United States District Court, C.D. California
Della
Roshawn Richardson, Plaintiff, Pro Se.
City
of Long Beach, Defendant, represented by Howard Darryl
Russell, Long Beach City Attorney's Office.
Former
Chief Police Anthony Batts, Defendant, represented by Howard
Darryl Russell, Long Beach City Attorney's Office.
Officer Uribe J. Lorenzo, Defendant, represented by Howard
Darryl Russell, Long Beach City Attorney's Office.
Andrea
D. Allen, Defendant, represented by Howard Darryl Russell,
Long Beach City Attorney's Office.
Officer Paul Munson, Defendant, represented by Howard Darryl
Russell, Long Beach City Attorney's Office.
Officer Robert Cruz, Defendant, represented by Howard Darryl
Russell, Long Beach City Attorney's Office.
Officer Christopher E Martinez, Defendant, represented by
Howard Darryl Russell, Long Beach City Attorney's Office.
Officer Sergio Ruvalcaba, Defendant, represented by Howard
Darryl Russell, Long Beach City Attorney's Office.
Officer Jesus E Valdez, Defendant, represented by Howard
Darryl Russell, Long Beach City Attorney's Office.
Officer C Ignacio, Defendant, represented by Howard Darryl
Russell, Long Beach City Attorney's Office.
STIPULATED PROTECTIVE ORDER
PAUL
L. ABRAMS, Magistrate Judge.
1. A.
PURPOSES AND LIMITATIONS
Discovery
in this action is a likely to 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. Accordingly, the parties hereby stipulate to and
petition the Court to enter the following Stipulated
Protective Order. The parties acknowledge that this Order
does not confer blanket protections on all disclosures or
responses to discovery and that the protection it affords
from public disclosure and use extends only to the limited
information or items that are entitled to confidential
treatment under the applicable legal principles. The parties
further acknowledge, as set forth in section 12.3, below,
that this Stipulated Protective 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.
B. GOOD
CAUSE STATEMENT
It
appearing that information from the files of the Long Beach
Police Department, requested by Plaintiff during discovery in
this matter, is information for which special protection from
public disclosure and from use for any purpose other than the
prosecution of this action is warranted. Such confidential
and proprietary materials and information consist of, among
other things, confidential personal or financial information,
information implicating privacy rights of 3rd parties, and
information otherwise generally unavailable to the public,
which may be privileged or otherwise protected from
disclosure under state or federal statutes, court rules, case
decisions, or common-law. Accordingly, to expedite the flow
of information, to facilitate the prompt resolution of
disputes over confidentiality of discovery materials, to
adequately protect information the parties are entitled to
keep confidential, to ensure that the parties are permitted
reasonable necessary uses of such material in preparation for
and conduct of trial, to address their handling at the end of
litigation, and serve the ends of justice, a protective order
for such information is justified in this matter. It is the
intent of the parties that information will not be designated
as confidential for tactical reasons and that nothing be so
designated without a good faith belief that it has been
maintained in a confidential, non-public manner, and there is
good cause why it should not be part of the public record of
this case.
2.
DEFINITIONS
2.1
Action: this pending federal law suit.
2.2
Challenging Party: a Party or Non-Party that challenges the
designation of information or items under this Order.
2.3
"CONFIDENTIAL" Information or Items: information
(regardless of how it is generated, stored or maintained) or
tangible things that qualify for protections under Federal
Rule of Civil Procedure 26(c), and as specified above in the
Good Cause Statement.
2.4
Counsel: Outside Counsel of Record and House Counsel (as well
as their support staff).
2.5
Designating Party: a Party or Non-Party that designates
information or items that it produces in disclosures or in
responses to discovery as "CONFIDENTIAL."
2.6
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 as a consultant in
this Action.
2.7
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
consultant in this Action.
2.8
House Counsel: attorneys who are employees of a party to this
Action. House Counsel does not include Outside Counsel of
Record or any other outside counsel.
2.9
Non-Party: any natural person, partnership, corporation,
association, or other legal entity not named as a Party to
this action.
2.10
Outside Counsel of Record: atttorneys who are not employees
of a party to this Action but are retained to represent or
advise a party to this Action and have appeared in this
Action on behalf of that party or are affiliated with a law
firm which has appeared on behalf of that party, and includes
support staff.
2.11
Party: any party to this Action, including all of its
officers, directors, employees, consultants, retained
experts, and outside ...