JAMES L. COMPTON, an individual, Plaintiff,
RIVERSIDE COUNTY SHERIFF'S DEPARTMENT, et al. Defendants.
[PROPOSED] ORDER GRANTING STIPULATION FOR PROTECTIVE ORDER TO RELEASE INFORMATION FROM LAW ENFORCEMENT PERSONNEL FILES RE DEPUTY LEONARDO PEREZ (#4770)
DAVID T. BRISTOW, Magistrate Judge.
Good cause appearing therefor from the Stipulation of the parties
IT IS ORDERED that the terms of the Protective Order are as follows:
1. Counsel for defendant, County of Riverside, shall disclose to counsel for plaintiff the names, addresses and telephone numbers of citizen complainants, witnesses and the names of involved officers concerning citizen complaints for use of excessive force, and/or dishonesty involving defendant Deputy Leonardo Perez (#4770) from September 6, 2004 (five years before the incident) through October 31, 2013.
2. Counsel for the plaintiff shall not convey, transfer, publish, distribute, copy, duplicate or disseminate the information so provided except as may be reasonably necessary for the prosecution of this litigation, by communicating with the plaintiff, or investigators, consultants and experts retained on behalf of the plaintiff in this matter.
3. Prior to the dissemination of any such information pursuant to this order, counsel for the plaintiff shall inform such person of the terms and conditions of this order and secure such person's agreement to be bound by it.
4. Plaintiff, plaintiff's counsel, and plaintiff's investigators, consultants and experts, are expressly prohibited from utilizing the disclosed information for any purpose other than the prosecution of COMPTON v. RIVERSIDE COUNTY SHERIFF'S DEPARTMENT, United States District Court Case No. CV 10-07490 BRO (DTBx) and the information disclosed shall not be utilized in any other proceeding or litigation, or for any other purpose.
5. Plaintiff, plaintiff's counsel, and plaintiff's investigators, consultants and experts are expressly prohibited from disclosing orally or otherwise the information subject to this Protective Order to any person other than those who are reasonably necessary for the prosecution of COMPTON v. RIVERSIDE COUNTY SHERIFF'S DEPARTMENT, United States District Court Case No. CV 10-07490 BRO (DTBx).
6. Plaintiff, plaintiff's counsel, and plaintiff's investigators, consultants and experts, are expressly prohibited from duplicating, copying or otherwise distributing or disseminating any of the disclosed information to any person or entity.
7. Counsel for each party shall take reasonable precaution to prevent the unauthorized or inadvertent disclosure of any of the protected information.
8. In the event anyone shall violate or threaten to violate any terms of this Protective Order, the aggrieved party may immediately apply to obtain injunctive relief and monetary sanctions to this court against any such person violating or threatening to violate any of the terms of this order. This court shall retain jurisdiction over the parties and any other persons subject to the terms of this order for the purpose of enforcing this Protective Order. The court shall have the power to impose whatever penalties it deems appropriate for the violation of said order, including, but not limited to, monetary and judicial sanctions and contempt.
9. This Protective Order shall survive the final termination of this action, to the extent that the information disclosed remains confidential and does not become known to the public. The court shall retain jurisdiction to resolve any dispute concerning the use of the information disclosed herein, and to impose whatever penalties it deems appropriate for the violation of ...