The opinion of the court was delivered by: Hon. Judge Stephen V. Wilson
PROTECTIVE ORDER RE CONFIDENTIAL INFORMATION AND DOCUMENTS
UPON JOINT STIPULATION AND MOTION OF THE PARTIES TO THE ABOVE-TITLED ACTION, AND GOOD CAUSE APPEARING THEREIN,
IT IS HEREBY ORDERED THAT the following terms and conditions shall apply in the above-titled action:
1. Defendant CITY OF REDONDO BEACH will identify and designate those documents responsive to plaintiff's request that defendant CITY OF REDONDO BEACH wishes to have covered by this Stipulation and Protective Order. Plaintiff will honor that designation, subject to paragraph 7 of this Stipulation and Protective Order. The parties request that any documents subject to the Court's production order be subject to the terms of paragraphs 12 through 24 of this Stipulation and Protective Order.
2. Plaintiff's counsel shall have sole custody and control over the documents identified in paragraph 1;
3. Documents set forth in paragraph 1 are deemed confidential, except to the extent set forth in this Stipulation and Order, and shall be used solely in connection with this above-titled litigation and the preparation and trial of this case, or any related appellate proceedings, and not for any other purpose, including any other litigation, and may not be disclosed or disseminated to any other persons, including to any other counsel other than as set forth herein;
4. Plaintiff's counsel alone will have custody, control and access to the documents, reports and writings, and will be prohibited from releasing or disseminating the reports or files, or the information contained within the reports or files, to other persons - including but not limited to legal counsel - other than as set in paragraph 16 herein;
5. Plaintiff's counsel may make copies of the reports and files, but plaintiff's counsel will be prohibited from releasing or disseminating such copies or the information contained within such copies other than as set forth herein;
6. The documents identified in paragraph 1 may be submitted in all law and motion proceedings up to the commencement of trial if done so pursuant to Local Rule 79-5 which states:
Except when authorized by statute or federal rule, no case or document shall be filed under seal without prior approval by the Court. Where approval is required, a written application and a proposed order shall be presented to the judge along with the document submitted for filing under seal. The proposed order shall address both the sealing of the application and order itself, if appropriate. The original and judge's copy of the document shall be sealed in separate envelopes with a copy of the title page attached to the front of each envelope. Conformed copies need not be placed in sealed envelopes. Where under-seal filings are authorized by statute or rule, the authority therefor shall appear on the title page of the proposed filing.
The parties agree to seek guidance from the Court at the time of trial regarding the procedure for lodging or filing of these documents under seal should plaintiff seek to submit or use the documents identified in Paragraph 1 as exhibits. Though this Stipulation and [Proposed] Protective Order does not apply to the handling of documents as exhibits after the commencement of trial, plaintiff agrees to not file or lodge the documents with the Court until the guidance from the Court on this issue is obtained.
7. All disputes regarding this Protective Order shall be handled pursuant to Local Rule 37. Plaintiff's counsel will advise defense counsel if they believe that any document(s) designated as confidential pursuant to this Stipulation and Order do(es) not warrant such designation. The parties will attempt to resolve the issue pursuant to Local Rule 37 before submitting the issue to the Court. However, the parties will continue to treat the document(s) at issue as confidential and subject to this Stipulation and Protective Order until the Court rules upon the dispute.
8. The documents covered by this Stipulation and Order may be disclosed only to ...