The opinion of the court was delivered by: Barbara A. McAuliffe United States Magistrate Judge
KATHLEEN BALES-LANGE, #094765 County Counsel for the County of Tulare TERESA M. SAUCEDO, # 093121 Chief Deputy County Counsel 2900 West Burrel, County Civic Center Visalia, California 93291 Phone: (559) 636-4950 Fax: (559) 737-4319 E-mail: email@example.com Attorneys for County of Tulare
STIPULATED PROTECTIVE ORDER; ORDER THEREON
On July 27, 2012, Plaintiff sent a subpoena to the Tulare County Sheriff's Department ("Department") requesting that the Department produce certain documents pertaining to the Department's investigation of a February 2, 2012 incident in which Plaintiff, Ben Velasquez was shot by an officer of the City of Tulare's Police Department. The Department has agreed to provide the requested information with the stipulation of a protective order.
In order to preserve and maintain the confidentiality of certain documents and information to be produced by the TULARE COUNTY SHERIFF'S DEPARTMENT in the above-captioned matter or otherwise made available by the County, it is hereby ordered that:
1. The Department has been asked to produce certain documents that the Department
2 contends are confidential. All parties and their clients agree that any material reflecting confidential 3 information contained in those documents produced shall not be disclosed or permitted to be 4 disclosed to anyone other than those individuals or entities bound by this Stipulated Protective Order 5
(the "Protective Order'). 6
2. The Protective Order governs the treatment and handling of all confidential
7 information and documents including witness addresses, telephone numbers, identifying information 8 such as social security numbers or employee identification numbers or status as confidential 9 informants whether contained in written, recorded, electronic or graphic matter produced to the parties in this action, pending in the United States District Court, Fresno Division, Case Number: 1:12-CV-00819 LJO-BAM ("Action").
3. All documents or information furnished by the Department which are confidential and privileged information shall be furnished by clearly labeling such material indicating it is being produced pursuant to the Protective Order. The labeling of a document shall be placed on the document in a manner that will not interfere with its legibility. Labeling the document as confidential on the first page will be sufficient to include all pages of the document within the Protective Order. Labeling the label of an electronic disc (cd or dvd) or a videotape as confidential will be sufficient to include all material included in the disc or videotape within the Protective Order.
4. Material designated as confidential pursuant to the Protective Order shall be used by a party receiving such material solely for purposes of this litigation and for no other purpose. Under no circumstances shall the party receiving such material disclose it to persons other than the following:
a. Hector Suarez, Esq., and associate attorneys in the offices of each, as counsel for Plaintiff;
b. Paralegal, clerical and secretarial personnel regularly employed by counsel referred to in subparts (a), including stenographic deposition reporters or ...