The opinion of the court was delivered by: Claudia Wilken
STIPULATED PROTECTIVE ORDER FOR CONFIDENTIAL OFFICIAL INFORMATION Date Action Filed: April 18, 2005 Trial Date: February 12, 2007.
Plaintiff Andrew Marconi has requested Defendants make available for inspection and copying certain documents that Defendants assert are confidential, private, privileged and protected from public disclosure under California and federal law.
During this action, with respect to any information, documents, or things obtained by any Party to this action in response to any discovery where such items are asserted to contain or comprise confidential information, including information protected by the right to privacy or other applicable privileges and protections, the following procedures shall be employed and the following restrictions shall govern:
It is the purpose of this Protective Order to allow the Parties to have reasonable access to information from all other Parties while protecting the confidential and/or private status of that information without frequent resort to determinations of discoverability by the Court.
2.1 Party. "Party" means any of the parties in these actions.
2.2 Discovery Material. "Discovery Material" means any information, document, or tangible thing upon which any expression, communication or representation has been recorded by any means, or response to any discovery request, including by way of example document requests, interrogatories, requests for admissions, notices of deposition, requests to inspect, and any other similar materials, or portions thereof.
2.3 Confidential. "Confidential" information is defined herein as information which has not been made public, the disclosure of which the disclosing party contends could violate the privacy rights and/or confidentiality concerns of the disclosing party including, but not limited to, personal financial information and employment or personnel information.
2.4 Confidential -- Attorneys' Eyes Only. "Confidential -- Attorneys' Eyes Only" information is defined herein as "Confidential" information which a disclosing party has reasonable grounds to believe would, if known to persons other than the Parties counsel, counsel's staff or experts or consultants retained by the Parties' Counsel to assist in the evaluation, preparation, or trial of this case, lead to a significant possibility of violation of the privacy rights and/or confidentiality concerns of the disclosing party including, but not limited to, personal financial information and employment or personnel information.
2.5 Protected Material. Protected Material is defined herein as any discovery material that has been marked "Confidential" or "Confidential -- Attorneys' Eyes Only" pursuant to this Order.
2.6 The parties agree that for the purposes of this order that the following documents are privileged:
- Office of Citizen Complaint records, including complaints and witness lists
- Personnel records for any officer of the San Francisco Police Department, including those of Jason Fox, ...