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Galvan v. City of La Habra

United States District Court, Ninth Circuit

August 12, 2013

MANUEL GALVAN, an individual, Plaintiff,
v.
CITY OF LA HABRA, a governmental entity; OFFICER JASON SANCHEZ, an individual; and DOES 1 through 10, inclusive, Defendants.

ORDER RE STIPULATION REGARDING DOCUMENTS IN THE POSSESSION OF THE ORANGE COUNTY DISTRICT ATTORNEY'S OFFICE

JEAN P. ROSENBLUTH, Magistrate Judge.

Having considered the stipulation of the Parties, and good cause appearing, this Court hereby ORDERS as follows:

(1) The OCDA has been subpoenaed to produce certain documents that it contends are confidential. Plaintiff and Defendants agree that any material reflecting confidential information contained in those documents shall not be disclosed or permitted to be disclosed to anyone other than those individuals or entities bound by this Stipulated Protective Order (the "Protective Order").

(2) The Protective Order governs the treatment and handling of all confidential information and documents in the possession of the OCDA, including but not limited to, witness addresses, telephone numbers, identifying information such as social security numbers or employee identification numbers or status as confidential informants whether contained in written, recorded, electronic or graphic matter produced to the parties in this action (the "Confidential Information").

(3) All documents or information produced by the OCDA which are Confidential Information shall be produced by labeling such material "confidential" indicating that it is being produced pursuant to this Protective Order. The labeling of a document shall be placed on the document in a manner that will not interfere with its legibility. Labeling the document as confidential on the first page will be sufficient to include all pages of the document within the Protective Order, but if only portions of the document are confidential, the producing party or non party should so indicate. Labeling the outside of an electronic disc (CD or DVD or otherwise), audio recording, or a videotape as confidential will be sufficient to include all material included within the disc, audio recording, or videotape within this Protective Order.

(4) Material designated as confidential pursuant to the Protective Order shall be used by a party receiving such material solely for purposes of this litigation and for no other purpose. Under no circumstances shall the party receiving such material disclose it to persons other than the following:

(A) Parties and their counsel including attorneys, paralegals, stenographic and clerical staff employed by such counsel;

(B) Stenographic employees, court reporters and videographers recording or transcribing testimony in this action;

(C) The Court, Special Master appointed by the Court, mediator, and any members of their staff to whom it is necessary to disclose the information;

(D) Any outside consultant or expert (and any employees thereof who would, in the course and scope of their employment, handle the at-issue documents), whether formally retained or not; and

(E) Any witness during a deposition in this action or during the trial of this action.

(5) Prior to the disclosure of any Confidential Information to any person identified in paragraph 4 (A), (B), (D), or (E) above, each such recipient of the Confidential Information shall be provided with a copy of the Protective Order. Upon reading the Protective Order, such person shall sign a Certification, the form annexed hereto as Exhibit A, acknowledging that he or she has read the Protective Order and shall abide by its terms. The Plaintiff and/or Defendants shall retain all executed Certifications until the end of the instant litigation and shall provide a copy of the executed Certifications to the OCDA within ten (10) days of a written request. However, persons subject to Section 4 (C), and (E), may view any confidential information without having to sign the Certification as defined in this Section 5. The person shall also consent to the jurisdiction of the United States District Court, Central District of California, for any issues that may arise out of the Protective Order.

(6) If Confidential Information is used, in any depositions taken in this matter, only those portions of the depositions that qualify for protection under the Federal Rules of Civil Procedure, Rule 26(c) should be designated for protection. The portion of the original transcript of the deposition, and all copies thereof, shall be stamped "Confidential." If any portions of the deposition transcript and/or video or audio versions of the depositions containing Confidential Information, or reference thereto, are filed with the Court, it shall be done in compliance with Paragraph (15) of the Protective Order.

(7) A copy of the Protective Order shall be attached as an exhibit to said deposition transcript and the court reporter shall be subject to the Protective Order and precluded from providing the original or copies of the deposition transcript or portions thereof, any copies thereof, to any persons or entities other than counsel of record in the instant action. In the event there is any audio and/or video ...


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