STIPULATED PROTECTIVE ORDER AND ORDER NOTE CHANGES MADE BY THE COURT.
WHEREAS, the parties have met and conferred and wish to avoid a protracted discovery dispute concerning confidential recorded information. The parties have now agreed to the following protective order pertaining to certain Santa Ana Police Department confidential Internal Affairs recorded information consisting of three recorded interviews. These documents will be produced once the protective order is executed and are contained on one CD bate stamped SA0051.
IT IS HEREBY STIPULATED by and through undersigned counsel that:
1. Counsel for the parties and retained consultants and/or experts shall have sole custody and control over the CD of the confidential recorded information bate stamped SA0051 and produced by the City of Santa Ana.
2. These recorded information is deemed confidential, except to the extent set forth within the Order and shall be used solely in connection with this litigation and the preparation and trial of this case, or any related appellate proceedings, and not for any other purpose, including any other litigation, and may not be disclosed or disseminated to other persons, including any other counsel other than as set forth in paragraph 5 herein.
3. Counsel for the parties alone will have custody, control and access to the CD and the recorded information contained therein, and will be prohibited from releasing or disseminating it, or the information contained therein to other persons including legal counsel other than as set forth in paragraph 5 herein.
4. Counsel for the parties may make copies of the CD and/or prepare transcript of the information contained therein, but counsel will be prohibited from releasing or disseminating such copies or the information contained therein other than as set forth in paragraph 5 herein.
5. The CD and the recorded information contained therein may be disclosed only in the preparation of this action, subject to this stipulation and only to the persons identified in sections a through e listed below. Disclosure of the CD and the recorded information for purposes of trial or any appellate proceeding shall be taken up with the judicial officer(s) conducting that proceeding at the appropriate time. If dissemination under this section occurs, the disclosure shall be accompanied with a copy of this Protective Order and written instructions from counsel directing compliance with same:
a. Counsel and law office personnel for any party to this action including outside counsel assisting in the litigation of the matter;
b. Court personnel including stenographic reporters engaged in such proceedings as are necessarily incident to preparation for trial in this action;
c. Any outside expert or consultant specifically retained and used in connection with this action;
d. Any "in-house" experts designated by the parties to testify at trial in this matter:
e. Any party to this action, however, counsel will maintain custody of the CD produced by the City of Santa Ana and no such copy will be turned over to the possession of the individual parties.
6. Nothing in this Protective Order is intended to prevent officials or employees of the City of Santa Ana or other authorized government officials from having access to the documents as they would have had access in the normal course of their job duties.
7. At the conclusion of the trial of any appeal, or upon other termination of this litigation, the CD produced by the City of Santa Ana and bate stamped as SA0051 (including any copies made or transcripts of the recorded information) shall ...