Joshua B Shapiro v. Thomas Anderson et al

Filing 118

ORDER ON STIPULATION FOR PROTECTIVE ORDER REGARDING DISCLOSURE OF LAW ENFORCEMENT PERSONNEL RECORDS AND RELATED DOCUMENTS by Magistrate Judge John E. McDermott. PURSUANT to the stipulation of the parties 116 , and good cause appearing there for, the following Protective Order is ordered by the Court. IT IS SO ORDERED. (See Order For Further Details) (kl)

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COLLINSON LAW
A Professional Corporation
Laura E. Inlow, State Bar No. 130584
E-mail: [e-mail]
21515 Hawthorne Blvd., Suite 800
Torrance, California 90503
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants, COUNTY OF LOS ANGELES, SERGIO FLORES and
THOMAS ANDERSON

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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JOSHUA SHAPIRO,

v.

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COLLINSON LAW

A PROFESSIONAL CORPORATION
21515 HAWTHORNE BLVD., SUITE 800
TORRANCE, CALIFORNIA 90503
TEL. [phone] | FAX [phone]

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CASE NO.: CV12-06852 JAK (JEM)

ORDER ON STIPULATION FOR
PROTECTIVE
ORDER REGARDING DISCLOSURE
OF LAW ENFORCEMENT
PERSONNEL RECORDS AND
RELATED DOCUMENTS

Plaintiff,

DEPUTY SHERIFF, THOMAS
ANDERSON, in his individual
capacity, COUNTY OF LOS
ANGELES SHERIFF’S
DEPARTMENT; SGT. SERGIO
FLORES, in his individual capacity,

Action Filed: August 16, 2012
Trial Date: None Set

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Defendants.
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ORDER

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PURSUANT to the stipulation of the parties, and good cause appearing

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there for, the following Protective Order is ordered by the Court.

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Defendants shall produce the following documents:

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1.

Redacted, if necessary to protect non-parties and other privileged and

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confidential information, copies of all records or reports filed, pending, completed,

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and/or otherwise made in connection with incident involving plaintiff on January

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-1ORDER ON STIPULATION FOR PROTECTIVE ORDER REGARDING DISCLOSURE OF LAW
ENFORCEMENT PERSONNEL RECORDS AND RELATED DOCUMENTS

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1, 2012, or a declaration of the custodian of records that no such documents exist.

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The names and other personal identifying information as to any law enforcement

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personnel other than employees of defendants shall be redacted from such report

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prior to production.

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2.

Redacted copies of the Personnel Files of defendants as may be

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ordered by the Court following the appropriate motion by plaintiff and an in

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camera review by the Court.

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COLLINSON LAW

A PROFESSIONAL CORPORATION
21515 HAWTHORNE BLVD., SUITE 800
TORRANCE, CALIFORNIA 90503
TEL. [phone] | FAX [phone]

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IT IS FURTHER ORDERED:

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1.

Plaintiff shall not convey, transfer, publish, distribute, copy, duplicate,

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or disseminate the records so produced, or information from such records so

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produced, except as may be reasonably necessary for the prosecution of this

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litigation by communicating with investigators, consultants and experts retained on

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behalf of the plaintiff in this matter.

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2.

Prior to dissemination of any confidential material produced pursuant

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to this order to investigators, consultants or experts retained on behalf of plaintiff,

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plaintiff shall inform such persons of the terms and conditions of the order and

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secure such person’s agreement, in writing, to be bound by it.

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3.

Copies of any records produced to plaintiff pursuant to this order shall

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be distinctively marked, provided that such marking does not obscure or obliterate

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the content of any record and may be stamped with the following language:
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ORDER ON STIPULATION FOR PROTECTIVE ORDER REGARDING DISCLOSURE OF LAW
ENFORCEMENT PERSONNEL RECORDS AND RELATED DOCUMENTS

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“CONFIDENTIAL – UNLAWFUL TO DUPLICATE”.

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4.

In the event of dissemination of any confidential materials produced

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pursuant to this order, copies of said materials must also bear the following

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language:

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“CONFIDENTIAL – UNLAWFUL TO DUPLICATE”.

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5.

Upon final conclusion of the present litigation, all copies (by

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whomever made) of materials ordered disclosed pursuant to this order shall be

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returned to counsel for defendants, who will then return them to the appropriate

COLLINSON LAW

A PROFESSIONAL CORPORATION
21515 HAWTHORNE BLVD., SUITE 800
TORRANCE, CALIFORNIA 90503
TEL. [phone] | FAX [phone]

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authorities of the Los Angeles County Sheriff’s Department or shall destroy said

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documents, at defendants' option.

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6.

This Stipulation shall not preclude plaintiff from presenting any and

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all evidence at trial, subject to all available and legitimate trial objections, and shall

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not preclude; limit and/or interfere with the plaintiff’s rights to any and all further

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discovery.

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7.

Copies of the records and information contained therein produced

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pursuant to this order shall not be used for any other purpose than in connection

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with this litigation.

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8.

In the event any party deems it necessary to file copies or a portion of

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copies of any documents covered by the Stipulation, all parties agree to meet and

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confer prior to filing such documents to reach an agreement or seek the court's

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ruling, if necessary, as to whether such d-3cuments (s) shall be lodged under seal.
oORDER ON STIPULATION FOR PROTECTIVE ORDER REGARDING DISCLOSURE OF LAW
ENFORCEMENT PERSONNEL RECORDS AND RELATED DOCUMENTS

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9.

In the event anyone shall violate or threaten to violate any terms of

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this Stipulation, the aggrieved party may immediately apply to obtain injunctive

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relief and other sanctions to this court against any such person violating or

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threatening to violate any of the terms of this Stipulation. This Court shall retain

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jurisdiction over the parties and any other persons subject to the terms of this

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Stipulation for the purpose of enforcing it. The Court shall have the power to

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impose whether penalties it deems appropriate for the violation of said Stipulation,

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including, but not limited, monetary and judicial sanctions and contempt.

COLLINSON LAW

A PROFESSIONAL CORPORATION
21515 HAWTHORNE BLVD., SUITE 800
TORRANCE, CALIFORNIA 90503
TEL. [phone] | FAX [phone]

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10.

The stipulated protective order shall survive the final termination of

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this action, to the extent that the information or documents disclosed remains

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confidential and does not become known to the public, and the court shall retain

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jurisdiction to resolve any dispute concerning the use of the information or

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documents disclosed herein.

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11.

All personal indentifying information shall be redacted without waiver

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to any party’s rights to subsequently seek disclosure of such redacted information

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for good cause shown.

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IT IS SO ORDERED.

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DATED: March 11, 2015
Honorable John E. McDermott
United States Magistrate Judge

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-4ORDER ON STIPULATION FOR PROTECTIVE ORDER REGARDING DISCLOSURE OF LAW
ENFORCEMENT PERSONNEL RECORDS AND RELATED DOCUMENTS