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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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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JASMINE E. JACKSON Individually and
as Guardian ad Litem for R.G., a Minor,

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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,

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Defendants.

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Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and based

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on the parties’ Stipulated Protective Order Governing Use and Disclosure of

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Confidential Records (“Stipulation”) filed on November 7, 2017, the terms of

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the protective order to which the parties have agreed are adopted as a

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protective order of this Court (which generally shall govern the pretrial phase

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of this action) except to the extent, as set forth below, that those terms have

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been modified by the Court’s amendment of paragraphs 2, 7, and 11 of the
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STIPULATED PROTECTIVE ORDER
Case No.: 2:17-CV-04935-SVW-KS

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Stipulation.

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AGREED TERMS OF THE PROTECTIVE ORDER AS ADOPTED AND

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MODIFIED BY THE COURT1

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1.

The Parties understand that the following, upon order thereon by the

above entitled Court, constitutes a binding Protective Order.

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2.

The Protective Order shall govern the disclosure of confidential

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records, documents, and/or information contained therein, as produced by the

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Juvenile Court in connection with pursuant to this Court’s Order granting the

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Parties’ Joint Stipulation regarding Production of Juvenile Case File RE: Plaintiff

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R.G. (Dkt. No. 34)., filed concurrently herewith.

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Stipulated Protective Order because said records, documents and information

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contained in the Juvenile Case File is protected under California Welfare and

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Institutions Code § 827 and California Rules of Court 5.552.

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3.

Good cause exists for this

All such records shall be designated by stamping copies of each

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document

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“CONFIDENTIAL” on the cover of any multi-page document shall designate all

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pages of the multi-page document as confidential, unless otherwise indicated.

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4.

“CONFIDENTIAL”

before

being

produced.

Stamping

Upon receiving confidential information or documents, all Parties and

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their attorneys of record shall personally safeguard and keep confidential all copies

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of the confidential information or documents provided by the County of Los

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Angeles, and all confidential information shall be used only for the purposes set

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forth below, and only for the purpose of litigating the case Jasmine E. Jackson et al.

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v. County of Los Angeles, et al., 2:17-CV-04935-SVW-KS.

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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.

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STIPULATED PROTECTIVE ORDER
Case No.: 2:17-CV-04935-SVW-KS

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being marked as “Confidential” under the terms of this Order, the Parties may

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designate and mark a document as “Confidential” at any time.

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6.

Any confidential document used as an exhibit during a deposition shall

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be attached to a separate deposition volume marked as “Confidential: Subject to

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Protective Order.”

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7.

The Parties may only disseminate the confidential information when

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necessary for the litigation of the above-entitled civil action as follows: a1) to their

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employees, including paralegal, clerical and secretarial staff, b2) to individuals

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testifying under oath at deposition or trial in this action, c3) to any expert retained

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by any Party in this case, Jasmine E. Jackson et al. v. County of Los Angeles, et al.,

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2:17-CV-04935-SVW-KS, if any, and d4) the Court and its personnel, members of

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its staff, including stenographic, jurors, and other court reporters, as necessary for

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use in this case, Jasmine E. Jackson et al. v. County of Los Angeles, et al., 2:17-CV-

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04935-SVW-KS. Any individual listed in paragraphs 7(a) through 7(c) above to

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whom disclosure is to be made will also be bound by the provisions of this

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Protective Order.

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information or records is made by the Parties or their attorneys, the recipient will be

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advised of this protective order and will confirm by date and signature his/her

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agreement to comply with it. In the event such individual does not consent to be

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bound by this Protective Order in writing, no disclosure of the confidential

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information or documents will be made to such individual.

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8.

Before such disclosure or dissemination of the confidential

Copies of all confidential documents and information shall only be

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used in connection with the litigation of the Jasmine E. Jackson et al. v. County of

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Los Angeles, et al., 2:17-CV-04935-SVW-KS matter, including depositions, law and

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motion, trial, and appeal, if any.

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9.

No Party or their attorneys shall disclose or disseminate to the general

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public or any news media any of the documents or information contained in the

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documents produced to either Party. This paragraph is not meant to address the use
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STIPULATED PROTECTIVE ORDER
Case No.: 2:17-CV-04935-SVW-KS

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of confidential documents at a deposition, or for law and motion proceedings and

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trial in the case Jasmine E. Jackson et al. v. County of Los Angeles, et al., 2:17-CV-

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04935-SVW-KS.

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10.

Upon conclusion of the Jasmine E. Jackson et al. v. County of Los

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Angeles, et al., 2:17-CV-04935-SVW-KS case, all confidential information, as well

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as any information obtained and/or derived from the disclosure of the confidential

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information, shall be kept confidential. All confidential records provided shall be

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returned to the producing party or destroyed at the conclusion of the Jasmine E.

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Jackson et al. v. County of Los Angeles, et al., 2:17-CV-04935-SVW-KS case.

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11.

If any Party should desire to include any Confidential Information

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or Item in any papers filed with the Court, the Party shall file an application, in

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accordance with the requirements of Local Rule 79-5, and provide the requisite

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showing for a Court order allowing such papers to be filed under seal pursuant

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to Federal Rule of Civil Procedure Rule 5.2(d).

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protected under this protective order are subject to the United States District Court

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Central District’s Local Rule 79-5 relating to procedures to file documents under

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seal. The parties agree to use the procedure listed in Local Rule 79-5 for the filing

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of any document that is subject to this protective order.

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12.

Documents produced and

The Court shall retain jurisdiction to resolve any dispute concerning the

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use of information disclosed hereunder and any alleged violation of this Protective

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Order. If there is deemed to be a violation of this order, the court shall determine

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sanctions or other remedies against the party found to be in violation.

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IT IS SO ORDERED.

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DATED: November 13, 2017
KAREN L. STEVENSON
UNITED STATES MAGISTRATE JUDGE
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STIPULATED PROTECTIVE ORDER
Case No.: 2:17-CV-04935-SVW-KS