Ryan White et al v. County of San Bernardino et al

Filing 30

ORDER GRANTING STIPULATED PROTECTIVE ORDER by Magistrate Judge Kenly Kiya Kato re Stipulation for Protective Order 29 (dts)

NO FEE DUE
GOV'T CODE § 6103
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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11 D.G.R. a minor, by and through her
Guardian Ad Litem, ELMER E.
12 WHITE, II, and KATHY WHITE,
individual,
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Plaintiffs,
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vs.
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COUNTY OF SAN BERNARDINO,
RYAN CONNER: PAUL KOWALSKI,
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and DOES 1-1 0, inclusive,
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Defendants.
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CASE NO. 5:1 6-CV-01812-RGK-KK
[PROPOSED] STIPULATED
PROTECTIVE ORDER

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1.

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Discovery in this action is likely to involve production of confidential,

PURPOSES AND LIMITATIONS

22 proprietary, or private information for which special protection from public
23 disclosure and from use for any purpose other than prosecuting this litigation may
24 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
25 enter the following Stipulated Protective Order. The parties acknowledge that this
26 Order does not confer blanket protections on all disclosures or responses to
27 discovery and that the protection it affords from public disclosure and use extends
28 only to the limited information or items that are entitled to confidential treatment
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[PROPOSED] STIPULATED PROTECTIVE ORDER

1 under the applicable legal principles. The parties further acknowledge, as set forth
2 in Section 13.3, below, that this Stipulated Protective Order does not entitle them to
3 file confidential information under seal; Civil Local Rule 79-5 sets forth the
4 procedures that must be followed and the standards that will be applied when a party
5 seeks permission from the court to file material under seal.
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2.

7

This action will involve law enforcement tactics, procedures, training,

GOOD CAUSE STATEMENT

8 regulations, personnel, investigations and rules for which special protection from
9 public disclosure and from use for any purpose other than prosecution of this action
10 is warranted. Such confidential and proprietary materials and information consist of,
11 among other things, certain documents maintained by the San Bernardino County
12 Sheriff's Department ("SBCSD") and/or the San Bernardino County District
13 Attorney ("SBCDA"), which include internal policies and procedures, internal
14 training materials, internal affairs investigation files, criminal investigation files,
15 personnel files of current and/or former SBCSD officers, and other documents and
16 information which implicate the privacy rights of parties and non-parties, which
17 information is generally unavailable to the public and which is privileged or
18 otherwise protected from disclosure under state and federal statutes, court rules, case
19 decisions, or common law. Accordingly, to expedite the flow of information, to
20 facilitate the prompt resolution of disputes over confidentiality of discovery
21 materials, to adequately protect information the parties are entitled to keep
22 confidential, to ensure that the parties are permitted reasonable necessary uses of
23 such material in preparation for and in the conduct of trial, to address their handling
24 at the end of the litigation, and serve the ends of justice, a protective order for such
25 information is justified in this matter. It is the intent of the parties that information
26 will not be designated as confidential for tactical reasons and that nothing be so
27 designated without a good faith belief that it has been maintained in a confidential,
28 non-public manner, and there is good cause why it should not be part of the public
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[PROPOSED] STIPULATED PROTECTIVE ORDER

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1 record in this case.
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3. DEFINITIONS

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3.1 Action: this pending lawsuit filed by D.G.R. a minor, by and

4 through her Guardian Ad Litem, ELMER E. WHITE, II, and KATHY WHITE,
against the County of San Bernardino, Ryan Conner, Paul Kowalski, and Does 1-10,
6 USDC Case no. 5:16-CV-01812-RGK-KK.
7

3.2 Challenging Party: a Party or Non-Party that challenges the

8 designation of information or items under this Order.
3.3 "CONFIDENTIAL" Information or Items: information

9

10 (regardless of how it is generated, stored or maintained) or tangible things that
11 qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified

12 above in the Good Cause Statement.
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3.4

Counsel: Outside Counsel of Record and House Counsel (as well

14 as their support staff).
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3.5 Designating Party:

a Party or Non-Party that designates

16 information or items that it produces in disclosures or in responses to discovery as
17 "CONFIDENTIAL."
3.6 Disclosure or Discovery Material: all items or information,

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19 regardless of the medium or manner in which it is generated, stored, or maintained
20 (including, among other things, testimony, transcripts, and tangible things), that are
21 produced or generated in disclosures or responses to discovery in this Action.
22

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

23 matter pertinent to the litigation who has been retained by a Party or its counsel to
24 serve as an expert witness or as a consultant in this Action.
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3.8

House Counsel: attorneys who are employees of a Party to this

26 Action. House Counsel does not include Outside Counsel of Record or any other
27 outside counsel.
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3.9 Non-Party:
4851-3078-91871

any natural person, partnership, corporation,
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[PROPOSED] STIPULATED PROTECTIVE ORDER

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1 association, or other legal entity not named as a Party to this action.
2

3.10 Outside Counsel of Record: attorneys who are not employees of

3 a Party to this Action but are retained to represent or advise a Party to this Action
4 and have appeared in this Action on behalf of that Party or are affiliated with a law
5 firm which has appeared on behalf of that Party.
6

3.11 Party: any party to this Action, including all of its officers,

7 directors, employees, consultants, retained experts, and Outside Counsel of Record
8 (and their support staffs).
9

3.12 Producing Party: a Party or Non-Party that produces Disclosure

10 or Discovery Material in this Action.
11

3.13 Professional Vendors: persons or entities that provide litigation

12 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
13 demonstrations, and organizing, storing, or retrieving data in any form or medium)
14 and their employees and subcontractors.
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3.14 Protected Material: any Disclosure or Discovery Material that is

16 designated as "CONFIDENTIAL."
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3.15 Receiving Party: a Party that receives Disclosure or Discovery

18 Material from a Producing Party.
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4. SCOPE

20

The protections conferred by this Stipulation and Order cover not only

21 Protected Material (as defined above), but also (1) any information copied or
22 extracted from Protected Material; (2) all copies, excerpts, summaries, or
23 compilations of Protected Material; and (3) any testimony, conversations, or
24 presentations by Parties or their Counsel that might reveal Protected Material.
25 However, the protections conferred by this Stipulation and Order do not cover the
26 following information: (a) any information that is in the public domain at the time of
27 disclosure to a Receiving Party or becomes part of the public domain after its
28 disclosure to a Receiving Party as a result of publication not involving a violation of
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[PROPOSED] STIPULATED PROTECTIVE ORDER

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1 this Order, including becoming part of the public record through trial or otherwise;
2 and (b) any information known to the Receiving Party prior to the disclosure or
3 obtained by the Receiving Party after the disclosure from a source who obtained the
4 information lawfully and under no obligation of confidentiality to the Designating
5 Party.
6

Any use of Protected Material at trial shall be governed by the orders of the

7 trial judge. This Order does not govern the use of Protected Material at trial.
8

5.

DURATION

9

Once a case proceeds to trial, all of the court-filed information that is to be

10 introduced that was previously designated as confidential or maintained pursuant to
11 this protective Order becomes public and will be presumptively available to all
12 members of the public, including the press, unless compelling reasons supported by
13 specific factual findings to proceed otherwise are made to the trial judge in advance
14 of the trial. Kamakana v. City and Colin°, of Honolulu, 447 F.3d 1172, 1180-81 (9th
15 Cir. 2006) [distinguishing "good cause" showing for sealing documents produced in
16 discovery from "compelling reasons" standard when merits-related documents are
17 part of court record]. Accordingly, the terms of this protective order do not extend
18 beyond the commencement of the trial.
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6.

DESIGNATING PROTECTED MATERIAL
6.1 Exercise of Restraint and Care in Designating Material for

20

21 Protection. Each Party or Non-Party that designates information or items for
22 protection under this Order must take reasonable care to limit any such designation
23 to specific material that qualifies under the appropriate standards. The Designating
24 Party must designate for protection only those parts of material, documents, items,
25 or oral or written communications that qualify so that other portions of the material,
26 documents, items, or communications for which protection is not warranted are not
27 swept unjustifiably within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations
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1 that are shown to be clearly unjustified or that have been made for an improper
2 purpose (e.g., to unnecessarily encumber the case development process or to impose
3 unnecessary expenses and burdens on other Parties) may expose the Designating
4 Party to sanctions.
5

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

6 designated for protection do not qualify for protection, that Designating party must
7 promptly notify all other Parties that it is withdrawing the inapplicable designation.
8

6.2

Manner and Timing of Designations. Except as otherwise

9 provided in this Order (see, e.g., second paragraph of section 6.2(a) below), or as
10 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for
11 protection under this Order must be clearly so designated before the material is
12 disclosed or produced.
13

Designation in conformity with this Order requires:
(a)

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for information in documentary form (e.g., paper or

15 electronic documents, but excluding transcripts of depositions or other pretrial or
16 trial proceedings), that the Producing Party affix, at a minimum, the legend
17 "CONFIDENTIAL" (hereinafter "CONFIDENTIAL legend") to each page that
18 contains protected material. If only a portion or portions of the material on a page
19 qualifies for protection, the Producing Party also must clearly identify the protected
20 portion(s) (e.g., by making appropriate markings in the margins)
21

A Party or Non-Party that makes original documents or materials available for

22 inspection need not designate them for protection until after the inspecting Party has
23 indicated which documents or materials it would like copied and produced. During
24 the inspection and before the designation, all of the material made available for
25 inspection shall be deemed "CONFIDENTIAL." After the inspecting Party has
26 identified the documents or materials it wants copied and produced, the Producing
27 Party must determine which documents, or portions thereof, qualify for protection
28 under this Order. Then, before producing the specified documents, the Producing
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1 Party must affix the "CONFIDENTIAL legend" to each page that contains Protected
2 Material. If only a portion or portions of the material on a page qualifies for
3 protection, the Producing party also must clearly identify the protected portion(s)
4 (e.g., by making appropriate markings in the margins)
(b)

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for testimony given in depositions or in other pretrial

6 proceedings, that the Designating Party identify the Disclosure or Discovery
7 Material on the record, before the close of the deposition, hearing, or other
8 proceeding.
(c)

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for information produced in some form other than

10 documentary and for any other tangible items, that the Producing Party affix in a
11 prominent place on the exterior of the container or containers in which the
12 information or item is stored the "CONFIDENTIAL legend." If only a portion or
13 portions of the information warrants protection, the Producing Party, to the extent
14 practicable, shall identify the protected portion(s).
6.3

15

Inadvertent Failures to Designate.

If timely corrected, an

16 inadvertent failure to designate qualified information or items does not, standing
17 alone, waive the Designating Party's right to secure protection under this Order for
18 such material. Upon timely correction of a designation, the Receiving Party must
19 make reasonable efforts to assure that the material is treated in accordance with the
20 provisions of this Order.
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7.

CHALLENGING CONFIDENTIALITY DESIGNATIONS.
7.1

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Timing of Challenges. Any Party or Non-Party may challenge a

23 designation of confidentiality at any time that is consistent with the Court's
24 Scheduling Order and any amendments thereto.
7.2

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Meet and Confer. The Challenging Party shall initiate the dispute

26 resolution process under Local Rule 37.1, et seq. Any discovery motion must strictly
27 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
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7.3 Burden. The burden of persuasion in any such challenge
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1 proceeding shall be on the Designating Party. Frivolous challenges, and those made
2 for an improper purpose (e.g., to harass or impose unnecessary expenses and
3 burdens on other Parties) may expose the Challenging Party to sanctions. Unless the
4 Designating Party has waived or withdrawn the confidentiality designation, all
5 Parties shall continue to afford the material in question the level of protection to
6 which it is entitled under the Producing Party's designation until the Court rules on
7 the challenge.
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8.

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ACCESS TO AND USE OF PROTECTED MATERIAL
8.1

Basic Principles. A Receiving Party may use Protected Material

10 that is disclosed or produced by another Party or by a Non-Party in connection with
11 this Action only for prosecuting, defending, or attempting to settle this Action. Such
12 Protected Material may be disclosed only to the categories of persons and under the
13 conditions described in this Order. When the Action has been terminated, a
14 Receiving Party must comply with the provisions of section 14 below (FINAL
15 DISPOSITION).
16

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

17 location and in a secure manner that ensures that access is limited to the persons
18 authorized under this Order.
8.2

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Disclosure of "CONFIDENTIAL" Information or Items. Unless

20 otherwise ordered by the Court or permitted in writing by the Designating Party, a
21 Receiving Party may disclose any information or item designated
22 "CONFIDENTIAL" only to:
23

(a)

the Receiving Party's Outside Counsel of Record in this Action, as well

24 as employees of said Outside Counsel of Record to whom it is reasonably necessary
25 to disclose the information for this Action;
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(b)

the officers, directors, and employees (including House Counsel) of the

27 Receiving Party to whom disclosure is reasonably necessary for this Action;
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(c)
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Experts (as defined in this Order) of the Receiving Party to whom
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[PROPOSED] STIPULATED PROTECTIVE ORDER

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1 disclosure is reasonably necessary for this Action and who have signed the
2 "Acknowledgment and Agreement to Be Bound" (Exhibit A);
3

(d)

the Court and its personnel;

4

(e)

court reporters and their staff;

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(f)

professional jury or trial consultants, mock jurors, and Professional

6 Vendors to whom disclosure is reasonably necessary for this Action and who have
7 signed the "Acknowledgement and Agreement to Be Bound" (Exhibit A);
8

(g)

the author or recipient of a document containing the information or a

9 custodian or other person who otherwise possessed or knew the information;
10

(h) during their depositions, witnesses and attorneys for witnesses in the

11 Action to whom disclosure is reasonably necessary provided: (I) the deposing party
12 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
13 not be permitted to keep any confidential information unless they sign the
14 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise
15 agreed by the Designating Party or ordered by the Court. Pages of transcribed
16 deposition testimony or exhibits to depositions that reveal Protected Material must
17 be separately bound by the court reporter and may not be disclosed to anyone except
18 as permitted under this Stipulated Protective Order; and
19

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

20 mutually agreed upon by any of the Parties engaged in settlement discussions.
21

9.

PROTECTED MATERIAL SUBPOENAED OR ORDERED

22 PRODUCED IN OTHER LITIGATION
23

If a Party is served with a subpoena or a court order issued in other litigation

24 that compels disclosure of any information or items designated in this Action as
25 "CONFIDENTIAL," that Party must:
26

(a)

promptly notify in writing the Designating Party. Such notification

27 shall include a copy of the subpoena or court order;
28

(b)
4851-3078-91-3].1

promptly notify in writing the party who caused the subpoena or order
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1 to issue in the other litigation that some or all of the material covered by the
2 subpoena or order is subject to this Protective Order. Such notification shall include
3 a copy of this Stipulated Protective Order; and
4

(c)

cooperate with respect to all reasonable procedures sought to be

5 pursued by the Designating Party whose Protected Material may be affected.
6

If the Designating Party timely seeks a protective order, the Party served with

7 the subpoena or court order shall not produce any information designated in this
S action as "CONFIDENTIAL" before a determination by the court from which the
9 subpoena or order issued, unless the Party has obtained the Designating Party's
10 permission. The Designating Party shall bear the burden and expense of seeking
11 protection in that court of its confidential material, and nothing in these provisions
12 should be construed as authorizing or encouraging a Receiving Party in this Action
13 to disobey a lawful directive from another court.
14

10.

A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE

15 PRODUCED IN THIS LITIGATION
16

(a)

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

17 Non-Party in this action and designated as "CONFIDENTIAL." Such information
18 produced by Non-Parties in connection with this litigation is protected by the
19 remedies and relief provided by this Order. Nothing in these provisions should be
20 construed as prohibiting a Non-Party from seeking additional protections.
21

(b)

In the event that a Party is required, by a valid discovery request, to

22 produce a Non-Party's confidential information in its possession, and the Party is
23 subject to an agreement with the Non-Party not to produce the Non-Party's
24 confidential information, then the Party shall:
25

(1)

promptly notify in writing the Requesting Party and the Non-

26 Party that some or all of the information requested is subject to a confidentiality
27 agreement with a Non-Party;
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(2)
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promptly provide the Non-Party with a copy of the Stipulated
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1 Protective Order in this Action, the relevant discovery request(s), and a reasonably
2 specific description of the information requested; and
(3)

3

make the information requested available for inspection by the

4 Non-Party, if requested.
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(c)

If the Non-Party fails to seek a protective order from this Court within

6 14 days of receiving the notice and accompanying information, the Receiving Party
7 may produce the Non-Party's confidential information responsive to the discovery
8 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
9 not produce any information in its possession or control that is subject to the
10 confidentiality agreement with the Non-Party before a determination by the Court.
11 Absent a court order to the contrary, the Non-Party shall bear the burden and
12 expense of seeking protection in this Court of its Protected Material.
13

11.

UNAUTHORIZED DISCLOSURE OF PROTECTED

14 MATERIAL
15

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

16 Protected Material to any person or in any circumstance not authorized under this
17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
18 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
19 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
20 persons to whom unauthorized disclosures were made of all the terms of this Order,
21 and (d) request such person or persons to execute the "Acknowledgment and
22 Agreement to Be Bound" that is attached hereto as Exhibit A.
23

12.

INADVERTENT PRODUCTION OF PRIVILEGED OR

24 OTHERWISE PROTECTED MATERIAL
25

When a Producing Party gives notice to Receiving Parties that certain

26 inadvertently produced material is subject to a claim of privilege or other protection,
27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
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1 may be established in an e-discovery order that provides for production without
2 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
3 as the parties reach an agreement on the effect of disclosure of a communication or
4 information covered by the attorney-client privilege or work product protection, the
5 parties may incorporate their agreement in the stipulated protective order submitted
6 to the Court.
7

13.

8

MISCELLANEOUS.
13.1 Right to Further Relief. Nothing in this Order abridges the right

9 of any person to seek its modification by the Court in the future.
10

13.2 Right to Assert Other Objections. By stipulating to the entry of

11 this Protective Order, no Party waives any right it otherwise would have to object to
12 disclosing or producing any information or item on any ground not addressed in this
13 Stipulated Protective Order. Similarly, no Party waives any right to object on any
14 ground to use in evidence of any of the material covered by this Protective Order.
15

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

16 any Protected Material must comply with Civil Local Rule 79-5. Protected Material
17 may only be filed under seal pursuant to a court order authorizing the sealing of the
18 specific Protected Material at issue; good cause must be shown in the request to file
19 under seal. If a Party's request to file Protected Material under seal is denied by the
20 Court, then the Receiving Party may file the information in the public record unless
21 otherwise instructed by the Court.
22

14.

FINAL DISPOSITION.

23

After the final disposition of this action, within 60 days of a written request

24 by the Designating Party each Receiving Party must return all Protected Material to
25 the Producing Party or destroy such material. As used in this subdivision, "all
26 Protected Material" includes all copies, abstracts, compilations, summaries, and any
27 other format reproducing or capturing any of the Protected Material. Whether the
28 Protected Material is returned or destroyed, the Receiving Party must submit a
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1 written certification to the Producing Party (and, if not the same person or entity, to
2 the Designating Party) by the 60 day deadline that (1) identifies (by category, where
3 appropriate) all the Protected Material that was returned or destroyed and (2) affirms
4 that the Receiving Party has not retained any copies, abstracts, compilations,
5 summaries or any other format reproducing or capturing any of the Protected
6 Material. Notwithstanding this provision, Counsel are entitled to retain an archival
7 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
8 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
9 work product, and consultant and expert work product, even if such materials
10 contain Protected Material. Any such archival copies that contain or constitute
11 Protected Material remain subject to this Protective Order as set forth in Section 4
12 (DURATION).
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1

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2
3
4 DATED: March , 2017
5
6
By:

7

\Pcki I. Sarmiento
Attorneys for Plaintiffs

8
9
10

DATED: March , 2017

11
12

By

13

Dale K. Galipo
Attorneys for 'laintiffs

14
15

DATED: March I , 2017

16
17
18

By
arry Hassan e g
Attorneys for Defendan

19
20

21 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22
23 DATED: March 2
24

2017

25
Kenly Kiya Kato
United States Magistrate Judge

26
27
28
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1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

[print or type full name], of

4

[print or type full address], declare under penalty of perjury

5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on [date] in the case of D.G.R., et al., v. County of San Bernardino, et al., USDC
8 Case no. 5:16-CV-01812-RGK-KK. I agree to comply with and to be bound by all
9 the terms of this Stipulated Protective Order and I understand and acknowledge that
10 failure to so comply could expose me to sanctions and punishment in the nature of
11 contempt. I solemnly promise that I will not disclose in any manner any
12 information or item that is subject to this Stipulated Protective Order to any person
13 or entity except in strict compliance with the provisions of this Order.
14

I further agree to submit to the jurisdiction of the United States District Court

15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint
18 type full name] of

[print or
[print or type

19 full address and telephone number] as my California agent for service of process in
20 connection with this action or any proceedings related to enforcement of this
21 Stipulated Protective Order.
22
23

Date:

24

City and State where sworn and signed:

25

Printed name:

26
27

Signature:

28
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