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Anderson v. City of Rialto

United States District Court, C.D. California, Central Division

May 22, 2017

GLEN ANDERSON, Plaintiff,
v.
CITY OF RIALTO, a municipal corporation, CITY OF RIALTO POLICE DEPARTMENT, RANDY DE ANDA, individually and in his capacity as the Chief of Police for the RIALTO Police Department, Defendants.

          Zahra Khoury Attorneys for Plaintiff Glen Anderson

          Mark Meyerhoff James Oldendorph Attorneys for Defendants City of Rialto, and Chief Randy De Anda

          STIPULATED PROTECTIVE ORDER [NOTE CHANGE MADE BY THE COURT IN¶ 6.3]

         1. PURPOSES AND LIMITATIONS

         The parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order as it pertains to the Protected Material specifically identified in Section 5.1 below. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or item(s) identified at Section 5.1, below, which is entitled to confidential treatment under the applicable legal principles. The parties further acknowledge, as set forth in Section 10.3, below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to file material under seal.

         2. DEFINITIONS

         2.1 Challenging Party:

         a Party or Non-Party that challenges the designation of information or items under this Order.

         2.2 “CONFIDENTIAL”

         Information or Items: information or tangible things identified in Section 5.1 below.

         2.3 Counsel (without qualifier):

         Outside Counsel of Record and In-House Counsel (as well as their support staff).

         2.4 Designating Party:

         a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

         2.5 Disclosure or Discovery Material:

         all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter.

         2.6 Expert:

         a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action.

         2.7 House Counsel:

         attorneys who are employees of a party to this action. In-House Counsel does not include Outside Counsel of Record or any other outside counsel.

         2.8 Non-Party:

         any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action.

         2.9 Outside Counsel of Record:

         attorneys who are not employees of a party to this action but are retained to represent or advise a party to this action and have appeared in this action on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.

         2.10 Party:

         any party to this action and their ...


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