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Borawick v. City of Los Angeles

United States District Court, C.D. California

October 30, 2017

MARINA BORAWICK, Plaintiff,
v.
CITY OF LOS ANGELES, ET AL., Defendants.

          PROTECTIVE ORDER FOR FILES PRODUCED BY THE PARTIES IN DISCOVERY [CHANGES MADE BY COURT TO PARAGRAPHS 1, 5, 8, 9, 10]

          HONORABLE JACQUELINE CHOOLJIAN U.S. MAGISTRATE JUDGE

         Based upon the Stipulation of the Parties and, GOOD CAUSE APPEARING, IT IS ORDERED THAT, 1. This order will allow the parties to designate materials as Confidential Information when they are newly disclosing information not available from other sources to the extent appropriate.

         2. Under the terms of this Order, the party designating Confidential Information is certifying to the Court that there is a good faith basis both in law and in fact for the designation within the meaning of Federal Rule of Civil Procedure 26(c).

         3. Confidential documents shall be so designated by stamping copies of the document or material produced by a party with the legend "CONFIDENTIAL" or “SUBJECT TO PROTECTIVE ORDER”. Stamping the legend "CONFIDENTIAL" or “SUBJECT TO PROTECTIVE ORDER” on the cover of any multi-page document or any multi-volume material, shall designate all pages of the document and all volumes of the material as confidential, unless otherwise indicated by the producing party.

         4. Testimony taken at a deposition may be designated as “Confidential” by making a statement to that effect on the record at that specific deposition and at the time the testimony is given. Arrangements shall be made with the court reporter transcribing the deposition to separately bind such portions of the transcript containing information designated as “Confidential”, and to label such portions appropriately.

         5. Absent further order of the Court, material designated as "Confidential" under this Order, the information contained therein, and any summaries, copies, abstracts, or other documents derived in whole or in part from material designated as Confidential (hereinafter "Confidential Material") shall be used solely for the purpose of litigating this action, and for no other action or purpose. Working or file copies of Confidential Material shall be stored and/or handled in a manner which will prevent the unauthorized disclosure thereof.

         6. Confidential Material produced in this action may be disclosed or made available to the following persons (hereinafter "Qualified Persons"):

         a. Each lawyer for a party in this action, including outside and in-house lawyers and other lawyers regularly employed in their offices, and such lawyers' staff to whom it is necessary that materials be disclosed for purposes of this litigation, including paralegals, assistants, law clerks, secretaries, and document clerks;

         b. Each party, partner, officer, director, agent, or employee of a party deemed necessary by counsel to work on this action;

         c. Independent experts or consultants retained by counsel for the purpose of assisting in this litigation, including their staff to whom it is necessary that materials be disclosed for purposes of this litigation, but only to the extent necessary for such expert or consultant to perform his or her assigned tasks in connection with this litigation;

         d. Any party-affiliated witness in preparation for his or her deposition or testimony at trial or a hearing in this litigation, with the written agreement of the party that marked the information confidential;

         e. Mediators, arbitrators, or similar outside parties and their staffs enlisted by all parties to assist in the resolution of this litigation;

         f. The Court and its personnel;

         g. Court reporters and stenographers ...


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