United States District Court, C.D. California
MICHAEL N. FEUER, City Attorney THOMAS H. PETERS, Chief
Assistant City Attorney CORY M. BRENTE, Assistant City
Attorney RENA M. SHAHANDEH, Deputy City Attorney Attorneys
for Defendants CITY OF LOS ANGELES, JOSE VAZOUEZ, and EAKAWAT
KANTANON
[PROPOSED] PROTECTIVE ORDER
HONORABLE PATRICK J. WALSH UNITED STATES MAGISTRATE JUDGE
THE
PARTIES HAVING STIPULATED TO THE FOLLOWING, this Court hereby
orders as follows:
1. The
parties may designate as confidential the following:
[A] Any and all personnel complaints made against the
Defendant Officers and provided to the Plaintiff during
discovery;
[B] Any and all documents to which the parties agree in
writing shall be kept confidential; all of which Defendants
believe might contain information of a privileged,
confidential, private or sensitive nature, by affixing to
such document or writing a legend, such as
"Confidential." "Confidential Documents,
" "Confidential Material, " "Subject to
Protective Order" or words of similar effect. This
category of documents and writings so designated, and all
information derived therefrom (hereinafter, collectively,
"Confidential Information"), shall be treated in
accordance with the terms of this stipulation.
2.
Confidential Information may be used by the persons receiving
such information only for the purpose of this litigation.
3.
Subject to the further conditions imposed by this
stipulation, Confidential Information may be disclosed only
to the following persons:
(a) Counsel for the parties and to experts, investigators,
paralegal assistants, office clerks, secretaries and other
such personnel working under their supervision;
(b) Such other parties as may be agreed by written
stipulation among the parties hereto.
4.
Prior to the disclosure of any Confidential Information to
any person described in paragraph 3(a) or 3(b), counsel for
the party that has received and seeks to use or disclose such
Confidential Information shall first provide any such person
with a copy of this stipulation, and shall cause him or her
to execute, on a second copy which counsel shall thereafter
serve on the other party the following acknowledgment:
"I understand that I am being given access to
Confidential Information pursuant to the foregoing
stipulation and order. I have read the Order and agree to be
bound by its terms with respect to the handling, use and
disclosure of such Confidential Information.
5. Upon
the final termination of this litigation, including any
appeal pertaining thereto, all Confidential Information and
all copies thereof shall be returned to the Defendants,
except as to Court personnel. All Confidential Information
disclosed to any person or party pursuant to any provision
hereof also shall be returned to the Defendants.
6. If
any party who receives Confidential Information receives a
subpoena or other request seeking Confidential Information,
he, she or it shall immediately give written notice to the
Defendants' counsel, identifying the Confidential
Information sought and the time in which production or other
disclosure is required, and shall object to the request or
subpoena on the grounds of this stipulation so as to afford
the Defendants an opportunity to obtain an order barring
production or other disclosure, or to otherwise respond to
the subpoena or other request for production or disclosure of
Confidential Material. Other than objecting on the grounds of
this stipulation, no party shall be obligated to seek an
order barring production of Confidential Information, which
obligation shall be borne by the ...