Estate of Raul Herrera III et al v. City of Ontario et al

Filing 29

STIPULATED PROTECTIVE ORDER by Magistrate Judge Sheri Pym. (ad)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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THE ESTATE OF RAUL HERRERA III
and JOE HERRERA,
Plaintiffs,

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)
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v.
CITY OF ONTARIO, BRAD KAYLOR,
ZACH MCWATERS, SCOTT SCHAFFER,
MICHAEL MORA and DOES 1 through
10, inclusive,
Defendants.

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Case No: 5:17-CV-00082 SP
Hon. Sheri Pym
STIPULATED PROTECTIVE
ORDER

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1.

A. PURPOSES AND LIMITATIONS
Disclosure and discovery activity in this action are likely

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to involve production of confidential, proprietary, or private

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information, including confidential personnel records of peace

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officers, for which special protection from public disclosure

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and from use for any purpose other than prosecuting this

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litigation would be warranted.

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stipulate to and petition the Court to enter the following

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Stipulated Protective Order.

Accordingly, the parties hereby

The parties acknowledge that this

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-1STIPULATED PROTECTIVE ORDER

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Stipulated Protective Order does not confer blanket protections

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on all disclosures or responses to discovery and that the

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protection it affords extends only to the limited information or

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items that are entitled under the applicable legal principles to

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treatment as confidential.

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set forth in section 12, below, that this Stipulated Protective

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Order creates no entitlement to file confidential information

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under seal; Civil Local Rule 79-5 sets forth the procedures that

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must be followed and reflects the standards that will be applied

The parties further acknowledge, as

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when a party seeks permission from the court to file material

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under seal.

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this Stipulated Protective Order shall preclude either party

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from asserting that a document is of such a confidential or

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private nature that it should not be produced or that it should

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only be produced in redacted form, or from seeking a protective

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order to preclude the production of certain documents.

The parties further acknowledge that nothing in

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B. GOOD CAUSE STATEMENT

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This action is likely to involve confidential information,

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including personnel records of the Defendant police officers,

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information otherwise generally unavailable to the public, or

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which may be privileged or otherwise protected from disclosure

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under state or federal statutes, court rules, case decisions or

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common law. Accordingly, to expedite the flow of information, to

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facilitate the prompt resolution of disputes over

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confidentiality of discovery materials, to adequately protect

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information the parties are entitled to keep confidential, to

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ensure that the parties are permitted reasonable necessary uses

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of such material in preparation for and in the conduct of trial,
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to address their handling at the end of the litigation, and

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serve the ends of justice, a protective order for such

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information is justified in this matter. It is the intent of the

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parties that the information will not be designated as

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confidential for tactical reasons and that nothing be so

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designated without a good faith belief that it has been

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maintained in a confidential, non-public manner, and there is

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good cause why it should not be part of the public record of

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this case.

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2.

DEFINITIONS
2.1. Party: any party to this action, including all of its

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officers, directors, employees, consultants, retained experts,

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and outside counsel (and their support staff).

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2.2. Disclosure or Discovery Material: all items or

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information, regardless of the medium or manner generated,

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stored, or maintained (including, among other things, testimony,

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transcripts, or tangible things) that are produced or generated

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in disclosures or responses to discovery in this matter.

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2.3. “Confidential” Information or Items: information

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(regardless of how generated, stored or maintained) or tangible

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things that contain information involving trade secrets,

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confidential business, personal or financial information or

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confidential personnel records.

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2.4. Receiving Party: a Party that receives Disclosure or
Discovery Material from a Producing Party.
2.5. Producing Party: a Party or non-party that produces
Disclosure or Discovery Material in this action.

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2.6. Designating Party: a Party or non-party that

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designates information or items that it produced in disclosures

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or in responses to discovery as “Confidential.”

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2.7. Protected Material: any Disclosure or Discovery
Material that is designated as “Confidential.”

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2.8

Outside Counsel: attorneys (as well as their support

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staff) who are not employees of a Party but who are retained to

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represent or advise a Party in this action.

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2.9

Expert: a person with specialized knowledge or

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experience in a matter pertinent to the litigation who has been

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retained by a Party or its counsel to serve as an expert witness

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or as a consultant in this action and who is not a past or a

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current employee of a Party or of a competitor of a Party and

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who, at the time of retention, is not anticipated to become an

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employee of a Party or a competitor of a Party.

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includes a professional, jury or trial consultant retained in

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connection with this litigation.

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This definition

2.10 Professional Vendors: persons or entities that provide

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litigation support services (e.g., photocopying, videotaping,

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translating, preparing exhibits or demonstrations, organizing,

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storing, retrieving data in any form or medium, etc.) and their

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employees and subcontractors.

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3.

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SCOPE
The protections conferred by this Stipulated Protective

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Order cover not only Protected Material (as defined above), but

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also any information copied or extracted therefrom, as well as

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all copies, excerpts, summaries, or compilations thereof, plus

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testimony, conversations, or presentations by parties or counsel
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to or in court or in other settings that might reveal Protected

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Material.

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Any use of Protected Material at trial shall be governed by

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the orders of the trial judge.

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use of Protected Material at trial.

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4.

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This Order does not govern the

DURATION
Once a case proceeds to trial, all of the information that

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was designated as confidential or maintained pursuant to this

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protective order becomes public and will be presumptively

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available to all members of the public, including the press,

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unless compelling reasons supported by specific factual findings

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to proceed otherwise are made to the trial judge in advance of

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the trial. See Kamakana v. City and County of Honolulu, 447 F.3d

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1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”

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showing for sealing documents produced in discovery from

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“compelling reasons” standard when merits-related documents are

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part of court record). Accordingly, the terms of this protective

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order do not extend beyond the commencement of the trial.

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5.

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DESIGNATING PROTECTED MATERIAL
5.1. Exercise of Restraint and Care in Designating Material

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for Protection. Each Party or non-party that designates

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information or items for protection under this Stipulated

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Protective Order must take care to limit any such designation to

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specific material that qualifies under the appropriate legal

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standards.

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protection only those parts of material, documents, items, or

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oral or written communications that qualify - so that other

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portions of the material, documents, items, or communications

A Designating Party must take care to designate for

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for which protection is not warranted are not swept

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unjustifiably within the ambit of this Stipulated Protective

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Order.

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Mass, indiscriminate, or routinized designations are

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prohibited.

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unjustified or that have been made for an improper purpose

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(e.g., unnecessarily to encumber the case development process or

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to impose unnecessary expenses or burdens on other parties) may

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expose the Designating Party to sanctions.

Designations that are shown to be clearly

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If it comes to a Party’s or a non-party’s attention that

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information or items that it designated for protection do not

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qualify for protection, that Party or non-party must promptly

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notify all other parties that it is withdrawing or modifying the

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mistaken designation.

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5.2. Manner and Timing of Designations.

Except as

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otherwise provided in this Stipulated Protective Order (see,

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e.g., second paragraph of section 5.2(a), below), or as

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otherwise stipulated or ordered, material that qualifies for

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protection under this Stipulated Protective Order must be

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clearly so designated before the material is disclosed or

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produced.

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Designation in conformity with this Stipulated Protective
Order requires:

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a.

For information in documentary form (apart from

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transcripts of depositions or other pretrial or trial

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proceedings), that the Producing Party affix the legend

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“CONFIDENTIAL” at the bottom-right of each page that

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contains Protected Material. If only a portion or portions
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of the material on a page qualifies for protection, the

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Producing Party must also clearly identify the protected

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portion(s) (e.g., by making appropriate markings in the

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margins).

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A Party or non-party that makes original documents or

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materials available for inspection need not designate them

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for protection until after the inspecting Party has

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indicated which material it would like copied and produced.

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During the inspection and before the designation, all of

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the material made available for inspection shall be deemed

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“CONFIDENTIAL.”

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the documents it wants copied and produced, the Producing

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Party must determine which documents, or portions thereof,

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qualify for protection under this Stipulated Protective

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Order.

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Producing Party must affix the appropriate legend

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(“CONFIDENTIAL”) at the bottom-right of each page that

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contains Protected Material. If only a portion or portions

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of the material on a page qualifies for protection, the

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Producing Party must also clearly identify the protected

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portion(s) (e.g., by making appropriate markings in the

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margins).

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b.

After the inspecting Party has identified

Then, before producing the specified documents, the

For testimony given in deposition or in other

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pretrial or trial proceedings, that the Party or non-party

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offering or sponsoring the testimony identify on the

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record, before the close of the deposition, hearing, or

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other proceeding, all protected testimony, and further

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specify any portions of the testimony that qualify as
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“CONFIDENTIAL.”

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separately each portion of testimony that is entitled to

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protection, and when it appears that substantial portions

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of the testimony may qualify for protection, the Party or

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non-party that sponsors, offers, or gives the testimony may

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invoke on the record (before the deposition or proceeding

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is concluded) a right to have up to 20 days to identify the

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specific portions of the testimony as to which protection

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is sought and to specify the level of protection being

When it is impractical to identify

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asserted (“CONFIDENTIAL”).

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testimony that are appropriately designated for protection

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within the 20 days shall be covered by the provisions of

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this Stipulated Protective Order.

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Only those portions of the

Transcript pages containing Protected Material must be

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separately bound by the court reporter, who must affix to

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the top of each such page the legend “CONFIDENTIAL,” as

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instructed by the Party or non-party offering or sponsoring

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the witness or presenting the testimony.

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c.

For information produced in some form other than

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documentary, and for any other tangible items, that the

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Producing Party affix in a prominent place on the exterior

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of the container or containers in which the information or

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item is stored the legend “CONFIDENTIAL.”

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of the information or item warrant protection, the

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Producing Party, to the extent practicable, shall identify

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the protected portions, specifying whether they qualify as

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“CONFIDENTIAL.”

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-8STIPULATED PROTECTIVE ORDER

If only portions

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5.3. Inadvertent Failures to Designate.

If timely

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corrected, an inadvertent failure to designate qualified

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information or items as “CONFIDENTIAL” does not, standing alone,

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waive the Designating Party’s right to secure protection under

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this Stipulated Protective Order for such material.

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is appropriately designated as “CONFIDENTIAL” after the material

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was initially produced, the Receiving Party, on timely

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notification of the designation, must make reasonable efforts to

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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.

If material

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1. Timing of Challenges.

Unless a prompt challenge to a

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Designating Party’s confidentiality designation is necessary to

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avoid foreseeable substantial unfairness, unnecessary economic

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burdens, or a later significant disruption or delay of the

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litigation, a Party does not waive its right to challenge a

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confidentiality designation by electing not to mount a challenge

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promptly after the original designation is disclosed.

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6.2. Meet and Confer.

A Party that elects to initiate a

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challenge to a Designating Party’s confidentiality designation

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must do so in good faith and pursuant to the dispute resolution

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process under Local Rule 37-1, et seq.

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6.3. Burden of Persuasion.

The burden of persuasion in any

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such challenge proceeding shall be on the Designating Party.

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Frivolous challenges, and those made for an improper purpose

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(e.g., to harass or impose unnecessary expenses and burdens on

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other parties) may expose the Challenging Party to sanctions.

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Until the Court rules on the challenge, all parties shall
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continue to afford the material in question the level of

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protection to which it is entitled under the Producing Party’s

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designation.

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7.

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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1. Basic Principles.

A Receiving Party may use Protected

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Material that is disclosed or produced by another Party or by a

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non-party in connection with this case only for prosecuting,

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defending, or attempting to settle this litigation.

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Protected Material may be disclosed only to the categories of

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persons and under the conditions described in this Stipulated

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Protective Order.

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Receiving Party must comply with the provisions of section 13,

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below (FINAL DISPOSITION).

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Such

When the litigation has been terminated, a

Protected Material must be stored and maintained by a

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Receiving Party at a location and in a secure manner that

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ensures that access is limited to the persons authorized under

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this Stipulated Protective Order.

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7.2. Disclosure of “CONFIDENTIAL” Information or Items.

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Unless otherwise ordered by the Court or permitted in writing by

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the Designating Party, a Receiving Party may disclose any

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information or item designated CONFIDENTIAL only to:

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a.

the Receiving Party’s Outside Counsel of record in

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this action and said Counsel’s paralegals, as well as other

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employees of said Counsel to whom it is reasonably necessary to

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disclose the information for this litigation and who have signed

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the “Agreement to Be Bound by Protective Order” that is attached

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hereto as Exhibit A;

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b.

the officers, directors, and employees of the

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Receiving Party to whom disclosure is reasonably necessary for

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this litigation and who have signed the “Agreement to Be Bound

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by Protective Order” (Exhibit A);

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c.

Experts (as defined in this Stipulated Protective

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Order) of the Receiving Party to whom disclosure is reasonably

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necessary for this litigation and who have signed the “Agreement

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to Be Bound by Protective Order” (Exhibit A);

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d.

the Court and its personnel;

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e.

court reporters, their staffs, and professional

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vendors to whom disclosure is reasonably necessary for this

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litigation;

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f.

professional jury or trial consultants, mock jurors,

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and Professional Vendors to whom disclosures is reasonably

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necessary for this lawsuit and who have signed the

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"Acknowledgement and Agreement to be Bound"(Exhibit A);

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g.

during their depositions, witnesses, and attorneys for

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the witnesses, in the action to whom disclosure is reasonably

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necessary, provided that they have signed the "Acknowledgement

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and Agreement to be Bound"(Exhibit A).

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deposition testimony or exhibits to depositions that reveal

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Protected Material must be separately bound by the court

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reporter and may not be disclosed to anyone except as permitted

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under this Stipulated Protective Order.

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h.

Pages of transcribed

the author of the document or the original source of

the information.

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i.

Any mediator or settlement officer, and their

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supporting personnel, mutually agreed upon by any of the parties

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engaged in settlement discussions.

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8.

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LITIGATION

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PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER

If a Receiving Party is served with a subpoena or an order

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issued in other litigation that would compel disclosure of any

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information or items designated in this action as

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“CONFIDENTIAL,” the Receiving Party must:

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(a) notify the Designating Party, in writing (by fax

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or email, if possible) immediately after receiving the

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subpoena or order.

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of the subpoena or court order;

Such notification must include a copy

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(b) immediately inform in writing the Party who caused

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the subpoena or order to issue in the other litigation that

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some or all the material covered by the subpoena or order

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is the subject of this Stipulated Protective Order.

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addition, the Receiving Party must deliver a copy of this

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Stipulated Protective Order promptly to the Party in the

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other action that caused the subpoena or order to issue;

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and

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In

(c) cooperate with respect to all reasonable

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procedures sought to be pursued by the Designating Party

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whose Protected Material may be affected.

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The purpose of imposing these duties is to alert the

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interested parties to the existence of this Stipulated

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Protective Order and to afford the Designating Party in this

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case an opportunity to try to protect its confidentiality
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interests in the court from which the subpoena or order issued.

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If the Designating Party timely seeks a protective order in

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relation to the subpoena or order issued in other litigation,

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the Party served with the subpoena or order shall not produce

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any information designated in this lawsuit as "CONFIDENTIAL"

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before the determination by the court from which the subpoena or

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order issued, unless the party has obtained the Designating

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Party's permission.

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burdens and the expenses of seeking protection in that court of

The Designating Party shall bear the

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its confidential material - and nothing in these provisions

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should be construed as authorizing or encouraging a Receiving

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Party in this action to disobey a lawful directive from another

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court.

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9.

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THIS LITIGATION

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A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN

(a) The terms of this Order are applicable to information

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produced by a Non-Party in this Action and designated as

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“CONFIDENTIAL.” Such information produced by Non-Parties in

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connection with this litigation is protected by the remedies and

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relief provided by this Order. Nothing in these provisions

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should be construed as prohibiting a Non-Party from seeking

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additional protections.

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(b) In the event that a Party is required, by a valid

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discovery request, to produce a Non-Party’s confidential

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information in its possession, and the Party is subject to an

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agreement with the Non-Party not to produce the Non-Party’s

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confidential information, then the Party shall:

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(1) promptly notify in writing the Requesting Party

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and the Non-Party that some or all of the information

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requested is subject to a confidentiality agreement with a

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Non-Party;

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(2) promptly provide the Non-Party with a copy of the

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Stipulated Protective Order in this Action, the relevant

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discovery request(s), and a reasonably specific description

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of the information requested; and

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(3) make the information requested available for

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inspection by the Non-Party, if requested.

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(c) If the Non-Party fails to seek a protective order from

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this Court within 14 days of receiving the notice and

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accompanying information, the Receiving Party may produce the

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Non-Party’s confidential information responsive to the discovery

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request. If the Non-Party timely seeks a protective order, the

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Receiving Party shall not produce any information in its

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possession or control that is subject to the confidentiality

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agreement with the Non-Party before a determination by the

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Court. Absent a court order to the contrary, the Non-Party shall

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bear the burden and expense of seeking protection in this Court

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of its Protected Material.

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10.

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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or

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otherwise, it has disclosed Protected Material to any person or

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in any circumstance not authorized under this Stipulated

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Protective Order, the Receiving Party must immediately (a)

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notify in writing the Designating Party of the unauthorized

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disclosures, (b) use its best efforts to retrieve all copies of
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the Protected Material, (c) inform the person or persons to

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whole unauthorized disclosures were made of all the terms of

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this Stipulated Protective Order, and (d) request such person or

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persons to execute the “Acknowledgment and Agreement to Be

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Bound” that is attached hereto as Exhibit A.

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11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED

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MATERIAL

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When a Producing Party gives notice to Receiving Parties
that certain inadvertently produced material is subject to a

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claim of privilege or other protection, the obligations of the

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Receiving Parties are those set forth in Federal Rule of Civil

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Procedure 26(b)(5)(B). This provision is not intended to modify

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whatever procedure may be established in an e-discovery order

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that provides for production without prior privilege review.

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Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as

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the parties reach an agreement on the effect of disclosure of a

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communication or information covered by the attorney-client

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privilege or work product protection, the parties may

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incorporate their agreement in the stipulated protective order

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submitted to the Court.

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12.

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FILING PROTECTED MATERIAL
Without written permission from the Designating Party or a

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Court order secured after appropriate notice to all interested

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persons, a party may not file in the public record in this

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action any protected material.

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seal any protected material must comply with Civil Local Rule

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79-5.

A party that seeks to file under

Protected Material may only be filed under seal pursuant

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to a Court order authorizing the sealing of the specific

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Protected Material at issue.

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13.

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FINAL DISPOSITION
Upon written request after the settlement or other

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termination of this action, each receiving party must return all

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protected material to the producing party or destroy such

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material within sixty days after the final termination of this

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action. As used in this subdivision, “all protected material”

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includes all copies (except as designated below), abstracts,

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compilations, summaries or any other form of reproducing or

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capturing any of the protected material. The receiving party may

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destroy some or all of the protected material instead of

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returning it.

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destroyed, the receiving party must submit a written

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certification to the producing party (and, if not the same

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person or entity, to the designating party) by the sixty-day

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deadline affirming that all the protected material was returned

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or destroyed and that the receiving party has not retained any

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copies, abstracts, compilations, summaries or other forms of

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reproducing or capturing any of the protected material.

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Notwithstanding this provision, counsel are entitled to retain

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an archival copy of all pleadings, motion papers, transcripts,

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legal memoranda, correspondence or attorney work product, even

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if such materials contain protected material. Any such archival

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copies that contain or constitute protected material remain

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subject to this stipulated protective order as set forth in

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section 4 (duration), above.

Whether the protected material is returned or

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14.

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MISCELLANEOUS
14.1.

Right to Further Relief.

Nothing in this

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Stipulated Protective Order abridges the right of any person to

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seek its modification by the Court in the future.

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14.2.

Right to Assert Other Objections.

By stipulating

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to the entry of this Stipulated Protective Order, no Party

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waives any right it otherwise would have to object to disclosing

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or producing any information or item on any ground not addressed

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in this Stipulated Protective Order.

Similarly, no Party waives

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any right to object on any ground to use in evidence of any of

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the material covered by this Stipulated Protective Order.

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15.

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VIOLATION
Any violation of this Order may be punished by any and all

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appropriate measures including, without limitation, contempt

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proceedings and/or monetary sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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PEREIRA LAW

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By:

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COTA COLE & HUBER LLP

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By:

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/S/CHRISTIAN F. PEREIRA
CHRISTIAN F. PEREIRA
Attorneys for Plaintiffs

/S/DENNIS M. COTA
DENNIS M. COTA
Attorneys for Defendants

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: May 24, 2017

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HON. SHERI PYM
UNITED STATES MAGISTRATE JUDGE
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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

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[print or type full name], of
[print or type full address], declare under

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penalty of perjury that I have read in its entirety and

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understand the Stipulated Protective Order that was issued by

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the United States District Court for the Central District of

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California on [date] in the case of The Estate of Raul Herrera

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III, et al., v. City of Ontario, et al., Case No. 5:17-cv-82 SP.

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I agree to comply with and to be bound by all the terms of this

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Stipulated Protective Order and I understand and acknowledge

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that failure to so comply could expose me to sanctions and

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punishment in the nature of contempt. I solemnly promise that I

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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

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entity except in strict compliance with the provisions of this

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Order. I further agree to submit to the jurisdiction of the

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United States District Court for the Central District of

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California for the purpose of enforcing the terms of this

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Stipulated Protective Order, even if such enforcement

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proceedings occur after termination of this action. I hereby

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appoint

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[print or type full name] of
[print or type full

address and telephone number] as my California agent for service

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of process in connection with this action or any proceedings

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related to enforcement of this Stipulated Protective Order.
{DSR/00051297. }

-18STIPULATED PROTECTIVE ORDER

City and State

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Date:

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where sworn and signed:

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Printed name:

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Signature:

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{DSR/00051297. }

-19STIPULATED PROTECTIVE ORDER