Bobby Willis v. Doe 1 et al

Filing 113

PROTECTIVE GOVERNING THE DISCLOSURE OF CONFIDENTIAL INFORMATION PURSUANT TO THE STIPULATION OF THE PARTIES ORDER by Judge Stephen V. Wilson (pj)

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FILED

Henry Patrick Nelson, CSB #32249
Amber A. Logan, CSB #166395
Rina M. Mathevosian, CSB #251423
Nelson & Fulton
Equitable Plaza, Suite 2800
3435 Wilshire Boulevard
Los Angeles, CA 90010-2014
[phone] / Fax[phone]
[e-mail]

CLERK, U.S. DISTRICT COURT

SEP 26 2013
CENTRAL DISTRICT OF CALIFORNIA

PMC
BY: ___________________ DEPUTY

Attorneys for Defendants,

Deputy David Aviles, Deputy Carlos Castillo, and Deputy Adrian Zuniga

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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BOBBY WILLIS,
Plaintiff,

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v.

DEPUTY DAVID AVILES, DEPUTY
CARLOS CASTILLO, DEPUTY
ADRIAN ZUNIGA,
Defendants.

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) CASE NO. CV 10-6357 SVW (JPR)
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) XXXXXXXXXXX PROTECTIVE ORDER
(PROPOSED)
) GOVERNING THE DISCLOSURE OF
) CONFIDENTIAL INFORMATION
) PURSUANT TO THE STIPULATION
) OF THE PARTIES
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The following Protective Order shall govern the disclosure of documents and

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information produced pursuant to the parties Stipulation regarding Disclosure of

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Confidential Information contained in Deputy David Aviles' Deputy Carlos Castillo's, and

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Deputy Adrian Zuniga's personnel files. The parties stipulated and agreed that disclosure

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of Confidential Information contained in Deputy David Aviles' , Deputy Carlos Castillo's,

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and Deputy Adrian Zuniga's personnel files will be limited to complaints of excessive

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force from January 19,2004 to January 19,2009.

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Under no circumstances shall Confidential Information be used in any
proceeding other than the instant case.

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Under no circumstances shall Confidential Information either orally, or by

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written form, be inputted into any computer program or database or listed

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manually in any manual, notebook or other listing as it pertains to law

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enforcement personnel. This does not apply to any computer program or

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case file maintained specifically as to this civil action.

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3.

Disclosure of Confidential Information shall be limited to the personnel

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and/or classification of persons listed below:

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a)

Counsel for any party to this action;

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b)

Staff personnel employed by counsel for any party;

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c)

The court and its personnel, in connection with this litigation;

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d)

Witnesses and jury at trial.

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4.

Plaintiffs counsel shall not provide to the plaintiff, either orally or in

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writing, with the addresses and telephone numbers of persons identified

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within the Confidential Information, but Plaintiffs counsel may discuss the

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information obtained from any investigation conducted with complainants or

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witnesses.

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IT IS SO ORDERED.

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09/26/13
DATED:- - - - - - -

HON. STEPHEN V. WILSON
United States District Court Judge

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