JOHN D. HIGGINBOTHAM, Bar No. 204179, ASSISTANT CITY ATTORNEY CITY OF CORONA, Corona, California, Attorneys for Defendants CITY OF CORONA, BLAIR MONTALBANO, DAVID DOPSON, and JEANETTE GONZALEZ.
[NOTE CHANGES MADE BY COURT]
SHERI PYM, Magistrate Judge.
BASED UPON THE STIPULATION OF THE PARTIES, BY AND THROUGH THEIR COUNSEL OF RECORD, IT IS HEREBY ORDERED that:
1. All originals and copies of personnel-file documents, police investigation documents, and documents evidencing police policies and practices, interrogatory responses obtained from Defendants pertaining to personnel-file documents, police investigation documents, and documents evidencing police policies and practice, and all originals and copies of transcripts, video recordings, and audio recordings of any deposition taken in this matter during which the Defendants' personnel-file documents, police investigation documents, and documents evidencing police policies and practice, or any of the foregoing interrogatory responses, are used, mentioned, reviewed, discussed, or referred to (hereinafter collectively "Protected Documents"), shall be subject to this Protective Order as follows.
2. All Protected Documents shall be stamped "CONFIDENTIAL".
3. Each person and/or entity receiving any Protected Documents shall not disclose to any person or entity, in any manner, including orally, any Protected Documents or any of the information contained therein. Any such disclosure shall be construed as a violation of this Order, except when used strictly for purposes of this litigation as described in Paragraph No. 9 of this Order and it is done so under seal.
4. Protected Documents and all information contained therein, may only be disclosed to the following "qualified" persons:
(a) Counsel of record for the parties to this civil litigation;
(b) Plaintiffs and Defendants;
(c) Paralegal, stenographic, clerical and secretarial personnel regularly employed by counsel referred to in subparagraph (a);
(d) Court personnel, including stenographic reporters engaged in such proceedings, as are necessarily incidental to preparation for the trial of this action;
(e) Expert witnesses employed by either counsel for Plaintiffs or Defendants; and
(f) The court reporter, videographer, and audiographer, if any, who record all or part of the depositions ...