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Fair Housing Council of v. Sanford A. Katz

August 26, 2011

FAIR HOUSING COUNCIL OF SAN FERNANDO VALLEY, INC., GABRIELA LOPEZ, AND ELSY QUEVEDO,
PLAINTIFFS,
v.
SANFORD A. KATZ, AS TRUSTEE OF SANFORD A. KATZ AND CAROLYN R. KATZ INTER-VIVOS TRUST OF 1979; CAROLYN KATZ, AS TRUSTEE OF SANFORD A. KATZ AND CAROLYN R. KATZ INTER-VIVOS TRUST OF 1979; STATEWIDE MANAGEMENT, INC., AND MIGUEL DELOYA,
DEFENDANTS.



The opinion of the court was delivered by: John E. Mcdermott United States Magistrate Judge

DISCOVERY MATTER [PROPOSED] PROTECTIVE ORDER IT IS HEREBY ORDERED THAT:

1. As used in this Protective Order, "Confidential Information" means:

(a) Defendants' tenant, applicant, and employee files, including documents reflecting personal and financial information about applicants, tenants, or employees;

(b) Defendants' financial records;*fn1

(c) Plaintiff Fair Housing Council of San Fernando Valley's investigation files;

(d) Plaintiff Gabriela Lopez's personal records; and,

(e) Plaintiff Elsy Quevedo's personal records.

2. The Confidential Information described above is properly subject to protection under Rule 26(c) of the Federal Rules of Civil Procedure. Counsel shall not designate any discovery material "CONFIDENTIAL" without first making a good faith determination that protection is warranted and that the material falls into one of the specific categories listed in paragraph 1, above.

3. If a party wishes to challenge the designation of a document or portion of a document as "CONFIDENTIAL," the party challenging the designation shall meet and confer in good faith with the designating party in an attempt to resolve the dispute. If the parties are unable to resolve their dispute, the party seeking confidentiality may file a motion with the Court seeking adjudication of the matter under Fed. R. Civ. P. 26(c). The party seeking confidentiality has the burden of establishing that protection is warranted under Fed. R. Civ. P. 26(c).

4. Confidential Information shall be disclosed by the parties and their counsel only in accordance with the terms of this Protective Order and shall be used solely for the purposes of this action and shall not be used by the parties or their counsel for any other purpose.

5. Confidential Information shall not be disclosed by the parties or their counsel to anyone other than the Court and its officers, counsel and their agents and employees, all of whom shall be advised of, and bound by, the terms of this Protective Order. Counsel may also disclose Confidential Information to qualified third-parties employed or retained to assist in the prosecution, defense, or settlement of this action, such as investigators, expert witnesses and technical advisers. Anyone (other than the Court and its personnel) who is allowed to receive Confidential Information shall be provided with a copy of this Protective Order and shall sign a Non-Disclosure Agreement in form set forth below or in a substantially similar form before such disclosure is made:

Non-Disclosure Agreement

I, (name of individual), have read and fully understand the Protective Order dated , in the action Fair Housing Council of San Fernando Valley, et al. v. Sanford Katz, et al., in the United States District Court for the Central District of California. I am familiar with and agree to comply with and be bound by the provisions of said Order and submit myself to the jurisdiction of the United States District Court for the Central District of California for any proceedings with respect to said Protective Order. I will not divulge to persons other than those specifically authorized by said Order, or copy or ...


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