On July 07, 2020 a
Stipulation,Agreement
was filed
involving a dispute between
Estate Of Moises Hernandez, Sr., By And Through Its Successor In Interest Justine,
Guillen, Yadira,
Hernandez Jr., Moises,
Hernandez, Justine,
Hernandez Moreno, Jesus Alberto,
Hernandez Moreno, Mayra Candelaria,
and
Apostolic Assembly Of The Faith In Christ Jesus, A California Corporation,
San Diego Gas & Electric Company A California Corporation,
Sempra Energy A California Corporation,
for PI personal injury not MV
in the District Court of San Bernardino County.
Preview
SUP
figifihlfigggggiggf“ PALIFOQEHA
G REENE B ROILLET & W HEELER, LLP (SPA 'fi
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LAWYERS
222 N. PACIFIC COAST HIGHWAY, SUITE 2100
P.o. Box 955
EL SEGUNDO, CALIFORNIA 90245 AUG 1 5 2022
TEL‘ (310) 576-1200
FAX. (310) 576-1220
ROBERT D. JARCHI, State Bar No. 204168 (rjarchi@gbw.lfig~\%fi
CHRISTIAN T. F. NICKERSON, State BarNo. 281084 (cnic eWgM HAPA, 0mm
Attorneysfor Plaintiffs
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
10 f‘ L. ,
l,
11 ESTATE OF MOISES HERNANDEZ, SR., by CASE NO. CIVDSZOI4862
and through its successor in interest JUSTINE [AssignedforAll Purposes t0 Hon. Brian S.
12 HERNANDEZ; JUSTINE HERNANDEZ, an McCarville, Dept. S30]
individual; MOISES HERNANDEZ, JR., an
13 individual; YADIRA GUILLEN, an individual; (Complaint Filed: July 7, 2020)
MAYRA CANDELARIA HERNANDEZ
14 MORENO, an individual; JESUS ALBERTO STIPULATION AND PROTECTIVE
HERNANDEZ MORENO, an individual, ORDER RE DOCUMENTS MARKED
CON IDENTIAL
Plaintiffs,
16
VS.
£w 4757a
17
SAN DIEGO GAS & ELECTRIC COMPANY,
18 a California Corporation; SEMPRA ENERGY,
a California Corporation; and APOSTOLIC
19 ASSEMBLY OF THE FAITH IN CHRIST
JESUS, a California Corporation, dba North
20 Coast Fellowship; and DOES 1 through 100,
inclusive,
21
Defendants.
22
23
24 IT IS HEREBY STIPULATED by and between the parties to Estate of Moises
25 Hernandez, Sr., et al. vs. San Diego Gas & Electric Company, et al, Case No. CIVD82014862
26 (“Patties”), by and through their respective counsel of record, that in order to facilitate the
27 exchange of documents, which may be subject to confidentiality limitations on disclosure, the
28 Parties stipulate as follows:
_ 1
_
Hernandez Protective Order
1. In this Stipulation and Protective Order, the words set forth below shall have the
following meanings:
a. “Proceeding” means the above—entitled proceeding Case No.
CIVD82014862.
b. “Court” means the Hon. Brian S. McCarville 0r any other judge t0 which
this Proceeding may be assigned, including Court staff participating in such proceedings.
c. “Confidential” and Confidential Materials means information in the
possession 0f a Designating Party, which believes in good faith contain information that is
entitled t0 confidential treatment under applicable law 0r that contains such other trade secrets,
10 proprietary, confidential 0r competitively sensitive business information that is not publicly
11 available.
LLP
12 d. “Designating Party” means the Party that designates the Documents,
WHEELER,
90245
13 Testimony, or Information, as defined below, as “Confidential.”
955
CA
14 e. “Disclose” 0r “Disclosed” 0r “Disclosure” means to reveal, divulge, give,
&
BOX
BROILLET
O SEGUNDO,
15 or make available Materials, or any part thereof, 0r any information contained therein.
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EL
16 f. “Documents” means (i) any “Writing,” “Original,” and “Duplicate” as
GREENE
17 those terms are defined by California Evidence Code Sections 250, 255, and 260, which have
18 been produced in discovery in this Proceeding by any person 0r entity, and (ii) any copies,
19 reproductions, or summaries of all or any part 0f the foregoing.
20 g. “Information” means the content 0f Documents or Testimony.
21 h. “Testimony” means all depositions, declarations, or other testimony taken
22 or used in this Proceeding.
23 2. It is understood by the parties that the only documents or information that a
24 Designating Party will designate as “Confidential” pursuant to this protective order will be good
25 faith believed t0 be confidential, and not public documents or documents shared with third
26 parties.
27 3. The entry of this Stipulation and Protective Order does not alter, waive, modify, or
28 abridge any right, privilege, or protection otherwise available to any Party with respect to the
- 2 _
Hernandez Protective Order
Preview
SUP figifihlfigggggiggf“ PALIFOQEHA G REENE B ROILLET & W HEELER, LLP (SPA 'fi WK ‘ ‘l ‘ ’~ L'géflMSIQN LY) LAWYERS 222 N. PACIFIC COAST HIGHWAY, SUITE 2100 P.o. Box 955 EL SEGUNDO, CALIFORNIA 90245 AUG 1 5 2022 TEL‘ (310) 576-1200 FAX. (310) 576-1220 ROBERT D. JARCHI, State Bar No. 204168 (rjarchi@gbw.lfig~\%fi CHRISTIAN T. F. NICKERSON, State BarNo. 281084 (cnic eWgM HAPA, 0mm Attorneysfor Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 10 f‘ L. , l, 11 ESTATE OF MOISES HERNANDEZ, SR., by CASE NO. CIVDSZOI4862 and through its successor in interest JUSTINE [AssignedforAll Purposes t0 Hon. Brian S. 12 HERNANDEZ; JUSTINE HERNANDEZ, an McCarville, Dept. S30] individual; MOISES HERNANDEZ, JR., an 13 individual; YADIRA GUILLEN, an individual; (Complaint Filed: July 7, 2020) MAYRA CANDELARIA HERNANDEZ 14 MORENO, an individual; JESUS ALBERTO STIPULATION AND PROTECTIVE HERNANDEZ MORENO, an individual, ORDER RE DOCUMENTS MARKED CON IDENTIAL Plaintiffs, 16 VS. £w 4757a 17 SAN DIEGO GAS & ELECTRIC COMPANY, 18 a California Corporation; SEMPRA ENERGY, a California Corporation; and APOSTOLIC 19 ASSEMBLY OF THE FAITH IN CHRIST JESUS, a California Corporation, dba North 20 Coast Fellowship; and DOES 1 through 100, inclusive, 21 Defendants. 22 23 24 IT IS HEREBY STIPULATED by and between the parties to Estate of Moises 25 Hernandez, Sr., et al. vs. San Diego Gas & Electric Company, et al, Case No. CIVD82014862 26 (“Patties”), by and through their respective counsel of record, that in order to facilitate the 27 exchange of documents, which may be subject to confidentiality limitations on disclosure, the 28 Parties stipulate as follows: _ 1 _ Hernandez Protective Order 1. In this Stipulation and Protective Order, the words set forth below shall have the following meanings: a. “Proceeding” means the above—entitled proceeding Case No. CIVD82014862. b. “Court” means the Hon. Brian S. McCarville 0r any other judge t0 which this Proceeding may be assigned, including Court staff participating in such proceedings. c. “Confidential” and Confidential Materials means information in the possession 0f a Designating Party, which believes in good faith contain information that is entitled t0 confidential treatment under applicable law 0r that contains such other trade secrets, 10 proprietary, confidential 0r competitively sensitive business information that is not publicly 11 available. LLP 12 d. “Designating Party” means the Party that designates the Documents, WHEELER, 90245 13 Testimony, or Information, as defined below, as “Confidential.” 955 CA 14 e. “Disclose” 0r “Disclosed” 0r “Disclosure” means to reveal, divulge, give, & BOX BROILLET O SEGUNDO, 15 or make available Materials, or any part thereof, 0r any information contained therein. P EL 16 f. “Documents” means (i) any “Writing,” “Original,” and “Duplicate” as GREENE 17 those terms are defined by California Evidence Code Sections 250, 255, and 260, which have 18 been produced in discovery in this Proceeding by any person 0r entity, and (ii) any copies, 19 reproductions, or summaries of all or any part 0f the foregoing. 20 g. “Information” means the content 0f Documents or Testimony. 21 h. “Testimony” means all depositions, declarations, or other testimony taken 22 or used in this Proceeding. 23 2. It is understood by the parties that the only documents or information that a 24 Designating Party will designate as “Confidential” pursuant to this protective order will be good 25 faith believed t0 be confidential, and not public documents or documents shared with third 26 parties. 27 3. The entry of this Stipulation and Protective Order does not alter, waive, modify, or 28 abridge any right, privilege, or protection otherwise available to any Party with respect to the - 2 _ Hernandez Protective Order