Martel

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

JOSEPH MARTIN DANKS, Case No. 1:11-cv-00223-JLT

Petitioner, DEATH PENALTY CASE

v. STIPULATED PROTECTIVE ORDER

RON BROOMFIELD, Warden of California State Prison at San Quentin, 15 Respondent.1 16 Petitioner JOSEPH MARTIN DANKS and Respondent RON BLOOMFIELD, as Warden of the California State Prison at San Quentin, by and through their counsel of record, stipulate that a protective order may be entered by the Court as follows (see Doc. 87): The parties agree that, to adequately litigate claims in the operative 28 U.S.C. § 2254 habeas corpus petition (Doc. 28), Respondent requires access to certain documents filed under seal in state court which are pending a sealing request in this proceeding (Doc. 86), viz. portions of sealed state Reporter’s Transcripts which intrude upon matters heretofore protected by the attorney-client and attorney work product privileges. These Transcripts relate to state court proceedings conducted pursuant to People v.…