James Nolan v. Los Angeles City of, et al

Filing 766

PROTECTIVE ORDER FOR PRODUCTION OF DOCUMENTS by Magistrate Judge Andrew J. Wistrich, re: Stipulation for Protective Order, 765 . (mz)

James Nolan v. Los Angeles City of, et al

Doc. 766

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A Professional Law Corporation 6033 W. Century Boulevard, Suite 500 Los Angeles, CA 90045

zBrian P. Walter, Bar No. 171429 [e-mail] Geoffrey S. Sheldon, Bar No. 185560 [e-mail] Ingrid B. Cobb, Bar No. 178859 [e-mail] T. Oliver Yee, Bar No. 237057 [e-mail] LIEBERT CASSIDY WHITMORE A Professional Law Corporation 6033 W. Century Boulevard, Suite 500 Los Angeles, CA 90045 Telephone: [phone] Facsimile: [phone] Carmen A. Trutanich, City Attorney, Bar No. 86629 Daniel Aguilera, Deputy City Attorney, Bar No. 108159 LOS ANGELES CITY ATTORNEY'S OFFICE 200 North Main Street, Room 700, City Hall East Los Angeles, CA 90012-4131 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant CITY OF LOS ANGELES UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA JAMES NOLAN, Plaintiff, v. CITY OF LOS ANGELES and DOES 1 through 10, Defendant. Case No. CV 03-2190 GAF (AJWx) [Assigned to the Honorable Gary A. Feess, Courtroom 740] PROTECTIVE ORDER FOR PRODUCTION OF DOCUMENTS

LIEBERT CASSIDY WHITMORE

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Having considered the parties' Stipulation Re: Protective Order for Production of Documents ("Stipulation"), and good cause appearing, the Court orders as follows: 1. That all documents produced by Defendant in discovery, including but
[PROPOSED] PROTECTIVE ORDER FOR PRODUCTION OF DOCUMENTS
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not limited to, documents produced and/or identified in Defendant's initial
416449.1 LO160-026

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A Professional Law Corporation 6033 W. Century Boulevard, Suite 500 Los Angeles, CA 90045

disclosures, supplemental disclosures, and responses to Plaintiffs' written discovery requests that contain a third party's private, confidential information, including but not limited to, third parties' names, phone numbers, addresses, social security numbers, arrest information, discipline, wages and similar information, some of which may be protected by California Penal Code sections 832.5 and 832.7, and California Evidence Code section, 1040 et seq., shall be kept strictly confidential and may only be examined by the attorneys for the parties, their agents, employees, consultants, witnesses, court reporters, deponents, the parties themselves, and/or the Court, and only in connection with this subject litigation, and shall not be published to any third parties or used in connection with any other litigation. 2. That in the event that either party uses such documents at trial or for pre-trial motion, or any other motion or filing, the parties may file protected documents so long as all protected information of third parties is redacted. Either party may seek a protective order to place such documents under seal or have them stricken based on failure to redact protected information. 3. After the conclusion of this litigation, the parties will return all documents subject to this Stipulation within 45 calendar days without awaiting the other parties' request. IT IS SO ORDERED.

LIEBERT CASSIDY WHITMORE

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DATED: 10/26/10

_________________________________ HONORABLE ANDREW J. WISTRICH Judge of the United States District Court

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[PROPOSED] PROTECTIVE ORDER FOR PRODUCTION OF DOCUMENTS