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Cristina Gutierrez, Hector Gutierrez Sr., Hector Gutierrez Jr v. County of Los Angeles

June 16, 2011

CRISTINA GUTIERREZ, HECTOR GUTIERREZ SR., HECTOR GUTIERREZ JR., PLAINTIFFS,
v.
COUNTY OF LOS ANGELES, DEPUTY REYES #480735, INDIVIDUALLY AND AS A PEACE OFFICER, DEPUTY D. PAYNE #470624 INDIVIDUALLY AND AS A PEACE OFFICER, STEVE SUZUKI #259461, CAPTAIN MATT DENDO AND DOES 1 THROUGH 10, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Hon. Judge Paul L. Abrams United States Magistrate Judge

Thomas C. Hurrell, State Bar No. 119876 E-Mail: thurrell@hurrellcantrall.com Mariam Kaloustian, State Bar No. 236702 E-Mail: mkaloustian@hurrellcantrall.com Erica Bianco, State Bar No. 254988 E-Mail: ebianco@hurrellcantrall.com HURRELL CANTRALL LLP 700 South Flower Street, Suite 900 Los Angeles, California 90017-4121 Telephone: (213) 426-2000 Facsimile: (213) 426-2020 Attorneys for Defendants COUNTY OF LOS ANGELES, DEPUTY REYES, DEPUTY D. PAYNE, DEPUTY STEVE SUZUKI and CAPTAIN MATT DENDO

STIPULATED PROTECTIVE ORDER

**NOTE CHANGES MADE

BY THE COURT**

After full consideration of the stipulation by the parties for a protective order, and for good cause shown, IT IS HEREBY ORDERED that:

1. In connection with informal or formal disclosure of documents and other materials in this action (including but not limited to those specified in Fed.R.Civ.P. 26(a)(1)(A)(ii) and 34(a)(1)(A) and (B)), and, in connection with discovery proceedings in this action, the parties may designate any document, thing, material, testimony, or other information derived therefrom, as "Confidential" under the terms of this Stipulated Protective Order (hereinafter "Order"). Confidential information is information which has not been made public, and which contains private, personal, proprietary, or otherwise sensitive information, the disclosure of which may have the effect of causing harm to the parties or other entities or persons. By designating a document, thing, material, testimony, or other information derived therefrom as "Confidential" under the terms of this Order, the party making the designation is certifying to the Court that there is a good-faith basis both in law and in fact for the designation within the meaning of Federal Rule of Civil Procedure 26(g).

GOOD CAUSE STATEMENT:

2. Good cause exists for entry of this Order. As for defendants, they expect to produce, among other things, materials comprising internal reports, COLA policies, and other documentation regarding the search which is the subject of this action which COLA believes in good faith constitute or embody confidential information, personnel records and/or other materials that are entitled to privileges and/or protections against discovery or disclosure by the United States Constitution, First Amendment; the California Constitution, Article I, Section 1; California Penal Code Sections 832.5, 832.7 and 832.8; California Evidence Code Sections 1040 and 1043 et. seq; the Official Information Privilege; the right to privacy; and decisional law relating to such provisions, which matter is not generally known and which COLA would not voluntarily reveal to third parties and therefore is entitled to heightened protection from disclosure, are to be designated as "confidential material."

In addition, these materials contain the names and other identifying information of law enforcement personnel who responded to the probation conditions search, and who thereafter conducted the search. Limiting disclosure of their identities to the context of this litigation as provided herein will, accordingly, further important law-enforcement objectives and interests.

As for plaintiffs, they expect to produce, among other things, personal medical records and bills relating to the care counseling Cristina Gutierrez received following the incident. These records and bills would contain sensitive medical and financial information that plaintiffs desire to be kept confidential and disclosed only in the context of this litigation.

3. Confidential documents shall be so designated by stamping copies of the document or material produced by a party with the legend "CONFIDENTIAL." Stamping the legend "CONFIDENTIAL" on the cover of any multipage document or any multi-volume material, shall designate all pages of the document and all volumes of the material as confidential, unless otherwise indicted by the producing party.

4. Testimony taken at a deposition may be designated as Confidential by making a statement to that effect on the record at the deposition. Arrangements shall be made with the court reporter transcribing the deposition to separately bind such portions of the transcript containing information designated as Confidential, and to label such portions appropriately.

5. Material designated as "Confidential" under this Order, the information contained therein, and any summaries, copies, abstracts, or other documents derived in whole or in part from material designated as Confidential (hereinafter "Confidential Material") shall be used solely for the purpose of litigating this action, and for no other action or purpose.

6. Confidential Material produced in this action may be disclosed or made available to the following persons ...


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