Evidence Code Sections 250, 255, and 260, which have been produced in discovery (formal or informal) in this Proceeding by any person or entity, and (ii) any copies, reproductions, or summaries 0f all or any part 0f the foregoing. _1\1\ AnAn-u-rr‘w um-rv-vrw A rrrvfi“ 1s“ Arn-r-u/Nrnw 7w Ahh-r-vw‘ n xv- AAru-u- rn-Ann A KOOOQO‘NUl-PUJNr-t NNNNNNNNNHHHHHHv-HHH OOQQUI-bUJNHOKOOOQQUI-PWNP-‘O h. “Information” means the content 0f Documents, Testimony, including all copies, abstracts, compilations, summaries, and any other format reproducing 0r capturing any of the content therein. i. “Testimony” means all depositions, declarations, 0r other testimony taken or used in this Proceeding. j. “Producing Party” means a Party or Non-Party that produces 0r makes a Disclosure 0f Information in this Action. k. “Receiving Party” means a Party that receives a Disclosure of Information from a Producing Party. 2. The Designating Party shall have the right t0 designate as “Confidential” only the non- public Documents, Testimony, 0r Information that the Designating Party in good faith believes would create a substantial risk of serious financial or other injury, if Disclosed to non-Party, and that such risk cannot be avoided by less restrictive means. 3. The entry 0f this Stipulation and Protective Order does not alter, waive, modify, 0r abridge any right, privilege, or protection otherwise available to any‘Party With respect to the discovery 0f matters, including but not limited to any Party’s right t0 assert the attomey-client privilege, the attorney work product doctrine, 0r other privileges, or any Party’s right to contest any such assertion. 4. Any Documents, Testimony, 0r Information t0 be designated as “Confidential” must be clearly so designated before the Document, Testimony, or Information is Disclosed 0r produced if Disclosed or produced by the Designating Party, subject t0 the exceptions herein. If the Document, Testimony, 0r Information is Disclosed 0r produced by a non-Designating Party or non-Party, the Receiving Party may retroactively designate the Document, Testimony, 0r Information as “Confidential” Within fifteen (15) days of receipt 0f the Document, Testimony, 0r Information by notifying all Parties and the producing party of the designation. a. For Documents (apart from transcripts of depositions or other pretrial or trial proceedings), the Designating Party must affix the legend “Confidential” on each page 0f any Document, containing such designated material. The “Confidential” designation should not obscure or interfere with the legibility ofthe designated Information. b. For Testimony given in depositions the Designating Party may either: 4 _“-\ Ahnnfifi-I nr-nm-‘rv-r A r-n-w-u-r‘ “1-. Amfimm" v-ra Ahh-u-u“ n \v Annv va-Ann A QWQONM-PUJNr-I NNNNNNNNNHHHr-Ar-ir-tr-tr-AHH ooflmm-PUJNHOKDOouQm-hwwi-to i. identify on the record, before the close of the deposition, all “Confidential” Terstimony, by specifying all portions of the Testimony that qualify as “Confidential.” The transcript pages containing “Confidential” Information may be separately bound by the court I reporter, Who must affix t0 the top 0f each page the legend “Confidential,” as instructed by the Designating Party, or, ii. designate specific portions of the testimony as “Confidential” within 30 days following receipt 0f the deposition transcript. c. For Information produced in some form other than Documents, and for any other tangible items, including, Without limitation, compact discs or DVDS, the Designating Party must affix in a prominent place on the exterior 0f the container or containers in Which the Information 0r item is stored the legend “Confidential.” d. For any data file containing Confidential Information, the Designating Party must affix in the file name the legend “Confidential.” If only portions of the Information or item warrant protection, the Designating Party, t0 the extent practicable, shall identify the “Confidential” portions. ’ 5. The inadvertent production by any 0f the undersigned Parties or non-Parties t0 the Proceedings ofany Document, Testimony, 0r Information during discovery in this Proceeding Without a “Confidential” designation, shall be Without prejudice t0 any claim that such item is “Confidential” and such Party shall not be held t0 have waived any rights by such inadvertent production. In the event that any Document, Testimony, 0r Information that is subject to a “Confidential” designation is inadvertently produced Without such designation, the Party that inadvertently produced the document shall give written notice of such inadvertent production within thirty (3 0) days 0f discovery of the inadvertent production, together with a further copy of the subject Document, Testimony, or Information designated as “Confidential” (the “Inadvertent Production Notice”). Any materials that have not been marked as “Confidential”, Which are the subj ect ofthe notice 0finadvertent production, shall be immediately considered Confidential and subject to the protections and provisions of this Stipulation and Protective Order. Upon receipt of such Inadvertent Production Notice, the Party that received the inadvertently produced Document, Testimony, 0r Information shall promptly destroy the inadvertently produced Document, Testimony, or Information and all copies thereof, or, at the expense 5 _1\~r\ AhAA-u-‘fi-I nm-rh-r-rv A rum“ 1x“ nmfi/Vr-nvv Th Ahfifi“ IV ‘1- Anmv va-Ann a \OOOQQUl-RUJNr-t NNNNNNNMNHHHh-tr-kh-dp-tr-tb-Ar-t OOQQM-PUJNHOKDOOVQM#UJNHO 0f the Producing Party, return such together with all copies 0f ‘ such Document, Testimony or Information to counsel for the Producing Party and shall retain only the “Confidential” materials. Should the Receiving Party choose t0 destroy such inadvertently produced Document, Testimony, 0r Information, the Receiving Party shall notify the Producing Party in writing 0f such destruction within ten (10) days of receipt of written notice of the inadvertent production. The Receiving Party’s notice shall: (1) identify (by category, where appropriate) all the Confidential Material, Document, . Testimony or Information that was returned or destroyed: (2) affirm that the receiving party has not retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the Confidential Materials; and (3) identify the parties to Whom any disclosure was made prior to receiving notice 0f the inadvertent disclosure, and the steps taken by the receiving party to retrieve the information. This provision is not intended to apply t0 any inadvertent production 0f any Information protected by. attorney-client 0r work product privileges. In the event that this provision conflicts with any applicable law regarding waiver of confidentiality through the inadvertent production of Documents, Testimony or Information, such law shall govern. 6. In the event that counsel for a Party receiving Documents, Testimony 0r Information in discovery designated as “Confidential” objects to such designation with respect t0 any 0r all of such items, said counsel shall advise counsel for the Designating Party, in writing, of such obj ections, the specific Documents, Testimony 0r Information to Which each objection pertains, and the specific reasons and support for such objections (the “Designation Objections”). The Parties Will attempt t0 resolve such disputes on an informal basis. If the dispute cannot be resolved, Counsel for the Designating Party shall have thirty (3 0) days from receipt 0f the written Designation Obj actions, or Within 14 days of the parties conclusion 0f the meet and confer process, Whichever is later, to either (a) agree in writing to de-designate Documents, Testimony, or Information pursuant t0 any or all of the Designation Objections and/or (b) file a motion with the Court seeking to uphold any 0r all designations 0n Documents, Testimony, or Information addressed by the Designation Objections (the “Designation Motion”). Pending a resolution of the Designation Motion by the Court, any and all existing designations on the Documents, Testimony, or Information at issue in such Motion shall remain in place. The Producing Party shall have the burden 0n any Designation Motion 0f establishing the inapplicability of the “Confidential” designation. 6 flux“ AhAn-r-uh-I rumm-rw A r-rrvfi-r‘ “h nmu-uflmnm Ahnr‘“ A x-r AAA:- vn-nnn A \D 00 fl O\ U! k‘w [\D r-t NNNNNNNNNb-kr-Ar-HHHr-Ir-th-AH OOQQUl-PUJNHOKOOOQQU‘I-PUJNHO 7. Access t0 and Disclosure 0f Confidential Materials shall be permitted only to the following persons 0r entities: a. the Court; b. (1) Attorneys of record in the Proceeding and their affiliated attorneys, paralegals, clerical and secretarial staff employed by such attorneys who are actively involved in the Proceeding and are not employees of any Party; and (2) In-house counsel t0 the undersigned Parties and the paralegal, clerical and secretarial staff employed by such counsel. Provided, however, that each non-lawyer given access t0 Confidential Materials shall be advised that such materials are being Disclosed pursuant t0, and are subject t0, the terms 0f this Stipulation and Protective Order and that they may not be used 0r Disclosed other than pursuant to its terms; c. The Parties; d. those officers, directors, partners, members, employees and agents 0f all non- designating Parties that counsel for such Parties deems necessary to aid counsel in the prosecution and defense 0f this Proceeding; provided, however, that prior to the Disclosure 0f Confidential Materials t0 Plaintiff and any such officer, director, partner, mem‘ber, employee or agent, counsel for the Party making the Disclosure shall deliver a copy 0f this Stipulation and Protective Order to such person, shall explain that such person is bound t0 follow the terms ofsuch Order, and shall secure the signature 0f such person 0n a statement in the form attached hereto as Exhibit A; e. court reporters in this Proceeding (whether at depositions, hearings, or any other proceeding); f. any deposition, trial, 0r hearing Witness in the Proceeding Who previously has had access to the Confidential Materials, 0r Who is currently or was previously an officer, director, partner, member, employee 0r agent of an entity that has had access t0 the Confidential Materials; g. any deposition 0r non-trial hearing witness in the Proceeding who previously did not have access to the Confidential Materials; provided, however, that each such witness given access t0 Confidential Materials shall be advised that such materials are being Disclosed pursuant to, and are subj ect to, the terms 0fthis Stipulation and Protective Order and that they may not be Disclosed other than pursuant to its terms; ..-w\“ AnAn-ufi-rx-I nrrvrhvv-r A y-I-u-‘fi “n Amfir‘n-n-rv vrq Afih-u-vr‘ rw xv Annvvannnn A KDOOQCNUl-PUJNH NNNNNNNNNr-tr-th-AHr-kr-tr-tr-tr-Ir-t ooflOxUI-PUJNr-OKDOOQONUI-bwwv-IO h. mock jury participants, provided, however, that prior t0 the Disclosure of Confidential Materials to any such mock jury participant, counsel for the Party making the Disclosure shall deliver a copy of this Stipulation and Protective Order to such person, shall explain that such person is bound to follow the terms of such Order, and shall secure the signature 0f such person 011 a statement in the form attached hereto as Exhibit A. i. outside experts or expert consultants consulted by the undersigned Parties or their counsel in connection With the Proceeding, whether or not retained to testify at any oral hearing; provided, however, that prior to the Disclosure of Confidential Materials t0 any such expert 0r expert consultant, counsel for the Party making the Disclosure shall deliver a copy 0f this Stipulation and Protective Order t0 such person, Shall explain its terms t0 such person, and shall secure the signature of such person on a statement in the form attached hereto as Exhibit A. It shall be the obligation of counsel, upon learning 0f any breach 0r threatened breach of this Stipulation and Protective Order by any such expert or expert consultant, to promptly notify counsel for the Designating Party of such breach or threatened breach; j . any other person or entity that the Designating Party agrees t0 in writing. 8. Confidential Materials shall be used by the persons 0r entities receiving them only for the purposes 0f prosecuting, defending, 0r attempting to settle the Proceeding, and shall not be used for any business 0r other purpose whatsoever, including in another action. 9. Any Party to the Proceeding (or other person subject t0 the terms 0f this Stipulation and Protective Order) may ask the Court, after appropriate notice to the other Parties to the Proceeding, to modify 0r grant relief from any provision of this Stipulation and Protective Order. 10. Entering into, agreeing t0, and/or complying with the terms of this Stipulation and Protective Order shall not: a. operate as an admission by any person that any particular Document, Testimony, or Information marked “Confidential” contains 0r reflects trade secrets, proprietary, confidential or competitively sensitive business, commercial, financial or personal information; or b. prejudice in any way the right of any Party (or any other person subject t0 the terms of this Stipulation and Protective Order): -r‘“ n1xnru-r1-rx-I nr-rrrn-rv-r A rrvr-rrx “1s Amv-‘flr-I-u" v“ Ahfifi“ n \1- AA/Nv vn-Ann A \DOOQQU‘I-DUJNb-k NNNNNNNNNr-tb-tr-kb-‘h-kr-dr-Ib-lr-tr-l OONQKJl-bUJNr-‘OKOOONONM-PUJNF-‘O i. to seek a determination by the Court of whether any particular Confidential Materials should be subject t0 protection under the terms 0f this Stipulation and Protective Order; or ii. to seek relieffrom the Court on appropriate notice to all other Parties t0 the Proceeding from any provision(s) 0f this Stipulation and Protective Order, either generally 0r as t0 any particular Document, Material or Information. 1 1. Any Party to the Proceeding Who has not executed this Stipulation and Protective Order as 0fthe time it is presented t0 the Court for signature may thereafter become a Party to this Stipulation and Protective Order by its counsel’s signing and dating a copy thereof and filing the same With the Court, and serving copies 0f such signed and dated copy upon the other Parties t0 this Stipulation and Protective Order. 12. Any Information that may be produced by a non-Party witness in discovery in the Proceeding pursuant to subpoena 0r otherwise may be designated by such non-Party as “Confidential” under the terms ofthis Stipulation and Protective Order, and any such designation by a non-Party shall have the same force and effect? and create the same duties and obligations, as if made by one 0f the undersigned Parties hereto. Any such designation shall also function as consent by such producing non-Party to the authority of the Court in the Proceeding t0 resolve and conclusively determine any motion or other application made by any person or Party With respect to such designation, 0r any other matter otherwise arising under this Stipulation and Protective Order. 13. If any person subject t0 this Stipulation and Protective Order Who has custody of any Confidential Materials receives a subpoena or other process (“Subpoena”) from any government 0r other person 0r entity demanding production of such materials, the recipient of the Subpoena shall promptly give notice 0f the same by electronic mail transmission, followed by either express mail or overnight delivery to counsel of record for the Designating Party, and shall furnish such counsel With a copy of the Subpoena. Upon receipt 0f this notice, the Designating Party may, in its sole discretion and at its own cost, move to quash or limit the Subpoena, otherwise oppose production of the Confidential Materials , and/or seek to obtain confidential treatment 0f such materials from the subpoenaing person 0r entity t0 the fullest extent available under law. The recipient 0f the Subpoena -nh Ahnnfifis nmm-r-vv A rn-u-‘fi “-rs Arnhnrn-rv 7-w- Anfih“ A ‘T Anny va-AAA A KOOOQO‘xUl-thr-t NNNNNNNNNHr-Ir-Ar-lr-Kr-tr-tr-AHH OOflam-PUJNi-‘OKDOOQQLh-PWNHO may not produce any Confidential Materials pursuant t0 the Subpoena prior to the date specified for production 0n the Subpoena. 14. Nothing in this Stipulation and Protective Order shall be construed to preclude either Party from asserting in good faith that certain Confidential Materials require additional protection. The Parties shall meet and confer to agree upon the terms 0f such additional protection or seek input or a ruling from the Court. Moreover, nothing in this Protective Order shall be deemed t0 be a limit or waiver of the attomey-client privilege, the work product doctrine, or any other relevant privilege. Inadvertent production of privileged information shall not waive the privilege. If privileged information is inadvertently produced, the recipient agrees that, upon request from the producing party, it shall promptly return all copies 0f all documents containing the privileged information, delete any versions 0f the documents containing the privileged information 0n any database 0r computer filing system it maintains, and make no use of the privileged information. 15. If, after execution of this Stipulation and Protective Order, any Confidential Materials submitted by a Designating Party under the terms 0fthis Stipulation and Protective Order is Disclosed by a non-Designating Party t0 any person other than in the manner authorized'by this Stipulation and Protective Order, the non-Designating Party responsible for the Disclosure shall (1) bring all pertinent facts relating to the Disclosure 0f such Confidential Materials to the immediate attention 0f the Designating Party, (2) use its best efforts t0 retrieve all copies ofthe Confidential Materials , (3) inform the person or persons to Whom the Disclosures were made 0f all the terms 0f this Protective Order, and (4) request that such person 0r persons execute Exhibit A. 16. This Stipulation and Protectivc Order is entered without prejudice t0 the right of any Party t0 knowingly waive the applicability ofthis Stipulation and Protective Order to any Confidential Materials designated by that Party. If the Designating Party uses Confidential Materials in a non- Confidential manner, then the Designating Party shall advise that the designation no longer applies. 17. Where any Confidential Materials, or Information derived therefrom, is included in any motion 0r other proceeding governed by California Rules of Court, Rules 2.550 and 2.551, the Parties and any involved non-party shall follow those rules. With respect t0 discovery motions 0r other proceedings not governed by California Rules of Court, Rules 2.550 and 2.551, the following shall apply: If Confidential Materials 0r Information derived therefrom are submitted to or otherwise 10 -v‘“ Anfiflfifiw nn-u-rn-rw A mfi“ h“ Amr-‘nr-n-rv vw-u Ahnw-xn A x-r Annv va-nnn A \DOOQQU‘I-BUJNr-t [\J [\3 N [\J [\J,l\) N N N r-t r-t r-t I-A r-t r-t r-t v-t r-a r-t OOflmm-PUJNP-‘OKDOOQONM-RWNF-‘O disclosed t0 the Court in connection with discovery motions and proceedings, the same shall be separately filed under seal With the clerk of the Court in an envelope marked: “CONFIDENTIAL - FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDERAND WITHOUT ANY FURTHER SEALING ORDER REQUIRED.” 18. The Parties shall meet and confer regarding the procedures for use 0f any Confidential Materials at trial and shall move the Court for entry 0f an appropriate order. 19. Nothing in this Stipulation and Protective Order shall affect the admissibility into evidence in this Proceeding 0f Confidential Materials, 0r abridge the rights of any person to seek judicial review 0r t0 pursue other appropriate judicial action With respect t0 any ruling made by the Court concerning the issue 0f the status 0f any Confidential Materials. 20. This Stipulation and Protective Order shall continue to be binding after the conclusion of this Proceeding and all subsequent proceedings arising from this Proceeding, except that a Party may seek the written permission 0f the Designating Party or may move the Court for relief from the provisions 0f this Stipulation and Protective Order. To the extent permitted by law, the Court Shall retain jurisdiction to enforce, modify, 0r reconsider this Stipulation and Protective Order, even after the Proceeding is terminated. 21. Upon written request made Within thirty (3 O) days after the settlement 0r other termination of the Proceeding, the undersigned Parties shall have thirty (30) days to either (a) destroy all Confidential Materials and all copies thereof (including Confidential Materials contained in deposition transcripts and attached to deposition transcripts as exhibits, and Confidential Materials contained in copies of pleadings filed with the court in connection With any motion 0r pleading), (b) file a motion seeking a Court order regarding proper preservation of such Materials, 0r (c) return all Confidential Materials. T0 the extent permitted by law the Court shall retain continuing jurisdiction t0 review and rule upon the motion referred to in sub-paragraph (b) herein. Whether the Confidential Materials are returned 0r destroyed, the receiving party shall submit a written certification t0 the other party under penalty ofperjury, that (1) identifies (by category, where appropriate) all the Confidential Material that was returned or destroyed and (2) affirms that the receiving party has not retained any copies, abstracts, compilations, summaries 0r any other format reproducing or capturing any of the Confidential Materials. Notwithstanding this provision, Counsel are entitled to retain an archival copy 11 _-r\-r\ AnAn-u-‘fi-u np-nmvw-r A m1-1“ “n Amwmm" vr‘ Auhh“ A 1T AAr-Vv va-Ann A \DOOQQU‘I-PWNH NNNNNNNNNr-lr-‘HHHn-Hv-Ar-xr-t OOQQUI-bLRNr-‘OKOOOQQUI-hUJNHO 0f all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports. Any such archival copies remain subj ect to this protective order. 22. After this Stipulation and Protective Order has been signed by counsel for all Parties, it shall be presented to the Court for entry. Counsel agree to be bound by the terms set forth herein with regard to any Confidential Materials that have been produced before the Court signs this Stipulation and Protective Order. 23. The Parties and all signatories to the Certification attached hereto as Exhibit A agree to be bound by this Stipulation and Protective Order pending its approval and entry by the Court. In the event that the Court modifies this Stipulation and Protective Order, or in the event that the Court enters a different Protective Order, the Parties agree to be bound by this Stipulation and Protective Order until such time as the Court may enter such a different Order. It is the Parties’ intent to be bound by the terms of this Stipulation and Protective Order pending its entry so as to allow for immediate production of Confidential Materials under the terms herein. 24. Any Violation of this Order may be punished by appropriate measures including, Without limitation, contempt proceedings and/or monetary sanctions. This Stipulation and Protective Order may be executed in counterparts. Dated: July 16, 2021 LAW OFFICE OF TANYA GOMERMAN, APC m f, Ix By: Maria Bourn Michael Brooks Attorneys for Plaintiff JANE DOE Dated: July 23, 2021 SILICON VALLEY LAW GROUP K ~_ V Edward A. Kraus Kathryn E. Barrett Marc G. van Niekerk Attorneys for Defendant Albert J. Chavez 12 -“1‘ AnAAfiR-u nmmvfi .mn“ 1-.“Amflmm Ann-u-rn n ‘7 nnnvva-AAA . \DOOQQUILUJNH NNNNNNNNNHr-AHHp-HHHr-nr- OOQO‘xLJI-PUJNHOKOOOQQUI-PUJNr-‘O Dated: July 23, 2021 JACKSON LEWIS P.C. fig“ Tyler A. Brown Kate L. Brown Attorneys for Defendants RURAL/METRO OF CALIFORNIA, INC.; AMERICAN MEDICAL RESPONSE WEST; AMERICAN MEDICAL RESPONSE, INC.; and CHRISTOPHER GARVIN 13-nn Anr‘nwu-‘n nmm-rw-r . "uh“ ““Amw-«mmwv-uw Annh“ A ‘1- -nH-~-_-fifl . \OOOQQUI-PUJNr-A NNNNNNNNNr-tb-r-tp-tr-tr-IHr-Ar-lr-t OOflmUl-RUJNr-‘OKDOOQONUl-PWNb-‘O [PR ED] ORDER GOOD CAUSE APPEARING, the Court hereby approves this Stipulation and Protective Order. V IT IS SO ORDERED. K (9.1M S' d:7/27/202111:10AM iw-JU P‘ - ‘ Dated: 'gne THE HONORABLE 14 -1-‘1‘ Ahrxn-r-uh-I nmm-‘r-v-r A mfi“ 1x“ Arn-ufirwrn-rrvw Anhfi“ A \w- AAr‘v vn-Ann A \DOOflQUl-PUJNr-A NNNNNNNNNr-tr-tr-Ir-Ar-av-tr-Ir-tr-Ap-I WNQm-PWNflowOOQCNm-RWNF-‘O EXHIBIT A CERTIFICATION RE CONFIDENTIAL DISCOVERY MATERIALS I hereby acknowledge that I, [NAME], [POSITION AND EMPLOYER], am about t0 receive Protected Materials supplied in connection With the Proceeding Jane Doe v. Rural/Metro OfCalifornz'a, Ina, Case No. 20CV373984. I certify that I understand that the Protected Materials are provided to me subject to the terms and restrictions 0f the Stipulated Protective Order filed in this. Proceeding. Ihave been given a copy 0f the Stipulated Protective Order; I have read it, and I agree to be bound by its terms. I understand that Protected Materials, as defined in the Stipulated Protective Order, including any notes 0r other records that may be made regarding any such materials, shall not be Disclosed to anyone except as expressly permitted by the Stipulation. Iwill not copy or use, except solely for the purposes of this Proceeding, any Protected Materials obtained pursuant to this Stipulated Protective Order, except as provided therein or otherwise ordered by the Court in the Proceeding. I further understand that I am t0 retain all copies 0f all Protected Materials provided t0 me in the Proceeding in a secure manner, and that all copies 0f such Materials are t0 remain in my personal custody until termination of my pafiicipation in this Proceeding, whereupon the copies 0f such Materials will be returned to counsel who provided me With such Materials. I declare under penalty ofperjury, under the laws 0fthe State 0f California, that the foregoing is true and correct. Executed this day 0f , 2021, at (County and State). DATED: BY: Signature Title Address City, State, Zip Telephone Number 15-““ AnAn-v-v-x-I nmm-rv-r A r-n-u-vu‘ 1-.“ An-w-‘mrn-rv 11-1 A““fi“ A ‘v Anmv vn-nnn n QONUI-bUJN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF 0F SERVICE ICCP 8 1010.6(2), CRC Rule 2.253(b)(1)(A) and General LR 6] I, Fatimah Sikin, declare that I am employed with the law film of Jackson Lewis P.C., Whose address is 50 California Street, 9th Floor, San Francisco, California 941 1 1-4615; I am over the age of eighteen (1 8) years and am not a party t0 this action. On July 23, 2021, I caused to be e-served the attached [PROPOSED] STIPULATED PROTECTIVE ORDER in this action by uploading a true and correct copy thereof, in PDF format, for electronic filing and service by Express Network (a court-approved Electronic Filing Service Provider), pursuant t0 Local Rule 2.1 1. Said document to be filed with the Court and e-served 0n counsel 0f record, Whose contact information is as follows: Maria Bourn Attorney for Plaintiff Michael Brooks Law Office of Tanya Gomerman, APC JANE DOE 825 Van Ness Avenue, Suite 502 San Francisco, CA 94109 Tel. (415) 545-8608 Fax (855) 545-8608 Email: maria@attornevtanva.com Email: michael@attornevtanva.com Chan Phan Senior Paralegal Email: Chan@attornevtanva.com Edward A. Kraus Attorneys for Defendant Kathryn E. Barrett Marc G. van Niekerk ALBERT J. CHAVEZ Silicon Valley Law Group One North Market Street, Suite 200 San Jose, CA 951 13 Tel. (408) 573-5700 Fax (408) 573-5701 E-mail: eak@svlg.com E-mail: keb@svlg.com E-mail: mvn@svlg.com I declare under penalty of perjury, under the laws of the State of California, that the above is true and correct. Executed on July 23, 2021, at San Francisco, California. Fatimah Sikin Proof 0f Service Case No. 20CV373984
