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Burrows v. County of Los Angeles

December 17, 2009

STEPHEN BURROWS, WILLA BURROWS, AS INDIVIDUALS AND SUCCESSORS IN INTEREST TO STANTON W. BURROWS, PLAINTIFFS,
v.
COUNTY OF LOS ANGELES, JESUS MOJARRO, DANIEL ORT, W. FABIAN, TASER INTERNATIONAL, INC. AND DOES 4 THROUGH 10, DEFENDANTS.



The opinion of the court was delivered by: Honorable Andrew J. Wistrich

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 Plaintiffs are Stephen and Willa Burrows, the parents of Stanton W. Burrows. ("Plaintiffs," "Receiving Parties," or "Receiving Party").

2. County Defendants. The County Defendants are the County of Los Angeles, and Los Angeles County Sheriff's Department ("LASD") deputies W. Fabian, Jesus Mojarro and Daniel Ort. ("County Defendants" and/or "Disclosing Party;" Plaintiffs and Defendants are collectively referred to as the "Parties").

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

4. Case Summary. This case arises from the death of Stanton Burrows following an altercation with LASD deputies on or about June 6, 2008.

5. 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.

6. 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.

7. 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.

8. 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 Confidential Information is used, mentioned, reviewed, discussed, or referred to. The Confidential Information shall be subject to this Protective Order as follows:

9. Storage Of Confidential Information. Immediately upon production by the Disclosing Party, attorneys for Receiving Party shall personally secure and maintain the Confidential Information in their possession. The Confidential Information shall not, under any circumstances, be left in an open or unsecured location where unauthorized persons (such as unauthorized employees of counsel, cleaning personnel, etc.) might have access to them.

10. Confidential Information Legend. All documents containing Confidential Information shall be stamped "CONFIDENTIAL" or "CONFIDENTIAL -- SUBJECT TO PROTECTIVE ORDER" ...


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