Leocadio Figueroa v. County of Los Angeles et al

Filing 309

PROTECTIVE ORDER by Magistrate Judge Frederick F. Mumm re Stipulation for Protective Order 308 : (see attached) (jm)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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LEOCAUDIO FIGUEROA,

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Plaintiff,
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v.
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COUNTY OF LOS ANGELES, et al., )
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Defendants.
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No. CV 11-6228 DMG (FFM)
PROTECTIVE ORDER PURSUANT TO
STIPULATION

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Pursuant to the stipulation of the parties, and good cause having been shown

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therefor, the Court enters the following protective order which shall govern the witness

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statements in the underlying criminal prosecution in CR 13-574 produced in this action:

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1.

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Any documents, including recordings or writings, sought by Plaintiffs’

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counsel pertaining to witness statements in the underlying criminal prosecution in CR

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13-0574, U.S. v. Eric Gonzales, Noel Womack, et al. are to be designated as

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“confidential material.”

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2.

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trial of the within case, Number 11-06228 DMG (FFMx) or any related appellate

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proceeding, and not for any other purpose, including any other litigation.

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Confidential material shall be used solely in connection with the preparation and

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3.

Confidential material may not be disclosed except as provided in paragraph 4.

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4.

Confidential material may be disclosed only to the following persons:

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(a) Counsel for any party to this litigation.

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(b) Paralegal, stenographic, clerical and secretarial personnel regularly employed

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by counsel referred to in (a).
(c) Court personnel, including stenographic reporters engaged in such proceedings

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as are necessarily incidental to preparation of the trial to this action.
(d) Any outside expert or consultant retained in connection with this action, and

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not otherwise employed by either party.

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Paragraph 4 is expressly intended to insure that confidential records that come into the

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hands of individuals pursuant to the Court’s ruling maintain their confidentiality and

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may not be disseminated or made part of the public record, except as may be admissible

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for trial.

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5.

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is to be made, shall, prior to the time of disclosure, be provided by the person furnishing

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him/her such material a copy of this order, and shall agree on the record, if any, or in

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writing that s/he has read the protective order and that s/he understands its provisions.

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Such person must also consent to be subject to the jurisdiction of the United States

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District Court with respect to any proceeding relating to the enforcement of this order,

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including without limitation, any proceeding for contempt. Unless made on the record in

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this litigation, counsel making the disclosure to any person described above shall retain

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the original executed copy of said agreement until final termination of this litigation.

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6.

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are presented to this or any other court in any other manner prior to the time of trial,

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pursuant to Local Rule 79-5.1, said information and/or documents shall be lodged under

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seal in an envelope clearly marked as follows: “Confidential Material Subject To A

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Protective Order.”

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Each person to whom disclosure of confidential employment or personnel records

If any information and/or documents which are the subject of this Protective Order

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7.

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litigation, all confidential materials received under the provisions of this order (including

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any copies made and/or any computer materials made or stored) shall be tendered back to

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Plaintiff’s counsel. Provisions of this order insofar as they restrict the disclosure and use

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of this material shall be in effect until further order of this Court.

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8.

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At the conclusion of the trial and of any appeal or upon termination of this

The foregoing is without prejudice to the right of any party:
(a) To apply to the Court for a further protective order relating to confidential

material or relating to discovery in this litigation;
(b) To apply to the Court for an order removing the confidential material
designation from any documents; and
(c) To apply to the Court for an order compelling production of documents.

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IT IS SO ORDERED.

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DATED: June 16, 2017

/S/ FREDERICK F. MUMM
FREDERICK F. MUMM
United States Magistrate Judge

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