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Doe v. County of Los Angeles

United States District Court, C.D. California

May 8, 2017

JOHN DOE, an individual; JANE DOE, an individual, Plaintiffs,
v.
COUNTY OF LOS ANGELES, a political subdivision of the State of California; CITY OF LOS ANGELES, a California municipal corporation; CITY OF TORRANCE, a California municipal corporation; CHRISTINE WYCOFF, an individual; ALAN BONE, an individual; UNKNOWN TORRANCE OFFICER 1, an individual and in his or her official capacity; UNKNOWN TORRANCE OFFICER 2, an individual and in his or her official capacity, UNKNOWN TORRANCE OFFICER 3, an individual and in his or her official capacity; UNKNOWN COUNTY DEPUTY, an individual and in his or her official capacity; DETECTIVE AL CONTRERAS, an individual and in his official capacity; UNKNOWN LAPD DETECTIVE, an individual and in his or her official capacity and DOES 1 -50, inclusive, Defendants.

          Complaint filed: July 1, 2016

          Trial Dated:August 22, 2017

          Roybal Hon. Paul L. Abrams, Magistrate Judge

         [DISCOVERY MATTER] PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

         PURSUANT TO THE STIPULATION OF THE PARITES (Stipulation of the Parties for Protective Order re Confidential Documents"), and pursuant to the Court's inherent and statutory authority, including but not limited to the Court's authority under applicable Federal Rules of Civil Procedure and United States District Court, Central District of California Local Rules; after due consideration of all relevant pleadings, papers, and records in this action; and upon such other evidence or argument as was presented to the Court; Good Cause appearing therefore, and in furtherance of justice, IT IS HEREBY ORDERED that:

         1. The parties, in the production or disclosure of documents, records, information, or tangible things in this case (hereafter" documents") may designate certain documents as "Confidential" (collectively herein as "Confidential Documents"). The types of documents which may be designated as Confidential Documents hereunder include: (1) peace officer personnel files and all records which are typically contained within or associated with such peace officer personnel files according to the regular practices of the law enforcement agency which is the custodian of such records - including but not limited to internal affairs investigations and related interviews and reports, peace officer personal financial and asset information, peace officer medical records in the custody of the peace officer's law enforcement agency employer, records regarding peace officer discipline, associated law enforcement agency employment/internal affairs investigations and related interviews and reports, interviews and reports related to personnel complaints by peace officers and/or citizen complaints against peace officers, and peace officer training records; and (2) comparable records of the parties that may otherwise be privileged from disclosure but which the parties may agree to produce pursuant to the terms of this Stipulation and [Proposed] Protective Order, including a party's medical records, financial records, or other privileged or confidential records, documents, or information. However, nothing in this Stipulation and [Proposed] Protective Order shall be construed as to require or mandate that any party disclose or produce privileged information or records or other Confidential Documents in this action.

         2. This Stipulation and [Proposed] Protective Order also requires each party to this action to return the Confidential Documents produced to that party at the conclusion of this lawsuit, subject to certain exceptions specified infra: this requirement is intended to ensure that the use of Confidential Documents is limited to the particular case in which the facts or documents are relevant or at issue. The parties further agree that this Stipulation and its terms and provisions, and any Order based thereon, is/are applicable only to the above entitled matter and may not be used in the proceedings of any other matter for the purpose of establishing good cause for a similar stipulation or protective order, nor as a basis for any contention that certain documents or records should or should not be produced in another matter.

         3. The mechanism by which parties may designate documents as Confidential Documents is either: (a) by marking the individual documents as being "Confidential, " such as on the footer of a specific/individual document, or (b) by enclosing, with the documents such party intends to be treated as Confidential Documents hereunder, written disclosures or discovery responses or correspondence specifically and individually identifying those enclosed documents as "Confidential" such party intends to be treated as Confidential Documents hereunder. The preferred method of designating documents as Confidential Documents is to employ all of the aforementioned means of designation, but such is not required hereunder.

         4. The parties agree that documents marked as "Confidential" shall be so marked in a manner that does not obstruct the substance of that document's text or content. The parties further agree that no party shall be permitted to alter or copy a document or record designated as "Confidential" so as to make it appear that such copy of such document or record was not a Confidential Document subject to the terms of this Stipulation and Protective Order; the parties further agree that such alteration or copying shall subject the party or counsel who engages in such action regarding such documents to sanctions, at the discretion of the Court. Nothing in this paragraph shall be construed so as to prohibit transparent "highlighting" of any Confidential Document for emphasis, provided that prior to filing any such "highlighted" document with the Court and/or prior to publishing such "highlighted" document to the finder of fact or jury in this matter, the party adding such "highlighting" emphasis informs the Court or the fact finder, as applicable, that the "highlighting" party has added such "highlighting" emphasis to the document at issue.

         5. Hereafter, a party who has designated documents as Confidential Documents shall be referred to as the "producing-disclosing party [or counsel]" and the party to whom such documents are produced or disclosed shall be referred to as the "recipient party [or counsel]."

         6. Confidential Documents shall be used only in preparation for the above entitled action, up to and including the completion of judicial proceedings, as well as any appellate phase of this action, and not for any other purpose, including any other litigation or dispute, and may not be disclosed or disseminated to any other persons, including to any other counsel, other than as set forth in this Stipulation and Protective Order.

         7. In the event that a recipient party or counsel contends that any Confidential Documents were already in the possession of that party, or that party's counsel, prior to the date of this Stipulation and Protective Order, or prior to such documents' production in this matter by the producing-disclosing party, the recipient party or counsel shall have the burden of proving that any such documents were in fact already in the possession of the recipient party or that party's counsel prior to the date of this Stipulation and Protective Order, or prior to such documents' production in this matter.

         8. The parties will attempt to resolve any issue regarding such disputed documents or records pursuant to Federal Rule of Civil Procedure 37(a) (1) before submitting any such dispute-issue to the Court.

         9. Notwithstanding the foregoing, and despite any dispute as to whether any documents produced should be subject to the terms of the Stipulation and Protective Order as a result of prior possession, the parties will continue to treat the document(s) at issue as confidential and subject to this Stipulation and Protective Order until the Court ...


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