The opinion of the court was delivered by: The Hon. Victor B. Kenton, United States Magistrate Judge
The Hon. Michael W. Fitzgerald
Magistrate Judge: The Hon. Victor B. Kenton
STIPULATION OF PARTIES FOR PROTECTIVE ORDER TO GOVERN CONFIDENTIAL PAST COMPLAINTS OF EXCESSIVE FORCE AGAINST DEFENDANT DEPUTIES THAMES AND ROTH [DISCOVERY MATTER]
[PROPOSED] STIPULATION OF PARTIES FOR PROTECTIVE ORDER TO GOVERN CONFIDENTIAL PAST COMPLAINTS OF EXCESSIVE FORCE AGAINST DEFENDANT DEPUTIES THAMES AND ROTH
IT IS HEREBY STIPULATED AND AGREED, by and between plaintiff Victor Shawn Brown ("Plaintiff") and defendants John Roth and C.L. Thames ("Defendants"), (collectively, "the parties"), through their counsel of record, that the following protective order will govern all privileged and confidential excessive force complaints, if any, made against defendants.
The following Protective Order shall govern the disclosure of documents and information produced to Plaintiff regarding any and all excessive force complaints, if any, made against Deputies C.L. Thames and John Roth.
1. Under no circumstances shall the disclosed documents or information contained in the disclosed documents, be used in any proceeding other than the matter of Victor Brown v. C.L. Thames, et al., CV 10-03178 JHN (VBK) ("this Matter").
2. Under no circumstances shall the disclosed documents or information contained in the disclosed documents be filed in a public record, compiled, stored, duplicated, used as a data base, or disseminated, in any form, except by Court Order, except that any such documents or information may be: (1) used in accordance with the further provisions set forth below and; (2) used during the trial of this Matter;
3. Disclosure of the material by this Order or information obtained therefrom shall be limited to the classification of persons listed below:
(a) Counsel for any party to this action;
(b) Staff and personnel employed by counsel for any party;
(c) The Court and its personnel, in connection with this litigation;
(d) An expert or consultant retained to work on this case by counsel for ...