Kallieldra Bonton et al v. City of Los Angeles et al

Filing 34

PROTECTIVE ORDER by Magistrate Judge Charles F. Eick re Stipulation for Protective Order 33 . (sp)

Ca: 2:17-cv-06984-SVW-E Document 33-1 Filed 04/10/18 Page 1 of 16 Page ID #:181

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KALLIELDRA BONTON and WAYNE
JOSEPH,SR., Individually and as
Successors-in-Interest to Ryan Joseph,
Deceased,

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CASE NO. CV17-06984 SVW (Ex)
H Judge Stephen V. Wilson — Ctrm. 10A, 10`h Fl.
on.
Hon. Mag. Charles F. Eick, Ctrm 750, 7`" Fl.

Plaintiffs,

PROTECTIVE
RDER RE: ISCLOSURE OF
CONFIDENTIAL INFORMATION

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vs.
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CITY OF LOS ANGELES,CITY OF LOS
ANGELES POLICE DEPARTMENT,
CHIEF CHARLIE BECK,ROBERTO
RiTIZ and DOES 1-10, Inclusive.

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Defendants.

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ORDER ON STIPULATION

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The Court, finding good cause, Orders as follows:
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A.

PURPOSES AND LIMITATIONS

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Discovery in this action is likely to involve production ofconfidential, proprietary

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or private information for which special protection from public disclosure and from use

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6 f any purpose other than prosecuting this litigation may be warranted. Accordingly
or
27 the parties hereby stipulate to and petition the Court to enter the following Stipulated
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Protective Order. The parties acknowledge that this Order does not confer blanket
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'Ca

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2:17-cv-06984-SVW-E Document 33-1 Filed 04/10/18 Page 2 of 16 Page ID #:182

protections on all disclosures or responses to discovery and that the protection it affc

rom public disclosure and use extends only to the limited information or items that
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3 ~ entitled to confidential treatment under the applicable legal principles.
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B
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GOOD CAUSE STATEMENT

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This action involves the City of Los Angeles and members of the Los Ange

7 Police Department. Plaintiff is seeking materials and information that Defendants i
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City of Los Angeles et al. ("City") maintains as confidential, such as personnel files

9 the police officers involved in this incident, Internal Affairs materials and informati~
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video recordings, audio recordings, Force Investigation Division materials

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information and other administrative materials and information currently in

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possession of the City and which the City believes need special protection from publi

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disclosure and from use for any purpose other than prosecuting this litigation. Plaintiff

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is also seeking official information contained in the persorulel files ofthe police officer

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involved in the subject incident, which the City maintains as strictly confidential an

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which the City believes need special protection from public disclosure and from use fc

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any purpose other than prosecuting this litigation.

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The City asserts that the confidentiality of the materials and information sougY

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by Plaintiff is recognized by California and federal law, as evidenced inter alia b;

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California Penal Code section 832.7 and Kerr v. United States Dist. Ct.for N.D. Cal

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511 F.2d 192, 198(9th Cir. 1975), affd,426 U.S. 394(1976). The City has not pul

22 released the materials and information referenced above except under protective
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or pursuant to a court order, if at all. These materials and information are of the

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that has been used to initiate disciplinary action against Los Angeles Police Depart

"LAPD") officers, and has been used as evidence in disciplinary proceedings, when
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the officers' conduct was considered to be contrary to LAPD policy.

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The City contends that absent a protective order delineating the responsibilities o

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nondisclosure on the part ofthe parties hereto,there is a specific risk ofunnecessary anc
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1 ~ undue disclosure by one or more of the many attorneys, secretaries, law cler
2 ~ ~ paralegals and expert witnesses involved in this case, as well as the corollary risk o
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embarrassment, harassment and professional and legal harm on the part of the

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officers referenced in the materials and information.

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The City also contends that the unfettered disclosure of the materials an.

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information, absent a protective order, would allow the media to share this information

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with potential jurors in the area, impacting the rights of the City herein to receive a fai

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trial.

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Accordingly, to expedite the flow of information, to facilitate the

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resolution of disputes over confidentiality of discovery materials, to adequately prc

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

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permitted reasonable necessary uses of such material in preparation for and in

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conduct of trial, to address their handling at the end ofthe litigation, and serve the E

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ofjustice, a protective order for such information is justified in this matter. It is

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intent of the parties that information will not be designated as confidential for tac

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reasons and that nothing be so designated without a good faith belief that it has 1

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maintained in a confidential, non-public manner, and there is good cause why it sh

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not be part ofthe public record of this case.

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C
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SEAL

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ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

The parties agree that any pleadings, motions, briefs, declarations, stipulation

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e~ibits or other written submissions to the Court in this litigation which contain

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incorporate Confidential Material shall be lodged with an application and/or joi

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stipulation to file the papers or the portion thereof containing the Confidential Materi~

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under seal.

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The parties agree that they will meet and confer regarding the necessity ofseeki

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an order from the Court filing under seal any pleadings, motions, briefs, declaration
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stipulations, exhibits or other documents and/or materials at least five (5) days prior to

iling any application and/or joint stipulation to file under seal.
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The parties further acknowledge, as set forth in Section 12.3, below, that this

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Stipulated Protective Order does not automatically entitle them to file confidential

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information under seal and that Local Civil Rule 79-5 sets forth the procedures that must

6 ~ be followed and the standards that will be applied when a party seeks permission
7 the Court to file material under seal.
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DEFINITIONS
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Action: Kallieldra Bonton, et al. v. City ofLos Angeles, et al. CV 17

SVW (Ex).
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Challenging Party: a Party or Non-Party that challenges the

ofinformation or items under this Order.
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"CONFIDENTIAL" Information or Items: information (regardless

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

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under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cap

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Statement. This also includes (1) any information copied or extracted from ~

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Confidential information;(2) all copies, excerpts, summaries, abstracts or compilatic

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of Confidential information; and(3)any testimony, conversations, or presentations t;

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might reveal Confidential information.

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Counsel: Counsel of record for the parties to this civil litigation and

22 support staff.
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Designating Party: a Party or Non-Party that designates information o

items that it produces in disclosures or in responses to discovery as"CONFIDENTIAL.'
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Disclosure or Discovery Material: all items or information, regardless o

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

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other things, testimony, transcripts, and tangible things), that are produced or generates

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in disclosures or responses to discovery in this matter

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2.7

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

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

3 ~ expert witness or as a consultant in this Action.
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terminated by way of settlement, dismissal, trial and/or appeal.
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House Counsel: attorneys other than Counsel(as defined in paragraph 2.4

and who are employees of a party to this Action.
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.10 Non-Party: any natural person, partnership, corporation, association o

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Final Disposition: when this Action has been fully and completel;

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

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.11 Outside Counsel of Record: attorneys who are not employees of a part;
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to this Action but are retained to represent or advise a party to this Action and have

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appeared in this Action on behalf of that party or are affiliated with a law firm that ha

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appeared on behalf of that party, and includes support staff.
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.12 Par

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

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boards, departments, divisions, employees, consultants, retained experts, and Outside

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Counsel of Record (and their support staffs).
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.13 Producing Party: a Party or Non-Party that produces Disclosure c

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Discovery Material in this Action.
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.14 Professional Vendors: persons or entities that provide litigation suppo~

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20 services (e.g., photocopying, videotaping, translating, preparing exhibits c
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demonstrations, and organizing, storing, or retrieving data in any form or medium) an•

22 their employees and subcontractors.
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.15 Protected Material: any Disclosure or Discovery Material that i

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designated as "CONFIDENTIAL."

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.16 Receiving Party: a Pariy that receives Disclosure or Discovery

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6 rom a Producing Party.
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SCOPE

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The protections conferred by this Stipulation and Order cover not only

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

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

4 Protected Material; and (3)any testimony, conversations, or presentations by Parties o
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their Counsel that might reveal Protected Material.
Any use ofProtected Material at trial shall be governed by the orders ofthe trial

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7 judge. This Order does not govern the use of Protected Material at trial.
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DURATION
Once a trial commences in this Action, information that was designated

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CONFIDENTIAL or maintained pursuant to this protective order and that is introduces

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or admitted as an exhibit at trial becomes public and will be presumptively available tc

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all members of the public, including the press, unless compelling reasons supported b;

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specific factual findings to proceed otherwise are made to the trial judge in advance o

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the trial. See Kamakana v. City and County ofHonolulu, 447 F.3d 1172, 1180-81 (9t1

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Cir. 2006)(distinguishing "good cause" showing for sealing documents produced i~

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discovery from "compelling reasons" standard when merits-related documents are par

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of court record). Accordingly, the terms of this protective order do not extend

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the commencement of the trial as to the CONFIDENTIAL information and n

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introduced or admitted as an exhibit at trial.

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DESIGNATING PROTECTED MATERIAL

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Each Party orNon-Party that designates information or items for protection unde

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

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

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

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

Exercise of Restraint and Care in DesiQ

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1 ~ which protection is not warranted are not swept unjustifiably within the ambit of this
2 ~ Order.
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Mass, indiscriminate or routinized designations are prohibited. Designations tha

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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) may expose the Designating Pariy to sanctions.

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

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

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

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Manner and Timing of Designations. Except as otherwise provided

12 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherw
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stipulated or ordered, Disclosure or Discovery Material that qualifies for protecti

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under this Order must be clearly so designated before the material is disclosed

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produced.

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Designation in conformity with this Order requires:

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

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excluding transcripts of depositions or other pretrial or trial proceedings), that tt

19 Producing Party affix at a minimum, the legend "CONFIDENTIAL" or words of
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similar effect, and that includes the case name and case number (hereinaft

CONFIDENTIAL legend"), to each page that contains protected material. If only
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portion ofthe material on a page qualifies for protection, the Producing Party also mu

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clearly identify the protected portions)(e.g., by making appropriate markings in tt

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margins).

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

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not designate them for protection until after the inspecting Party has indicated whicY

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documents it would like copied and produced. During the inspection and before the

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designation, all of the material made available for inspection shall be deemec
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2:17-cv-06984-SVW-E Document 33-1 Filed 04/10/18 Page 8 of 16 Page ID #:188

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"CONFIDENTIAL." After the inspecting Party has identified the documents it wa

2 copied and produced,the Producing Party must determine which documents, or porti~
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thereof, qualify for protection under this Order. Then, before producing the specif

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documents,the Producing Party must affix the "CONFIDENTIAL legend" to each p.

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that contains Protected Material. If only a portion ofthe material on a page qualifies

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protection, the Producing Party also must clearly identify the protected portions)(e

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by making appropriate markings in the margins).

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

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Disclosure or Discovery Material on the record, before the close of the deposition

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( for information produced in some form other than documentary and for a:
c)

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other tangible items, that the Producing Party affix in a prominent place on the exteri

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of the container or containers in which the information is stored the le~e~

CONFIDENTIAL." If only a portion or portions of the information
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protection, the Producing Party, to the extent practicable, shall identify the

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portion(s).
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Inadvertent Failures to Designate. If timely corrected, an inadvertf

failure to designate qualified information or items does not, standing alone, waive 1

19 Designating Party's right to secure protection under this Order for such material. Up
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timely correction of a designation, the Receiving Party must make reasonable efforts

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assure that the material is treated in accordance with the provisions of this Order.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS

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Timing of Challenges.

Any Party or Non-Party may challenge

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designation of confidentiality at any time that is consistent with the Court's Scheduli

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Order.

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6.2

Meet and Confer.

The Challenging Party shall initiate the dis

resolution process under Local Rule 37.1 et seq.

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6.3

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

2 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
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to harass or impose unnecessary expenses and burdens on other parties) may expose the

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Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

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the confidentiality designation, all parties shall continue to afford the material in

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question the level of protection to which it is entitled under the Producing Party's

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designation until the Court rules on the challenge.

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ACCESS TO AND USE OF PROTECTED MATERIAL
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Basic Principles. A Receiving Party may use Protected Material that i

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

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only for prosecuting, defending or attempting to settle this Action. Such Protecte~

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

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

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comply with the provisions of section 13 below(FINAL DISPOSITION).

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

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

18 I authorized under this Order.
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Disclosure of "CONFIDENTIAL" Information or Items.

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otherwise ordered by the court or permitted in writing by the Designating Party,

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Receiving Party may disclose any information or item designated "CONFIDENTIAL'

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2 only to:
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( the Receiving Party's Counsel of Record in this Action, as well as employee.
a)

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ofsaid Counsel ofRecord to whom it is reasonably necessary to disclose the information

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f this Action;
or

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

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is reasonably necessary for this Action and who have signed the "Acknowledgment anc

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Agreement to Be Bound"(Exhibit A);

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(c) the court and its personnel;

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( court reporters and their staff;
e)

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

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

Acknowledgment and Agreement to Be Bound"(E~ibit A);
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( the author or recipient ofa document containing the information or a custodi~
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7 or other person who otherwise possessed or knew the information;
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( during their depositions, witnesses, and attorneys for witnesses, in the Actic
g)

9 to whom disclosure is reasonably necessary provided:(1) the deposing party reques
10 that the witness sign the form attached as Exhibit A hereto; and (2) they will not t
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permitted to keep any confidential information unless they sign the "Acknowledgme~

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and Agreement to Be Bound"(Exhibit A), unless otherwise agreed by the Designatir.

13 Party or ordered by the court. Pages of transcribed deposition testimony or e~chibits ~
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depositions that reveal Protected Material may be separately bound by the court report•

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

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Order; and

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

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agreed upon by any ofthe parties engaged in settlement discussions and who have si

19 the "Acknowledgment and Agreement to Be Bound"(Exhibit A).
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.3. Counsel making the disclosure to any qualified person described herein

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shall retain the original executed copy ofthe Nondisclosure Agreement until sixty(60

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days after this litigation has become final, including any appellate review, any

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monitoring of an injunction. Counsel for the Receiving Party shall maintain all signet

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Nondisclosure Agreements and shall produce the original signature page

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reasonable written notice from opposing counsel. Ifan issue arises regarding a purpo

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unauthorized disclosure of Confidential Information, upon noticed motion of Conte

iled by the Designating Party, counsel for the Receiving Party may be required to
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the signed Nondisclosure Agreements, as well as a list of the disclosed materials, ir.

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camera with the Court having jurisdiction ofthe Stipulation.

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PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

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

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include a copy ofthe subpoena or court order;

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

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in the other litigation that some or all ofthe material covered by the subpoena or

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

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

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the Designating Party whose Protected Material may be affected.

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The Party served with the subpoena or court order shall not produce a

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information designated in this action as "CONFIDENTIAL", unless the Party r

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obtained the Designating Party's permission or an order from the court from which t

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subpoena or order issued.

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

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f
rom another court.

Nothing in these provisions should be construed

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ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION

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

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Party in this Action and designated as "CONFIDENTIAL." Such information produced
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1 ~ by Non-Parties in connection with this litigation is protected by the remedies and reli
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provided by this Order. Nothing in these provisions should be construed as prohibitin

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a Non-Party from seeking additional protections.

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

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a Non-Party's confidential information in its possession, and the Party is subject to a

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agreement with the Non-Party not to produce the Non-Party's confidential information

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then the Party shall:

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

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some or all ofthe information requested is subject to a confidentiality agreemen
with allon-Party;

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

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Protective Order in this Action,the relevant discovery request(s), and a reasonab

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specific description ofthe information requested; and
( make the information requested available for inspection by the Non
3)

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Party, if requested.

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

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ofreceiving the notice and accompanying information,the Receiving Party may product

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the Non-Party's confidential information responsive to the discovery request. If the

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Non-Party timely seeks a protective order, the Receiving Party shall not produce an;

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information in its possession or control that is subject to the confidentiality agreemen

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with the Non-Party before a determination by the court. Absent a court order to the

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contrary, the Non-Party shall bear the burden and expense of seeking protection in thi

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court of its Protected Material.

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10.

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

27 Protected Material to any person or in any circumstance not authorized under
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Stipulated Protective Order, the Receiving Party must immediately(a) notify in wri
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the Designating Party ofthe unauthorized disclosures,(b) use its best efforts to retrie

2 all unauthorized copies of the Protected Material,(c) inform the person or persons
3

whom unauthorized disclosures were made of all the terms ofthis Order, and(d)requ

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such person or persons to execute the "Acknowledgment and Agreement to Be Bour.

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that is attached hereto as E~ibit A.

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7 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
8

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 ofthe Receiving Parties are those set forth in Federal Rule ofCivil Procedure

12 26(b)(5)(B). This provision is not intended to modify whatever procedure may be
13

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

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review. Pursuant to Federal Rule ofEvidence 502(d)and (e), insofar as the parties reach

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an agreement on the effect of disclosure of a communication or information covered by

16 the attorney-client privilege or work product protection,the parties may incorporate their
17 agreement in the stipulated protective order submitted to the court.
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12.

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

person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry of thi:

23 Protective Order, no Party waives any right it otherwise would have to object tc
24

disclosing or producing any information or item on any ground not addressed in thi:

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Stipulated Protective Order. Similarly, no Party waives any right to object on and

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ground to use in evidence of any ofthe material covered by this Protective Order.

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

28 Protected Material must comply with Local Civil Rule 79-5. Protected Material ma}
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Cash 2:17-cv-06984-SVW-E Document 33-1 Filed 04/10/18 Page 14 of 16 Page ID #:194

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only be filed under seal pursuant to a court order authorizing the sealing of the specific

2 Protected Material at issue. If a Party's request to file Protected Material under seal is
3

denied by the court, then the Receiving Party may file the information in the public

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record unless otherwise instructed by the court.

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6

13.

FINAL DISPOSITION

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After the FINAL DISPOSITION of this Action, as defined in paragraph 2.8

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within 30 days ofa written request by the Designating Party, each Receiving Party mus

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return all Protected Material to the Producing Party. As used in this subdivision, "al

10 Protected Material" includes all copies, abstracts, compilations, summaries, and am
11

other format reproducing or capturing any of the Protected Material. The Receiving

12 Party must submit a written certification to the Producing Party (and, if not the samf
13

person or entity, to the Designating Party) by the 30 day deadline that(1) identifies (b;

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category, where appropriate) all the Protected Material that was returned and(2)affirm.

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that the Receiving Party has not retained any copies, abstracts, compilations, summaries

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or any other format reproducing or capturing any ofthe Protected Material.

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14.

VIOLATION
Any violation of this Order may be punished by appropriate measures incl

without limitation, contempt proceedings and/or monetary sanctions.

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ITISSO STIPULATED:

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24 ~ ~ Dated: April 10, 2018

LAW OFFICES OF DALE K. GALIPO

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By:

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/s/Hang D. Le
DALE K. GALIPO,Esq.
HANG D. LE,Esq.
Attorneys for Plaintiffs, KALLIELDRA BONTON
and WAYNE JOSEPH,SR.
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~ 2:17-cv-06984-SVW-E Document 33-1 Filed 04/10/18 Page 15 of 16 Page ID #:195

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~ Dated: April 10, 2018

LAW OFFICE OF STEVEN WOLFSON

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By:

/s/Steven Wolfson
STEVEN WOLFSON,Esq.
Attorneys for Plaintiffs, KALLIELDRA BONTON
and WAYNE JOSEPH,SR.

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~ Dated: April 10, 2018

LAW OFFICE OF WAYNE MCCLEAN

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By:

/s/Rov W. McClean
ROY W. MCCLEAN,Esq.
VANESSA P. NATIVIDAD,Esq.
Attorneys for Plaintiffs, KALLIELDRA BONTON
and WAYNE JOSEPH,SR.

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12 ~ Dated: April 10, 2018
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MICHAEL N. FEUER,City Attorney
THOMAS H.PETERS,Chief Assistant City A
CORY M.BRENTE,Assistant City Attorney
By:

/s/ Colleen R. Smith
COLLEEN R. SMITH,Deputy City Attorney
Attorneys for Defendants, CITY OF LOS ANGELE
and CHIEF CHARLIE BECK

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Dated: April 10, 2018

ORBACH HUFF SUAREZ and HENDERSON L]
By:

/s/Kevin E. Gilbert
KEVIN E. GILBRT,Esq.
Attorneys for Defendant, ROBERTO RUIZ

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FOR GOOD CAUSE SHOWN,IT IS SO ORDERED.
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Dated:~~,
2018

By:

~~~_~~
~ ~ ~~v~~~

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HONORABLE CHARLES F. EICK

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UNITED STATES MAGISTRATE JUDGE

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~ 2:17-cv-06984-SVW-E Document 33-1 Filed 04/10/18 Page 16 of 16 Page ID #:196

ATTACHMENT "A"

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NONDISCLOSURE AGREEMENT

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I,

do solemnly swear that I am fully familiar with

the terms of the Protective Order entered in Kallieldra Bonton, et al. v. City of Los
Angeles, et al., United States District Court for the Central District ofCalifornia, Central
Division, Case No. CV17-06984 SVW (Ex), and hereby agree to comply with and be
bound by the terms and conditions of said 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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