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Rickley v. County of Los Angeles

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 ...


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