United States District Court, C.D. California
ERSELL V. REID, Plaintiff,
CITY OF GARDENA; GARDENA POLICE DEPARTMENT, CHIEF OF POLICE EDWARD MEDRANO, OFFICER JACKSON and DOES 1 through 10, Defendant. v.
Otis D. Wright, II, Judge.
[PROPOSED] PROTECTIVE ORDER
RE CONFIDENTIAL DOCUMENTS
MICHAEL R. WILNER, MAGISTRATE JUDGE
TO THE STIPULATION OF THE PARTIES ("Joint Stipulation
for Entry of Protective Order re Confidential
Documents") Good Cause appearing therefore, and in
furtherance of the interests of justice, IT IS HEREBY ORDERED
CONDITIONS, AND REQUIREMENTS OF THE PROTECTIVE ORDER
the purpose of this Protective Order "CONFIDENTIAL
DOCUMENTS" shall be defined as: All documents produced
by GARDENA POLICE DEPARTMENT in response to any Request for
Production of Documents by plaintiff, pertaining to:
a. Personally identifying information of any third party
witnesses and/or victims; and
b. Any documents pertaining to any police officers'
confidential personnel files and/or any documents or
information derived therefrom.
the purpose of this Protective Order the following additional
definitions shall apply:
a. Challenging Party: a Party or Non-Party that
challenges the designation of information or items under this
b. Designating Party: a Party or Non-Party that
designates information or items that it produces in
disclosures or in responses to discovery as
c. Disclosure or Discovery Material: all items or
information, regardless of the medium or manner in which it
is generated, stored, or maintained (including, among other
things, testimony, transcripts, and tangible things), that
are produced or generated in disclosures or responses to
discovery in this matter.
d. 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 expert
witness or as a consultant in this action.
e. Party: any party to this action, including all of
its officers, directors, employees, consultants, retained
experts, and Outside Counsel of Record (and their support
f. Producing Party: a Party or Non-Party that
produces Disclosure or Discovery Material in this action.
g. Receiving Party: a Party that receives Disclosure
or Discovery Material from a Producing Party.
identification of categories of documents that are considered
to be "CONFIDENTIAL DOCUMENTS", supra, is
not to be interpreted as an agreement that such documents
will be produced by GARDENA POLICE DEPARTMENT or as a waiver
of any applicable objections that GARDENA POLICE DEPARTMENT
may raise in regard to ...