Tommie Castrejon v. Stanley Sniff et al

Filing 84

REVISED PROTECTIVE ORDER by Magistrate Judge Andrew J. Wistrich re Notice (Other),, 80 . See document for details. (yb)

NO FEE DUE
GOV'T CODE § 6103
1 LEWIS BRISBOIS BISGAARD & SMITH LLP
ARTHUR K. CUNNINGHAM, SB# 97506
E-Mail: [e-mail]
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STEPHANIE J. TANADA, SB# 257769
E-Mail: [e-mail]
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650 East Hospitality Lane, Suite 600
4 San Bernardino, California 92408
Telephone: [phone]
5 Facsimile: 909.387.1138
6 Attorneys for Defendants
COUNTY OF RIVERSIDE,
7 LIEUTENANT DONALD SHARP,
SERGEANT RUDY CORTEZ, DEPUTY
8 FENG VANG, DEPUTY RONALD
WOODS, CORPORAL JERRY
9 SAPPINGTON, SERGEANT
RAYMOND DIETRICH, DEPUTY
10 AARON NELSON, DEPUTY MICHAEL
CONTRERAS and DEPUTY AARON
11 GUZMAN
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

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15 TOMMIE CASTREJON,
Plaintiff,

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vs.

18 STANLEY SNIFF,
et al.,
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Defendant.
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CASE NO. EDCV 13-1254-DOC
(AJW)
REVISED PROTECTIVE ORDER
[Filed Concurrently With Notice of
Addendum]

The information and documents to be disclosed pursuant to this Court’s Order

22 are subject to the following terms and conditions:
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1. The plaintiff shall not convey, transfer, publish, distribute, copy, duplicate

24 or disseminate the information or documents so provided except as may be
25 reasonably necessary for the prosecution of this litigation, by communicating with
26 the parties, or investigators, consultants and experts retained on behalf of the parties
27 in this matter.

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2. Prior to the dissemination of any such information or documents pursuant
4828-7351-5813.1

[PROPOSED] PROTECTIVE ORDER

1 to this order, plaintiff shall inform such person of the terms and conditions of this
2 Agreement and secure such person's agreement to be bound by it.
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3. Plaintiff is expressly prohibited from utilizing the disclosed information or

4 documents for any purpose other than the prosecution this case, Castrejon v. Stanley
5 Sniff, et al. EDCV 13-01254 DOC (AJW). The information and/or documents
6 disclosed shall not be utilized in any other proceeding or litigation, or for any other
7 purpose.
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4. Plaintiff is expressly prohibited from duplicating, copying or otherwise

9 distributing or disseminating any of the disclosed information or documents to any
10 person or entity other than as necessary in the prosecution of this case.
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5. Plaintiff may only access the responsive materials in the Prison Litigation

12 Coordinator’s Office. All materials will be sent by Defendants directly to the
13 Litigation Coordinator’s Office at Corcoran State Prison where plaintiff may arrange
14 for a legal review of such documents. Plaintiff may not remove the documents from
15 the Litigation Coordinator’s Office.
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6. All parties shall take reasonable precautions to prevent the unauthorized or

17 inadvertent disclosure of any of the protected information or documents.
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7.The copies of any records disclosed to plaintiff pursuant to this Order may

19 be distinctively marked, provided that such marking does not obscure or obliterate
20 the content of any record, and may be stamped with substantially the following
21 language: "CONFIDENTIAL - UNLAWFUL TO DUPLICATE."
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8. In the event plaintiff shall violate or threaten to violate any terms of this

23 Agreement, the aggrieved party may immediately apply to obtain injunctive relief
24 from this court against Plaintiff violating or threatening to violate any of the terms
25 of this Agreement. The parties hereto, and those persons to whom disclosures are
26 made under the terms of this Agreement, consent that the court shall have the power
27 to impose whatever penalties it deems appropriate for the violation of this

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4828-7351-5813.1

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[PROPOSED] PROTECTIVE ORDER

1 Agreement.
9. This Agreement shall survive the final termination of this action, to the

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3 extent that the information or documents disclosed remain confidential and have not
4 become known to the public, and the court shall retain jurisdiction to resolve any
5 dispute concerning the use of the information or documents disclosed herein.
10. Upon final conclusion of the present litigation, all copies of all documents

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7 ordered disclosed pursuant to this Order shall be returned to counsel for defendants
8 who will then return them to the appropriate authorities of the COUNTY OF
9 RIVERSIDE.
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4828-7351-5813.1

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[PROPOSED] PROTECTIVE ORDER

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11. The production of any documents pursuant to this Agreement does not

2 represent an admission on the part of defendants that any of the documents so
3 produced are admissible in evidence, and does not waive any objections to the
4 admission of such documents at trial or hearing.
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IT IS SO ORDERED.

6 DATED: __June 29, 2015
By:

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Andrew J. Wistrich
U. S. MAGISTRATE JUDGE

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4828-7351-5813.1

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[PROPOSED] PROTECTIVE ORDER