Reginald Smith v. County of Los Angeles et al

Filing 129

PROTECTIVE ORDER RE PRODUCTION OF ROBERT GRANILLO CONTACT INFORMATION by Magistrate Judge Patrick J. Walsh 127 . SEE ORDER. (im)

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2:11-cv-10666-DDP-PJW Document 127-1 Filed 03/12/15 Page 1 of 3 Page ID
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KAMALA D. HARRIS

Attorney General of California
JENNIE M. KELLY
Supervising Deputy Attorney General
ERNESTO J. FONG
Deputy Attorney General
State Bar No. 192899
300 South Spring Street, Suite 1702
Los Angeles, CA 90013
Telephone: [phone]
Fax: [phone]
E-mail Ernesto.Fongdoj .ca.gov
:
Attorneys for Custodian of Records of the
California Department of Corrections and
Rehabilitation

FILED

JA-B KL . S. DISTRICT COURT

MAR 1 2 2015
RN IA

W. COOK
Attorney at Law
3435 Wilshire Blvd., Suite 2910
Los Angeles, CA 90010
213)2g2-9444
~213) 252-0091 facsimile
A ttorney for Plaintiff
DONALD

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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REGINALD LENARD SMITH,
Individually and as a class
representative,

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V.

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STIPULATED PROTECTIVE
ORDER REGARDING
Plaintiff, PRODUCTION OF ROBERT
GRANILLO CONTACT
INFORMATION

COUNTY OF LOS ANGELES, LOS
ANGELES COUNTY SHERIFF’S
DEPARTMENT, CITY OF LOS
ANGELES, LOS ANGELES
POLICE DEPARTMENT, LEE
BACA, DOES 1 through 102 both their
personal and official capacities

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Defendants.
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CV1 1-10666 DDP (PJWx)

as 2:11-cv-10666-DDP-PJW Document 127-1 Filed 03/12/15
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Upon the stipulation filed by Plaintiff and non-party California Department of

2 Corrections and Rehabilitation ("CDCR") and good cause appearing therefore,
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IT IS HEREBY ORDERED, as follows:

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This Stipulated Protective Order shall govern the use and disclosure of the last

5 known address and telephone number (but not the birth date) of retired Parole
6 Agent Robert Granillo ("Granillo Information").
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1. Under no circumstances shall the Granillo Information be used in any

8 proceeding other than the instant case, or be disseminated, in any form, except by
9 court order.
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2. Disclosure of Granillo 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 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) Experts or consultants retained to work on this case by counsel for

16 any part to this case; and
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(e) Investigators retained by counsel for any party to this case, as

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3. Plaintiff’s counsel shall not provide the Granillo Information to Plaintiff,

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4. Counsel for any party to this action shall advise those individuals to

22 whom disclosure of the Granillo Information is to be made of the contents of this
23 Stipulated Protective Order. Counsel shall obtain the agreement of such individual
24 that he or she will be bound by this Stipulated Protective Order. In the event such
25 individual does not agree to be bound by the Stipulated Protective Order, no
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disclosure of the Granillo Information will be made to such individual.

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5.

Any counsel, expert, consultant or investigator retained by counsel for

any party to this case shall not refer to the Granillo Information in any other court

3 proceeding subject to further order of this court.
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6. If a party learns that, by inadvertence or otherwise, it has disclosed the

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Granillo Information to any person or in any circumstance not authorized under this

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Stipulated Protective Order, the party must immediately (a) notify in writing to

7 counsel for the California Department of Corrections and Rehabilitation, (b) use its
8 best efforts to retrieve all copies of the Granillo Information, and (c) inform the
9 person or persons to whom unauthorized disclosures were made of all the terms of
10 this Stipulated Protective Order.
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7. This Stipulated Protective Order, and the obligations of all persons

12 thereunder, including those relating to the disclosure and use of the Granillo
13 Information, shall survive the final termination of this case, whether such
14 termination is by settlement, judgment, dismissal, appeal or otherwise, until further
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order of the court.
8. Nothing in this Stipulated Protective Order is intended to prevent

17 authorized individuals from having access to the Granillo Information if they would
18 have had access in the normal course of their duties.
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IT IS SO ORDERED.

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IL

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HON. PATRICK J. WALSH
U.S. MAGISTRATE JUDGE

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L 20 10502970
--AProposed Stipulated Protective Order (GranilIo).doc

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