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Ivan E. Henriquez v. City of Los Angeles

December 8, 2010

IVAN E. HENRIQUEZ, PLAINTIFF,
v.
CITY OF LOS ANGELES, LOS ANGELES POLICE DEPARTMENT, CHIEF OF POLICE CHARLIE BECK, OFFICERS JUAN ROTHEMICH AND PAUL FEDYNICH AND DOES 1 THROUGH 50, INCLUSIVE. DEFENDANTS



STIPULATION PROTECTIVE ORDER RE PRIVILEGED DOCUMENTS AND THINGS TO THE HONORABLE MAGISTRATE JUDGE:

Plaintiff IVAN HENRIQUEZ, by and through his attorneys of record, Lisa Holder and Christopher Canlas, and Defendants CITY OF LOS ANGELES, LOS ANGELES POLICE DEPARTMENT, CHIEF CHARLIE BECK, JUAN BARRILLAS, NICHOLAS ROTHEMICH AND PAUL FEDYNICH (hereinafter referred to as "Defendants"), by and through their attorneys of record, Carmen A. Trutanich, City Attorney, Cory M. Brente, Supervising Assistant City Attorney, and Elizabeth T. Fitzgerald, Deputy City Attorney, HEREBY STIPULATED AND AGREED between the parties hereto, by their undersigned counsel of record, that the following Protective

Order, and its terms shall govern the following documents and things in this matter: This Protective Order concerns the disclosure and/or ordered production of any and all documents and things which are believed by Defendants, in good faith, to be privileged, confidential, private or sensitive. This Protective Order is intended to cover documents and things disclosed pursuant to discovery, stipulation or court order. The Court orders as follows:

TERMS OF THE PROTECTIVE ORDER

1. Defendants and Plaintiffs have agreed that the below-listed documents shall be designated confidential documents and/or writings because Defendants believe, in good faith, that these documents and/or writings are privileged, confidential, private or sensitive nature. This will be accomplished by affixing to such document or writing a legend, such as "Confidential," "Confidential Documents," "Confidential Material Subject to Protective Order" or words of similar effect. Documents and writings so designated, and all information derived therefrom (hereinafter, collectively, "Confidential Information"), shall be treated in accordance with the terms of this stipulation/protective order. Documents, writings and things to be designated as such, include and are not limited to the following:

Any LAPD Internal Affairs and/or Professional Standards and/or Force Investigation Division investigation files including but not limited to, tape recorded interviews, compelled statements of police officers, complainants, and other witnesses, and supporting documentation.

2. Confidential Information may be used by the persons receiving such information [hereinafter "Receiving Party(ies)"] only for the purpose of this above-captioned litigation.

3. Subject to the further conditions imposed by this stipulation/protective order, Confidential Information may be disclosed only to the following persons:

a. Counsel for Plaintiff and to experts, investigators, paralegal assistants, office clerks, secretaries and other such personnel working under their supervision.

b. Such other parties as may be agreed by written stipulation among the parties hereto, or by Court Order.

4. Prior to the disclosure of any Confidential Information to any person described in paragraph 3(a), or 3(b), counsel for the Receiving Party who seeks to use or disclose such Confidential Information shall first provide a copy of this Stipulation and have the individual to whom the Receiving Party intends to disclose said Confidential Information sign a nondisclosure agreement, stating that the person has received and read a copy of the Stipulation and understands that s/he is bound by the terms of the Stipulation in substantially the form set forth below:

A. I understand that I am being given access to Confidential Information pursuant to the foregoing Stipulation and Order. I have read the Stipulation and Order and agree to be bound by its terms with respect to the handling, use, and disclosure of such Confidential Information.

Dated:

Signed:

Counsel for the Receiving Party shall maintain all signed acknowledgments of receipt of the Stipulation until such time as the case is concluded and all related appellate issues are resolved. If an issue arises regarding a purported unauthorized disclosure of Confidential Information, upon noticed motion of contempt filed by the Disclosing Parties, counsel for the Receiving Party may be required to file the signed acknowledgment of the receipt and review of the Stipulation. The Receiving Party may not be required to produce any documents that ...


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