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Prison Legal News, A Project of the Human Rights Defense Center v. County of Sacramento; Scott R. Jones

August 23, 2011

PRISON LEGAL NEWS, A PROJECT OF THE HUMAN RIGHTS DEFENSE CENTER PLAINTIFF,
v.
COUNTY OF SACRAMENTO; SCOTT R. JONES, INDIVIDUALLY AND IN HIS CAPACITY AS SHERIFF OF THE COUNTY OF SACRAMENTO; DOES 1- 20, IN THEIR INDIVIDUAL AND OFFICIAL CAPACITIES, DEFENDANT



STIPULATED PROTECTIVE ORDER L.R. 141.1

Defendants COUNTY OF SACRAMENTO and SCOTT JONES (collectively hereafter "Defendants") in good faith believe that certain documents relevant to the above-captioned case contain information that is (a) confidential, sensitive, or potentially invasive of an individual's privacy interests; (b) not generally known; and (c) not normally revealed to the public or third parties, or if disclosed to third parties, would require such third parties to maintain the information in confidence. These confidential documents include, but are not limited to, the following:

1. Video of Prisoners/Inmates manufacturing weapons in jail

2. Photographs of weapons made by inmates at the Main Jail and/or Rio Cosumnes Correctional Center ("RCCC")

The documents to be kept confidential were made for purposes of training Sacramento Sheriff's deputies that work in the Main Jail and RCCC. These documents are for internal use by the department only. Publication of these documents would threaten the safety and security of Sacramento County's as well as other, penal institutions. Further, although the video makes every effort to conceal the faces of the featured individuals, there is no way to guarantee that these individuals could not be identified based on other features or markings. Publication of the video footage would threaten the safety and security of the individuals cooperating with law enforcement and demonstrating how various weapons can be made in a penal institution. According to Plaintiff's website, the majority of its subscribers are state and federal prisoners. Plaintiff's publication aims to provide information to prisoners and others concerned about prisoner rights regarding various issues including, but not limited to, prison conditions, disciplinary hearings, excessive force, mail censorship, jail litigation, and retaliation. Due to the sensitive nature of the documents to be disclosed, Defendants hereby request disclosure be governed by a court-ordered protective order. Defendants believe a court order, not a private agreement, properly facilitates the limited disclosure of such documents while protecting them from general disclosure.

Subject to approval of this Court, the parties by and through their counsels of record hereby stipulate that the documents described herein contain protected information and may only be disclosed and/or produced subject to the following Protective Order:

1. The disclosed documents shall be used solely in connection with the civil case Prison Legal News v. Jone,s et al., Case No. 2:11-cv-00907-JAM-DAD (U.S. District Court, Eastern District of California), and in preparation and trial of the case or any related proceeding. Defendants do not waive any objection to the admissibility of the documents or portions thereof in future proceedings in this case, including trial.

2. All Protected information produced and designated as confidential hereunder shall have stamped or affixed on each page that contains Protected information "CONFIDENTIAL" and "DO NOT DUPLICATE," providing that such marking does not obscure or obliterate the content of any record. Stamping or affixing "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. If any confidential materials cannot be labeled with this marking, those materials shall be placed in a sealed envelope or other container that is in turn stamped or affixed "CONFIDENTIAL" and "DO NOT DUPLICATE."

3. Documents or materials designated under this Protective Order as "CONFIDENTIAL" may only be disclosed to the following persons:

a. Counsel for the receiving party, including paralegal, clerical, and secretarial staff, and other associated personnel employed by such counsel;

b. Plaintiff, provided that such review by Plaintiff occurs in the presence of its counsel of record and that Plaintiff is not provided with or allowed to maintain a copy, electronic or otherwise, of any documents designated by Defendants as subject to this protective order;

c. Experts and consultants who are requested by counsel of the receiving party to furnish technical, legal, expert, or other specialized services in connection with this litigation;

d. An officer before whom a deposition is taken, including stenographic reporters and any necessary secretarial, clerical, or other lay personnel of such officer; and

e. Any other person to whom the parties agree in writing or as allowed by the Court.

4. Prior to disclosure of any protected information to any person identified in paragraph 3 and its subparts, each such recipient shall be provided with a copy of this Stipulated Protective Order, and shall review ...


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