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Garcia v. County of Riverside

United States District Court, C.D. California

February 6, 2014

MARGIE GARCIA, FERNANDO GARCIA CAMPISTA, ALICIA LEGUIZAMO, FERNANDO GARCIA JR. Plaintiffs,
v.
COUNTY OF RIVERSIDE, GOLDEN STATE INVESTIGATIONS a business entity, BAD BOY BAIL BONDS, a business entity, C. JEFFREY STANLEY, CRUZ BUSTAMONTE, JOSE ALBERT MENDOZA, DEPUTY CARDINALE #4176, individually and as a peace officer, DEPUTY T. MOUNTZ #4276, individually and as a peace officer, DEPUTY J. PATTERSON #3923, individually and as a peace officer, DEPUTY GRECO #3765, individually and as a peace officer, DEPUTY HEUER #3222, individually and as a peace officer, DEPUTY PRATT #3223, DOES 1-10, inclusive. Defendants.

Thomas E. Beck, Esq. THE BECK LAW FIRM Attorney for Plaintiffs.

Lewis, Brisbois, Bisgaard & Smith John M. Porter, Esq. Attorneys for Defendants County of Riverside Deputy Cardinale #4176, Deputy T. Mountz #4276, Deputy J. Patterson #3923, Deputy Greco #37655, Deputy Heurer #3222, Deputy Pratt #3223

Christopher D. Lockwood, Esq. Aries & Lockwood Attorneys for Defendants County of Riverside Deputy Cardinale #4176, Deputy T. Mountz #4276, Deputy J. Patterson #3923, Deputy Greco #37655, Deputy Heurer #3222, Deputy Pratt #3223

Lewis, Brisbois, Bisgaard & Smith Justine Grubb, Esq. Attorneys for Defendants C. Jeffrey Stanley dba Bad Boy Bail Bonds, Cruz Bustmonte, Jose Albert Mendoza

Cohon & Pollak Henry Nicholls, Esq. Jeffrey M. Cohon, Esq. Attorneys for Defendants Bad Boys Bail Bonds, Cruz Bustamante, Golden State Investigations, Jose Albert Mendoza, C. Jeffrey Stanley

Los Angeles City Attorney Jess J. Gonzalez, Esq. Attorney for Custodian of Records, Los Angeles Police Department.

STIPULATION FOR PROTECTIVE ORDER [DISCOVERY MATTER FOR DETERMINATION BY MAGISTRATE JUDGE SHERI PYM]

SHERI PYM, Magistrate Judge.

IT IS HEREBY STIPULATED by and through undersigned counsel that:

1. The documents requested by plaintiffs' subpoenas for records dated December 18, 2013 respectively to the Custodian of Records, Los Angeles Police Department (LAPD) are subject to the terms of this protective order. The LAPD documents maintained by the City of Los Angeles are part of defendant Cruz Bustamante's former employment with LAPD prior to termination. The documents requested by Plaintiffs' subpoenas served on December 18, 2013 are to be designated as "CONFIDENTIAL INFORMATION." Such designation shall be made by stamping or otherwise marking the documents prior to production or use in this litigation as follows:

"CONFIDENTIAL INFORMATION MATERIAL SUBJECT TO PROTECTIVE ORDER"

2. CONFIDENTIAL INFORMATION shall be used solely in connection with the preparation and trial of the within case, Case No. EDCV 12-881VAP (SPx) or any related appellate proceeding, and not for any other purpose, including any other litigation.

3. Testimony taken at a deposition may be designated as confidential by making a statement to that effect on the record at the deposition. Arrangements shall be made with the court reporter taking and transcribing such deposition to separately bind such portions of the transcript containing information designated as confidential, and to label such portions appropriately.

4. Material designated as confidential under this Order, the information contained therein, and any summaries, copies, abstracts, or other documents derived in whole or in part from material designated as confidential shall be used only for the purpose of the ...


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