Jhonny Roldan v. County of Los Angeles et al
Filing
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STIPULATED PROTECTIVE ORDER by Magistrate Judge Stephanie S. Christensen re Stipulation for Protective Order 44 (tsn)
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JILL WILLIAMS - State Bar No. 221793
ESTHER TEIXEIRA – State Bar No. 346431
CARPENTER, ROTHANS & DUMONT LLP
500 South Grand Avenue, 19th Floor
Los Angeles, California 90071
(213) 228-0400 / (213) 228-0401 (Fax)
jwilliams@crdlaw.com / eteixeira@crdlaw.com
Attorneys for Specially Appearing,
County of Los Angeles
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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JHONNY ROLDAN, Individually, ) Case No. 2:24-cv-03485íPA (SSCx)
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Plaintiff,
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) STIPULATED PROTECTIVE ORDER
v.
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COUNTY OF LOS ANGELES, a )
public entity, 168 REALTY INC., )
TONY CHANG, VICTOR S K
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KUNG, and Individual LASD
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Sheriff Deputies DOES 1 through )
10, Jointly and Severally,
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Defendants.
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1.
INTRODUCTION
1.1
Purposes and Limitations. Discovery in this action is likely to involve
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production of confidential, proprietary, or private information for which special
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protection from public disclosure and from use for any purpose other than
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prosecuting this litigation may be warranted. Accordingly, the parties hereby
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stipulate to and petition the court to enter the following Stipulated Protective
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Order. The parties acknowledge that this Order does not confer blanket
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protections on all disclosures or responses to discovery and that the protection it
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affords from public disclosure and use extends only to the limited information or
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items that are entitled to confidential treatment under the applicable legal
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principles.
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1.2
Good Cause Statement. There is good cause and a particularized need
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for a protective order to preserve the interests of confidentiality and privacy in
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peace officer personnel file records and associated investigative or confidential
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records.
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Peace officers have a federal privilege of privacy in their personnel file
records: a reasonable expectation of privacy therein that is underscored, specified,
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and arguably heightened by the Pitchess protective procedure of California law.
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See Sanchez v. Santa Ana Police Dept., 936 F.2d 1027, 1033-1034 (9th Cir. 1990);
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Hallon v. City of Stockton, 2012 U.S. Dist. LEXIS 14665, *2-3, 12-13 (E.D. Cal.
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2012) (concluding that “while “[f]ederal law applies to privilege based discovery
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disputes involving federal claims,” the “state privilege law which is consistent with
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its federal equivalent significantly assists in applying [federal] privilege law to
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discovery disputes”); Soto v. City of Concord, 162 F.R.D. 603, 613 n. 4, 616 (N.D.
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Cal. 1995) (peace officers have constitutionally-based “privacy rights [that] are not
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inconsequential” in their police personnel records); cf. Cal. Penal Code §§ 832.7,
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832.8; Cal. Evid. Code §§ 1040-1047. Unrestricted disclosure of such personnel
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file information could potentially threaten the safety of non-party witnesses,
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officers, and their families/associates.
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Second, municipalities and law enforcement agencies have federal
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deliberative-executive process privilege, federal official information privilege,
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federal law enforcement privilege, and federal attorney-client privilege (and/or
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attorney work product protection) interests in the personnel files of their peace
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officers – particularly as to those portions of peace officer personnel files that
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contain critical self-analysis, internal deliberation/decision-making or
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evaluation/analysis, or communications for the purposes of obtaining or rendering
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legal advice or analysis – potentially including but not limited to evaluative /
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analytical portions of Internal Affairs type records or reports, evaluative /
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analytical portions of supervisory records or reports, and/or reports prepared at the
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direction of counsel, or for the purpose of obtaining or rendering legal advice
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Defendants further contend that municipalities and law enforcement agencies have
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duties to respect the privacy rights of officers and third parties to this litigation,
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and such duties may bear on the course of discovery in this matter. See Sanchez,
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936 F.2d at 1033-1034; Maricopa Audubon Soc’y v. United States Forest Serv.,
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108 F.3d 1089, 1092-1095 (9th Cir. 1997); Soto, 162 F.R.D. at 613, 613 n. 4;
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Kelly v. City of San Jose, 114 F.R.D. 654, 668-671 (N.D. Cal. 1987); Tuite v.
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Henry, 181 F.R.D. 175, 176-177 (D. D.C. 1998); Hamstreet v. Duncan, 2007 U.S.
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Dist. LEXIS 89702 (D. Or. 2007); Admiral Ins. Co. v. United States Dist. Ct., 881
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F.2d 1486, 1492, 1495 (9th Cir. 1988). Defendants further contend that such
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personnel file records are restricted from disclosure by the public entity’s
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custodian of records pursuant to applicable California law and that uncontrolled
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release is likely to result in needless intrusion of officer privacy; impairment in the
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collection of third-party witness information and statements and related legitimate
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law enforcement investigations/interests; and a chilling of open and honest
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discussion regarding and/or investigation into alleged misconduct that can erode a
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public entity’s ability to identify and/or implement any remedial measures that
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may be required.
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Third, because peace officers do not have the same rights as other private
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citizens to avoid giving compelled statements, it is contrary to the fundamental
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principles of fairness to permit uncontrolled release of officers’ compelled
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statements. See generally Lybarger v. City of Los Angeles, 40 Cal.3d 822, 828-
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830 (1985); cf. U.S. Const., amend V.
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Accordingly, without a protective order preventing such, production of
confidential records in the case can and will likely substantially impair and harm
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the public entity’s interests in candid self-critical analysis, frank internal
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deliberations, obtaining candid information from witnesses, preserving the safety
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of witnesses, preserving the safety of peace officers and peace officers’ families
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and associates, protecting the privacy officers of peace officers, and preventing
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pending investigations from being detrimentally undermined by publication of
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private, sensitive, or confidential information – as can and often does result in
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litigation.
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It is the intent of the parties that information will not be designated as
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confidential for tactical reasons and that nothing be so designated without a good
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faith belief that it has been maintained in a confidential, non-public manner, and
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there is good cause why it should not be part of the public record of this case.
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1.3
Acknowledgment of Procedure for Filing Under Seal. The parties
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further acknowledge, as set forth in Section 12.3, below, that this Stipulated
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Protective Order does not entitle them to file confidential information under seal;
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Local Rule 79-5 sets forth the procedures that must be followed and the standards
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that will be applied when a party seeks permission from the court to file material
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under seal.
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There is a strong presumption that the public has a right of access to judicial
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proceedings and records in civil cases. In connection with non-dispositive
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motions, good cause must be shown to support a filing under seal. See Kamakana
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v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel.
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Ests. of Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002),
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Makar-Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
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stipulated protective orders require good cause showing), and a specific showing
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of good cause or compelling reasons with proper evidentiary support and legal
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justification, must be made with respect to Protected Material that a party seeks to
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file under seal. The parties’ mere designation of Disclosure or Discovery Material
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as CONFIDENTIAL does not—without the submission of competent evidence by
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declaration, establishing that the material sought to be filed under seal qualifies as
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confidential, privileged, or otherwise protectable—constitute good cause.
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Further, if a party requests sealing related to a dispositive motion or trial, then
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compelling reasons, not only good cause, for the sealing must be shown, and the
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relief sought shall be narrowly tailored to serve the specific interest to be protected.
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See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For
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each item or type of information, document, or thing sought to be filed or
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introduced under seal in connection with a dispositive motion or trial, the party
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seeking protection must articulate compelling reasons, supported by specific facts
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and legal justification, for the requested sealing order. Again, competent evidence
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supporting the application to file documents under seal must be provided by
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declaration.
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Any document that is not confidential, privileged, or otherwise protectable
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in its entirety will not be filed under seal if the confidential portions can be
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redacted. If documents can be redacted, then a redacted version for public
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viewing, omitting only the confidential, privileged, or otherwise protectable
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portions of the document, shall be filed. Any application that seeks to file
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documents under seal in their entirety should include an explanation of why
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redaction is not feasible.
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2.
DEFINITIONS
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2.1
Action: Jhonny Roldan v. County of Los Angeles, et al, United States
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District Court Case No. 2:24-cv-03485íPA (SSCx).
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Challenging Party: a Party or Non-Party that challenges the
designation of information or items under this Order.
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“CONFIDENTIAL” Information or Items: information (regardless of
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how it is generated, stored or maintained) or tangible things that qualify for
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protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as
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specified above in the Good Cause Statement.
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Counsel: Outside Counsel of Record and House Counsel (as well as
their support staff).
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Designating Party: a Party or Non-Party that designates information
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or items that it produces in disclosures or in responses to discovery as
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“CONFIDENTIAL.”
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2.6
Disclosure or Discovery Material: all items or information, regardless
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of the medium or manner in which it is generated, stored, or maintained (including,
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among other things, testimony, transcripts, and tangible things), that are produced
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or generated in disclosures or responses to discovery in this matter.
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Expert: a person with specialized knowledge or experience in a matter
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pertinent to the litigation who has been retained by a Party or its counsel to serve
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as an expert witness or as a consultant in this Action.
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2.8
Final Disposition: the later of (1) dismissal of all claims and defenses
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in this Action, with or without prejudice; and (2) final judgment herein after the
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completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
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this Action, including the time limits for filing any motions or applications for
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extension of time pursuant to applicable law.
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2.9
In-House Counsel: attorneys who are employees of a party to this
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Action. In-House Counsel does not include Outside Counsel of Record or any
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other outside counsel.
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2.10 Non-Party: any natural person, partnership, corporation, association,
or other legal entity not named as a Party to this action.
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2.11 Outside Counsel of Record: attorneys who are not employees of a
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party to this Action but are retained to represent or advise a party to this Action
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and have appeared in this Action on behalf of that party or are affiliated with a law
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firm which has appeared on behalf of that party, and includes support staff.
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2.12 Party: any party to this Action, including all of its officers, directors,
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employees, consultants, retained experts, and Outside Counsel of Record (and their
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support staffs).
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2.13 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
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2.14 Professional Vendors: persons or entities that provide litigation-
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support services (e.g., photocopying, videotaping, translating, preparing exhibits or
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demonstrations, and organizing, storing, or retrieving data in any form or medium)
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and their employees and subcontractors.
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2.15 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”
2.16 Receiving Party: a Party that receives Disclosure or Discovery
Material from a Producing Party.
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3.
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The protections conferred by this Stipulation and Order cover not only
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Protected Material (as defined above), but also (1) any information copied or
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extracted from Protected Material; (2) all copies, excerpts, summaries, or
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compilations of Protected Material; and (3) any testimony, conversations, or
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presentations by Parties or their Counsel that might reveal Protected Material.
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Any use of Protected Material at trial shall be governed by the orders of the trial
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judge. This Stipulated Protective Order does not govern the use of Protected
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Material at trial.
SCOPE
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4.
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The terms of this Stipulated Protective Order apply through Final
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TRIAL AND DURATION
Disposition of the Action.
Once a case proceeds to trial, information that was designated as
CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and
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used or introduced as an exhibit at trial becomes public and will be presumptively
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available to all members of the public, including the press, unless compelling
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reasons supported by specific factual findings to proceed otherwise are made to the
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trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81
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(distinguishing “good cause” showing for sealing documents produced in
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discovery from “compelling reasons” standard when merits-related documents are
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part of court record). Accordingly, for such materials, the terms of this Stipulated
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Protective Order do not extend beyond the commencement of the trial.
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Even after Final Disposition of this litigation, the confidentiality obligations
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imposed by this Stipulated Protective Order shall remain in effect until a
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Designating Party agrees otherwise in writing or a court order otherwise directs.
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5.
DESIGNATING PROTECTED MATERIAL
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5.1
Exercise of Restraint and Care in Designating Material for Protection.
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Each Party or Non-Party that designates information or items for protection under
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this Order must take care to limit any such designation to specific material that
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qualifies under the appropriate standards. The Designating Party must designate
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for protection only those parts of material, documents, items, or oral or written
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communications that qualify so that other portions of the material, documents,
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items, or communications for which protection is not warranted are not swept
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unjustifiably within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations
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that are shown to be clearly unjustified or that have been made for an improper
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purpose (e.g., to unnecessarily encumber the case development process or to
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impose unnecessary expenses and burdens on other parties) may expose the
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Designating Party to sanctions.
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If it comes to a Designating Party’s attention that information or items that it
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designated for protection do not qualify for protection, that Designating Party must
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promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2
Manner and Timing of Designations. Except as otherwise provided in
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this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a)
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below), or as otherwise stipulated or ordered, Disclosure or Discovery Material
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that qualifies for protection under this Stipulated Protective Order must be clearly
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so designated before the material is disclosed or produced.
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Designation in conformity with this Stipulated Protective Order requires:
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(a) for information in documentary form (e.g., paper or electronic
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documents, but excluding transcripts of depositions or other pretrial or trial
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proceedings), that the Producing Party affix at a minimum, the legend
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“CONFIDENTIAL” to each page that contains protected material. If only a
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portion or portions of the material on a page qualifies for protection, the Producing
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Party also must clearly identify the protected portion(s) (e.g., by making
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appropriate markings in the margins).
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A Party or Non-Party that makes original documents available for inspection
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need not designate them for protection until after the inspecting Party has indicated
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which documents it would like copied and produced. During the inspection and
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before the designation, all of the material made available for inspection shall be
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deemed CONFIDENTIAL. After the inspecting Party has identified the
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documents it wants copied and produced, the Producing Party must determine
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which documents, or portions thereof, qualify for protection under this Stipulated
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Protective Order. Then, before producing the specified documents, the Producing
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Party must affix the “CONFIDENTIAL” legend to each page that contains
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Protected Material. If only a portion or portions of the material on a page qualifies
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for protection, the Producing Party also must clearly identify the protected
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portion(s) (e.g., by making appropriate markings in the margins).
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(b)
for testimony given in depositions that the Designating Party identify
the Disclosure or Discovery Material on the record, before the close of the
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deposition all protected testimony.
(c)
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for information produced in some form other than documentary and
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for any other tangible items, that the Producing Party affix in a prominent place on
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the exterior of the container or containers in which the information is stored the
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“CONFIDENTIAL” legend. If only a portion or portions of the information
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warrants protection, the Producing Party, to the extent practicable, shall identify
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the protected portion(s).
5.3
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Inadvertent Failures to Designate. If timely corrected, an inadvertent
failure to designate qualified information or items does not, standing alone, waive
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the Designating Party’s right to secure protection under this Order for such
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material. Upon timely correction of a designation, the Receiving Party must make
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reasonable efforts to assure that the material is treated in accordance with the
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provisions of this Stipulated Protective Order.
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6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
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6.1
Timing of Challenges. Any Party or Non-Party may challenge a
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designation of confidentiality at any time that is consistent with the court’s
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Scheduling Order.
6.2
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Meet and Confer. The Challenging Party shall initiate the dispute
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resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge
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Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”1
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The burden of persuasion in any such challenge proceeding shall be
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on the Designating Party. Frivolous challenges, and those made for an improper
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purpose (e.g., to harass or impose unnecessary expenses and burdens on other
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parties) may expose the Challenging Party to sanctions. Unless the Designating
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Party has waived or withdrawn the confidentiality designation, all parties shall
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Judge Christensen’s Procedures are available at
https://www.cacd.uscourts.gov/honorable-stephanie-s-christensen.
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continue to afford the material in question the level of protection to which it is
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entitled under the Producing Party’s designation until the court rules on the
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challenge.
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7.
ACCESS TO AND USE OF PROTECTED MATERIAL
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7.1
Basic Principles. A Receiving Party may use Protected Material that
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is disclosed or produced by another Party or by a Non-Party in connection with
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this Action only for prosecuting, defending, or attempting to settle this Action.
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Such Protected Material may be disclosed only to the categories of persons and
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under the conditions described in this Order. When the Action reaches a Final
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Disposition, a Receiving Party must comply with the provisions of section 13
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below.
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Protected Material must be stored and maintained by a Receiving Party at a
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location and in a secure manner that ensures that access is limited to the persons
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authorized under this Stipulated Protective Order.
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7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless
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otherwise ordered by the court or permitted in writing by the Designating Party, a
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Receiving Party may disclose any information or item designated
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“CONFIDENTIAL” only:
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(a) to the Receiving Party’s Outside Counsel of Record in this Action, as
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well as employees of said Outside Counsel of Record to whom it is reasonably
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necessary to disclose the information for this Action;
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(b) to the officers, directors, and employees (including House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this Action;
(c) to Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this Action and who have signed the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d) to the court and its personnel;
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(e) to court reporters and their staff;
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(f) to professional jury or trial consultants, mock jurors, and Professional
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Vendors to whom disclosure is reasonably necessary for this Action and who have
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signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(g) to the author or recipient of a document containing the information or
a custodian or other person who otherwise possessed or knew the information;
(h) during their depositions, to witnesses, and attorneys for witnesses, in
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the Action to whom disclosure is reasonably necessary, provided: (1) the deposing
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party requests that the witness sign the “Acknowledgment and Agreement to Be
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Bound” (Exhibit A); and (2) the witness will not be permitted to keep any
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confidential information unless they sign the “Acknowledgment and Agreement to
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Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
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ordered by the court. Pages of transcribed deposition testimony or exhibits to
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depositions that reveal Protected Material may be separately bound by the court
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reporter and may not be disclosed to anyone except as permitted under this
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Stipulated Protective Order; and
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(i) to any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions.
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8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION
If a Party is served with a subpoena or a court order issued in other litigation
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that compels disclosure of any information or items designated in this Action as
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“CONFIDENTIAL,” that Party must:
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(a) promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order;
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(b) promptly notify in writing the party who caused the subpoena or order to
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issue in the other litigation that some or all of the material covered by the
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subpoena or order is subject to this Protective Order. Such notification shall
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include a copy of this Stipulated Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be pursued by
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the Designating Party whose Protected Material may be affected.
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If the Designating Party timely seeks a protective order, the Party served
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with the subpoena or court order shall not produce any information designated in
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this action as “CONFIDENTIAL” before a determination by the court from which
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the subpoena or order issued, unless the Party has obtained the Designating Party’s
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permission. The Designating Party shall bear the burden and expense of seeking
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protection in that court of its confidential material and nothing in these provisions
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should be construed as authorizing or encouraging a Receiving Party in this Action
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to disobey a lawful directive from another court.
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9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
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9.1
Application. The terms of this Stipulated Protective Order are
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applicable to information produced by a Non-Party in this Action and designated
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as “CONFIDENTIAL.” Such information produced by Non-Parties in connection
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with this litigation is protected by the remedies and relief provided by this Order.
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Nothing in these provisions should be construed as prohibiting a Non-Party from
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seeking additional protections.
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9.2
Notification. In the event that a Party is required, by a valid discovery
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request, to produce a Non-Party’s confidential information in its possession, and
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the Party is subject to an agreement with the Non-Party not to produce the Non-
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Party’s confidential information, then the Party shall:
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(a) promptly notify in writing the Requesting Party and the Non-Party
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that some or all of the information requested is subject to a
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confidentiality agreement with a Non-Party;
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(b) make the information requested available for inspection by the NonParty, if requested.
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9.3
Conditions of Production. If the Non-Party fails to seek a protective
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order from this court within 14 days of receiving the notice and accompanying
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information, the Receiving Party may produce the Non-Party’s confidential
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information responsive to the discovery request. If the Non-Party timely seeks a
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protective order, the Receiving Party shall not produce any information in its
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possession or control that is subject to the confidentiality agreement with the Non-
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Party before a determination by the court. Absent a court order to the contrary, the
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Non-Party shall bear the burden and expense of seeking protection in this court of
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its Protected Material.
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10.
UNAUTHORIZED DISCLOSURE OF PROTECTED
MATERIAL
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If a Receiving Party learns that, by inadvertence or otherwise, it has
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disclosed Protected Material to any person or in any circumstance not authorized
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under this Stipulated Protective Order, the Receiving Party must immediately (a)
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notify in writing the Designating Party of the unauthorized disclosures, (b) use its
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best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
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the person or persons to whom unauthorized disclosures were made of all the terms
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of this Order, and (d) request such person or persons to execute the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A).
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11.
INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL
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
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protection, the obligations of the Receiving Parties are those set forth in Rule
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26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended
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to modify whatever procedure may be established in an e-discovery order that
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provides for production without prior privilege review. Pursuant to Rules 502(d)
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and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement
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on the effect of disclosure of a communication or information covered by the
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attorney-client privilege or work product protection, the parties may incorporate
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their 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 Stipulated Protective Order
abridges the right of any person to seek its modification by the court in the future.
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12.2 Right to Assert Other Objections. By stipulating to the entry of this
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Stipulated Protective Order no Party waives any right it otherwise would have to
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object to disclosing or producing any information or item on any ground not
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addressed in this Stipulated Protective Order. Similarly, no Party waives any right
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to object on any ground to use in evidence of any of the material covered by this
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Stipulated Protective Order.
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12.3 Filing Protected Material. A Party that seeks to file under seal any
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Protected Material must comply with Local Rule 79-5. Protected Material may
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only be filed under seal pursuant to a court order authorizing the sealing of the
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specific Protected Material at issue. If a Party's request to file Protected Material
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under seal is denied by the court, then the Receiving Party may file the information
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in the public record unless otherwise instructed by the court.
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13.
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After the Final Disposition of this Action, as defined in paragraph 4, within
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60 days of a written request by the Designating Party, each Receiving Party must
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return all Protected Material to the Producing Party or destroy such material. As
FINAL DISPOSITION
-15STIPULATED PROTECTIVE ORDER
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used in this subdivision, “all Protected Material” includes all copies, abstracts,
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compilations, summaries, and any other format reproducing or capturing any of the
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Protected Material. Whether the Protected Material is returned or destroyed, the
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Receiving Party must submit a written certification to the Producing Party (and, if
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not the same person or entity, to the Designating Party) by the 60 day deadline that
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(1) identifies (by category, where appropriate) all the Protected Material that was
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returned or destroyed and (2) affirms that the Receiving Party has not retained any
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copies, abstracts, compilations, summaries or any other format reproducing or
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capturing any of the Protected Material. Notwithstanding this provision, Counsel is
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entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
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and hearing transcripts, legal memoranda, correspondence, deposition and trial
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exhibits, expert reports, attorney work product, and consultant and expert work
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product, even if such materials contain Protected Material. Any such archival
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copies that contain or constitute Protected Material remain subject to this
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Protective Order as set forth in Section 4.
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14.
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Any violation of this Stipulated Protective Order may be punished by any
VIOLATION
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and all appropriate measures including, without limitation, contempt proceedings
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and/or monetary sanctions.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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-16STIPULATED PROTECTIVE ORDER
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DATED: September 23, 2024
CURD GALIDO & SMITH LLP
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By: /s/ Maximilliano Galindo
ALEX GALINDO
MAXIMILIANO GALINDO
Attorneys for Plaintiff,
Jhonny Roldan
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DATED: September 23, 2024
CARPENTER, ROTHANS & DUMONT
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By: /s/ Jill Williams
JILL WILLIAMS
ESTHER TEIXEIRA
Attorneys for Specially Appearing,
County of Los Angeles
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: September 24, 2024
_________________________________
___________________
Stephanie S. Christensen
United States Magistrate Judge
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-17STIPULATED PROTECTIVE ORDER
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I,
______________________________________________ [print or
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type full name], of
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__________________________________________________________________
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_________________________________________ [print or type full address],
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declare under penalty of perjury that I have read in its entirety and understand the
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Stipulated Protective Order that was issued by the United States District Court for
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the Central District of California on ________________________ [date] in the
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case of Jhonny Roldan v. County of Los Angeles, et al, United States District
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Court Case No. 2:24-cv-03485íPA (SSCx).
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I agree to comply with and to be bound by all the terms of this Stipulated
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Protective Order and I understand and acknowledge that failure to so comply could
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expose me to sanctions and punishment in the nature of contempt. I solemnly
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promise that I will not disclose in any manner any information or item that is
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subject to this Stipulated Protective Order to any person or entity except in strict
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compliance with the provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District
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Court for the Central District of California for the purpose of enforcing the terms
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of this Stipulated Protective Order, even if such enforcement proceedings occur
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after termination of this action. I hereby appoint ___________________________
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_____________________________________________[print or type full name]
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of_________________________________________________________________
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____________________________________________________________ [print
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or type full address and telephone number] as my California agent for service of
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process in connection with this action or any proceedings related to enforcement of
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this Stipulated Protective Order.
-18STIPULATED PROTECTIVE ORDER
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Date:
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City and State where sworn and
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signed:
___________________________
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Printed name:
___________________________
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Signature:
___________________________
___________________________
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-19STIPULATED PROTECTIVE ORDER
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