Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Appling v. Riverside County

United States District Court, C.D. California

May 10, 2017

KEITH APPLING, Plaintiff,
v.
RIVERSIDE COUNTY, Defendant.

          PROTECTIVE ORDER FOR DOCUMENTS SUBMITTED TO AND USED BY SPECIAL MASTERS

          Hon. Jay C. Gandhi UNITED STATES DISTRICT COURT MAGISTRATE JUDGE

         TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

         The Court has reviewed the stipulation for protective order by the parties. Good cause appearing, the Court hereby enters a protective order and orders as follows:

         A. Graphics that Defendant reasonably believes in good faith are confidential and/or proprietary, and qualify for protection under Federal Rule of Civil Procedure 26(c), may be designated as such at the time of production (“Confidential Graphics”). Defendant must take care to limit any such designation to specific material that qualifies under the appropriate standards. Defendant must designate for protection only those parts of the Graphics that qualifies as confidential so that other portions of Graphics for which protection is not warranted are not swept unjustifiably within the ambit of this Protective Order. Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber the case development process or to impose unnecessary expenses and burdens on other parties) may expose the designating party to sanctions. The copies of any Confidential Graphics disclosed pursuant to this Protective Order must be distinctively marked, and such marking must not obscure or obliterate the content of the Graphics, with substantially the following language: “CONFIDENTIAL - UNLAWFUL TO DUPLICATE.”

         B. Thereafter, the Special Masters shall not convey, transfer, publish, distribute, copy, duplicate or disseminate the Confidential Graphics so provided except as may be reasonably necessary for drafting their reports pursuant to the PROTOCOL.

         C. No Confidential Graphics are to be shared, shown or discussed with the plaintiffs themselves or any other convicted felons.

         D. Unless the Court orders otherwise, Confidential Graphics may be disclosed to the Special Masters; one designated assistant for each Special Master that is made known to the parties; counsel of record; paralegal, attorney, stenographic, clerical and secretarial personnel employed by counsel of record; and court personnel.

         E. All Confidential Graphics may be released to additional individuals aside from those described in Paragraph D above upon written agreement by the parties and/or by order of the Court.

         F. The parties may not publicly file any Confidential Graphics in the Special Masters Reports submitted to the Court and Plaintiffs. Any such Confidential Graphics included in the Special Masters Reports must be redacted in the public report as filed, and the unredacted reports will be filed under seal. Only the Confidential Graphics in the Special Masters Report shall be redacted.

         G. Confidential Graphics may be publicly filed in unredacted form in the Special Masters Reports only upon written agreement by the parties and further Order of this Court.

         H. Confidential Graphics shall be redacted from copies of the reports by the Special Masters that are made available to the general public. Only the Confidential Graphics in the Special Masters Report shall be redacted. The counsel for plaintiffs shall receive unredacted copies of the reports.

         I. The Confidential Graphics produced pursuant to this Protective Order may not be used for any purpose other than preparation of the Special Masters' Reports.

         J. Prior to the dissemination of any Confidential Graphics to the Special Masters pursuant to this Protective Order, counsel for Defendant shall inform the Special Masters of the terms and conditions of this Protective Order and secure each Special Master's written, faxed, or emailed agreement to be bound by it. The written agreement will be produced to counsel for the Plaintiff.

         K. The Special Masters shall take reasonable precautions to prevent the unauthorized or inadvertent ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.