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Rickley v. County of Los Angeles

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION


February 6, 2009

REBECCA A. RICKLEY, PLAINTIFF,
v.
COUNTY OF LOS ANGELES, WILLIAM HOWARD, KEVIN PETROWSKY, SOHEILA KALHOR, MICHAEL TRIPP, RAJESH PATEL AND DOES 2 THROUGH 20, INCLUSIVE, DEFENDANTS.

The opinion of the court was delivered by: Honorable Alicia G. Rosenberg United States Magistrate Judge

PROTECTIVE ORDER REGARDING PERSONNEL FILES; EXHIBIT A

Pursuant to the Stipulation for Protective Order Relating to Personnel Files, IT IS HEREBY ORDERED: All documents in the personnel files being produced by the County of Los Angeles relating to Defendants Kevin Petrowsky, Michael Tripp and Soheila Kalhor will be held confidential by Plaintiff, subject to the terms and conditions of the Stipulation executed by Counsel of Record for the Parties and attached hereto as Exhibit A.

[Proposed] Protective Order submitted concurrently

Hon. Stephen V. Wilson

EXHIBIT A

WHEREAS, Plaintiff Rebecca A. Rickley served a Notice of Taking Deposition and Demand to Produce Documents in this action on Defendants Kevin Petrowsky, Michael Tripp, and Sohelia Kalhor ("County Individual Defendants") seeking various documents including their respective personnel records.

WHEREAS, the County of Los Angeles has firm policies restricting access to personnel files. Pursuant to these policies, only County management, not individual employees, may exercise custody or control over personnel files. Therefore, the County Individual Defendants initially objected to Plaintiff's requests for production of these documents. Subsequently, the parties have met and conferred over this issue.

WHEREAS, in an effort to resolve this dispute, the County of Los Angeles will agree to provide copies of the personnel files for Defendants Petrowsky, Tripp and Kalhor subject to agreement by Plaintiff to the terms of this Stipulation for Protective Order. All personal information in the personnel files has been redacted and certain documents which contain solely personal information have been withheld (i.e., medical records, home phone numbers, social security data, etc.) because this information is privileged and confidential and because it was specifically excluded from the document requests.

NOW, THEREFORE, IT IS HEREBY STIPULATED and agreed by and between Plaintiff Rebecca A. Rickley, and County Individual Defendants Kevin Petrowsky, Michael Tripp, and Sohelia Kalhor, through their counsel of record, that a Protective Order may be entered in the above-captioned action.

A. The following definitions apply herein:

1. "Personnel files" shall mean those official files maintained by the Human Resources Department of the County of Los Angeles for employees Kevin Petrowsky, Michael Tripp, and Sohelia Kalhor and which contain official information relating to their employment with the County.

2. "Party" means a named party to this action.

3. "Counsel of Record" means the attorneys and law firms which have formally appeared as counsel of record for any Party, including all attorneys, paraprofessionals, clerks and secretaries associated with or employed by such attorneys and law firms.

4. "Expert/Consultant" means any person hired to assist a Counsel of Record in the litigation or trial of this action, including that person's partners, associates and staff.

B. All documents in the personnel files of Kevin Petrowsky, Soheila Kalhor and Michael Tripp being produced by the County of Los Angeles will be held confidential by Plaintiff, subject to the terms of this Stipulation for Protective Order and the Protective Order submitted concurrently herewith.

C. All documents produced pursuant to this Stipulation and the Protective Order shall be used solely in connection with this litigation and the preparation and trial of this case, or any related appellate proceeding, and not for any other purpose, including any other litigation. Copies of these documents will not be made without the express written consent of the County Individual Defendants Kevin Petrowsky, Michael Tripp, and Soheila Kalhor.

D. All documents produced pursuant to this Stipulation and the Protective Order may be disclosed only to the following persons:

1. Counsel of Record;

2. Court personnel including stenographic reporters engaged in such proceedings as are necessarily incidental to preparation for the trial of this action;

3. Experts/consultants; and

4. Witnesses may have the documents disclosed to them during deposition proceedings; the witnesses may not leave the deposition with copies of the documents and shall be bound by the provisions of this Stipulation and the Protective Order.

E. Each person to whom disclosure is made, with the exception of Counsel of Record who are presumed to know of the contents of this Stipulation and the Protective Order, shall prior to the time of disclosure be provided by the person furnishing him/her such material a copy of the Protective Order and shall agree on the record or in writing that he/she has read and will abide by this Stipulation and the Protective Order. Unless made on the record in this litigation, counsel making the disclosure to any person described above shall retain the original executed copy of said agreement until final termination of this litigation.

F. Provisions of this Stipulation and the Protective Order insofar as they restrict disclosure and use of the material shall be in effect until further order of this Court.

G. This Stipulation and the Protective Order shall not affect the right of any Party to object to the production of any documents provided pursuant to the Protective Order or to demand more stringent restrictions upon the treatment and disclosure of any documents or materials, on the ground that such documents or materials contain particularly sensitive information, or otherwise.

H. At the conclusion of this litigation, all copies of documents produced pursuant to this Stipulation and Protective Order will be destroyed.

I. This instrument may be signed in counterparts and shall become effective upon signature by Counsel of Record for the Parties hereto. A signature on a faxed or emailed signature page shall have the same effect as an original signature.

IT IS SO STIPULATED.

20090206

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