Christian Rodriguez et al v. City of Los Angeles et al

Filing 155

PROTECTIVE ORDER by Magistrate Judge John E. McDermott re Stipulation for Protective Order 154 . [See Order for details.] (san)

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DAVIS WRIGHT TREMAINE LLP
KELLI L. SAGER (SBN 120162)
[e-mail]
ROCHELLE L. WILCOX (SBN 197790)
[e-mail]
865 S. Figueroa Street, Suite 2400
Los Angeles, CA 90017-2566
Telephone: [phone]
Fax: [phone]

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LOS ANGELES TIMES
7 COMMUNICATIONS LLC
JEFF GLASSER (SBN 252596)
8 202 West First Street
Los Angeles, CA 90012
9 Telephone: [phone]
Fax: [phone]

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MICHAEL N. FEUER
City Attorney (SBN 111529x)
THOMAS H. PETERS
Chief Assistant City Attorney
CORY M. BRENTE
Assistant City Attorney
RENA M. SHAHANDEH
Attorneys for Intervenor LOS ANGELES
Deputy City Attorney (SBN 198072)
TIMES COMMUNICATIONS LLC
Police Litigation Section
600 City Hall East, 200 North Main St.
Los Angeles, CA 90012-4119
OLU K. ORANGE (SBN 213653)
Telephone: [phone]
[e-mail]
Fax: [phone]
ORANGE LAW OFFICES
3435 Wilshire Blvd., Suite 2900
Attorneys for Defendants
Los Angeles, CA 90010
CITY OF LOS ANGELES, CARMEN
Telephone: [phone]
TRUTANICH, CHARLES BECK, AND
Fax: [phone]
ANGEL GOMEZ

Attorneys for Plaintiffs
CHRISTIAN RODRIGUEZ, ALBERTO
CAZAREZ, individually and as class
18 representatives
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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Plaintiffs,
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vs.
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CITY OF LOS ANGELES, CARMEN )
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TRUTANICH, CHARLES BECK,
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ANGEL GOMEZ, AND DOES 1
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THROUGH 10,
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Defendants.
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CHRISTIAN RODRIGUEZ,
ALBERTO CAZAREZ, individually
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Case No. CV11-01135 DMG (JEMx)
[PROPOSED] ORDER RE:
PRODUCTION OF DOCUMENTS
AND MODIFICATION OF
PROTECTIVE ORDER

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[PROPOSED] ORDER RE PRODUCTION OF DOCUMENTS
DWT 24082962v6 0026175-000417

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This matter came before the Court on the “Stipulation Re Production of

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Documents and Modification of Protective Order” (the “Stipulation”) submitted by

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Non-Party Intervenor Los Angeles Times Communications LLC (“The Times”),

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Plaintiffs Christian Rodriguez and Alberto Cazarez, individually and as class

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representatives (“Plaintiffs”), and Defendants the City of Los Angeles (“City”),

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Carmen Trutanich , Charles Beck, Allan Nadir, and Angel Gomez, on the third hand

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(“Defendants”) (collectively, the “Parties”). The Stipulation is filed pursuant to an

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Order entered by this Court on February 19, 2013, in response to The Times’ Motion

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to Modify the Protective Orders issued by this Court on November 21, 2011, and

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December 5, 2011, to permit release of gang injunction service and arrest records that

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have been produced in pretrial discovery (the “Records”), following the meet-and-

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confer required by that Order.

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The Court having reviewed and considered the Stipulation and the papers

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submitted in connection with The Times’ previously-filed Motion to Modify the

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Protective Orders, and good cause having been shown:

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IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows:

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1) The Protective Orders in this matter are modified to allow release of the

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Records subject to the redactions described in Paragraph (3), below.

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2) The City shall produce the Records to The Times in the form described in

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Paragraph (3), below, in the timeframe described in Paragraphs (4) and (5),

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below.

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3) The Records shall not be edited or modified by the City in any way prior to

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production, except that the City may redact only the following information

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from the Records:

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a. Driver’s license numbers;

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b. Social Security numbers;

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c. Names of juveniles;

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d. Medical information;
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[PROPOSED] ORDER RE PRODUCTION OF DOCUMENTS
DWT 24082962v6 0026175-000417

DAVIS WRIGHT TREMAINE LLP
865 S. FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

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e. Residential street addresses, although the city, state and zip code of
any residences shall not be redacted;

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f. Names of associates of arrested or enjoined individuals; and,

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g. Names of witnesses.

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4) The City will produce the Records to The Times on a rolling basis every
two weeks, beginning two weeks from the date of entry of this stipulation.
5) The City will complete its review and production of the Records to The
Times within 90 days of the date of entry of this stipulation.

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6) Upon receipt of any record, The Times will have thirty days to challenge

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any redactions to a document by filing an objection with this Court. The

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City will have two weeks to respond to any objection filed by the Times.

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7) In the event this litigation is resolved before resolution of all issues related

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to production of the Records, the Court will retain jurisdiction over this

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matter until thirty (30) days after the production of the Records to The

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Times is completed, unless any objections are pending at that time, in

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which case the Court will retain jurisdiction until those objections are

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resolved.

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IT IS SO ORDERED.
DATED: July 10, 2014

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Honorable John E. McDermott
United States Magistrate Judge
For the Central District of California

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[PROPOSED] ORDER RE PRODUCTION OF DOCUMENTS
DWT 24082962v6 0026175-000417

DAVIS WRIGHT TREMAINE LLP
865 S. FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]