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Dominguez v. Los Angeles County

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION


August 7, 2009

JONATHAN DOMINGUEZ, A MINOR, BY AND THROUGH HIS GUARDIAN AD LITEM, CECILIA DOMINGUEZ; JAMES FLORES A MINOR, BY AND THROUGH HIS GUARDIAN AD LITEM, MELISA HERNANDEZ; JEFFREY FUNES; DANIEL GONZALEZ, PLAINTIFFS,
v.
LOS ANGELES COUNTY; CHARLES MC DANIEL; GILES WRIGHT; LIEUTENANT CLAUS; LEROY BACA AND DOES 1-50, DEFENDANTS.

The opinion of the court was delivered by: Judge Manuel L. Real

Case Filed: 12/24/08

PROTECTIVE ORDER REGARDING PRODUCTION OF DOCUMENTS BY DEFENDANT COLA

Trial Date: 10/20/09

PROTECTIVE ORDER

IT IS HEREBY ORDERED as follows:

1. That the information contained in the documents or items produced by defendant County of Los Angeles ("COLA") in response to plaintiff's Request for Production, Set One, may contain privileged, proprietary and/or confidential official information. Specifically, this protective order protects the following documents and information defendants will produce to plaintiff:

(1) Documents in the Internal Affairs Bureau ("IAB") investigative file relating to the subject incident.

These documents shall not be divulged: (1) to any expert witness retained by the non-producing party or its attorney who has not signed the "Agreement to Be Bound by Protective Order," attached hereto as Exhibit "A"; or (2) to any third party who is not directly involved in the above-entitled action, without the written consent of the parties or the attorneys for the parties or further order of this court.

2. Working copies or file copies of documents or items containing such privileged, proprietary and/or confidential information produced pursuant to this Protective Order during discovery can be made for: (1) the attorneys (including paralegals, law clerks or other support personnel necessary for preparation of the case) for the parties; (2) the parties themselves; (3) experts retained by the opposing party to whom disclosure is reasonably necessary for this litigation and who have agreed in writing to be bound by this Protective Order by signing the "Agreement to Be Bound by Protective Order," attached hereto as Exhibit "A"; or (4) other persons who have agreed in writing to be bound by this Protective Order by signing the "Agreement to Be Bound by Protective Order," attached hereto as Exhibit "A". These copies are to be used exclusively in connection with the above-captioned action. Any copies or other methods of reproduction of the documents or items made pursuant to this Order shall be stored and/or handled by the above-listed persons in a manner which will prevent the unauthorized disclosure thereof.

3. Documents or items containing such privileged, proprietary and/or confidential information pursuant to this Protective Order which pertain to information exchanged in discovery and other proceedings before the Magistrate Judge and are used as deposition exhibits, or in other discovery and/or pre-trial motions involving discovery shall be marked "privileged and confidential." Any portion of a deposition transcript filed or lodged with the Court in connection with discovery or other proceedings before the Magistrate Judge containing proprietary and/or confidential information or items as an exhibit shall be filed and/or lodged under seal pursuant to paragraph 5, absent an order of the court providing otherwise.

4. Documents containing privileged, proprietary and/or confidential information or items pursuant to this Protective Order shall not be used by the parties hereto for any purpose whatsoever other than for preparation for trial and/or trial of the above-captioned action.

5. If any of the documents designated as privileged, proprietary and/or confidential pursuant to this Protective Order which pertain to information exchanged in discovery and other proceedings before the magistrate judge are filed and/or lodged with the court, counsel for the respective parties are directed to file and/or lodge such documents pursuant to Local Rule 79-5 of the United States District Court, Central District of California.

6. Each expert, agent, representative or consultant who is permitted by any attorney for the parties to view, examine, scan or otherwise inspect the documents containing privileged, proprietary and/or confidential information or items pursuant to this Protective Order shall agree in writing to be bound by this Protective Order by signing the "Agreement to Be Bound by Protective Order," attached hereto as Exhibit "A". A copy of this Protective Order shall be delivered to each of the above-listed persons by the attorneys for the parties.

7. No party to this action or experts retained by the parties or agents or representatives of the parties, other than attorneys to the parties, will make copies or other types of reproductions, other than working copies or file copies for the persons described in paragraph 2, of any document or item containing proprietary and/or confidential information made or produced pursuant to this Protective Order.

8. That all documents or items produced by the parties pursuant to this Protective Order, and any copies, lists or summaries thereof, shall be returned to the party who produced such documents or items after trial and/or other final resolution of the above-entitled action, unless these documents or items are introduced as evidence or exhibits at the time of trial.

9. Documents or items containing privileged, proprietary and/or confidential information produced pursuant to this Protective Order apply to information exchanged in discovery and other proceedings.

APPROVED AND SO ORDERED:

JUDGE MANUEL L. REAL U. S. DISTRICT

EXHIBIT "A"

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, _________________________________________, hereby acknowledge that I have read in its entirety and understand the stipulated Protective Order that was issued by the United States District Court for the Central District of California in the case of J.D. et. al v. Los Angeles County et. al, Central District of California (Western Division -- Los Angeles), Case No. CV08-08456 R (SHx). I understand the provisions prohibiting the disclosure of confidential information produced pursuant to the Protective Order for any purpose or in any manner not connected with the prosecution or defense of this action and I agree to be bound by all provisions of that Order.

Date: ________________________ Signature: ____________________________

Print Full Name and Address: __________________________________________

20090807

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