United States District Court, C.D. California
AMELIA SANCHEZ, et. al, Plaintiffs,
CITY OF EL MONTE; and DOES 1-10 inclusive Defendants.
[PROPOSED] PROTECTIVE ORDER
RE HOMICIDE BOOK COMPILED BY THE LOS ANGELES COUNTY
SHERIFF'S DEPARTMENT, HOMICIDE BUREAU
J. WISTRICH, UNITED STATES MAGISTRATE JUDGE
IS HEREBY ORDERED, ADJUDGED AND DECREED that: The
Los Angeles County Sheriff's Department
(“LASD”) is producing, pursuant to a subpoena
duces tecum, documents deemed confidential by LASD,
under Federal and California State Law. These documents are
compiled in an LASD's “Homicide Book.” Such
documents shall hereinafter be referred to as
“Confidential Information.” The Plaintiffs do not
deem these documents to be “confidential information,
” although Plaintiffs acknowledge some may be of a
confidential nature, but to avoid further delay and dispute,
Plaintiffs accept these conditions, reserving the right to
seek judicial determination within 90-days of receipt of the
documents by submitting any item in dispute for an in-camera
review and determination by the Court.
agree that should they move for further order regarding
determination of the “confidentiality” of a
document, Plaintiffs will first meet and confer with LASD in
an effort to jointly resolve any issue in dispute before
requesting an in-camera review and determination by the
Court orders that the following terms and conditions of this
Protective Order shall govern the use and disclosure of
Confidential Information and information derived therefrom
until further order of the Court.
investigation of an Officer Involved Shooting of December 23,
2016 by the Los Angeles County Sheriff's Department -
Homicide Bureau, is subject to the terms of this protective
order. The investigation contained in the “Homicide
Book” is part of an ongoing criminal investigation that
is confidential official information. The disclosure of the
documents in the Homicide Book pursuant to Rule 26 discovery
rules are to be designated as “CONFIDENTIAL
INFORMATION.” Such designation shall be made by
stamping or otherwise marking the documents prior to
production or use in this litigation as follows:
MATERIAL SUBJECT TO PROTECTIVE ORDER”
labeled “CONFIDENTIAL INFORMATION” shall be used
solely in connection with the preparation and trial of the
within, Case No. 2:17-cv-03235 GW (AJW); consolidated
with Case No. EDCV 17-971 GW (AJWx) or any related
appellate proceeding, and not for any other purpose,
including any other litigation.
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 shall be used only
for the purpose of the prosecution, defense or settlement of
this action, and for no other purpose.
CONFIDENTIAL INFORMATION may not be disclosed, except as
provided in paragraphs 5, 6 and 7.
CONFIDENTIAL INFORMATION may be disclosed only to the
(a) Counsel for any party and any party to this litigation;
(b) Paralegal, stenographic, clerical and secretarial
personnel regularly employed by counsel referred to in (a).
(c) Court personnel, including stenographic reporters engaged
in such proceedings as are necessarily incidental to
preparation for the trial of this action;
(d) Any outside expert or consultant retained in connection
with this action, and not otherwise employed ...