The opinion of the court was delivered by: Honorable Paul L. Abrams
NOTE CHANGES MADE BY THE COURT (see pages 7 and 8)
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 Plaintiffs are Carolina Crespo Silva, the wife of Cesar Silva,
2. Plaintiff. and Eileen Martinez, as Guardian Ad Litem for D.M., a minor (collectively, "Plaintiffs," "Receiving Parties," or "Receiving Party").
3. County Defendants. The County Defendants are the County of Los Angeles, and Los Angeles County Sheriff's Department ("LASD") deputies Casey Dowling, Armando Orellana, Guillermo Sanchez, John Spiropoulos, and Sal Stewart ("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 the death of Cesar Silva following an altercation with LASD deputies on or about November 20, 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 private medical records and various records subject to the Health Insurance Portability and Accountability Act, the Confidentiality of Medical Information Act, 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.
7. Interests In Favor Of Protective Order. This order is necessary to expedite discovery, while maintaining confidential and private information of defendants, 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 ...