Earl H Bond Jr v. Fontana Police Department
Filing
151
PROTECTIVE ORDER by Magistrate Judge Paul L. Abrams. THIS COURT, HONORABLE PAUL L. ABRAMS, hereby orders the following: (See attached Order.) (es)
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RINOS & MARTIN, LLP
LINDA B. MARTIN, ESQ. (SBN 105445)
ALEX HACKERT, ESQ. (SBN 267342)
17822 17th Street, Suite 401
Tustin, California 92780
Telephone: (714) 734-0400
Facsimile: (714) 734-0480
E-Mail: firm@rmlaw.org
Attorneys for Defendants, CITY OF FONTANA (erroneously sued and served as
FONTANA POLICE DEPARTMENT); OFFICER BRANDON BOWIE; OFFICER
RAJAIE SAYEGH; OFFICER MICHAEL ERNES (erroneously sued and served as
OFFICER MICHAEL EARNS); OFFICER EDUARDO CONTRERAS; OFFICER
JOHN COLLOPY; OFFICER JOSHUA MACMILLAN; OFFICER JOE MORENO;
OFFICER DANIEL ROMERO; and OFFICER JAMES CLAY
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA – LOS ANGELES JURISDICTION
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) CASE NO: ED CV 11-2021-DDP (PLA)
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) ASSIGNED TO:
Pregerson
) Honorable District Judge Dean D.L. Abrams
Plaintiff,
Honorable Magistrate Judge Paul
) Complaint Filed: December 29, 2011
) First Amended Complaint Filed: January 25, 2012
vs.
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) [PROPOSED] PROTECTIVE ORDER
FONTANA POLICE DEPARTMENT, et al )
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Defendants.
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____________________________________
EARL H. BOND, JR.,
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THIS COURT, HONORABLE PAUL L. ABRAMS, hereby orders the following:
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All internal investigation, personnel, employment, education, and training records
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[PROPOSED] PROTECTIVE ORDER
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relating to Fontana Police Department Officers JUSTIN MOYER, BRANDON BOWIE,
RAJAIE
SAYEGH,
MICHAEL
ERNES,
EDUARDO
CONTRERAS,
JOHN
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COLLOPY, JOSHUA MACMILLAN, JOE MORENO, DANIEL ROMERO and
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JAMES CLAY, as well as all prior claims, citizen complaints and lawsuits, produced in
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this litigation, and in response to this Court’s order regarding plaintiff’s motions to
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compel further responses to request for documents and interrogatories dated January 18,
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2013 (Docket No. 140), shall only be used in connection with this litigation which bears
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the following Case No: ED CV 11-2021-DDP (PLA).
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Further, it is hereby ORDERED that after the completion of the litigation, all
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copies of the documents stated above produced to the plaintiff in this litigation, shall be
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immediately returned to Rinos and Martin, LLP within 10 days thereafter, and the
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plaintiff shall file a declaration with this Court, signed under the penalty of perjury,
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stating that he has returned said documents, within 10 days after the completion of the
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litigation. Failure to abide by these requirements can subject the plaintiff to sanctions
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and can be punishable as contempt of court.
It is further ORDERED that:
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All internal investigation, personnel, employment, and training records, as
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well as all prior claims, citizen complaints and lawsuits, produced in this litigation, and
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in response to plaintiff’s request for documents and interrogatories, shall not be
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disclosed, reproduced, or distributed, except as to the following persons:
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a.
Counsel for any party and any party to this litigation;
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[PROPOSED] PROTECTIVE ORDER
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b.
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Paralegal, stenographic, clerical and secretarial personnel regularly
employed by counsel referred to in (a);
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c.
proceedings as are necessarily incidental for preparation of trial.
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Court personnel, including stenographic reporters engaged in such
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Expert witnesses retained in connection with this action for purposes of
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testifying pursuant to FED.R.EVID. 702, 703 and 705.
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2.
Nothing pursuant to this protective order, as stipulated by both parties, is
intended to prevent officials or employees of the City of Fontana or other authorized
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governmental officials from having access to any documents if they would have had
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access to said documents in the normal course of their job duties. Further, nothing in
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this protective order in intended to prevent a witness from disclosing events or activities
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personal to him or her.
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Each person to whom disclosure of any records concerning this order,
including internal investigation, personnel, employment, and training records, as well as
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all prior claims, citizen complaints and lawsuits, shall, prior to the time of disclosure, be
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provided by the person furnishing him/her such material a copy of this order, and shall
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agree on the record or in writing that he/she has read the protective order, and that he/she
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understands the provisions of the protective order. Such person also must consent to be
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subject to the jurisdiction of the United States District Court with respect to any
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proceeding relating to enforcement of this order, including without limitation, any
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proceeding for contempt. Unless made on the record in this litigation, counsel or the
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________________________________________________________________________________________________
[PROPOSED] PROTECTIVE ORDER
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party making the disclosure to any person described above shall retain the original
executed copy of this agreement until final termination of this litigation.
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4.
If any information and/or documents which are the subject of this Protective
Order are presented to this or any other court in any other manner prior to the time of
trial, said information and/or documents shall be lodged under seal in an envelope
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clearly marked as follows: “CONFIDENTIAL MATERIAL SUBJECT TO A
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PROTECTIVE ORDER.”
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IT IS SO ORDERED:
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DATED: January 31, 2013
___________________________
Hon. Paul L. Abrams
United States Magistrate Judge
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[PROPOSED] PROTECTIVE ORDER
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