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)

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NO FEE DUE GOV'T CODE § 6103 1 LEWIS BRISBOIS BISGAARD & SMITH LLP ARTHUR K. CUNNINGHAM, SB# 97506 E-Mail: 2 STEPHANIE J. TANADA, SB# 257769 E-Mail: 3 650 East Hospitality Lane, Suite 600 4 San Bernardino, California 92408 Telephone: 909.387.1130 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 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 14 15 TOMMIE CASTREJON, Plaintiff, 16 17 vs. 18 STANLEY SNIFF, et al., 19 Defendant. 20 21 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: 23 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. LEWI S BRISBOI S BISGAAR 28 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. 3 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. 8 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. 11 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. 16 6. All parties shall take reasonable precautions to prevent the unauthorized or 17 inadvertent disclosure of any of the protected information or documents. 18 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." 22 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 LEWI S BRISBOI S BISGAAR 28 4828-7351-5813.1 2 [PROPOSED] PROTECTIVE ORDER 1 Agreement. 9. This Agreement shall survive the final termination of this action, to the 2 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 6 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. 10 // 11 // 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 LEWI S BRISBOI S BISGAAR 28 4828-7351-5813.1 3 [PROPOSED] PROTECTIVE ORDER 1 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. 5 IT IS SO ORDERED. 6 DATED: __June 29, 2015 By: 7 Andrew J. Wistrich U. S. MAGISTRATE JUDGE 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 LEWI S BRISBOI S BISGAAR 28 4828-7351-5813.1 4 [PROPOSED] PROTECTIVE ORDER

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