United States District Court, E.D. California
LYLE S. MCFARLAND, an individual, Plaintiff,
CITY OF CLOVIS; CLOVIS POLICE DEPARTMENT, a municipal law enforcement agency; JACOB RIOS, an Officer of Defendant CLOVIS POLICE DEPARTMENT, and an individual; and DOES 1-20, Defendants.
D. Praet, G. Craig Smith FERGUSON, PRAET & SHERMAN A
Professional Corporation, Attorneys for Defendants.
[PROPOSED] ORDER RE STIPULATED PROTECTIVE
M. SNYDER UNITED STATES MAGISTRATE JUDGE.
expedite the flow of discovery materials, 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
only materials that the parties and third-parties are
entitled to keep confidential are subject to such treatment,
and to ensure that the parties are permitted reasonably
necessary uses of such materials in preparation for and in
the conduct of trial, pursuant to Rule 26(c) of the Federal
Rules of Civil Procedure, it is HEREBY ORDERED THAT:
Documents designated as “Confidential” or
“Confidential - Counsel Only” (hereinafter
collectively “Protected Information”), and
produced by parties to this action, are subject to this
“Confidential” documents shall be defined as
documents for whichthe designating party would be entitled to
have protected from public disclosure by Court order under
Rule 26(c) of the Federal Rules of Civil Procedure and the
relevant case law.
“Confidential - Counsel Only” documents shall be
defined as “Confidential” documents, as defined
in paragraph 2, that also contain sensitive personal
information, including, for example, personnel records and
Protected Information shall be used solely in connection with
the civil case of Lyle S. McFarland v. City of Clovis, et
al, Case No. 1:15-cv-01530 AWI-SMS, and in the
preparation of trial of this case, or any related proceeding.
party producing the documents and materials described above
may designate those materials by affixing a mark labeling
them as “Confidential” or “Confidential
-Counsel Only.” If any Protected Information cannot be
labeled with the aforementioned marking, those materials
shall be placed in a sealed envelope or other container that
is in turn marked with the appropriate designation in a
manner agreed upon by the disclosing and requesting parties.
Protected Information designated under this Protective Order
as “Confidential” may only be disclosed to the
a) Counsel for the parties;
b) Paralegal, clerical, and secretarial personnel regularly
employed by counsel referred to in subpart (a) directly
above, including stenographic deposition reporters or
videographers retained in connection with this action;
c) Court personnel including stenographic reporters or
videographers engaged in proceedings as are necessarily
incidental to the preparation for the trial of the civil
d) Any expert or consultant retained in connection with this
e) The finder of fact at the time of trial, subject to the
court’s rulings on in limine motions and ...