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Fuentes v. County of Los Angeles

October 6, 2009

LUZ FUENTES, ETC., PLAINTIFFS,
v.
COUNTY OF LOS ANGELES; ET AL., DEFENDANTS.
LUZ FUENTES, ET AL., PLAINTIFFS,
v.
WARDEN HAWS, ET AL., DEFENDANTS.



The opinion of the court was delivered by: Hon. Suzanne H. Segal

DISCOVERY MATTER

PROTECTIVE ORDER

Having reviewed and considered the Parties' Stipulation For Protective Order, good cause showing therein, IT IS SO ORDERED:

I. INTRODUCTION AND STATEMENT OF GOOD CAUSE.

1. Plaintiff. The Plaintiff in this action is Luz Fuentes ("Plaintiff" and/or "Receiving Party"), the mother of Decedent Jose Daniel Cruz, aka, Jose Daniel Cruz Fuentes, Edgar Jimenez, and Jose Garcia ("Decedent").

2. State Defendants. The State Defendants are the State of California employees S. Mohr, G. Hing and F. Haws ("State Defendants").

3. County Defendants. The County Defendants are the County of Los Angeles, Los Angeles County Sheriff Leroy Baca, Assistant Sheriff Marvin O. Cavanaugh, Chief Mark L. Klugman, Chief Sammy L. Jones, Robert Fish, Ph.D., Chief Neal Tyler, Commander Carl Deeley and Sergeant Dan Belland ("County Defendants" and/or "Disclosing Party;" Plaintiffs and Defendants are collectively referred to as the "Parties").

4. Receiving Parties. The Receiving Parties shall refer to all Parties receiving information from the County Defendants pursuant to this protective order.

5. Case Summary. This case arises from inmate Kurt Karcher's altercation with Decedent, his cellmate in Defendant County's jail, in or around May 2007. Decedent died in or about June 2007.

6. Good Cause Statement. The Parties anticipate that during discovery in this action they will exchange documents, items, or materials and other information that contain sensitive and confidential information that derives actual or potential value from not being generally known to the public and are the subject of reasonable efforts to maintain their secrecy and confidentiality ("Confidential Information"). Confidential Information includes the County jail custody records of third-party-inmate Kurt Karcher and homicide investigations relating to Mr. Karcher. Such information is subject to the official information privilege, the right to privacy guaranteed in Federal Constitution, First Amendment and California Constitution, Article I, Section I, and various California Government, Penal, and Evidence Code sections, and thus protected from disclosure. Further, the underlying criminal case is currently being prosecuted against Mr. Karcher.

7. Interests In Favor Of Protective Order. This order is necessary to expedite discovery, while maintaining confidential and private information of inmate Kurt Karcher and contained in the homicide investigations that serve as the bases if this action, and to protect parties or persons from annoyance, embarrassment, oppression, or undue burden or expense. Further, disclosure of such information without a protective order may compromise the safety third parties.

8. Stipulation. The Parties are entering into this Stipulated Protective Order to protect against any improper disclosure or risk of circumvention of law that might result from disclosure of sensitive and confidential law enforcement information as described in this Order. To informally resolve this discovery matter, the Parties have agreed to this stipulated protective order that carefully limits the use and dissemination of the Confidential Information.

II. USE AND DISSEMINATION OF THE CONFIDENTIAL INFORMATION.

9. Confidential Information. This protective order shall apply to all Confidential Information, produced by The County Defendants to the Parties. The Confidential Information shall include, but not be limited to, originals and copies of relevant interrogatory responses obtained from the County Defendants in this matter; all originals and copies of relevant documents responsive to the Parties' requests for production of documents obtained from the County Defendants in this matter; and all originals and copies of transcripts, video recordings, and audio recordings of any deposition taken in this matter during which the ...


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