United States District Court, C.D. California
MARY AMADOR, individually and as class representatives, et al., Plaintiffs,
SHERIFF LEROY D. BACA, individually and in his official capacity, et al, Defendants.
Barrett S. Litt, SBN 45527, Lindsay B. Battles, SBN 262862, Kaye, McLane, Bednarski & Litt, LLP, Pasadena, California.
Donald W. Cook, SBN 116666, Attorney at Law, Los Angeles, California.
Cynthia Anderson-Barker, SBN 175764, Law Offices Of Cynthia Anderson-Barker Los Angeles, California, Attorneys for Plaintiffs.
[PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER
JOHN E. McDERMOTT, Magistrate Judge.
The parties' joint request for stipulated protective order is hereby GRANTED, pursuant to the terms set forth herein:
I. PURPOSES AND LIMITATIONS
Disclosure and discovery activity in this action involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. This private and confidential information includes confidential jail records earlier produced by Defendants' and (previously) designated as "Confidential, " inmate surveys concerning strip search conditions, and inmate declarations concerning strip search conditions. The parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order to address sensitive and confidential information contained in the above-described materials.
The parties acknowledge that this Order extends only to the information or items described in Section 2.6, below. The parties further acknowledge that this Order does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to file material under seal.
2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.
2.2 "Confidential" Information or Items: information or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c).
2.3 Designating Party: a Party or Non-Party that designates information or items that it produces as "CONFIDENTIAL" or "CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER."
2.4 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an ...