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Perry Grays, An Individual v. City of Long Beach

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA


April 9, 2013

PERRY GRAYS, AN INDIVIDUAL, PLAINTIFF,
v.
CITY OF LONG BEACH, SALVADOR ALATORRE,
ALVINO HERRERA, GEORGE EVANS, DAISY ORTIZ, RODERICK TITH, AND DOES 1-10, INCLUSIVE, DEFENDANT.

The opinion of the court was delivered by: Honorable Gary A. Feess, Judge

Courtroom 740, Roybal Honorable Ralph Zarefsky, Magistrate Judge PROTECTIVE ORDER STIPULATION

Complaint Filed: September 14, 2011 Trial Date: March 19, 2013

WHEREAS, Federal Rule of Civil Procedure 26(c)(1) provides that the court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense; and

WHEREAS, Plaintiffs' Request for Production of Documents -- Set One request responses and documents that Defendants CITY OF LONG BEACH (hereinafter CITY) consider to constitute confidential and/or privileged official information including personnel complaints, investigative reports, personnel files, Internal Affairs interviews, and disciplinary records regarding the individual Defendant Officers, as well as, Long Beach Police Department training and instructional information and procedures, the following protective order shall apply to the names and addresses, and other information and/or documents, if any, ordered released by the Long Beach Police Department to the prosecution and defense in this action.

IT IS HEREBY STIPULATED THAT:

1. Attorneys for the parties shall receive from the Long Beach Police Department Custodian of Records copies of portions of the personnel files of defendant officers SALVADOR ALATORRE, ALVINO HERRERA, GEORGE EVANS, DAISY ORTIZ PAUL, RODERICK TITH, limited to Internal affairs complaints (summary and complainant/witness contact information), records of discipline and citizen complaints for each Defendant Officer as it pertains to complaints of excessive force, dishonesty, false arrests and false police reports for the ten year period before the incident.

2. Attorneys for the parties shall personally secure and maintain said copies in their possession to the end that said copies are to be used only for the purposes set forth below and for no other purpose.

3. Copies of the record shall only be used for preparing for and prosecuting or defending this case pending the completion of the judicial process including appeal, if any.

4. Copies of the records may be used at time of trial only if so ordered by the court. Additionally, reference to the content of any records, or the existence of any such record shall only be made after so ordered by the Court.

5. If necessary in the judgment of the attorneys for the parties in this case, they may show or reveal the contents of the copies to their employees or agents, if the same may actively assist in the prosecution or defense of this case.

6. Plaintiff's attorneys may show or reveal contents of documents to their client, only in the event the documents describe or refer to incidents involving Plaintiff, unless otherwise ordered by the court

7. Any depositions, during which the contents of copies of the records are part of the testimony or copies of the records are attached as exhibits, shall be sealed as to any confidential portions.

8. After completion of the judicial process in this case, attorneys for the parties shall return the above-referenced records to the Office of the City Attorney as attorney for the Custodian of Records for the Long Beach Police Department and shall retain no copy of such material in any form.

9. Attorneys for the parties shall cause the substance of this Order to be communicated to each person to whom the information is revealed in accordance with this Order.

10. The attorneys for the parties shall not cause or knowingly permit disclosure of the contents of the copies beyond the disclosure permitted under the terms and conditions of this Order, including but not limited to any news media which is inclusive of film or video, television, radio or print.

11. This order may be signed in counterparts. A faxed signature shall serve with the same force and effect of an original signature.

DATED: April 9, 2013 ROBERT E. SHANNON, City Attorney By: /s/ Howard D. Russell HOWARD D. RUSSELL Deputy City Attorney Attorneys for Defendants CITY OF LONG BEACH SALVADOR ALATORRE ALVINO HERRERA GEORGE EVANS DAISY ORTIZ PAUL RODERICK TITH DATED: March 27, 2013 LAW OFFICES OF DALE K. GALIPO /s/ Dale K. Galipo By:__________________________________ DALE K. GALIPO, Esq. Attorneys for Plaintiff PERRY GRAYS

IT IS SO STIPULATED ORDERED

DATED: March April 9, 2013

Hon. Ralph Zarefsky, Magistrate Judge UNITED STATES DISTRICT COURT

20130409

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