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Holly Rudolph v. County of Los Angeles Sheriff's Department Deputy Phillips #456136

April 16, 2013

HOLLY RUDOLPH, PLAINTIFF,
v.
COUNTY OF LOS ANGELES SHERIFF'S DEPARTMENT DEPUTY PHILLIPS #456136; COUNTY OF LOS ANGELES SHERIFF'S DEPARTMENT DEPUTY CHAVEZ #473574; AND DOES 1 TO 25, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Hon. Andrew J. Wistrich United States Magistrate Judge

DISCOVERY MATTER [Discovery Matters Assigned to Andrew J. Wistrich, Courtroom "690"] PROTECTIVE ORDER FOR CONFIDENTIAL MATERIALS AND INFORMATION [Judge Margaret M. Morrow Courtroom "780"]

Trial Date: August 27, 2013

Subject to the approval of this Court, the parties, plaintiff HOLLY RUDOLPH, by and through his attorney of record, Dennis M. Elber, Esq. of Stolpman, Krissman, Elber, & Silver LLP, and defendants DEPUTY JAMES PHILLIPS and DEPUTY OMAR CHAVEZ (collectively, "defendants"), by and through their attorneys of record, Thomas C. Hurrell, Esq. and Brittany L. Vannoy, Esq. of Hurrell Cantrall LLP, hereby stipulate for entry of the following Protective Order:

1. In connection with informal or formal disclosure of information or materials in this action (including, but not limited to, those specified in Federal Rules of Civil Procedure, Rules 26(a)(1)(A)(ii) and 34(a)(1)(A) and (B)), and, in connection with discovery proceedings in this action, the parties may designate any document, thing, material, testimony, or other information derived therefrom as "Confidential" under the terms of this Stipulated Protective Order (hereinafter "Order"). Confidential information is information which has not been made public, and which contains private, personal, proprietary, or otherwise sensitive information, the disclosure of which may have the effect of causing harm to the parties or other entities or persons.

By designating a document, thing, material, testimony, or other information derived therefrom as Confidential under the terms of this Order, the party making the designation is certifying to the Court that there is a good-faith basis both in law and in fact for the designation within the meaning of Federal Rules of Civil Procedure, Rule 26(g).

GOOD CAUSE STATEMENT:

2. Good cause exists for entry of this Order. As for defendants, they expect they may be asked to produce, among other things, testimony or materials related to personnel records, internal reports, County of Los Angeles (COLA) policies, investigative documents, and other documentation regarding the subject of this action, which defendants believe in good faith constitute or embody Confidential information entitled to privileges and/or protections against discovery or disclosure by the First Amendment to the United States Constitution; the California Constitution, Article I, Section 1; California Penal Code sections 832.5, 832.7 and 832.8; California Evidence Code sections 1040 and 1043 et. seq; the Official Information Privilege; the right to privacy; and decisional law relating to such provisions, which matter is not generally known and which defendants would not voluntarily reveal to third parties and therefore are entitled to heightened protection from disclosure. Such information and materials are to be designated as "Confidential Material."

In addition, these materials and information may contain the names and other identifying information of law enforcement personnel on unrelated matters that preceded or post-dated the incident. Limiting disclosure of their identities to the context of this litigation as provided herein will, accordingly, further important law-enforcement objectives and interests.

3. Confidential documents shall be so designated by stamping copies of the material produced by a party with the legend "CONFIDENTIAL." Stamping the legend "CONFIDENTIAL" on the cover of any multipage document or any multi-volume material shall designate all pages of the document and all volumes of the material as Confidential, unless otherwise indicted by the producing party.

4. Testimony taken at a deposition may be designated as Confidential by making a statement to that effect on the record at the deposition. Arrangements shall be made with the court reporter transcribing the deposition to separately bind such portions of the transcript containing information designated as Confidential, and to label such portions appropriately.

5. Material designated as Confidential under this Order, the information contained therein, and any summaries, copies, abstracts, or other documents derived in whole or in part from material designated as Confidential Material shall be used solely for the purpose of litigating this action, and for no other action or purpose.

6. Confidential Material produced in this action may be disclosed or made available to the following persons (hereinafter "Qualified Persons"):

a. Each lawyer for a party in this action, including outside and in-house lawyers and other lawyers regularly employed in their offices, and such lawyers' staff to whom it is necessary that materials be disclosed for purposes of this litigation, including paralegals, assistants, law clerks, secretaries, and document clerks;

b. Each party, partner, officer, director, agent, or employee of a party deemed necessary by counsel to work on this action;

c. Independent experts or consultants retained by counsel for the purpose of assisting in this litigation, including their staff to whom it is necessary that materials be disclosed for purposes of this litigation, but only to the extent necessary for such expert or consultant ...


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