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Barnes v. City of Pasadena

April 19, 2010

MAYLEISHA BARNES; DETRICK BRIGHT GUARDIAN AD LITEM FOR ANARI BARNES; ESTATE OF LEROY BARNES, PLAINTIFFS,
v.
CITY OF PASADENA; UNIDENTIFIED POLICE OFFICERS NO. 1 AND NO. 2; DOES 1 THROUGH X, DEFENDANTS.



The opinion of the court was delivered by: Magistrate Judge Patrick J. Walsh

NOTE: CHANGES MADE BY THE COURT

STIPULATION AND PROPOSED PROTECTIVE ORDER

STIPULATION

Plaintiffs MAYLEISHA BARNES, DETRICK BRIGHT guardian ad litem for ANARI BARNES, ESTATE OF LEROY BARNES and Defendants CITY OF PASADENA, and its Officers by and through their undersigned counsel of record, and subject to the approval of the Court, stipulate to the following Protective Order as set forth below:

1. In connection with any discovery proceedings in this action, the parties may agree or the Court may direct that the identity of any document, thing, material, testimony or other information derived there from, be designated as "Confidential" under the terms of this Stipulated Protective Order ("Order"). Confidential information is information which has not been made public and is privileged and confidential and protected from public disclosure under applicable Federal or California State law.

2. Confidential documents shall be so designated by stamping copies of the document produced to a party with the legend "CONFIDENTIAL." Stamping the legend "CONFIDENTIAL" on the cover of any multi-page document shall designate all pages of the document as confidential, unless otherwise indicated by the producing party.

3. Material designated as Confidential under this Order, the information contained therein, and any summaries, copies, abstracts, or documents derived in whole or in part from material designated as Confidential shall be used only for the purpose of the prosecution, defense, or settlement of this action and for no other purpose.

4. For purposes of this Agreement, the term "Confidential" shall be deemed to apply to all documents not publicly disclosed prior to the execution of the protective order in the possession or control of the City of Pasadena and/or Plaintiffs concerning or related to the shooting of Leroy Barnes, on or about February 19, 2009 and to the personnel and Police Department records of the officers responding thereto.

5. Confidential material produced pursuant to this Order may be disclosed or made available only to the Court, to counsel for a party (including the paralegal, clerical, and secretarial staff employed by such counsel) and to the "qualified persons" designated below:

a. Experts or consultants (together with their clerical staff) retained by such counsel to assist in the prosecution, defense or settlement of this action;

b. Court reporters employed in this action;

c. A witness at any deposition or proceedings in this action who is approved to review confidential material by all counsel in writing;

d. Parties to the action; and

e. Any other person as to whom the parties ...


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