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Louie Rosales, An Individual; Jessica Rosales, An Individual v. City of Los Angeles

December 14, 2012

LOUIE ROSALES, AN INDIVIDUAL; JESSICA ROSALES, AN INDIVIDUAL, PLAINTIFF,
v.
CITY OF LOS ANGELES, A MUNICIPAL ENTITY; LOS ANGELES POLICE DEPARTMENT, A DEPARTMENT OF THE CITY OF LOS ANGELES; DANIEL GAGILONE AN INDIVIDUAL; CHRISTINA MEJICANOS, AN INDIVIDUAL, DEFENDANTS



The opinion of the court was delivered by: Hon. Michael R. Wilner United States Magistrate Judge

Assigned to: Honorable Dean D. Pregerson Assigned to: Magistrate Michael R. Wilner

DEFENDANT CITY OF LOS ANGELES AND PLAINTIFFS STIPULATED PROTECTIVE ORDER RE OFFICER INVOLVED SHOOTING INVESTIGATION PROTECTIVE ORDER FORCE INVESTIGATION DIVISION REPORTS

After the Plaintiffs LOUIE ROSALES and JESSICA ROSALES, (hereinafter referred to as "Plaintiffs"), by and through their attorneys of record, Philip J. Layfield, Esq. and Jamie Keaton, Esq. of The Layfield Lawfirm, APC and Defendants CITY OF LOS ANGELES, a local public entity (hereinafter referred to as "Defendants"), by and through their attorneys of record, Carmen A. Trutanich, City Attorney, Cory M. Brente, Supervising Assistant City Attorney and Christian R. Bojorquez conferred regarding the Production of the Shooting Investigation in the above-entitled case, IT IS HEREBY STIPULATED AND AGREED between the parties hereto, by their undersigned counsel of record, that the following Protective Order, and its terms shall govern documents and things in this matter:

For purposes of this Order, Confidential Materials include, but are not limited to:

1. Force Investigation Division Investigation Report;

2. Any and all documents, interviews, Officer Statements and/or writings created during the Shooting Investigation, which include, but are not limited to, the following:

A. Force Investigation Division Report

M Interviews;

M Officer Statements; M Legend w/diagram; M Pictures; M Investigative Narrative.

I. TERMS OF THE PROTECTIVE ORDER

A.

1. The Confidential Documentation being provided pursuant to this Protective Order will be accomplished by affixing to such document or writing a legend, such as "Confidential," "Confidential Documents," "Confidential Material Subject to Protective Order" or words of similar effect. The documents and writings so designated, and all information derived therefrom (hereinafter, collectively, "Confidential Information"), shall be treated in accordance with the terms of this stipulation/protective order. The "Confidential" Watermark shall not obscure the writings on the document's legibility and shall not be repeated more than once per page.

2. Confidential Information may be used by the persons receiving such information only for the purpose of this above-captioned litigation

3. Subject to the further conditions imposed by this stipulation/protective order, Confidential Information may be ...


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