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Omar Rodriguez v. City of Burbank

June 29, 2012

OMAR RODRIGUEZ, PLAINTIFF,
v.
CITY OF BURBANK, TIM STEHR, SCOTT LACHASSE, AND DOES 1 THROUGH 10, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Judge: Hon. George H. Wu

NOTE: CHANGES HAVE BEEN MADE TO THIS DOCUMENT

Location: Courtroom 10 [PROPOSED] PROTECTIVE ORDER [Fed.R.Civ.P. 26(c); L.R. 7-1] [Discovery Document: Referred to Magistrate Judge Ralph Zarefsky] Action Filed: April 11, 2011 Trial Date: October 2, 2012

PROTECTIVE ORDER

1. Any party to this action may designate as "confidential" any documents, things, discovery responses, trial or deposition testimony, or other material that contains or discloses any of the following:

a. Police officer personnel information or police officer personnel records; or

b. Plaintiff Omar Rodriguez's ("Plaintiff's") social security number, home address, telephone number, private financial information, including but not limited to, his pay stubs, wage statements, tax returns, benefits documents, retirement programs, and/or bank account information, or Plaintiff's medical information including but not limited to his, medical records, bills, treatment, and/or medical history.

The term "Confidential Information" as used in this Protective Order shall refer to the original and copies of any so-designated document, testimony, or other discovery material, and shall also refer to the information contained in such material. All notes, extracts and summaries of such Confidential Information shall be considered confidential and be subject to the terms of this Protective Order.

The parties shall mark any documents produced that constitute or contain Confidential Information with a label designating them as "Confidential: Subject to Protective Order."

GOOD CAUSE STATEMENT: Good cause exists to treat police officer personnel information and records as "Confidential Information" in this matter in the manner described herein. Such items include information about complaints, investigations, and discipline involving the officers; officers' financial information; details relating to the officers' private lives, including contact information; and birth dates and social security numbers. Police officers' jobs require that they frequently testify under oath, and unlimited dissemination of such sensitive information would undermine their ability to effectively testify in legal proceedings.*fn1 Importantly, given the unique nature of police officers' jobs, unlimited disclosure of contact information and other personal information in personnel records can also compromise the safety of the officers and their families.

Good cause also exists to treat Plaintiff's social security number, home address, telephone number, private financial information, and medical information as Confidential Information in this matter in the manner described herein. Plaintiff maintains a reasonable and legitimate interest in safeguarding the privacy of his social security number, financial information, and medical conditions, treatment, and history. Plaintiff would sustain significant damages if this private information was publicly disclosed or available for review.*fn2

2. Absent a specific order of this Court, the parties shall use the Confidential Information solely for the purposes of litigation in this action-Omar Rodriguez v. City of Burbank, et al., United States District Court, Central District, Case No. 11-CV-03045-GW-RZ(X) (the "Action")-and shall not disclose any portion of the Confidential Information to any other person, firm or corporation except:

a. Counsel of record in this action, and bona fide employees of that counsel's offices, and then only to the extent necessary to enable said persons to assist in litigation of this Action;

b. Plaintiff, to the extent necessary for the prosecution of this Action;

c. Non-party experts or other consultants who are not affiliated with a party and who are expressly engaged by counsel to provide expert testimony in this matter or to assist in discovery and/or preparation of this action for trial, with ...


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