Jasmine E. Jackson et al v. County of Los Angeles et al

Filing 35

PROTECTIVE ORDER by Magistrate Judge Karen L. Stevenson re Stipulation for Protective Order, 32 (See Order for details) (rh)

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1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 8 9 10 11 JASMINE E. JACKSON Individually and as Guardian ad Litem for R.G., a Minor, 12 13 14 15 16 17 18 CV 17-4935-SVW (KSx) Plaintiffs, vs. STIPULATED PROTECTIVE ORDER GOVERNING USE AND DISCLOSURE OF CONFIDENTIAL RECORDS COUNTY OF LOS ANGELES, DEPARTMENT OF PROBATION, DEPARTMENT OF CHILDREN AND FAMILY SERVICES, SUPERVISING PROBATION OFFICER JOHN PERRICO, DEPUTY PROBATION OFFICER GUSTAVO JIMENEZ, DCFS SOCIAL WORKERS KAREN VANCE and MICHELE LOYA-CHHABRA, and DOES 1-10, 19 20 Defendants. 21 22 Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and based 23 on the parties’ Stipulated Protective Order Governing Use and Disclosure of 24 Confidential Records (“Stipulation”) filed on November 7, 2017, the terms of 25 the protective order to which the parties have agreed are adopted as a 26 protective order of this Court (which generally shall govern the pretrial phase 27 of this action) except to the extent, as set forth below, that those terms have 28 been modified by the Court’s amendment of paragraphs 2, 7, and 11 of the 1 STIPULATED PROTECTIVE ORDER Case No.: 2:17-CV-04935-SVW-KS 1 Stipulation. 2 3 AGREED TERMS OF THE PROTECTIVE ORDER AS ADOPTED AND 4 MODIFIED BY THE COURT1 5 6 7 1. The Parties understand that the following, upon order thereon by the above entitled Court, constitutes a binding Protective Order. 8 2. The Protective Order shall govern the disclosure of confidential 9 records, documents, and/or information contained therein, as produced by the 10 Juvenile Court in connection with pursuant to this Court’s Order granting the 11 Parties’ Joint Stipulation regarding Production of Juvenile Case File RE: Plaintiff 12 R.G. (Dkt. No. 34)., filed concurrently herewith. 13 Stipulated Protective Order because said records, documents and information 14 contained in the Juvenile Case File is protected under California Welfare and 15 Institutions Code § 827 and California Rules of Court 5.552. 16 3. Good cause exists for this All such records shall be designated by stamping copies of each 17 document 18 “CONFIDENTIAL” on the cover of any multi-page document shall designate all 19 pages of the multi-page document as confidential, unless otherwise indicated. 20 4. “CONFIDENTIAL” before being produced. Stamping Upon receiving confidential information or documents, all Parties and 21 their attorneys of record shall personally safeguard and keep confidential all copies 22 of the confidential information or documents provided by the County of Los 23 Angeles, and all confidential information shall be used only for the purposes set 24 forth below, and only for the purpose of litigating the case Jasmine E. Jackson et al. 25 v. County of Los Angeles, et al., 2:17-CV-04935-SVW-KS. 26 27 28 5. Should any document be inadvertently produced without properly The Court’s additions to the agreed terms of the Protective Order are generally indicated in bold typeface, and the Court’s deletions are indicated by lines through the text being deleted. 1 2 STIPULATED PROTECTIVE ORDER Case No.: 2:17-CV-04935-SVW-KS 1 being marked as “Confidential” under the terms of this Order, the Parties may 2 designate and mark a document as “Confidential” at any time. 3 6. Any confidential document used as an exhibit during a deposition shall 4 be attached to a separate deposition volume marked as “Confidential: Subject to 5 Protective Order.” 6 7. The Parties may only disseminate the confidential information when 7 necessary for the litigation of the above-entitled civil action as follows: a1) to their 8 employees, including paralegal, clerical and secretarial staff, b2) to individuals 9 testifying under oath at deposition or trial in this action, c3) to any expert retained 10 by any Party in this case, Jasmine E. Jackson et al. v. County of Los Angeles, et al., 11 2:17-CV-04935-SVW-KS, if any, and d4) the Court and its personnel, members of 12 its staff, including stenographic, jurors, and other court reporters, as necessary for 13 use in this case, Jasmine E. Jackson et al. v. County of Los Angeles, et al., 2:17-CV- 14 04935-SVW-KS. Any individual listed in paragraphs 7(a) through 7(c) above to 15 whom disclosure is to be made will also be bound by the provisions of this 16 Protective Order. 17 information or records is made by the Parties or their attorneys, the recipient will be 18 advised of this protective order and will confirm by date and signature his/her 19 agreement to comply with it. In the event such individual does not consent to be 20 bound by this Protective Order in writing, no disclosure of the confidential 21 information or documents will be made to such individual. 22 8. Before such disclosure or dissemination of the confidential Copies of all confidential documents and information shall only be 23 used in connection with the litigation of the Jasmine E. Jackson et al. v. County of 24 Los Angeles, et al., 2:17-CV-04935-SVW-KS matter, including depositions, law and 25 motion, trial, and appeal, if any. 26 9. No Party or their attorneys shall disclose or disseminate to the general 27 public or any news media any of the documents or information contained in the 28 documents produced to either Party. This paragraph is not meant to address the use 3 STIPULATED PROTECTIVE ORDER Case No.: 2:17-CV-04935-SVW-KS 1 of confidential documents at a deposition, or for law and motion proceedings and 2 trial in the case Jasmine E. Jackson et al. v. County of Los Angeles, et al., 2:17-CV- 3 04935-SVW-KS. 4 10. Upon conclusion of the Jasmine E. Jackson et al. v. County of Los 5 Angeles, et al., 2:17-CV-04935-SVW-KS case, all confidential information, as well 6 as any information obtained and/or derived from the disclosure of the confidential 7 information, shall be kept confidential. All confidential records provided shall be 8 returned to the producing party or destroyed at the conclusion of the Jasmine E. 9 Jackson et al. v. County of Los Angeles, et al., 2:17-CV-04935-SVW-KS case. 10 11. If any Party should desire to include any Confidential Information 11 or Item in any papers filed with the Court, the Party shall file an application, in 12 accordance with the requirements of Local Rule 79-5, and provide the requisite 13 showing for a Court order allowing such papers to be filed under seal pursuant 14 to Federal Rule of Civil Procedure Rule 5.2(d). 15 protected under this protective order are subject to the United States District Court 16 Central District’s Local Rule 79-5 relating to procedures to file documents under 17 seal. The parties agree to use the procedure listed in Local Rule 79-5 for the filing 18 of any document that is subject to this protective order. 19 12. Documents produced and The Court shall retain jurisdiction to resolve any dispute concerning the 20 use of information disclosed hereunder and any alleged violation of this Protective 21 Order. If there is deemed to be a violation of this order, the court shall determine 22 sanctions or other remedies against the party found to be in violation. 23 24 IT IS SO ORDERED. 25 26 27 28 DATED: November 13, 2017 KAREN L. STEVENSON UNITED STATES MAGISTRATE JUDGE 4 STIPULATED PROTECTIVE ORDER Case No.: 2:17-CV-04935-SVW-KS

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