United States District Court, C.D. California
LUIS RANERO; and JASMIN RANERO, in each individually, Plaintiffs,
COUNTY OF SAN BERNARDINO and DOES 1-10, inclusive, Defendant
OFFICES OF DALE K. GALIPO AARON MEYER LAW, Dale K. Galipo,
Esq., Renee V. Masongsong, Esq., Aaron Meyer, Esq., Attorneys
BRISBOIS BISGAARD & SMITH LLP, Dana A. Fox, Esq. Barry
Hassenburg, Esq. Wiener Cadet, Esq., Attorneys for Defendant,
County of San Bernardino.
Consuelo B. Marshall Judge.
Kenly Kiya Kato United States Magistrate Judge.
PURPOSES AND LIMITATIONS
in this action is likely to involve production of
confidential, proprietary, or private information for which
special protection from public disclosure and from use for
any purpose other than prosecuting this litigation may be
warranted. Accordingly, the parties hereby stipulate to and
petition the Court to enter the following Stipulated
Protective Order. 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 items that are entitled to confidential
treatment under the applicable legal principles. The parties
further acknowledge, as set forth in Section 12.3, 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.
GOOD CAUSE STATEMENT
action will involve law enforcement tactics, procedures,
training, regulations, personnel, investigations and rules
for which special protection from public disclosure and from
use for any purpose other than prosecution of this action is
warranted. Such confidential and proprietary materials and
information consist of, among other things, certain documents
maintained by the San Bernardino County Sheriff's
Department (“SBCSD”) and/or the San Bernardino
County District Attorney (“SBCDA”), which include
internal policies and procedures, internal training
materials, internal affairs investigation files, criminal
investigation files, personnel files of current and/or former
SBCSD officers, and other documents and information which
implicate the privacy rights of parties and non-parties,
which information is generally unavailable to the public and
which is privileged or otherwise protected from disclosure
under state and federal statutes, court rules, case
decisions, or common law.
to expedite the flow of information, to facilitate the prompt
resolution of disputes over confidentiality of discovery
materials, to adequately protect information the parties are
entitled to keep confidential, to ensure that the parties are
permitted reasonable necessary uses of such material in
preparation for and in the conduct of trial, to address their
handling at the end of the litigation, and serve the ends of
justice, a protective order for such information is justified
in this matter. It is the intent of the parties that
information will not be designated as confidential for
tactical reasons and that nothing be so designated without a
good faith belief that it has been maintained in a
confidential, non-public manner, and there is good cause why
it should not be part of the public record of this case.
Action: this pending federal law suit, Luis
Ranero and Jasmine Ranero v. County of San Bernardino, et
al., case number 5:16-cv-02655-CBM-DTB.
Challenging Party: a Party or Non-Party that
challenges the designation of information or items under this
“CONFIDENTIAL” Information or Items:
information (regardless of how it is generated, stored or
maintained) or tangible things that qualify for protection
under Federal Rule of Civil Procedure 26(c), and as specified
above in the Good Cause Statement.
Counsel: Outside Counsel of Record and House Counsel
(as well as their support staff).
Designating Party: a Party or Non-Party that
designates information or items that it produces in
disclosures or responses to discovery as
“CONFIDENTIAL.” 2.6 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
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.
House Counsel: attorneys who are employees of a
party to this Action. House Counsel does not include Outside
Counsel of Record or any other outside counsel.
Non-Party: any natural person, partnership,
corporation, association, or other legal entity not named as
a Party to this action.
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, and
includes support staff.
Party: any party to this Action, including all of
its officers, directors, employees, consultants, retained
experts, and Outside Counsel of Record (and their support
Producing Party: a Party or Non-Party that produces
Disclosure or Discovery Material in this Action.
Professional Vendors: persons or entities that
provide litigation support services (e.g., photocopying,
videotaping, translating, preparing exhibits or
demonstrations, and organizing, storing, or retrieving ...