STEWART KATZ (SBN 127425) Law Offices of Stewart Katz, Sacramento, CA, Attorneys for Plaintiff OLEGS KOZACENKO.
OFFICE OF THE ATTORNEY GENERAL JILL SCALLY, Attorneys for Defendant CALIFORNIA HIGHWAY PATROL.
PLACER COUNTY COUNSEL'S OFFICE BRIAN R. WIRTZ, Attorneys for Third Party PLACER COUNTY DISTRICT ATTORNEY'S OFFICE.
CORRECTED STIPULATION FOR PROTECTIVE ORDER; ORDER
DALE A. DROZD, District Judge.
The Parties, through their attorneys of record, have agreed to the following protective order to govern the handling of the documents subpoenaed by both Plaintiff Kozacenkco and Defendant California Highway Patrol (herein referred to as "Parties") and turned over by the Placer County District Attorney's Office.
Both Parties have served a subpoena on the Placer County District Attorney's Office seeking disclosure of the entirety of the District Attorney's file in the criminal case of People v. Olegs Kozacenkco, Placer County Superior Court Case No. 62-112550. The subpoenas seek disclosure of the entirety of the District Attorney's file, including documents that represent the thought processes and mental process of that office.
In light of the holding in Doubleday v. Ruh, (1993) 149 F.R.D. 601, and pursuant to Local Rule 141, the undersigned agree that having the Placer County District Attorney's file be subject to a stipulated protective order will serve to facilitate discovery in the instant case while ensuring the District Attorney's files are protected from disclosure to the maximum extent possible.
DOCUMENTS SUBJECT TO THE PROTECTIVE ORDER
The entirety of the DA's file will be Bates stamped, marked "subject to protective order, " and marked "Kozacenko." The undersigned agree that the entire file in the case of People v. Kozacenko, Placer County Superior Court Case No. 62-112550, will be provided, with one exception - a cell phone number of a California Highway Patrol Officer will be redacted and not disclosed to either party to this lawsuit.
PROCEDURE FOR MODIFYING SCOPE OF THIS ...