United States District Court, C.D. California
Armando Quezada, Catalina De Quezada, R.V., M.Q., and A.Q.C, Plaintiff,
CITY OF LOS ANGELES, LAPD CHIEF CHARLES BECK, individually and in his official capacity, LAPD DETECTIVE JUAN TOPETE, #27454, individually and in his official capacity, LAPD OFFICER GABRIEL BUCKNELL, #35961, individually and in his official capacity, LAPD OFFICER BRISCOE, #39133, individually and in his official capacity, LAPD OFFICER LUKE BENNETT, #38384, individually and in his official capacity, LAPD OFFICER MIRANDA, #39874, individually and in his official capacity, LAPD DETECTIVE WILBUR, #33756, individually and in his official capacity, LAPD DETECTIVE MUNOZ, #27719, individually and in his official capacity, AND DOES 1-20, Defendants.
COHEN TREYZON SALO, LLP, Boris Treyzon, Esq. Meagan Melanson,
Esq. Attorneys for Plaintiffs
MICHAEL N. FEUER, City Attorney, THOMAS H. PETERS, Chief
Assistant City Attorney CORY M. BRENTE, Senior Assistant City
D. WRIGHT, JUDGE.
PATRICK J. WALSH 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
Angeles Police Department conducted a non-categorical use of
force investigation and internal affairs investigation, both
internal investigations, into this matter. As part of the
investigation compelled statements were taken from police
officers. Such information is obtained through the
administrative investigation of this matter by the LAPD and
maintained as confidential peace officer personnel records
and utilized for administrative issues. A protective order is
appropriate for this information and related documents as
such internal investigations can be used to ascertain if
police policies and procedures in such areas as supervision,
training, tactics, policies, etc., should be modified. These
internal investigations are an essential aid to providing a
critical, self-evaluation of LAPD officers and policies and
accordingly serve the residents of Los Angeles.
reports, a 911 call, police radio communication and documents
describing said information, were also generated as part of
the incident. These documents and audio contain confidential,
personal information for unrelated third-parties. A
protective order is appropriate for this information and all
third-party information, to protect their privacy and prevent
embarrassment or humiliation for persons not involved in this
LAPD use of force investigations and internal affairs
complaint investigations may, at some point, also be produced
as a part of discovery in this litigation. For identical
reasons as those listed in the first paragraph of this
section, a protective order is appropriate for any such
information which may be produced as a part of this
medical records for Plaintiff may be produced as discovery in
this litigation. Any medical records would inherently contain
confidential, private information. A protective order is
appropriate for any medical records produced in this
litigation to prevent humiliation, embarrassment and a breach
of confidential medical information.
Action: This pending federal lawsuit, Armando Quezada, v.
City of Los Angeles,,
Challenging Party: a Party or Non-Party that challenges the
designation of information or items under this Order.
“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 in
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 matter.
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
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
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 ...