Juan Frias v City of Los Angeles et al

Filing 47

PROTECTIVE ORDER by Magistrate Judge Steve Kim. In re: Notice of Lodging Proposed Protective Order 45 (mkr)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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Plaintiff,
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vs.
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CITY OF LOS ANGELES, et al.
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Defendants.
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__________________________________ )
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AND CONSOLIDATED CASE.
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JUAN FRIAS, et al.

Case No. CV16-4626 PSG (SKx)
Consolidated with CV17-00827
Hon Judge Philip S. Gutierrez; Crtm 6A
Hon Magistrate Judge Steve Kim

[PROPOSED]
PROTECTIVE ORDER

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1.

INTRODUCTION

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a. PURPOSES AND LIMITATIONS

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Discovery in this action is likely to involve production of items defendants allege

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are confidential, proprietary, or private information for which special protection from

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public disclosure and from use for any purpose other than prosecuting this litigation may

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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter

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the following Stipulated Protective Order. The parties acknowledge that this Order does

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not confer blanket protections on all disclosures or responses to discovery and that the

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protection it affords from public disclosure and use extends only to the limited
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information or items that are entitled to confidential treatment under the applicable legal

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principles. The parties further acknowledge, as set forth in Section 11.3., below, that this

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Stipulated Protective Order does not entitle them to file confidential information under

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seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the

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standards that will be applied when a party seeks permission from the court to file

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material under seal.

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b.

GOOD CAUSE STATEMENT

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Plaintiff JUAN FRIAS, individually and as successor of interest on behalf of the

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estate of Cesar Frias, by and through his Counsel of Record, Plaintiff L.D., a minor, by

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and through her Guardian Ad Litem Desiree De Leon, individually and successor in

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interest to Cesar Frias, by and through her Counsel of Record, and Defendants CITY OF

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LOS ANGELES and ENRIQUE ANZALDO, by and through their Counsel of Record,

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conferred regarding the production of various documents. These include documents

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defendants contend are confidential and to be kept private:

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1. Personnel Documents; any Complaints of Excessive Force and Discipline

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for Excessive Force (5 years) with respect to Officer Enrique Anzaldo.

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2. Force Investigation Division (FID) Report regarding the force used

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against decedent Cesar Frias, except for any documents contained in the

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FID Report which, on their own, are not confidential, e.g. the arrest

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report, the 51.7 form, among other things.

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Defendants contend the Force Investigation Division of the Los Angeles Police

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Department and the Internal Affairs and/or Complaint Investigators conduct internal

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administrative investigations of categorical officer-involved uses of force and internal

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complaints and external citizen complaints of police misconduct. In this above-captioned

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matter, the Force Investigation Division of the Los Angeles Police Department conducted

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an internal administrative investigation into the events of this underlying incident. Such

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information is obtained through the administrative investigation of this incident and are

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maintained as confidential peace officer personnel records and utilized for administrative
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issues for any involved Officers. Defendants contend that a Protective Order is

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appropriate for the following Good Cause reasons:

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Once completed, an FID report and/or Personnel Complaint Investigation is

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prepared. Such reports are reviewed by appropriate command officers in the Department

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and by the Board of Police Commissioners. This review has several purposes: (1) to

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determine whether the involved officers violated any Department policies or procedures;

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(2) to determine whether administrative discipline and/or retraining of the involved

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officers is necessary; (3) to ascertain if police policies and procedures in such areas as

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supervision, training, tactics, policies, etc.; should be modified. In sum, FID reports

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and/or Personnel Complaint Investigations are an essential aid to providing critical self-

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evaluation of Department officers and policies and to determine the most effective way to

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serve the citizens of Los Angeles.
Accordingly, to expedite the flow of information, to facilitate the prompt resolution

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of disputes over confidentiality of discovery materials, to adequately protect information

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the parties are entitled to keep confidential, to ensure that the parties are permitted

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reasonable necessary uses of such material in preparation for and in the conduct of trial,

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to address their handling at the end of the litigation, and serve the ends of justice, a

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protective order for such information is justified in this matter. It is the intent of the

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parties that information will not be designated as confidential for tactical reasons and that

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nothing be so designated without a good faith belief that it has been maintained in a

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confidential, non-public manner, and there is good cause why it should not be part of the

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public record of this case.

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2.

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DEFINITIONS
2.1 Action: This pending lawsuit, Juan Frias, et al. vs City of Los Angeles, et al.

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2:16-cv-04626 PSG (SKx); and consolidated case L.D., a minor, et al. vs.

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City of Los Angeles, et al. CV17-00827 PSG (SKx).

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2.2 Challenging Party: a Party or Non-Party that challenges the designation of
information or items under this Order.
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2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it

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is generated, stored or maintained) or tangible things that qualify for

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protection under Federal Rule of Civil Procedure 26(c), as specified above in

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the Good Cause Statement.

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2.4 Counsel: Counsel of Record and their support staff.

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2.5 Designating Party: a Party or Non-Party that designates information or items

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that it produces in disclosures or in responses to discovery as

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“CONFIDENTIAL”.

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2.6 Disclosure or Discovery Material: all items or information, regardless of the

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medium or manner in which it is generated, stored, or maintained (including,

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among other things, testimony, transcripts, and tangible things), that are

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produced or generated in disclosures or responses to discovery in this

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manner.

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2.7 Expert: a person with specialized knowledge or experience in a matter

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pertinent to the litigation who has been retained by a Party or its counsel to

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serve as an expert witness or as a consultant in this Action.

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2.8 Non-Party: any natural person, partnership, corporation, association, or other
legal entity not named as a Party to this action.
2.9 Outside Counsel of Record: attorneys who are not employees of a party to

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this Action but are retained to represent or advise a party to this Action and

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have appeared in this Action on behalf of that party, and includes support

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staff.

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2.10 Party: any party to this Action, including all of its officers, directors,

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employees, consultants, retained experts, and Outside Counsel of Record

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(and their support staffs).

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2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
Material in this Action.

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2.12 Professional Vendors: persons or entities that provide litigation support

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services (e.g., photocopying, videotaping, translating, preparing exhibits or

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demonstrations, and organizing, storing, or retrieving data in any form or

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medium) and their employees and subcontractors.

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2.13 Protected Material: Any Disclosure or Discovery Material that is designated

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as “CONFIDENTIAL.” Pursuant to several meet and confers, in lieu of

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seeking Court Intervention, Defendants have agreed to Provide the

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Following Documents as “CONFIDENTIAL” materials:

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A)

Personnel Documents regarding the subject matters of: 1) Excessive

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Force; 2) Disciplinary Actions: 3) Disciplinary Investigations; 4)

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Disciplinary Recommendations; and 5) Reprimands for the past five (5)

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years as follows:

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a. Internal Affairs Investigations of Complaints of Excessive Force

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for the past five (5) years with the understanding that any and all documents,

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summaries, Officer Statements and/or writings created during the above-

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listed Complaints, whether recorded or transcribed are protected;

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b. Any records revealing the result(s) of the use of forces described
above within the past five (5) years.

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c. Any records of re-training regarding the uses of force described
above.

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d. Any records of disciplinary action within the past five (5) years

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for uses of force described above.

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B)

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abovementioned lawsuit, as follows, except for any documents contained in

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the FID Report which, on their own, are not confidential documents, e.g. the

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arrest report, the 51.7 form, among others:

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Force Investigation Division Documents Re: the underlying

a. Force Investigation Division Investigation Records;

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b. Any and all documents, interviews, Officer Statements and/or

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writings created during such Investigation, which include, but are not limited

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to, the following:

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Force Investigation Division Records

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• Interviews;

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• All Bodycam Footage of Involved Officers;

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• Officer Statements, whether written or recorded;

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• Legend w/diagram;

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• Pictures - Which coincide with an Officer(s) compelled statement

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which were intended to reflect the Officer’s stated or perception of

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events;

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• Investigative Internal Narrative Memoranda;

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• All addenda

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This list is not exclusive, and also includes other materials later agreed-upon and/or

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ordered by the Court to be designated as Protected Material under this Protective Order.

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The inclusion of this list does not constitute an agreement by Plaintiffs that the

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CONFIDENTIAL designation is in fact appropriate for any of the aforementioned

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materials. Plaintiffs reserve all rights to challenge these and any other designations

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pursuant to the procedures set forth below in section 6 et seq.

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It must be noted that Defendants are producing the FID Investigation materials

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based upon the agreement of Counsel to enter into this Stipulation for Protective Order

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and are relying upon the good faith negotiations that have taken place this far in this

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litigation.

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2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from

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a Producing Party.

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3.

SCOPE
The protections conferred by this Stipulation and Order cover not only Protected

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Material (as defined above), but also (1) any information copied or extracted from

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Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

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Material; and (3) any testimony, conversations, or presentations by Parties or their

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Counsel that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders of the trial

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judge. This Order does not govern the use of Protected Material at trial.

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4.

DURATION
Should any Protected Material become part of the public record at trial or

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otherwise (such as a where the Court denies the request to file under seal), this Protective

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Order shall no longer apply to such portions at Trial which became part of the public

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record, with the exception that all such material/documents, whether part of the public

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record or not, must still be returned in compliance with Section 12: Final Disposition.

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Should any portion of the Protected Material remain confidential until trial, during

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any portion of the trial of this action which could entail the discussion or disclosure of

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Confidential Information, that Defendants may request the opportunity to show good

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cause to the Court as to why access to the courtroom should be limited to parties, their

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counsel and other designated representative, experts or consultants who agreed to be

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bound by this stipulation/protective order, and court personnel.

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For all portions of the Protected Material after final disposition of the Trial,

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whether they became part of the pubic record or not, the confidentiality obligations by

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this Order shall remain in full effect.

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Final disposition shall be deemed to be the later of (1) dismissal of all claims and

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defenses in this Action, with or without prejudice; (2) In any event wherein any portion

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of this matter is remanded to State Court, refiled in State Court or severed from the

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Federal matter and returned to State Court; and/or (3) final judgment herein after the

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completion and exhaustion of all appeals, re-hearings, remands, trials, or reviews of this

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Action, including the time limits for filing any motions or applications for extension of

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time pursuant to applicable law.

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5.

DESIGNATING PROTECTED MATERIAL

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5.1

Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or Non-Party that designates information or items for protection under

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this Order must take care to limit any such designation to specific material that qualifies

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under the appropriate standards. The Designating Party must designate for protection

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only those parts of material, documents, items, or oral or written communications that

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qualify so that other portions of the material, documents, items, or communications for

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which protection is not warranted are not swept unjustifiably within the ambit of this

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Order. Mass, indiscriminate, or routinized designations are prohibited. Designations that

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are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

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to unnecessarily encumber the case development process or to impose unnecessary

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expenses and burdens on other parties).

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If it comes to a Designating Party's attention that information or items that it

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designated for protection do not qualify for protection, that Designating Party must

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promptly notify all other Parties that it is withdrawing the inapplicable designation.

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5.2

Manner and Timing of Designations.

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Designating the Protected Material listed above shall be accomplished by affixing

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to such document or writing a legend-Watermark, such as “Confidential,” “Confidential

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Documents,” “Confidential Material Subject to Protective Order,” or words of similar

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effect with corresponding case number which shall cover each page. The documents and

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writings so designated, and all information derived therefrom shall be treated in

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accordance with the terms of this stipulation/protective order. Any party stamping-

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watermarking any of the Confidential Materials may not stamp-watermark the records in
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such a way as to make any written portion of the records illegible. For testimony given in

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deposition, the Designating Party must so identify it before the close of the deposition

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and all such information cannot be questioned about unless under seal.

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5.3

Inadvertent Failures to Designate.

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If timely corrected, an inadvertent failure to designate qualified information or

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items does not, standing alone, waive the Designating Party's right to secure protection

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under this Order for such material. Upon timely correction of a designation, the

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Receiving Party must make reasonable efforts to assure that the material is treated in

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accordance with the provisions of this Order.

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6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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6.1

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Any Party or Non-Party may challenge a designation of confidentiality at any time

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Timing of Challenges.

that is consistent with the Court's Scheduling Order.

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6.2

Meet and Confer.

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The Challenging Party shall initiate the dispute resolution process under Local

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Rule 37.1 et seq.

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6.3

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While the burden of persuasion in any such challenge proceeding shall be on the

Burden of Persuasion

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Designating Party, the challenging party must initiate their legal challenge with

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appropriate and applicable legal justification with support thereof. Frivolous challenges,

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and those made for an improper purpose (e.g., to harass or impose unnecessary expenses

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and burdens on other parties) may expose the Challenging Party to sanctions. Unless the

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Designating Party has waived or withdrawn the confidentiality designation, all parties

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shall continue to afford the material in question the level of protection to which it is

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entitled under the Producing Party's designation until the Court rules on the challenge.

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7.

ACCESS TO AND USE OF PROTECTED MATERIAL

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7.1

Basic Principles.

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A Receiving Party may use Protected Material that is disclosed or produced by

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another Party or by a Non-Party in connection with this Action only for prosecuting,

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defending, or attempting to settle this Action and no other matter. Such Protected

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Material may be disclosed only to the categories of persons and under the conditions

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described in this Order. When the Action has been terminated, a Receiving Party must

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comply with the provisions of section 12 below (FINAL DISPOSITION).

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In the event only certain claims are severed and remanded to State Court, refiled in

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State Court or claims severed and remanded to State Court, then the Parties shall meet

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and confer pursuant to Local Rule 37-1 regarding the disposition of all materials

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produced pursuant to this Protective Order. In no event shall any documents provided

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pursuant to this Protective Order be utilized in any other case other than this underlying

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case. In the event that the parties are unable to reach an informal agreement, the Parties

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shall file an appropriate motion with the Court utilizing the joint stipulation procedures

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set forth in Local Rule 37-2, or if the time period to utilize Local Rule 37-1 is no longer

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applicable, then a joint motion shall be lodged with the Court.

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In the event this entire matter is remanded to State Court or dismissed and refiled

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in State Court then all materials, including the FID Investigation as well as any other

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Court Ordered Documents provided pursuant to this Protective Order and all copies

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thereof shall be returned to the Offices of the Los Angeles City Attorney’s Office, 6th

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Floor, City Hall East, Los Angeles, California 90012 for destruction/shredding no later

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than one (1) week after the case has been removed/terminated in this Court. All

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Confidential documentation provided to any person or party, pursuant to any provision

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hereof, also shall be returned to the City Attorney’s Office.

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Protected Material must be stored and maintained by a Receiving Party at a

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location and in a secure manner that ensures that access is limited to the persons

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authorized under this Order.
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Disclosure of “CONFIDENTIAL” Information or Items.

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7.2

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Unless otherwise ordered by the court or permitted in writing by the Designating

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Party, a Receiving Party may disclose any information or item designated

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“CONFIDENTIAL” only to:

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(a) the Receiving Party's Counsel of Record in this Action, as well as employees

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of said Counsel of Record to whom it is reasonably necessary to disclose the information

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for this Action;

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(b) the Receiving Party, including the officers, directors, and employees

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(including House Counsel) of the Receiving Party to whom disclosure is reasonably

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necessary for this Action;
(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is

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reasonably necessary for this Action and who have signed the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A);

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(d) the court and its personnel;

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(e) court reporters and their staff;

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(f) professional jury or trial consultants, mock jurors, and Professional Vendors to

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whom disclosure is reasonably necessary for this Action and who have signed the

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“Acknowledgment and Agreement to Be Bound” (Exhibit A);

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(g) the author or recipient of a document containing the information or a custodian
or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses, and attorneys for witnesses, in the Action to

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whom disclosure is reasonably necessary provided: (1) the deposing party requests that

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the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted

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to keep any confidential information unless they sign the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party

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or ordered by the court. Pages of transcribed deposition testimony or exhibits to

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depositions that reveal Protected Material may be separately bound by the court reporter

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and may not be disclosed to anyone except as permitted under this Stipulated Protective

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Order, as such information must be under seal; and
(i) any mediator or settlement officer, and their supporting personnel, mutually

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agreed upon by any of the parties engaged in settlement discussions.

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8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

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OTHER LITIGATION

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If a Party is served with a subpoena or a court order issued in other litigation that

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compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL,” that Party must:
(a) promptly notify in writing the Designating Party. Such notification shall

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include a copy of the subpoena or court order;

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(b) promptly notify in writing the party who caused the subpoena or order to issue

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in the other litigation that some or all of the material covered by the subpoena or order is

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subject to this Protective Order. Such notification shall include a copy of this Stipulated

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Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be pursued by the

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Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with the

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subpoena or court order shall not produce any information designated in this action as

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“CONFIDENTIAL” before a determination by the court from which the subpoena or

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order issued, unless the Party has obtained the Designating Party’s permission. The

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Designating Party shall bear the burden and expense of seeking protection in that court of

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its confidential material and nothing in these provisions should be construed as

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authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive

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from another court.

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UNAUTHORIZED DISCLOSURE OR PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

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Protected Material to any person or in any circumstance not authorized under this

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Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

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the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

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all unauthorized copies of the Protected Material, (c) inform the person or persons to

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whom unauthorized disclosures were made of all the terms of this Order, and (d) request

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such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

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that is attached hereto as Exhibit A.

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10.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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inadvertently produced material is subject to a claim of privilege or other protection, the

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obligations of the Receiving Parties are those set forth in Federal Rule of Civil

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Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

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may be established in an e-discovery order that provides for production without prior

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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

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parties reach an agreement on the effect of disclosure of a communication or information

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covered by the attorney-client privilege or work product protection, the parties may

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incorporate their agreement in the stipulated protective order submitted to the court.

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11.

MISCELLANEOUS

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11.1 Right to Further Relief.

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Nothing in this Order abridges the right of any person to seek its modification by

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the Court in the future.

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11.2 Right to Assert Other Objections.

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By stipulating to the entry of this Protective Order no Party waives any right it
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otherwise would have to object to disclosing or producing any information or item on any

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ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any

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right to object on any ground to use in evidence of any of the material covered by this

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Protective Order.

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11.3 Filing Protected Material.

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A Party that seeks to file under seal any Protected Material must comply with Civil

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Local Rule 79-5 et seq. Protected Material may only be filed under seal pursuant to a

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court order authorizing the sealing of the specific Protected Material at issue.

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12.

FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 20 days

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of a written request by the Designating Party, each Receiving Party must return all

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Protected Material to the Producing Party. As used in this subdivision, “all Protected

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Material” includes all copies, abstracts, compilations, summaries, and any other format

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reproducing or capturing any of the Protected Material.
Once the Protected Material is returned, the Receiving Party must submit a written

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certification to the Producing Party (and, if not the same person or entity, to the

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Designating Party) by the 20-day deadline that (1) identifies (by category, where

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appropriate) all the Protected Material that was returned and (2)affirms that the Receiving

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Party has not retained any copies, abstracts, compilations, summaries or any other format

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reproducing or capturing any of the Protected Material.
Notwithstanding this provision, Counsel are entitled to retain an archival copy of

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all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

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correspondence, deposition and trial exhibits, expert reports, attorney work product, and

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consultant and expert work product, even if such materials contain some references to

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Protected Material. Any such archival copies that contain or constitute Protected

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Material remain subject to this Protective Order as set forth in Section 4 (DURATION).

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13.

VIOLATIONS OF ORDER:
Any violation of this Order may be punished by any and all appropriate measures

including, without limitation, contempt proceedings and/or monetary sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: October 16, 2017

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THE SEHAT FIRM
By:

/S/ Cameron Sehat
CAMERON SEHAT, ESQ.
Attorneys for Plaintiff JUAN FRIAS

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Dated: October 16, 2017

THE LAW OFFICE OF DALE K. GALIPO
By:

/S/ Renee V. Masongsong
DALE K. GALIPO, ESQ.
RENEE V. MASONGSONG, ESQ.
Attorneys for Plaintiff L.D., a minor, by and through
her Guardian Ad Litem Desiree De Leon

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Dated: October 16, 2017

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MICHAEL N. FEUER, City Attorney
THOMAS H. PETERS, Chief Assistant City Attorney
CORY M. BRENTE, Supervising City Attorney
By:
/S/ Christian R. Bojorquez
CHRISTIAN R. BOJORQUEZ, Deputy City Attorney
Attorneys for Defendants CITY OF LOS ANGELES and
ENRIQUEZ ANZALDO

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: October 20, 2017

__________________________________
HON. STEVE KIM
United States Magistrate Judge
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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, _____________________________ [full name], of _________________

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[full address], declare under penalty of perjury that I have read in its entirety and

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understand the Stipulated Protective Order that was issued by the United States

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District Court for the Central District of California on [date] in the case of

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___________ [insert case name and number]. I agree to comply with and to be bound

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by all the terms of this Stipulated Protective Order and I understand and acknowledge

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that failure to so comply could expose me to sanctions and punishment in the nature of

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contempt. I solemnly promise that I will not disclose in any manner any information or

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item that is subject to this Stipulated Protective Order to any person or entity except in

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strict compliance with the provisions of this Order.

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I further agree to submit to the jurisdiction of the United States District Court for

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the Central District of California for the purpose of enforcing the terms of this Stipulated

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Protective Order, even if such enforcement proceedings occur after termination of this

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action. I hereby appoint __________________________ [full name] of

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_______________________________________ [full address and telephone number]

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as my California agent for service of process in connection with this action or any

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proceedings related to enforcement of this Stipulated Protective

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Order.

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Date: ______________________________________

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City and State where signed: _________________________________

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Printed name: _______________________________

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Signature: __________________________________

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