Dave Betkey v. County of Los Angeles et al

Filing 22

PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg re Stipulation for Protective Order 21 . ***** SEE ORDER FOR DETAILS. ***** (mp)

1 Thomas C. Hurrell, State Bar No. 119876
E-Mail: [e-mail]
2 Mariam Kaloustian, State Bar No. 236702
E-Mail: [e-mail]
3 Angela Y Park, State Bar No. 287315
E-Mail: [e-mail]
4 HURRELL CANTRALL LLP
300 South Grand Avenue, Suite 1300
5 Los Angeles, California 90071
Telephone: [phone]
6 Facsimile: [phone]

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7 Attorneys for Defendants, COUNTY OF LOS ANGELES and SHERIFF JOHN
SCOTT
8
9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

11
12

DAVE BETKEY,

13
14

Plaintiff,

CASE NO. CV16-5863-DMG (AGRx)
PROTECTIVE ORDER

v.

15

COUNTY OF LOS ANGELES;
16 SHERIFF JOHN SCOTT; and DOES 130, inclusive,
17
Defendants.
18

[Assigned to Judge Dolly M Gee
Courtroom "7"]

19
20
21 I.

PURPOSES AND LIMITATIONS

22

Discovery in this action is likely to involve production of confidential,

23 proprietary, or private information for which special protection from public
24 disclosure and from use for any purpose other than prosecuting this litigation may
25 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
26 enter the following Stipulated Protective Order. The parties acknowledge that this
27 Order does not confer blanket protections on all disclosures or responses to
28 discovery and that the protection it affords form public disclosure and use extends

1 only to the limited information or items that are entitled to confidential treatment
2 under the applicable legal principles. The parties further acknowledge, as set forth
3 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
4 file confidential information under seal; Civil Local Rule 79-5 sets forth the
5 procedures that must be followed and the standards that will be applied when a party
6 seeks permission from the court to file material under seal.

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A.

8
HURRELL CANTRALL LLP

7

This action is likely to involve peace officer information including: addresses

GOOD CAUSE STATEMENT

9 and telephone numbers of County of Los Angeles ("COLA") employees, employee
10 and personnel records, internal affairs and administrative investigation reports and
11 materials, and all materials that constitute or embody personnel records and/or
12 materials that are entitled to privileges under applicable laws, including the official
13 information privilege, statutes, case decisions, or common law, or information
14 otherwise generally unavailable to the public. Accordingly, to expedite the flow of
15 information, to facilitate the prompt resolution of disputes over confidentiality of
16 discovery materials, to adequately protect information the parties are entitled to keep
17 confidential, to ensure that the parties are permitted reasonably necessary uses of
18 such material in preparation for an in the conduct of trial, to address their handling
19 at the end of the litigation, and serve the ends of justice, a protective order for such
20 information is justified in this matter.

It is in the intent of the parties that

21 information will not be designated as confidential for tactical reasons and that
22 nothing be so designated without a good faith belief that it has been maintained in a
23 confidential, non-public matter, and there is good cause why it should not be part of
24 the public record of this case.
25

Since the same law firms are involved in the state action, Goran v. County of

26 Los Angeles, which has similar issues and documents, it is agreed discovery in this
27 action may be used in the Goran case subject to the terms of this Stipulation and
28 Protective Order, and any protective order entered into in the Goran case. Plaintiff
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1 shall execute the attached Acknowledgement and Agreement to be Bound,
2 indicating his understanding of the terms of the instant protective order and
3 agreement to have discovery pertaining to him used in the Goran matter.
4 II.

DEFINITIONS

5

2.1

Action: this pending federal lawsuit.

6

2.2

Challenging Party: a Party or Non-Party that challenges the designation

7 of information or items under this Order.

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8

2.3

"CONFIDENTIAL" Information or Items: information (regardless of

9 how it is generated, stored or maintained) or tangible things that qualify for
10 protection under Federal Rule of Civil Procedure 26(c), as specified above in the
11 Good Cause Statement.
12

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as

13 their support staff).
14

2.5

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

15 items that it produces in disclosures or in responses to discovery as
16 "CONFIDENTIAL."
17

2.6

Disclosure or Discovery Material: all items or information, regardless

18 of the medium or manner in which it is generated, stored, or maintained (including,
19 among other things, testimony, transcripts, and tangible things), that are produced or
20 generated in disclosures or responses to discovery in this matter.
21

2.7

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

22 pertinent to the litigation who has been retained by a Party or its counsel to serve as
23 an expert witness or as a consultant in this Action.
24

2.8

House Counsel: attorneys who are employees of a party to this Action.

25 House Counsel does not include Outside Counsel or Record or any other outside
26 counsel.
27

2.9

Non-Party: any natural person, partnership, corporation, or association,

28 or other legal entity not named as a Party to this action.
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1

2.10 Outside Counsel of Record: attorneys who are not employees of a party

2 to this Action but are retained to represent or advise a party to this Action and have
3 appeared in this Action on behalf of that party or are affiliated with a law firm which
4 has appeared on behalf of that party, and includes support staff.
5

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

6 employees, consultants, retained experts, and Outside Counsel of Record (and their
7 support staffs).

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8

2.12 Producing Party: a Party or Non-Party that produces Disclosure or

9 Discovery Material in this Action.
10

2.13 Professional Vendors: persons or entities that provide litigation support

11 services (e.g. photocopying, videotaping, translating, preparing exhibits or
12 demonstrations, and organizing, storing, ore retrieving data in any form or medium)
13 and their employees and subcontractors.
14

2.14 Protected Material: any Disclosure or Discovery Material that is

15 designated as "CONFIDENTIAL."
16

2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

17 from a Producing Party.
18 III.

SCOPE

19

The protections conferred by this Stipulation and Order cover not only

20 Protected Material (as defined above), but also (1) any information copied or
21 extracted from Protected Material; (2) all copies, excerpts, summaries, or
22 compilations of Protected Material; and (3) any testimony, conversations, or
23 presentations by parties or their Counsel that might reveal Protected Material.
24

However, this Stipulation and Order does not apply to items in discovery

25 produced in any other litigation, without a confidentiality or protective order, or
26 otherwise available to the general public outside of discovery, e.g., produced in
27 court documents in other lawsuits, or in the media.
28

Any use of Protected Material at trial shall be governed by the orders of the
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1 trial judge. This Order does not govern the use of Protected Material at trial.
2 IV.

DURATION

3

Even after final disposition of this litigation, the confidentiality obligations

4 imposed by this Order shall remain in effect until a Designating Party agrees
5 otherwise in writing or a court order otherwise directs. Final disposition shall be
6 deemed to be the later of (1) dismissal of all claims and defenses in this Action and
7 the Goran case, with or without prejudice; and (2) final judgment herein after the

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8 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
9 this Action and the Goran case, including the time limits for filing any motions or
10 applications for extension of time pursuant to applicable law.
11

Nothing in this stipulation grants Counsel the right to waive any privileges or

12 rights to confidentiality held by COLA or any current or former employee of
13 COLA; likewise, nothing in this stipulation is to be deemed as a waiver of any
14 governmental privilege or protected information to which plaintiff may have access
15 in light of his former or current position with COLA.
16 V.

DESIGNATING PROTECTED MATERIAL

17

5.1

Exercise of Restraint and Care in Designating Material for Protection.

18 Each Party or Non-Party that designates information or items for protection under
19 this Order must take care to limit any such designation to specific material that
20 qualifies under the appropriate standards. The Designating Party must designate for
21 protection only those parts of material, documents, items, or oral or written
22 communications that qualify so that other portions of the material, documents,
23 items, or communications for which protection is not warranted are not swept
24 unjustifiably within the ambit of this Order.
25

Mass, indiscriminate, or routinized designations are prohibited. Designations

26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber the case development process or to impose
28 unnecessary expenses and burdens on other parties) may expose the Designating
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1 Party to sanctions.
2

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

3 designated for protection do not qualify for protection, that Designating Party must
4 promptly notify all other Parties that it is withdrawing the inapplicable designation.
5

5.2

Manner and Timing of Designations. Except as otherwise provided in

6 this Order (see e.g., second paragraph of section 5.2(a) below), or as otherwise
7 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

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8 under this Order must be clearly so designated before the material is disclosed or
9 produced.
10

Designation in conformity with this Order requires:

11

(a) for information in documentary form (e.g., paper or electronic documents,

12 but excluding transcripts of depositions or other pretrial or trial proceedings), that
13 the Producing Party affix at a minimum, the legend "CONFIDENTIAL" (hereinafter
14 "CONFIDENTIAL legend"), to each page that contains protected material. If only a
15 portion or portions of the material on a page qualifies for protection, the Producing
16 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
17 markings in the margins).

The “Confidential Legend” shall not block out or

18 obliterate any document.
19

A Party or Non-Party that makes original documents available for inspection

20 need not designate them for protection until after the inspecting Party has indicated
21 which documents it would like copied and produced. During the inspection and
22 before the designation, all of the material made available for inspection shall be
23 deemed "CONFIDENTIAL."

After the inspecting Party has identified the

24 documents it wants copied and produced, the Producing Party must determine which
25 documents it wants copied and produced, the Producing Party must determine which
26 documents, or portions thereof, qualify for protection under this Order.

Then,

27 before producing the specified documents, the Producing Party must affix the
28 "CONFIDENTIAL legend" to each page that contains Protected Material. If only a
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1 portion or portions of the material on a page qualifies for protection, the Producing
2 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
3 markings in the margins).
4

(b) for testimony given in depositions that the Designating Party identify the

5 Disclosure or Discovery Material on the record, before the close of the deposition all
6 protected testimony.
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(c) for information produced in some form other than documentary and for

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8 any other tangible items, that the Producing Party affix in a prominent place on the
9 exterior of the container or containers in which the information is stored the legend
10 "CONFIDENTIAL." If only a portion or portions of the information warrants
11 protection, the Producing Party, to the extent practicable, shall identify the protected
12 portion(s).
13

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

14 failure to designate qualified information or items does not, standing alone, waive
15 the Designating Party's right to secure protection under this Order for such material.
16 Upon timely correction of a designation, the Receiving Party must make reasonable
17 efforts to assure that the material is treated in accordance with the provisions of this
18 Order.
19 VI.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

20

6.1

Timing of Challenges.

Any Party or Non-Party may challenge a

21 designation of confidentiality at any time that is consistent with the Court's
22 Scheduling Order.
23

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

24 resolution process under Local Rule 37.1 et seq.
25

6.3

The burden of persuasion in any such challenge proceeding shall be on

26 the Designating Party.

Frivolous challenges, and those made for an improper

27 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
28 parties) may expose the Challenging Party to sanctions. Unless the Designating
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1 Party has waived or withdrawn the confidentiality designation, all parties shall
2 continue to afford the material in question the level of protection to which it is
3 entitled under the Producing Party's designation until the Court rules on the
4 challenge.
5 VII. ACCESS TO AND USE OF PROTECTED MATERIAL
6

7.1

Basic Principles. A Receiving Party may use Protected Material that

7 is disclosed or produced by another Party or by a Non-Party in connection with this

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8 Action only for prosecuting, defending, or attempting to settle this Action or the
9 Goran case. Such Protected Material may be disclosed only to the categories of
10 persons and under the conditions described in this Order. When this Action and the
11 Goran case have been terminated, a Receiving Party must comply with the
12 provisions of Section 13 below (FINAL DISPOSITION).
13

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

14 location and in a secure manner that ensures that access is limited to the persons
15 authorized under this Order.
16

7.2

Disclosure of "CONFIDENTIAL" Information or Items. Unless

17 otherwise ordered by the court or permitted in writing by the Designating Party, a
18 Receiving

Party

may

disclose

any

information

or

item

designated

19 "CONFIDENTIAL" only to:
20

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

21 employees of said Outside Counsel of Record to whom it is reasonably necessary to
22 disclose the information for this Action;
23

(b) the officers, directors, and employees (including House Counsel) of the

24 Receiving Party to whom disclosure is reasonably necessary for this Action;
25

(c) Experts (as defined in this Order) of the Receiving Party to whom

26 disclosure is reasonably necessary for this Action and who have signed the
27 "Acknowledgement and Agreement to Be Bound" (Exhibit A);
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(d) the court and its personnel;
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1

(e) court reporters and their staff;

2

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

3 Vendors to whom disclosure is reasonably necessary for this Action and who have
4 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A);
5

(g) the author or recipient of a document containing the information or a

6 custodian or other person who otherwise possessed or knew the information;
7

(h) during their depositions, witnesses, and attorneys for witnesses, in the

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8 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
9 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
10 not be permitted to keep any confidential information unless they sign the
11 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise
12 agreed by the Designating Party or ordered by the court. Pages of transcribed
13 deposition testimony or exhibits to depositions that reveal Protected Material may
14 be separately bound by the court reporter and may not be disclosed to anyone except
15 as permitted under this Stipulated Protective Order;
16

(i) any mediator or settlement officer, and their supporting personnel,

17 mutually agreed upon by any of the parties engaged in settlement discussions; and
18

(j) parties to this Action.

19 VIII. PROTECTED MATERIAL SUBPOENAED OR ORDERED
20

PRODUCED IN OTHER LITIGATION

21

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

22 that compels disclosure of any information or items designated in this Action as
23 "CONFIDENTIAL," that Party must:
24

(a) promptly notify in writing the Designating Party. Such notification shall

25 include a copy of the subpoena or court order;
26

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

27 issue in the other litigation that some or all of the material covered by the subpoena
28 or order is subject to this Protective Order. Such notification shall include a copy of
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1 this Stipulated Protective Order; and
2

(c) cooperate with respect to all reasonable procedures sought to be pursued

3 by the Designating Party whose Protected Material may be affected.
4

If the Designating Party timely seeks a protective order, the Party served with

5 the subpoena or court order shall not produce any information designated in this
6 action as "CONFIDENTIAL" before a determination by the court from which the
7 subpoena or order issued, unless the Party has obtained the Designating Party's

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8 permission. The Designating Party shall bear the burden and expense of seeking
9 protection in that court of its confidential material and nothing in these provisions
10 should be construed as authorizing or encouraging a Receiving Party in this Action
11 to disobey a lawful directive from another court.
12 IX.

A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE

13

PRODUCED IN THIS LITIGATION

14

(a) The terms of this Order are applicable to information produced by a Non-

15 Party in this Action and designated as "CONFIDENTIAL."

Such information

16 produced by Non-Parties in connection with this litigation is protected by the
17 remedies and relief provided by this Order. Nothing in these provisions should be
18 construed as prohibiting a Non-Party from seeking additional protections.
19

(b) In the event that a Party is required, by a valid discovery request, to

20 produce a Non-Party's confidential information in its possession, and the Party is
21 subject to an agreement with the Non-Party not to produce the Non-Party's
22 confidential information, then the Party shall:
23

(1) promptly notify in writing the Requesting Party and the non-Party

24 that some or all of the information requested is subject to a confidentiality
25 agreement with a Non-Party;
26

(2) promptly provide the Non-Party with a copy of the Stipulated

27 Protective Order in this Action, the relevant discovery request(s), and a reason
28 nable specific description of the information requested; and
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1

(3) make the information requested available for inspection by the Non-

2 Party, if requested.
3

(c) If the Non-Party fails to seek a protective order from this court within 14

4 days of receiving the notice and accompanying information, the Receiving Party
5 may produce the Non-Party's confidential information responsive to the discovery
6 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
7 not produce any information in its possession or control that is subject to the

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8 confidentiality agreement with the Non-Party before a determination by the court.
9 Absent a court order to the contrary, the Non-Party shall bear the burden and
10 expense of seeking protection in this Court of its Protected Material.
11 X.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

12

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

13 Protected Material to any person or in any circumstance not authorized under this
14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
17 persons to whom unauthorized disclosures were made of all the terms of this Order,
18 and (d) request such person or persons to execute the "Acknowledgment and
19 Agreement to Be Bound" that is attached hereto as Exhibit A.
20 XI.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

21

PROTECTED MATERIAL

22

When a Producing Party gives notice to Receiving Parties that certain

23 inadvertently produced material is subject to a claim of privilege or other protection,
24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
25 Procedure 26(b)(5)(B).

This provision is not intended to modify whatever

26 procedure may be established in an e-discovery order that provides for production
27 without prior privilege review.
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1
2 XII. MISCELLANEOUS
3

12.1 Right to Further Relief. Nothing in this Order abridges the right of any

4 person to seek its modification by the Court in the future.
5

12.2 Right to Assert Other Objections. By stipulating to the entry of this

6 Protective Order no Party waives any right it otherwise would have to object to
7 disclosing or producing any information or item on any ground not addressed in this

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8 Stipulated Protective Order. Similarly, no Party waives any right to object on any
9 ground to use in evidence of any of the other material covered by this Protective
10 Order.
11

12.3 Filing Protected Material. A Party that seeks to file under seal any

12 Protected Material must comply with Civil Local Rule 79-5. Protected Material
13 may only be filed under seal pursuant to a court order authorizing the sealing of the
14 specific Protected Material at issue. If a Party's request to file Protected Material
15 under seal is denied by the court, then the Receiving Party may file the information
16 in the public record unless otherwise instructed by the court.
17 XIII. FINAL DISPOSITION
18

After the final disposition of this Action, as defined in paragraph 4, within 60

19 days of a written request by the Designating Party, each Receiving Party must return
20 all Protected Material to the Producing Party or destroy such material. As used in
21 this subdivision, "all Protected Material" includes all copies, abstracts, compilations,
22 summaries, and any other formal reproducing or capturing any of the Protected
23 Material. Whether the Protected Material is returned or destroyed, the Receiving
24 Party must submit a written certification to the Producing Party (and, if not the same
25 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
26 (by category, where appropriate) all the Protected Material that was returned or
27 destroyed and (2) affirms that the Receiving Party has not retained any copies,
28 abstracts, compilations, summaries or any other format reproducing or capturing any
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1 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
2 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
3 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
4 reports, attorney work product, and consultant and expert work product, even if such
5 materials contain Protected Material. Any such archival copies that contain or
6 constitute Protected Material remain subject to this Protective Order as set forth in
7 Section 4.
Any violation of this Order may be punished by monetary sanctions.

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8
9

10 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
11
12 DATED: November 1, 2016
13

THE LAW OFFICES OF GOLDBERG AND
GAGE
By: /S/ Milad Sadr
BRADLEY GAGE
TERRY GOLDBERG
MILAD SADR
Attorneys for Plaintiff DAVE BETKEY

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////

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25 ////
26 ///
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1 DATED: November 1, 2016
2

HURRELL CANTRALL LLP
By: /S/ Mariam Kaloustian
THOMAS C. HURRELL
MARIAM KALOUSTIAN
ANGELA Y. PARK
Attorneys for Defendant COUNTY OF
LOS ANGELES and FORMER INTERIM
SHERIFF JOHN SCOTT

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10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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DATED: November 3, 2016
By:
HON. ALICIA G. ROSENBERG
UNITED STATES
DISTRICT/MAGISTRATE JUDGE

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1

EXHIBIT 1

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I,

_______________________________

[print

or

type

full

name],

of

4 _______________________________ [print or type full address], declare under
5 penalty of perjury that I have read in its entirety and understand the Stipulated
6 Protective Order that was issued by the United States District Court for the Central
7 District of California on ____________ [ date] in the case DAVE BETKEY V.

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8 COUNTY OF LOS ANGELES et al., Case No. 2:16-cv-05863-DMG-AGR. I agree
9 to comply with and to be bound by all the terms of this Stipulated Protective Order
10 and I understand and acknowledge that failure to so comply could expose me to
11 sanctions and punishment in the nature of contempt. I solemnly promise that I will
12 not disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the
14 provisions of this Order. I further agree to submit to the jurisdiction of the United
15 States District Court for the Central District of California for the purpose of
16 enforcing the terms of this Stipulated Protective Order, even if such enforcement
17 proceedings occur after termination of this action.
18 ________________________

[print

or

type

I hereby appoint
full

name]

of

19 __________________________________ [print or type full address and telephone
20 number] as my California agent for service of process in connection with this action
21 or any proceedings related to enforcement of this Stipulated Protective Order.
22 Date: ____________________________
23 City and State where sworn and signed: _______________________________
24 Printed name: _______________________
25 Signature: _________________________
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