Reid v. City of Gardena

          Hon. Otis D. Wright, II, Judge.

          [PROPOSED] PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

          MICHAEL R. WILNER, MAGISTRATE JUDGE

         PURSUANT 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 that:

         TERMS, CONDITIONS, AND REQUIREMENTS OF THE PROTECTIVE ORDER

         1. For 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^[1] and/or any documents or information derived therefrom.

         2. For 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 Order.

b. Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as "CONFIDENTIAL."

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 staffs).

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.

         3. The 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 ...