REGGIE D. COLE, Plaintiff,
CITY OF LOS ANGELES, MARCELLA WINN, PETER RAZANSKAS, and DOES 1-45 inclusive, Defendants. OBIE S. ANTHONY, III, Plaintiff,
CITY OF LOS ANGELES, MARCELLA WINN, PETER RAZANSKAS, and DOES 1-10 INCLUSIVE, Defendants.
PROTECTIVE ORDER FOR CDCR RECORDS
ANDREW J. WISTRICH, Magistrate Judge.
GOOD CAUSE HAVING BEEN SHOWN, based on the stipulation of the parties, and pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the Court hereby GRANTS the parties' stipulated request for a protective order, set Case 5:12-cv-01332-CBM-AJW Document 45 Filed 01/16/14 Page 2 of 5 Page ID #:273 forth below.
STATEMENT OF GOOD CAUSE
WHEREAS, during the course of discovery, Defendants have issued discovery requests seeking records maintained by the CDCR pertaining to the incarceration of Plaintiffs Obie Anthony and Reggie Cole, including medical records ("CDCR Records").
WHEREAS, in response to Defendants' discovery requests, CDCR Records have been produced which contain personal and sensitive information regarding Mr. Anthony and Mr. Cole that would have been kept confidential if it were not for this litigation and which should not be in the public domain.
Accordingly, for these reasons of confidentiality, privacy, and privilege, the parties shall comply with the following protective order:
PROTECTIVE ORDER TERMS
1. The CDCR Records shall be treated as confidential by the parties and their counsel, and the CDCR Records shall not be further disclosed, disseminated, or otherwise distributed except as provided in this Protective Order.
2. The CDCR Records shall be used solely in connection with the preparation and trial of the above-captioned actions and any related appellate proceedings. The CDCR Records shall not be used for any other purpose, including any other litigation.
3. Defendants and their attorneys of record shall not show or disclose any of the CDCR Records or information derived from those records to anyone other than the following individuals:
(i) Counsels of record, including attorneys, support staff, legal assistants, paralegals, investigators and clerical staff who are engaged in assisting in this action;
(ii) Parties and testifying witnesses;
(iii) Claims adjusters, risk managers and in-house counsel who are necessary to assist defense counsel in this action;
(iv) Any independent outside expert or consultant, and employees and assistants under the control of such expert or consultant, who are engaged by ...