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Alvaro Quezada v. Al K. Scribner

December 5, 2011

ALVARO QUEZADA, PETITIONER,
v.
AL K. SCRIBNER, RESPONDENT.



The opinion of the court was delivered by: Honorable Marc L. Goldman United States Magistrate Judge

ANDREA SHERIDAN ORDIN, County Counsel ROGER H. GRANBO, Assistant County Counsel JONATHAN McCAVERTY, Deputy County Counsel (SBN 210922) * jmccaverty@counsel.lacounty.gov 648 Kenneth Hahn Hall of Administration 500 West Temple Street Los Angeles, California 90012-2713 Telephone: (213) 974-1828 Fax: (213) 626-2105 Attorneys for Los Angeles County District Attorney's Office BRIAN M. POMERANTZ (No. 214264) Deputy Federal Public Defender E-mail: Brian_Pomerantz@fd.org TRACY CASADIO (No. 235557) Deputy Federal Public Defender E-mail: Tracy_Casadio@fd.org 321 East 2nd Street Los Angeles, California 90012-4202 Telephone: (213) 894-8859 Fax: (213) 894-1221 Attorneys for Petitioner Alvaro Quezada

HOA.841375.1

STIPULATION FOR PROTECTIVE ORDER FOR DISTRICT ATTORNEY FILES

Petitioner ALVARO QUEZADA ("Petitioner"), and the Office of the Los Angeles County District Attorney, (collectively referred to as "DA COR"), through their respective attorneys, hereby stipulate, agree and request that this Court enter the following Protective Order set forth below regarding only the two specific documents referenced in County Counsel's November 4, 2011 privilege log (collectively referred to hereinafter as the "PROTECTED DOCUMENTS"):

1. The attorney for Petitioner issued subpoenas duces tecum dated October 7, 2010 and November 12, 2010.

2. The DA will produce documents, in the Office of the Los Angeles County District Attorney's possession, custody or control, in compliance with the subpoenas duces tecum issued as noted in paragraph 1 above. Specifically, the DA will produce, subject to the Protective Order as set forth below, all documents in its possession, custody or control, responsive to the subpoenas duces tecum.

3. The DA maintains and asserts through this stipulation, that it has a legitimate need to limit access of information on the grounds that disclosure of information in the materials requested would (a) implicate the subjects' rights to privacy, (b) disclose attorney work product, and (c) disclose information protected by the deliberative processes privilege. The DA maintains and asserts that it has a legitimate need to limit access to information about internal decision making for the conduct and course of prosecutions. The DA maintains and asserts that it has a legitimate need to meet its obligations to maintain confidentiality and/or privacy of information as required by statute and judicial decision.

4. Petitioner QUEZADA and the DA have met and conferred pursuant to Local Rule 37-1 and are desirous of resolving the disputes about disclosure and use of information acquired by Petitioner from the Office of the Los Angeles County District Attorney and its personnel.

5. To comply with Petitioner's subpoenas duces tecum expeditiously, to regulate the disclosure and use of information from the DA, and to meet the above identified needs of DA, the following procedures and limitations shall govern the use, disclosure, distribution or dissemination of the PROTECTED DOCUMENTS.

a. The PROTECTED DOCUMENTS shall be used solely in connection with the preparation and trial of this action, Case No. CV 04-7532, or any related appellate proceeding, and not for any other purpose, including any other litigation unless the documents are subject to normal disclosure obligations consistent with Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963) and its progeny. This paragraph shall not preclude the Petitioner's attorney of record in this case from indicating, in connection with discovery or a discovery motion in another action, an awareness of responsive documents. In indicating such awareness in any other action, the Petitioner's attorney of record shall not disclose the substance of the Confidential Information.

b. The PROTECTED DOCUMENTS, or any portion thereof, may not be disclosed, distributed or disseminated except as provided in subparagraphs (c) and

(d). c. The PROTECTED DOCUMENTS shall be treated as confidential by Petitioner and his counsel and shall not be further disclosed, disseminated or otherwise distributed except as provided in this Protective Order unless the documents are subject to normal disclosure obligations consistent with Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963) and its progeny, in which case they are excluded from the protections of this Protective Order.

d. Unless the documents are subject to normal disclosure obligations consistent with Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963) and its progeny, in which case they are excluded from the protections of this Protective Order, The PROTECTED DOCUMENTS, or any portion thereof, may only be disclosed to the following persons:

(1) Counsel for Parties only and specifically not to QUEZADA with the exception of any recordings, written or ...


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