John Doe et al v County of Los Angeles et al

Filing 59

PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS 58 by Magistrate Judge Paul L. Abrams. [NOTE CHANGES MADE BY THE COURT] IT IS HEREBY ORDERED that: 1. The parties, in the production or disclosure of documents, records,information, or tangible things in this case (hereafter" documents") may designate certain documents as "Confidential" (collectively herein as "Confidential Documents"). (SEE ORDER FOR FURTHER DETAILS) (gr)

F{lED
DIST4

M AY - 8 2011
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OF CALIFORNIA

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NOTE: CHANGES MADE BY THE COURT

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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JOHN DOE an individual; JANE
DOE,an individual,
Plaintiffs,

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CASE NO. CV16-5946 RGK(PLA)
Hon. R. Gary Klausner
Courtroom 850 — Roybal

VS.

Hon. Paul L. Abrams, Magistrate Judge

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COUNTY OF LOS ANGELES,a
Courtroom 780 - Roybal
olitical subdivision of the State of
California• CITY OF LOS
ANGELE~,a California municipal
DISCOVERY MATTERI
(
cor~poration; CITY OF TORRANCE,
a ('~alifornia munici al corporation;
PROTECTIVE ORDER RE
CHRISTINE WYC~FF an
CONFIDENTIAL
individual; ALAN BON an
DOCUMENTS
individual; UNKNOWN ~'ORRANCE
OFFICER 1, an individual and in his
or her official ca aci~y UNKNOWN
TORRANCE O~FICE~ 2, an
Complaintfiled: July 1, 2016
individual and in his or her official
August 22, 2017
capacit_y,~ UNKNOWN TORRANCE Trial date:
OFFIC,~JR 3, an individual and in his
or her official ca~ pachy; UNKNOWN
COUNTY DEPUTY,an individual
and in his or her official capacity;
DETECTIVE AL CONTRERAS,an
individual and in his official cap~achy•
UNKNOWN LAPD DETECTIVE an
individual and in his or her officia~
capacity and DOES 1 -50 ,inclusive,
Defendants.

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

PURSUANT TO THE STIPULATION OF THE PARITES (Stipulation of
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the Parties for Protective Order re Confidential Documents"), and pursuant to the

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Court's inherent and statutory authority, including but not limited to the Court's

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authority under applicable Federal Rules of Civil Procedure and United States

s District Court, Central District of California Local Rules; after due consideration
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of all relevant pleadings, papers, and records in this action; and upon such other
evidence or argument as was presented to the Court; Good Cause appearing

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and in furtherance ofjustice,
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IT IS HEREBY ORDERED that:

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1.

The parties, in the production or disclosure of documents, records,

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information, or tangible things in this case (hereafter" documents") may designate

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certain documents as "Confidential"(collectively herein as "Confidential

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Documents"). The types of documents which may be designated as Confidential

is Documents hereunder include:(1)peace officer personnel files and all records
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which are typically contained within or associated with such peace officer

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personnel files according to the regular practices of the law enforcement agency

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which is the custodian of such records —including but not limited to internal affairs

~9 investigations and related interviews and reports, peace officer personal financial
20 and asset information, peace officer medical records in the custody of the peace
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officer's law enforcement agency employer, records regarding peace officer

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discipline, associated law enforcement agency employment/internal affairs

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investigations and related interviews and reports, interviews and reports related to
personnel complaints by peace officers and/or citizen complaints against peace
officers, and peace officer training records; and (2)comparable records ofthe

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parties that may otherwise be privileged from disclosure but which the parties may
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agree to produce pursuant to the terms of this Stipulation and [Proposed] Protective

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

I, Order, including a party's medical records, financial records, or other privileged or
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confidential records, documents, or information. However, nothing in this

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Stipulation and [Proposed] Protective Order shall be construed as to require or

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mandate that any party disclose or produce privileged information or records or

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other Confidential Documents in this action.

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This Stipulation and [Proposed] Protective Order also requires each

party to this action to return the Confidential Documents produced to that party at

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the conclusion of this lawsuit, subject to certain exceptions specified infra: this
requirement is intended to ensure that the use of Confidential Documents is limited
to the particular case in which the facts or documents are relevant or at issue. The

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parties further agree that this Stipulation and its terms and provisions, and any
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Order based thereon, is/are applicable only to the above entitled matter and may
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not be used in the proceedings of any other matter for the purpose of establishing
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good cause for a similar stipulation or protective order, nor as a basis for any
contention that certain documents or records should or should not be produced in
another matter.
3.

The mechanism by which parties may designate documents as

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Confidential Documents is either:(a) by marking the individual documents as

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being "Confidential," such as on the footer of a specific/individual document, or

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( by enclosing, with the documents such party intends to be treated as
b)

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Confidential Documents hereunder, written disclosures or discovery responses or

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correspondence specifically and individually identifying those enclosed documents

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as "Confidential" such party intends to be treated as Confidential Documents

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hereunder. The preferred method of designating documents as Confidential

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Documents is to employ all of the aforementioned means of designation, but such

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is not required hereunder.

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

4.

The parties agree that documents marked as "Confidential" shall be so

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marked in a manner that does not obstruct the substance of that document's text or

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content. The parties further agree that no party shall be permitted to alter or copy a

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document or record designated as "Confidential" so as to make it appear that such

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copy of such document or record was not a Confidential Document subject to the

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terms of this Stipulation and Protective Order; the parties further agree that such
alteration or copying shall subject the party or counsel who engages in such action

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such documents to sanctions, at the discretion ofthe Court. Nothing in
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this paragraph shall be construed so as to prohibit transparent "highlighting" of any
Confidential Document for emphasis, provided that prior to filing any such
"
highlighted" document with the Court and/or prior to publishing such

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"
highlighted" document to the finder offact or jury in this matter, the party adding
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such "highlighting" emphasis informs the Court or the fact finder, as applicable,
that the "highlighting" party has added such "highlighting" emphasis to the
document at issue.

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5.

Hereafter, a party who has designated documents as Confidential

is Documents shall be referred to as the "producing-disclosing party [or counsel]"
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and the party to whom such documents are produced or disclosed shall be referred

20 to as the "recipient party [or counsel]."
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6.

Confidential Documents shall be used only in preparation for the

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above entitled action, up to and including the completion ofjudicial proceedings,

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as well as any appellate phase ofthis action, and not for any other purpose,

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including any other litigation or dispute, and may not be disclosed or disseminated

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Stipulation and Protective Order.

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

7.

In the event that a recipient party or counsel contends that any

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Confidential Documents were already in the possession of that party, or that

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party's counsel, prior to the date of this Stipulation and Protective Order, or prior

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to such documents' production in this matter by the producing-disclosing party, the

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recipient party or counsel shall have the burden of proving that any such
documents were in fact already in the possession ofthe recipient party or that
party's counsel prior to the date ofthis Stipulation and Protective Order, or prior to

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such documents' production in this matter.
8.

The parties will attempt to resolve any issue regarding such disputed

documents or records pursuant to Federal Rule of Civil Procedure 37(a)(1) before

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submitting any such dispute-issue to the Court.
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Notwithstanding the foregoing, and despite any dispute as to whether

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any documents produced should be subject to the terms of the Stipulation and
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Protective Order as a result of prior possession, the parties will continue to treat the
documents)at issue as confidential and subject to this Stipulation and Protective
Order until the Court rules upon the dispute or until the parties reach agreement on
the issue, whichever comes first.
10.

If, upon review of such a dispute, the Court determines that the

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disputed Confidential Documents were already in the possession of the recipient

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party or counsel prior to the date ofthis Stipulation and Protective Order, or prior

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to such documents' production in this matter, those specific documents shall not be

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subject to the provisions on destruction of copies(¶ 25, infra) nor to the provisions

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on return of documents at the conclusion of litigation(¶ 26, infra), nor shall the

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recipient party or counsel be prohibited from using those specific documents in

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other litigation or at trial of this action: otherwise, the remaining provisions of this

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

Stipulation and Protective Order shall continue to apply to such documents as
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'Confidential Documents hereunder.
1 1.

The recipient parties to the above entitled action, and/or their counsel,

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and/or their agents or the agents or employees oftheir counsel, shall secure and

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maintain the confidentiality of any and all Confidential Documents in their

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possession, and shall ensure that such Confidential Documents are used only for
the purposes set forth herein below, and for no other purpose, and subject to the

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terms and provisions of this Stipulation and Protective Order.
12.

Nothing in the parties' Stipulation and Protective Order shall be

construed as a waiver by any party of any right to object on any ground to the use

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in any proceeding, or to the admission into evidence, of any Confidential
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Documents. Nothing in this Stipulation and Protective Order shall be construed so
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as to prevent the admission of Confidential Documents into evidence at the trial of
this matter, or in appellate proceedings on this matter, solely on the basis of the
documents' designation as Confidential Documents.
13.

Nothing in the parties' Stipulation and Protective Order shall be

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construed as a waiver by any party of any right it would otherwise have to object to

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disclosing or producing any information or documents on any ground not

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specifically addressed in this Stipulation and Protective Order, including but not

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limited to objections pursuant to the California Government Code, California

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Evidence Code, California Penal Code,the Official Records Privilege, the federal

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Official Information Privilege, the federal Executive Deliberative Process

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Privilege, the law enforcement-investigative privilege, the attorney-client privilege,

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the physician-patient privilege, the therapist-patient privilege, the attorney work

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product protection, the taxpayer privilege, or the right to Privacy under the United

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States Constitution, the California Constitution or any other applicable state or

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

federal authority (as underscored and/or augmented by the statutory peace officer
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personnel records privileges pursuant to California Penal Code sections 832.5

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through 832.8, as well as California Evidence Code sections 1040 through 1048,

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and the associated case law), or any other privilege against disclosure or

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production available under any provision offederal or California law. Nothing in

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the parties Stipulation and Protective Order shall be construed as requiring the
production or disclosure of documents or information that may be or have been

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designated as Confidential Documents. Nothing in the parties Stipulation and
Protective Order shall be construed as a waiver by any party of any right it would
otherwise have to obtain, acquire, or discover documents or records from any party
to the extent permitted under federal or California law, as applicable.

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14.

The parties' Stipulation and this Protective Order shall not be

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construed as a stipulation by any party that any privilege asserted by any party
regarding Confidential Documents, whether produced or disclosed or not, is
applicable or valid as to such documents; however, all parties, by and through their

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undersigned counsel, agree to abide by the terms ofthe parties' Stipulation and this

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Protective Order and to maintain such documents' confidentiality pursuant to the

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terms of the parties' Stipulation and this Protective Order.

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15.

Confidential Documents produced in this action shall remain in the

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sole custody of recipient counsel to whom such documents are produced, who shall

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be prohibited from releasing or disseminating, to any other persons —including but

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not limited to legal counsel —any or all such Confidential Documents, except as

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specifically delineated in the parties Stipulation and this Protective Order.

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16.

All those permitted by a recipient counsel or party to review any

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Confidential Documents must be informed of the terms of the parties Stipulation

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and this Protective Order and must agree to abide by such Stipulation and

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

Protective Order before the recipient party or counsel may produce or disclose
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such documents to such person(s).
17.

Confidential Documents may be disseminated, released, copied,

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shared, or otherwise reproduced by a recipient party or counsel only to the

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f
ollowing persons:

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( counsel for any party and any party's insurance carrier's authorized
a)
representative in this action who is also a party to the parties Stipulation;

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( paralegal, stenographic, clerical and/or secretarial personnel regularly
b)

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employed by counsel referred to in paragraph (a);

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( court personnel, including stenographic reporters engaged in such
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proceedings as are necessary incident to preparation for the trial and pret2

trial proceedings in the above entitled action;
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( any outside expert or consultant retained in connection with this action,
d)
and not otherwise employed by either of the parties —provided that such

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expert or consultant understands and agrees to abide by the terms of the

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parties' Stipulation of this Protective Order and signs and returns

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Attachment"A" ofthe Proposed Order to the recipient party or counsel;

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( any "in-house" or outside experts designated by the defendants)to
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testify at trial in this matter; and/or

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( any party or witnesses to this action, provided that such party or witness
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understands and agrees to abide by the terms ofthe parties' Stipulation

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and this Protective Order.

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18.

Confidential Documents may be submitted in all law and motion

proceedings before the Court if done so under seal pursuant to Federal Rules of
' Civil Procedure 5.2 and 26 and/or United States District Court, Central District of
California Local Rules 79-5.1 and 79-5.2 as applicable and pursuant to the

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

provisions of this paragraph. If any party attaches any Confidential Documents to
any pleading, motion, or other paper to be filed, lodged, or otherwise submitted to
the Court, that Confidential Documents)shall be filed/lodged under seal pursuant
to Federal Rules of Civil Procedure 5.2 and 26 and/or United States District Court,
Central District of California Local Rules 79-5.1 and 79-5.2 to the extent
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applicable."Good cause must be shown for the under seal filing." However,
this paragraph shall not be construed so as to prevent aproducing-disclosing party

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or counsel from submitting, filing, lodging, or publishing any document it has
previously designated as a Confidential Document without compliance with this
paragraph's requirement to do so under seal (i.e., aproducing-disclosing party or

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counsel may submit or publish its own Confidential Documents without being in
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violation of the terms ofthe parties' Stipulation and this Protective Order).
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19.
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Furthermore, a recipient party or counsel shall be exempted from the

requirements of the foregoing paragraph(¶ 18)as to any specifically identified
Confidential Documents) where the counsel for the producing-disclosing party of

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such specifically identified Confidential Documents)serves an express, written

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waiver as to such specifically identified Confidential Documents)prior to the

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submission or publication ofthe Confidential Documents)at issue, either upon

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initiative. A recipient party or counsel shall also be exempted from the

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requirements of such paragraph as to any specifically identified Confidential

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Documents) where such Confidential Documents)is/are not documents, records,

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or information regarding(1) private, personal information contained in peace

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officer personnel files (such as social security numbers, driver's license numbers or

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comparable personal government identification numbers, residential addresses,

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compensation or pension or personal property information, credit card numbers or

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

credit information, dates of birth, tax records and information, information related
to the identity of an officer's family members or co-residents, and comparable
personal information about the officer or his family);(2)any internal affairs or
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comparable investigation by any law enforcement agency into alleged officer

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misconduct; or(3)the medical records or records of psychiatric or psychological

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treatment of any peace officer or party to this action. The parties shall confer in
good faith regarding any request for waiver from this sealing requirement. Prior to

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submitting in any law and motion proceedings before the Court any Confidential
Documents)exempted from the sealing requirement of this Stipulation and any
associated Protective Order, a recipient party or counsel shall confer in good faith

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with the producing-disclosing party or counsel on the issue of whether the parties
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can agree on whether such exempted Confidential Documents)should be filed
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under seal or whether, if the parties cannot agree, the producing-disclosing party or
counsel should move to have such Confidential Documents)placed under seal by

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the Court. Defendants further contend that all Confidential Documents not subject

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to an express waiver by the producing-disclosing party should be subject to the

is requirements ofthis paragraph; however, plaintiffs disagree with such contention
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and plaintiffs do not stipulate to such a provision; nothing in this paragraph or in

20 the parties' Stipulation shall be construed as an agreement by plaintiffs to file any
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Confidential Documents)under seal other than documents, records, or information

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produced-disclosed by defendants (if any)regarding(1) private, personal

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information contained in peace officer personnel files (such as social security

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numbers, driver's license numbers or comparable personal government

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identification numbers, residential addresses, compensation or pension or personal

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property information, credit card numbers or credit information, dates of birth, tax

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records and information, information related to the identity of an officer's family

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

members or co-residents, and comparable personal information about the officer or
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his family);(2)any internal affairs or comparable investigation by any law

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enforcement agency into alleged officer misconduct; or(3)the medical records or

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records of psychiatric or psychological treatment of any peace officer or party to

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this action. Additionally, nothing in this paragraph shall be construed to bind the

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Court so as to limit or prevent the publication of any Confidential Documents to
the jury or factfinder, at the time of trial of this matter, where the Court has

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deemed such Confidential Documents to be admissible into evidence.
20.

Nothing in the parties' Stipulation and this Protective Order shall be

construed as requiring aproducing-disclosing party or counsel to waive the

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requirements hereunder of filing, lodging, or otherwise submitting Confidential
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Documents to the Court only pursuant to the terms of this Stipulation and
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Protective Order and/or to applicable federal or local rules.
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21.

If, in connection with any deposition taken in this action, counsel

questions a witness regarding materials subject to this Stipulation and Protective

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Order, or uses)Confidential Documents as deposition exhibits, at the request of

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opposing counsel or party, the portions ofthe transcripts of such deposition

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testimony wherein such materials are discussed, and the applicable attached

20 exhibits, shall be designated as Confidential Documents and shall be subject to the
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provisions of this Stipulation and Protective Order. However, only deposition

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exhibits that are designated as Confidential Documents shall be subject to the end-

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of
-litigation return requirement of the parties Stipulation and this Protective Order,

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infra (¶¶ 25,26 of this Order; ¶¶ 46-47 of the Stipulation); deposition transcripts

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designated as Confidential Documents shall not be subject to the aforementioned

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end-of
-litigation return requirement of this Stipulation and Protective Order.

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

22.
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The parties Stipulation and this Protective Order is not intended, and

shall not be construed, to prevent current officials or current employees of the City,
or Police Department, or Defendant(s), or other authorized government officials,

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f
rom having access to any documents)to which such officials or employees would
have had access in the normal course of their job duties.
23.

Confidential Documents shall not be shown, produced, shared, copied

to, published, or otherwise disseminated or produced to any person by any
recipient party or counsel, or their agents or persons to whom such recipient party
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or counsel discloses or produces such Confidential Documents, other than as
specified in the parties Stipulation and this Protective Order.
24.

Confidential Documents shall not be shown, produced, shared, copied

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to, published, or otherwise disseminated or produced by any recipient party or
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recipient party's counsel, or their agents or employees, to any member of the press
or news or entertainment media under any circumstances or at any time.
25.

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Electronic copies of any Confidential Documents may be made by any

recipient party or counsel but such copies, and their dissemination by any means or
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medium, shall also be subject to the terms ofthe parties Stipulation and this

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Protective Order, and all such copies in the possession of any recipient party or

20 counsel, or their agents, shall be destroyed or permanently deleted at the
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conclusion of the legal proceedings in the above entitled matter.
26.

At the conclusion-end of the legal proceedings in the above entitled

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matter, each person or entity —except court personnel —who has received any

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Confidential Documents, or any copy thereof, and who is not the producing-

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disclosing party thereof, shall return all such Confidential Documents to the

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producing-disclosing counsel within thirty(30)calendar days of the conclusion of

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such proceedings, or be subject to monetary or other sanctions at the Court's

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

discretion. No recipient party or counsel may retain any Confidential Documents,
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or copies thereof, or permit any person or entity to whom the recipient party or

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counsel provided such documents)to retain any Confidential Documents, after

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legal proceedings in the above entitled matter have concluded.

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27.

All counsel in the above entitled action specifically agree not to cause

or knowingly permit any disclosure or production of any Confidential Documents,
or the contents thereof, except as permitted by the terms ofthe parties Stipulation

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and this Protective Order.
28.

Any restriction or obligation ofthe parties Stipulation and this

Protective Order that applies to any recipient party likewise applies to any
recipient counsel, and vice versa.

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29.

In the event that any party, person, or entity subject to the terms of the

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IS
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parties Stipulation and this Protective Order violates the terms or provisions
thereof, in a manner consistent with the requirements of Due Process and the
applicable provisions governing motions for sanctions under federal law, including
but not limited to the Federal Rules of Civil Procedure and the United States

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District Court, Central District of California Local Rules, to the extent applicable,

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at the Court's discretion, the Court may impose sanctions against the party, person,

20 or entity that the Court finds to have violated ofthe terms of the parties Stipulation
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and this Protective Order. However, nothing in this paragraph shall be construed so

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as to subject counsel for any party in the above entitled action to sanctions for any

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violations) of the parties Stipulation and this Protective Order that are committed

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by other persons or entities —including but not limited to any agent or employee of

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any recipient party or counsel or any consultants or experts retained by any

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recipient party or counsel —provided that, in the event ofthe filing of a motion for

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sanctions for violation ofthe terms of the parties Stipulation and this Protective

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[PROPOSED PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

Order, or within thirty (30) days of the termination of this action (whichever is
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sooner), recipient counsel files a sworn declaration with this Court affirming that:

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( the alleged violator was informed of all of the applicable terms and provisions
a)

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ofthe parties' Stipulation and this Protective Order prior to being provided with

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any Confidential Documents;(b)the alleged violator agreed to abide by the
applicable terms and provisions ofthe parties Stipulation and this Protective Order
prior to being provided with any Confidential Documents; and (c)the recipient

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party and recipient counsel otherwise complied with the end-of
-litigation
return/destruction provisions ofthe parties' Stipulation and this Protective Order
(
e.g., ¶¶ 25-26 of this Order; ¶¶ 46-47 of the parties' Stipulation), to the extent

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applicable. Nothing in the parties Stipulation and this Protective Order shall be
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construed as providing for sanctions or the enforcement of any Court orders
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beyond the powers conferred upon the Court under existing law.
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30.
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shall be in effect until further Order ofthe Court or further written Stipulation by
the parties by and through their attorneys of record.
31.

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The provisions of the parties' Stipulation and this Protective Order

This Protective Order does not govern the use of confidential material

at trial and that use of confidential material at trial shall be governed by order of

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32.

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Any challenge to a confidentiality designation shall be submitted to

the Court in the form of a joint stipulation under Local Rule 37.
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/~/

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~PROPOSEDJ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

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33.

Any procedures specified above in this Protective Order are in

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addition to, and not in lieu of, compliance with the local rules regarding discovery

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motions.

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IT SO ORDERED.

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Dated: May 8, 2017

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UNITED STATES MAGISTRATE JUDGE

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~PROPOSED~ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS

ATTACHMENT "A"

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NONDISCLOSURE AGREEMENT
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I,

do solemnly swear that I am fully familiar with

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the terms of the Protective Order entered in John Doe, et al. v. County of

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Los Angeles, et al., United States District Court for the Central District of
California, Central Division, Case No. CV 16-5946 RGK (PLA), and hereby

s agree to comply with and be bound by the terms and conditions of said
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to
it

Order. I hereby consent to the jurisdiction of the United States District
Court for the Central District of California for purposes of enforcing this
Order.

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Dated:

Signed:

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~0783020.docx

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~PROPOSEDJ PROTECTIVE ORDER RE CONFIDENTIAL DOCUMENTS