MICHAEL HUEY, individually and as successor-in-interest to decedent J.H., a minor, and JANEEN LOTTON, individually and as successor-in-interest to decedent J.H., a minor, Plaintiff,
CITY OF VALLEJO, a municipal corporation; ROBERT NICHELINI, individually and in his official as Chief of Police for the CITY OF VALLEJO; JOSEPH KREINS, in his official capacity as Chief of Police for the CITY OF VALLEJO; KEVIN BARTLETT, individually and in his official capacity as police officer for the CITY OF VALLEJO; JEREMY HUFF, individually and in his official capacity as police officer for the CITY OF VALLEJO and DOES 1-25, inclusive, Defendants.
CLAUDIA M. QUINTANA, City Attorney, SBN 178613 KELLY J. TRUJILLO, Deputy City Attorney, SBN 244286 CITY OF VALLEJO, City Hall Vallejo, CA, Attorneys for Defendants: CITY OF VALLEJO, R. NICHELINI, J. KREINS, K. BARTLETT, J. HUFF
DAN SIEGEL (SBN 56400) DEAN ROYER (SBN 233292) SIEGEL & YEE, Oakland, CA, Attorneys for Plaintiff: MICHAEL HUEY
DOUGLAS PHARR, ESQ. Law Office of Douglas Pharr, Napa, CA, Attorneys for Plaintiff: JANEEN LOTTON
STIPULATION FOR PROTECTIVE ORDER AND ORDER IN CONNECTION WITH PLAINTIFF'S MOTION TO COMPEL
KENDALL J. NEWMAN, Magistrate Judge.
WHEREAS, the Court issued an Order granting in part plaintiff Michael Huey's Motion to Compel Further Responses by Defendant City of Vallejo, subject to a protective order. (ECF No. 36).
IT IS HEREBY STIPULATED BY ALL PARTIES to this action by and through their attorneys of record as follows:
1. That in order to protect the confidentiality of the records described below, any of said records disclosed are subject to a protective order (and designated as "Confidential Material") as follows:
A. Request for Production of Documents (RFP) No. 10 - Any citizen complaints filed in the last five years concerning excessive force or dishonesty against defendants Kevin Bartlett and Jeremy Huff.
B. RFP No. 4, 6, 9, 12, and 19 - (i) incident reports from any other incidents where a City of Vallejo police officer shot a civilian resulting in a fatality from January 1, 2011 to the present; and (ii) either any civil complaints filed regarding those incidents or any other documents disputing the involved officer's version of events.
2. Confidential material may not be disclosed except as set forth in paragraphs 3- 5.
3. Confidential Material may be disclosed only to the following persons:
a. Counsel for any party to this action.
b. Paralegal, stenographic, clerical and secretarial personnel regularly employed by counsel referred to in 4(a);
c. Court personnel including stenographic reporters engaged in such proceedings as are necessarily incidental to ...