A.P. v. Glendale Unified School District

Filing 30

PROTECTIVE ORDER by Magistrate Judge Frederick F. Mumm re Stipulation for Protective Order 29 : (see attached) (jm)

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NANCY P. DOUMANIAN, ESQ., SBN: 168925
DOUMANIAN & ASSOCIATES
2626 Foothill Boulevard, Suite 250
La Crescenta, California 91214
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant,
GLENDALE UNIFIED SCHOOL DISTRICT, A Public Entity

PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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A.P., a minor, by and through his
guardian ad litem, C.P.

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PROTECTIVE ORDER
REGARDING DISCOVERY
CONCERNING MINOR
PLAINTIFF’S SCHOOL;
MEDICAL AND SPECIAL
EDUCATION RECORDS

Plaintiff,

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CASE NO. 2:16-CV-01404-GW-FFM

v.
GLENDALE UNIFIED SCHOOL
DISTRICT, AND DOES 1-10
inclusive,

(NOTE CHANGES MADE BY
COURT)

Defendants.

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GOOD CAUSE APPEARING, the Court hereby approves this Stipulation
and Protective Order on the following terms:

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1.

THE PARTIES & RELATED PARTIES. This Stipulation is

entered into by and between the following persons or parties:
Plaintiff, A.P., a minor by and through his Guardian ad Litem, C.P., and
their attorneys of record Surisa Rivers of Surisa Rivers Law Office; and
Defendant, GLENDALE UNIFIED SCHOOL DISTRICT, and its attorneys
Nancy Doumanian of Doumanian & Associates.

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-1STIPULATION AND PROTECTIVE ORDER REGARDING DISCOVERY CONCERNING MINOR
PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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2.

SCOPE OF DISCOVERY. Discovery in this matter has or will

occur between the parties, and the parties anticipate that during the course of

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discovery in this litigation documents and information will be requested and

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exchanged that are or will include matters that are privileged, proprietary,

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confidential, private and/or otherwise protected from general and public disclosure.

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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The parties mutually agree and stipulate to the following Protective Order in order

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to facilitate the production and exchange of documents and information between

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them for use through the final disposition of this litigation, whether through award,

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settlement, judgment or appeal.

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In this Stipulation and Protective Order, the words set forth below shall have
the following meanings:
a.

“Proceeding” means the above-entitled proceeding (Case No.

BC562719) and all discovery or information related to the pending lawsuit.
b.

“Court” means the Hon. George H. Wu, or any other judge to which

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this Proceeding may be assigned, including Court staff participating in such

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proceedings.

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c.

“Confidential” means any information which is in the possession of a

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Designating Party who believes in good faith that such information is entitled to

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confidential treatment under applicable law.

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d.

“Confidential Materials” means any Documents, Testimony or

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Information as defined below designated as “Confidential” pursuant to the

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provisions of this Stipulation and Protective Order.
“Designating Party” means the Party that designates Materials as

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e.

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“Confidential.”

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f.

“Disclose” or “Disclosed” or “Disclosure” means to reveal, divulge,

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give, or make available Materials, or any part thereof, or any information contained

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therein.

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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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g.

“Documents” means (i) any “Writing,” “Original,” and “Duplicate” as

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those terms are defined by California Evidence Code Sections 250, 255, and 260,

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which have been produced in discovery in this Proceeding by any person, and (ii)

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any copies, reproductions, or summaries of all or any part of the foregoing.
h.

“Information” means the content of Documents or Testimony.

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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i.

“Testimony” means all depositions, declarations or other testimony

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taken or used in this Proceeding. “Documents” includes any documents sought by

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any party, including without limitation “writings” as defined in California

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Evidence Code Section 250.

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j.

“Education records” means all information about a student that is

maintained by Glendale Unified School District in any recorded way, including:
i.

date and place of birth, parent(s) and/or guardian addresses, and

where parents can be contacted in emergencies;
ii.

grades, test scores, courses taken academic specializations and

activities, and official letters regarding a student’s status in school;

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iii.

Special education records;

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iv.

IEP records or 504 Plan records;

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v.

Records of any School Psychologist or Counselor;

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vi.

The cum file with the School District;

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vii.

School records of any former or current school of either

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Plaintiff.

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viii. Disciplinary records;

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ix.

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and maintains;

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x.

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Medical and health records that the school creates or collects

Any records of any written or other communication between the

school and the family of the plaintiff;
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Documentation of attendance, schools attended, courses taken,

awards conferred, and degrees earned;
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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

xii.

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Personal information such as a student's identification code,

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social security number, picture, or other information that would make it easy

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to identify or locate a student.

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k.

“Medical records” means all information provided by plaintiff’s

health care providers to include any medical doctor, mental health care provider

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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(including any therapist, counsel, psychologist, psychiatrist), or any record of any

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medical or mental health care provider who treated or evaluated the Plaintiff at any

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time.

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3.

The Designating Party, at his/her/its/their option shall have the right to

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designate as “Confidential” any Documents, Testimony or Information that the

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Designating Party in good faith believes to contain non-public information that is

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entitled to confidential treatment under applicable law.

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4.

The entry of this Stipulation and Protective Order does not alter,

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waive, modify, or abridge any right, privilege or protection otherwise available to

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any Party with respect to the discovery of matters, including but not limited to any

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Party’s right to assert the attorney-client privilege, the attorney work product

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doctrine, or other privileges, or any Party’s right to contest any such assertion.

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5.

Any Documents, Testimony or Information to be designated as

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“Confidential” must be clearly so designated before the Document, Testimony or

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Information is Disclosed or produced.

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a.

For Documents (apart from transcripts of depositions or other pretrial

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or trial proceedings), the Designating Party must affix the legend “Confidential” on

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each page of any Document containing such designated Confidential Material.

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b.

For Testimony given in depositions the Designating Party may either:
i.

identify on the record, before the close of the deposition, all

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“Confidential” Testimony, by specifying all portions of the Testimony that

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qualify as “Confidential;” or

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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

ii.

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designate the entirety of the Testimony at the deposition as

“Confidential” (before the deposition is concluded) with the right to identify

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more specific portions of the Testimony as to which protection is sought

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within 30 days following receipt of the deposition transcript. In

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circumstances where portions of the deposition Testimony are designated for

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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protection, the transcript pages containing “Confidential” Information may

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be separately bound by the court reporter, who must affix to the top of each

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page the legend “Confidential,” as instructed by the Designating Party.

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c.

For Information produced in some form other than Documents, and

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for any other tangible items, including, without limitation, compact discs or DVDs,

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the Designating Party must affix in a prominent place on the exterior of the

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container or containers in which the Information or item is stored the legend

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“Confidential.” If only portions of the Information or item warrant protection, the

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Designating Party, to the extent practicable, shall identify the “Confidential”

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portions.

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6.

The inadvertent production by any of the undersigned Parties or non-

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Parties to the Proceedings of any Document, Testimony or Information during

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discovery in this Proceeding without a “Confidential” designation, shall be without

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prejudice to any claim that such item is “Confidential” and such Party shall not be

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held to have waived any rights by such inadvertent production. In the event that

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any Document, Testimony or Information that is subject to a “Confidential”

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designation is inadvertently produced without such designation, the Party that

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inadvertently produced the document shall give written notice of such inadvertent

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production within twenty (20) days of discovery of the inadvertent production,

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together with a further copy of the subject Document, Testimony or Information

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designated as “Confidential” (the “Inadvertent Production Notice”). Upon receipt

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of such Inadvertent Production Notice, the Party that received the inadvertently

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produced Document, Testimony or Information shall promptly destroy the
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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

inadvertently produced Document, Testimony or Information and all copies

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thereof, or, at the expense of the producing Party, return such together with all

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copies of such Document, Testimony or Information to counsel for the producing

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Party and shall retain only the “Confidential” designated Materials. Should the

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receiving Party choose to destroy such inadvertently produced Document,

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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Testimony or Information, the receiving Party shall notify the producing Party in

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writing of such destruction within ten (10) days of receipt of written notice of the

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inadvertent production. This provision is not intended to apply to any inadvertent

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production of any Information protected by attorney-client or work product

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privileges. In the event that this provision conflicts with any applicable law

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regarding waiver of confidentiality through the inadvertent production of

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Documents, Testimony or Information, such law shall govern.

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7.

In the event that counsel for a Party receiving Documents, Testimony

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or Information in discovery designated as “Confidential” objects to such

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designation with respect to any or all of such items, said counsel shall advise

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counsel for the Designating Party, in writing, of such objections, the specific

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Documents, Testimony or Information to which each objection pertains, and the

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specific reasons and support for such objections (the “Designation Objections”).

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Counsel for the Designating Party shall have thirty (45) days from receipt of the

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written Designation Objections to either (a) agree in writing to de-designate

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Documents, Testimony or Information pursuant to any or all of the Designation

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Objections and/or (b) file a motion with the Court seeking to uphold any or all

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designations on Documents, Testimony or Information addressed by the

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Designation Objections (the “Designation Motion”). Pending a resolution of the

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Designation Motion by the Court, any and all existing designations on the

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Documents, Testimony or Information at issue in such Motion shall remain in

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place. In the event that the Designation Objections are neither timely agreed to nor

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timely addressed in the Designation Motion, then such Documents, Testimony or
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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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Information shall be de-designated in accordance with the Designation Objection

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applicable to such material.
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Access to and/or Disclosure of Confidential Materials designated as

“Confidential” shall be permitted only to the following persons:
a.

the Court;

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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b.

(1) Attorneys of record in the Proceedings and their affiliated

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attorneys, paralegals, clerical and secretarial staff employed by such attorneys who

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are actively involved in the Proceedings and are not employees of any Party. (2)

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In-house counsel to the undersigned Parties and the paralegal, clerical and

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secretarial staff employed by such counsel. Provided, however, that each non-

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lawyer given access to Confidential Materials shall be advised that such Materials

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are being Disclosed pursuant to, and are subject to, the terms of this Stipulation

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and Protective Order and that they may not be Disclosed other than pursuant to its

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terms;
c.

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those officers, directors, partners, members, employees and agents of

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all nondesignating Parties that counsel for such Parties deems necessary to aid

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counsel in the prosecution and defense of this Proceeding; provided, however, that

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prior to the Disclosure of Confidential Materials to any such officer, director,

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partner, member, employee or agent, counsel for the Party making the Disclosure

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shall deliver a copy of this Stipulation and Protective Order to such person, shall

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explain that such person is bound to follow the terms of such Order, and shall

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secure the signature of such person on a statement in the form attached hereto as

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Exhibit A;
d.

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court reporters in this Proceeding (whether at depositions, hearings, or

any other proceeding);
e.

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any deposition, trial or hearing witness in the Proceeding who

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previously has had access to the Confidential Materials, or who is currently or was

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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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previously an officer, director, partner, member, employee or agent of an entity

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that has had access to the Confidential Materials;

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f.

any deposition or non-trial hearing witness in the Proceeding who

previously did not have access to the Confidential Materials; provided, however,

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that each such witness given access to Confidential Materials shall be advised that

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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such Materials are being Disclosed pursuant to, and are subject to, the terms of this

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Stipulation and Protective Order and that they may not be Disclosed other than

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pursuant to its terms;

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g.

mock jury participants who are unrelated to the Proceeding, provided,

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however, that prior to the Disclosure of Confidential Materials to any such mock

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jury participant, counsel for the Party making the Disclosure shall deliver a copy of

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this Stipulation and Protective Order to such person, shall explain that such person

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is bound to follow the terms of such Order, and shall secure the signature of such

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person on a statement in the form attached hereto as Exhibit A.

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h.

outside experts or expert consultants consulted by the undersigned

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Parties or their counsel in connection with the Proceeding, whether or not retained

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to testify at any oral hearing; provided, however, that prior to the Disclosure of

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Confidential Materials to any such expert or expert consultant, counsel for the

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Party making the Disclosure shall deliver a copy of this Stipulation and Protective

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Order to such person, shall explain its terms to such person, and shall secure the

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signature of such person on a statement in the form attached hereto as Exhibit A. It

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shall be the obligation of counsel, upon learning of any breach or threatened breach

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of this Stipulation and Protective Order by any such expert or expert consultant, to

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promptly notify counsel for the Designating Party of such breach or threatened

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breach; and

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i.

any other person that the Designating Party agrees to in writing.

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9.

Confidential Materials shall be used by the persons receiving them

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only for the purposes of preparing for, conducting, participating in the conduct of,
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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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and/or prosecuting and/or defending the Proceeding, and not for any business or

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other purpose whatsoever.
10.

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Any Party to the Proceeding (or other person subject to the terms of

this Stipulation and Protective Order) may ask the Court, after appropriate notice to

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the other Parties to the Proceeding, to modify or grant relief from any provision of

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this Stipulation and Protective Order.
11.

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Entering into, agreeing to, and/or complying with the terms of this

Stipulation and Protective Order shall not:
a.

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operate as an admission by any person that any particular Document,

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Testimony or Information marked “Confidential” contains or reflects trade secrets,

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proprietary, confidential or competitively sensitive business, commercial, financial

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or personal information; or
b.

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prejudice in any way the right of any Party (or any other person

subject to the terms of this Stipulation and Protective Order):
i.

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to seek a determination by the Court of whether any particular

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Confidential Material should be subject to protection as “Confidential”

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under the terms of this Stipulation and Protective Order; or
ii.

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to seek relief from the Court on appropriate notice to all other

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Parties to the Proceeding from any provision(s) of this Stipulation and

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Protective Order, either generally or as to any particular Document, Material

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or Information.

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12.

Any Party to the Proceeding who has not executed this Stipulation and

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Protective Order as of the time it is presented to the Court for signature may

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thereafter become a Party to this Stipulation and Protective Order by its counsel’s

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signing and dating a copy thereof and filing the same with the Court, and serving

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copies of such signed and dated copy upon the other Parties to this Stipulation and

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Protective Order.

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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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13.

Any Information that may be produced by a non-Party witness in

discovery in the Proceeding pursuant to subpoena or otherwise may be designated

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by such non-Party as “Confidential” under the terms of this Stipulation and

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Protective Order, and any such designation by a non-Party shall have the same

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force and effect, and create the same duties and obligations, as if made by one of

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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the undersigned Parties hereto. Any such designation shall also function as a

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consent by such producing Party to the authority of the Court in the Proceeding to

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resolve and conclusively determine any motion or other application made by any

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person or Party with respect to such designation, or any other matter otherwise

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arising under this Stipulation and Protective Order.
14.

If any person subject to this Stipulation and Protective Order who has

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custody of any Confidential Materials receives a subpoena or other process

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(“Subpoena”) from any government or other person or entity demanding

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production of Confidential Materials, the recipient of the Subpoena shall promptly

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give notice of the same by electronic mail transmission, followed by either express

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mail or overnight delivery to counsel of record for the Designating Party, and shall

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furnish such counsel with a copy of the Subpoena. Upon receipt of this notice, the

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Designating Party may, in its sole discretion and at its own cost, move to quash or

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limit the Subpoena, otherwise oppose production of the Confidential Materials,

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and/or seek to obtain confidential treatment of such Confidential Materials from

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the subpoenaing person or entity to the fullest extent available under law. The

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recipient of the Subpoena may not produce any Documents, Testimony or

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Information pursuant to the Subpoena prior to the date specified for production on

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the Subpoena.

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15.

Nothing in this Stipulation and Protective Order shall be construed to

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preclude either Party from asserting in good faith that certain Confidential

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Materials require additional protection. The Parties shall meet and confer to agree

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upon the terms of such additional protection.
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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

16.

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If, after execution of this Stipulation and Protective Order, any

Confidential Materials submitted by a Designating Party under the terms of this

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Stipulation and Protective Order is Disclosed by a non-Designating Party to any

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person other than in the manner authorized by this Stipulation and Protective

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Order, the non-Designating Party responsible for the Disclosure shall bring all

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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pertinent facts relating to the Disclosure of such Confidential Materials to the

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immediate attention of the Designating Party.
17.

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This Stipulation and Protective Order is entered into without prejudice

to the right of any Party to knowingly waive the applicability of this Stipulation

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and Protective Order to any Confidential Materials designated by that Party. If the

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Designating Party uses Confidential Materials in a non-Confidential manner, then

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the Designating Party shall advise that the designation no longer applies.
18.

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A Party that seeks to file under seal any Confidential Material must

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comply with Civil Local Rule 79-5. Confidential Material may only be filed under

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seal pursuant to a court order authorizing the sealing of the specific Confidential

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Material at issue. If a Party’s request to file Confidential Material under seal is

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denied by the court, then the Receiving Party may file the information in the public

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record unless otherwise instructed by the court.
19.

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The Parties shall meet and confer regarding the procedures for use of

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Confidential Materials at trial and shall move the Court for entry of an appropriate

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order.

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20.

Nothing in this Stipulation and Protective Order shall affect the

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admissibility into evidence of Confidential Materials, or abridge the rights of any

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person to seek judicial review or to pursue other appropriate judicial action with

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respect to any ruling made by the Court concerning the issue of the status of

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Protected Material.

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21.

This Stipulation and Protective Order shall continue to be binding

after the conclusion of this Proceeding and all subsequent proceedings arising from
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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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this Proceeding, except that a Party may seek the written permission of the

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Designating Party or may move the Court for relief from the provisions of this

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Stipulation and Protective Order. To the extent permitted by law, the Court shall

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retain jurisdiction to enforce, modify, or reconsider this Stipulation and Protective

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Order, even after the Proceeding is terminated.

PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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22.

Upon written request made within thirty (30) days after the settlement

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or other termination of the Proceeding, the undersigned Parties shall have thirty

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(30) days to either (a) promptly return to counsel for each Designating Party all

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Confidential Materials and all copies thereof (except that counsel for each Party

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may maintain in its files, in continuing compliance with the terms of this

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Stipulation and Protective Order, all work product, and one copy of each pleading

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filed with the Court, (b) agree with counsel for the Designating Party upon

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appropriate methods and certification of destruction or other disposition of such

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Confidential Materials, or (c) as to any Documents, Testimony or other

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Information not addressed by sub-paragraphs (a) and (b), file a motion seeking a

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Court order regarding proper preservation of such Materials. To the extent

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permitted by law the Court shall retain continuing jurisdiction to review and rule

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upon the motion referred to in sub-paragraph (c) herein.

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23.

After this Stipulation and Protective Order has been signed by counsel

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for all Parties, it shall be presented to the Court for entry. Counsel agree to be

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bound by the terms set forth herein with regard to any Confidential Materials that

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have been produced before the Court signs this Stipulation and Protective Order.

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24.

The Parties and all signatories to the Certification attached hereto as

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Exhibit A agree to be bound by this Stipulation and Protective Order pending its

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approval and entry by the Court. In the event that the Court modifies this

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Stipulation and Protective Order, or in the event that the Court enters a different

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Protective Order, the Parties agree to be bound by this Stipulation and Protective

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Order until such time as the Court may enter such a different Order. It is the
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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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Parties’ intent to be bound by the terms of this Stipulation and Protective Order

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pending its entry so as to allow for immediate production of Confidential Materials

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under the terms herein.

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IT IS SO ORDERED.

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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DATED: October 24, 2016

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

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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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EXHIBIT A

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ACKNOWLEDGMENT OF PROTECTIVE ORDER
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I, _______________, declare:
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1.

My address is: ________________________________________________

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

__________________________________________________________________
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__________________________________________________________________
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2.

My present occupation is: _____________________________________

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__________________________________________________________________
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3.
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I have received a copy of the Stipulation for Protective Order (the

“Protective Order”) regarding confidential information in the action entitled A.P. v.

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Glendale Unified School District, Case No. 2:16-CV-01404-GW-FFM, pending in
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the United States District Court, Central District of California (the “Litigation”). I

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have carefully read and understand the provisions of the Protective Order.
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4.

I will comply with all of the provisions of the Protective Order. I will hold

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in confidence, will not disclose to anyone other than those persons specifically
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authorized by the Protective Order, and will not copy or use except for purposes of
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the Litigation, any material designated “Confidential” which I receive in the

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Litigation.
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Executed this ___ day of ______, 201__ at
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____________________________________________________________
(city/state)
I declare under penalty of perjury under the laws of the State of California
that the foregoing is true and correct.
_____________________________________________
Signature
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PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS

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PROOF OF SERVICE

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STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

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I, the undersigned, am employed in the County of Los Angeles, State of
California. I am over the age of eighteen (18) years and not a party to the
within action. My business address is 2626 Foothill Boulevard, Suite 250, La
Crescenta, CA 91214.

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PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’T. CODE §6103

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On October 24, 2016, I served the foregoing document, described as
PROTECTIVE ORDER REGARDING DISCOVERY CONCERNING
MINOR PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL
EDUCATION RECORDS in this action by:
Submitting an electronic version of the document to ECF (Electronic
Case Filing).
and by placing
the original of the document
true copies of the
document in separate sealed envelopes to the following addresses:
Surisa Rivers, Esq.
Sarah Gross, Esq.
Surisa Rivers Law Office
2529 Foothill Blvd. Suite 202
La Crescenta, CA 91214
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]

Attorneys for Plaintiff,
A.P. by and through his guardian ad
litem, C.P

BY U.S. MAIL - I deposited said envelopes in the mail at Los Angeles,
California. The envelopes were mailed with fully prepaid postage
affixed thereon. I am readily familiar with Doumanian & Associates’
practice of collection and processing correspondence for mailing.
Under that practice, documents are deposited with the U.S. Postal
Service on the same day stated in this proof of service in the ordinary
course of business. I am aware that, on motion of the party served,
service is presumed invalid if the postal cancellation date or postage
meter date is more than one (1) day after the date stated in this proof of
service.

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FEDERAL I declare that I am employed in the office of a member of
the bar of this court at whose direction the service was made.

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Executed on October 24, 2016, at La Crescenta, California.

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Janna Delgado
(Type or Print Name)

(Signature of Declarant)

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- 15 STIPULATION AND PROTECTIVE ORDER REGARDING DISCOVERY CONCERNING MINOR
PLAINTIFF’S SCHOOL; MEDICAL AND SPECIAL EDUCATION RECORDS