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Sanders v. City of Anaheim

United States District Court, C.D. California

April 6, 2017

CHERYL SANDERS, Plaintiff,
v.
CITY OF ANAHEIM, a municipal corporation and DOES 1 through 10, inclusive, Defendant.

          PROTECTIVE ORDER RE CONFIDENTIAL INFORMATION

         Action Filed: May 2, 2016 Trial Dated: December 19, 2017 On April 3, 2017, the parties stipulated to a protective order regarding confidential information and seek to have a protective order entered by the Court based on that stipulation. The stipulation has been filed with the Court. Based on that Stipulation and it appearing that the information is confidential and good cause appearing therefor, the following Protective Order shall apply to any Documents produced by Defendant to Plaintiff's counsel in this action:

         1. Attorney for Plaintiff shall receive from Defendant a copy of the This Protective Order applies to and governs the use of confidential personnel records concerning third party employees which are being produced to Plaintiff by the City. This Order shall apply to and govern (hereinafter referred to as “Confidential Information”), including but not limited to confidential personnel records of plaintiff's former co-workers Ron Pickett and Richard Garcia. The City may affirmatively designate such records as "Confidential" and shall give notice to Plaintiff of which records are governed by this order when said documents are produced.

         The term Confidential Information shall mean and include the documents listed above, any and all portions thereof, and all documents of whatever kind containing information set forth in or obtained from these documents.

         2. Attorney for Plaintiff shall personally secure and maintain the Confidential Records in their possession to the end that Confidential Records to be used only for the purposes set forth below and for no other purpose.

         3. Plaintiff's counsel's copy of the Confidential Records shall only be used for preparing for and prosecuting this case pending the completion of the judicial process including appeal, if any. No copies of the File shall be made for any other purpose 4. Plaintiff's counsel shall use the Confidential Information solely for the purposes of this litigation, and shall not disclose any portion of the Confidential Information to any other person, firm or corporation except:

A. Bona fide employees of counsel's law offices, and then only to the extent necessary to enable said persons to assist in litigation of this action;
B. Plaintiff, but only to the extent deemed necessary by counsel for the prosecution of this litigation;
C. Expert witnesses employed by the parties to this action;
D. Consultants retained by the parties to this action; or
E. The Court, filed under seal as described below.

         5. Duration: Once a case proceeds to trial, all of the information that was designated as confidential or maintained pursuant to this protective order becomes public unless compelling reasons supported by specific factual findings to proceed otherwise are made to the trial judge in advance of the trial. Kamakana v. City and County of Honolulu (9th Cir. 2006) 447 F.3d 1172, 1180-1181 (distinguishing "good cause" showing for sealing documents produced in discovery from "compelling reasons" standard when merits-related documents are part of court record). Accordingly, the terms of this protective order do not extend beyond the commencement of the trial.

         6. Final Disposition: After the final disposition of this Action, Plaintiff's Counsel shall return all Protected Material and/or Confidential Information to counsel for the City or shall destroy such material, including all copies and extracts thereof, abstracts, compilations, summaries, and any other format reproducing or capturing any of the Protected Material and/or Confidential Information with the exception of those documents affected by the attorney work-product doctrine or attorney-client privilege. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if such materials contain material Protected Material and/or Confidential Information produced subject to this order. Any such archival copies that contain or constitute Protected Material and/or Confidential Information remain subject to this Protective Order.

         7. Attorney for Plaintiff shall cause the substance of this order to be communicated to each person to whom the File is revealed in accordance with this order and prior to disclosure of the Confidential Information, have such person execute a written Understanding and Agreement to be bound by this Stipulation for Protective Order in the form attached hereto as Exhibit 1.

         8. The attorney for Plaintiff shall not cause or knowingly permit disclosure of the contents of the File beyond the disclosure permitted under the terms and conditions of this order, including but not limited to any news ...


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