UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION
April 1, 2013
VICTOR SHAWN BROWN,
C.L. THAMES, JOHN ROTH AND DOES 1-10, DEFENDANTS.
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 any party to this case;
(e) An investigator retained by counsel for any party to this case. 4. Plaintiff's counsel shall not provide the plaintiff with the documents disclosed, nor will plaintiff's counsel provide plaintiff with any addresses or telephone numbers of persons identified within the disclosures, but may discuss the information
obtained from any investigation with the plaintiff;
5. Counsel for all parties to this action shall advise those individuals to whom disclosure is made of the documents or information governed by this Protective Order, and shall obtain the consent of such individual that he or she will be bound by this Protective Order. In the event such individual does not consent to be bound by this Protective Order, no disclosure or information contained in the disclosures will be made to such individual;
6. Provisions of this Order, insofar as they restrict disclosure and the use of the disclosed information and material shall be in effect until further order of the Court;
7. Plaintiff's counsel shall return all copies of the disclosed documents remaining within their possession to defendants' counsel upon resolution of this case;
8. Nothing in this Protective Order is intended to prevent the officials or employees of the Los Angeles County Sheriff's Department or other authorized individuals from having access to documents if they would have had access in the normal course of their job duties.
Dated: March 28, 2013 Respectfully submitted, AKIN GUMP STRAUSS HAUER & FELD LLP SARAH GETTINGS GARRETT LLEWELLYN By: /s/ Sarah Gettings . Sarah Gettings Attorneys for Plainitff, VICTOR SHAWN BROWN Dated: March 28, 2013 Respectfully submitted, NELSON & FULTON By: /s/ Elise H. Hur . HENRY PATRICK NELSON ELISE H. HUR Attorneys for Defendants, C.L. Thames and John Roth
IT IS SO ORDERED.
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