Preston McCormick et al v. County of Riverside et al

Filing 35

STIPULATED PROTECTIVE ORDER by Magistrate Judge Sheri Pym re Stipulation for Protective Order 33 . (see document for details). (et)

1 Nathan A. Oyster (SBN 225307)
E-mail: [e-mail]
2
Michaela Battista Sozio (SBN 179148)
3 Email: [e-mail]
Caylin W. Jones (SBN 327829)
4
E-mail: [e-mail]
5 BURKE, WILLIAMS & SORENSEN, LLP
444 South Flower Street, Suite 2400
6
Los Angeles, California 90071-2953
7 Tel: [phone] Fax: [phone]
8
9
10
11
12
13

Attorneys for Defendants
COUNTY OF RIVERSIDE (also
erroneously sued herein as RIVERSIDE
COUNTY SHERIFF’S DEPARTMENT),
JEFFREY ANTHONY VAN
WAGENEN, JR., SHERIFF CHAD
BIANCO, and JOSE TRUJILLO
VILLASENOR

14

UNITED STATES DISTRICT COURT

15

CENTRAL DISTRICT OF CALIFORNIA

16
17 PRESTON MCCORMICK, an
18 individual; and EAST WIND AG, a
California corporation,
19

STIPULATED PROTECTIVE
ORDER; ORDER THEREON

Plaintiff,

20
21

Case No. 5:23-cv-02569-SSS-SPx

Magistrate Judge Sheri Pym

v.

22

COUNTY OF RIVERSIDE, a public
23 entity; JEFFREY ANTHONY VAN
24 WAGENEN, JR., an individual and in
his official capacity; RIVERSIDE
25
COUNTY SHERIFF’S
26 DEPARTMENT, a division of a public
entity; SHERIFF CHAD BIANCO, an
27
individual and in his official capacity;
28 JOSE-TRUJILLO VILLASENOR, an
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1 individual and in his official capacity;
IMPERIAL IRRIGATION DISTRICT,
2
a public entity; JAMIE L. ASBURY, an
3 individual and in her official capacity;
and DOES 1 through 150, individually,
4
jointly and severally,
5
Defendants.
6
7
8
9

A. PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,

10 proprietary, or private information for which special protection from public
11 disclosure and from use for any purpose other than prosecuting this litigation may
12 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
13 enter the following Stipulated Protective Order (the “Order”).
14

The parties acknowledge that this Order does not confer blanket protections

15 on all disclosures or responses to discovery and that the protection it affords from
16 public disclosure and use extends only to the limited information or items that are
17 entitled to confidential treatment under applicable legal principles.
18

The parties further acknowledge, as set forth in Section 12.3, below, that this

19 Stipulated Protective Order does not entitle them to file confidential information
20 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed
21 and the standards that will be applied when a party seeks permission from the court
22 to file material under seal.
23

B. GOOD CAUSE STATEMENT

24

This action relates to the execution of a search warrant by Riverside County

25 Sheriff’s Department deputies on a property operated by Plaintiffs Preston
26 McCormick and East Wind AG that such Plaintiffs assert is located on sovereign
27 Indian tribal land. The anticipated documents and other relevant material in this
28 case includes, but is not limited to, body-worn camera footage, police reports,
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1 witness statements, and information about individuals who are not parties to this
2 litigation.
The parties submit that good cause exists to enter into this Order to balance

3

4 the County Defendants’ concerns that the documents and other relevant material
5 may consist of police reports and private information concerning the parties to this
6 litigation, which may be protected by the official information privilege, law
7 enforcement privilege, and the right to privacy, as protected by the California and
8 United States Constitution, with the Plaintiff’s concerns as to their rights to
9 unfettered and robust discovery of documents and other relevant information
10 important to their prosecution of this case in litigation.
Accordingly, to expedite the flow of information, to facilitate the prompt

11

12 resolution of disputes over confidentiality of discovery materials, to adequately
13 protect information the parties are entitled to keep confidential, to ensure that the
14 parties are permitted reasonable necessary uses of such material in preparation for
15 and in the conduct of trial, to address their handling at the end of the litigation, and
16 serve the ends of justice, a protective order for such information is justified in this
17 matter.
It is the intent of the parties that documents and other relevant information

18

19 will not be designated as confidential pursuant to this Order for tactical reasons or
20 improper purpose and that nothing be so designated without a good faith belief that
21 same has been maintained in a confidential, non-public manner, and there is good
22 cause why it should not be part of the public record in this case.
23 2.

DEFINITIONS

24

2.1

Action: this pending federal lawsuit entitled Preston McCormick et al.

25 v. County of Riverside, et al, case number 5:23-cv-02569-SSS (SPx).
2.2 Challenging Party: a Party or Non-Party that challenges the
26
27 designation of information or items under this Order.
28 / / /
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2.3

“CONFIDENTIAL” Information or Items: information (regardless of

2 how it is generated, stored or maintained) or tangible things that qualify for
3 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
4 the Good Cause Statement.
5

2.4

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

6 their support staff).
7

2.5

Designating Party: a Party or Non-Party that designates information or

8 items that it produces in disclosures or in responses to discovery as
9 “CONFIDENTIAL.”
10

2.6

Disclosure or Discovery Material: all items or information, regardless

11 of the medium or manner in which it is generated, stored, or maintained (including,
12 among other things, testimony, transcripts, and tangible things), that are produced or
13 generated in disclosures or responses to discovery in this matter.
14

2.7

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

15 pertinent to the litigation who has been retained by a Party or its counsel to serve as
16 an expert witness or as a consultant in this Action.
17

2.8

House Counsel: attorneys who are employees of a party to this Action.

18 House Counsel does not include Outside Counsel of Record or any other outside
19 counsel.
20

2.9

Non-Party: any natural person, partnership, corporation, association, or

21 other legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: attorneys who are not employees of a
22
23 party to this Action but are retained to represent or advise a party to this Action and
24 have appeared in this Action on behalf of that party or are affiliated with a law firm
25 which has appeared on behalf of that party, and includes support staff.
2.11 Party: any party to this Action, including all of its officers, directors,
26
27 employees, consultants, retained experts, and Outside Counsel of Record (and their
28 support staffs).
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2.12 Producing Party: a Party or Non-Party that produces Disclosure or

2 Discovery Material in this Action.
3

2.13 Professional Vendors: persons or entities that provide litigation

4 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
5 demonstrations, and organizing, storing, or retrieving data in any form or medium)
6 and their employees and subcontractors.
7

2.14 Protected Material: any Disclosure or Discovery Material that is

8 designated as “CONFIDENTIAL.”
9

2.15 Receiving Party: a Party that receives Disclosure or Discovery

10 Material from a Producing Party.
11

3. SCOPE

12

The protections conferred by this Order cover not only Protected Material (as

13 defined above), but also (1) any information copied or extracted from Protected
14 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;
15 and (3) any testimony, conversations, or presentations by Parties or their Counsel
16 that would necessarily reveal Protected Material.
17

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

18 trial judge. This Order does not govern the use of Protected Material at trial.
19
20

4. DURATION
Even after final disposition of this litigation, the confidentiality obligations

21 imposed by this Order shall remain in effect until a Designating Party agrees
22 otherwise in writing or a court order otherwise directs. Final disposition shall be
23 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
24 or without prejudice; and (2) final judgment herein after the completion and
25 exhaustion of all appeals, re-hearings, remands, trials, or reviews of this Action,
26 including the time limits for filing any motions or applications for extension of time
27 pursuant to applicable law.
28 / / /
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5. DESIGNATING PROTECTED MATERIAL

2

5.1 Exercise of Restraint and Care in Designating Material for Protection:

3 Each Party or Non-Party that designates information or items for protection under
4 this Order must take care to limit any such designation to specific material that
5 qualifies under the appropriate standards. The Designating Party must designate for
6 protection only those parts of material, documents, items, or oral or written
7 communications that qualify so that other portions of the material, documents,
8 items, or communications for which protection is not warranted are not swept
9 unjustifiably within the ambit of this Order.
10

Mass, indiscriminate, or routinized designations are prohibited. Designations

11 that are shown to be clearly unjustified or that have been made for an improper
12 purpose (e.g., to unnecessarily encumber the case development process or to impose
13 unnecessary expenses and burdens on other parties) may expose the Designating
14 Party to sanctions.
15

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

16 designated for protection do not qualify for protection, that Designating Party must
17 promptly notify all other Parties that it is withdrawing the inapplicable designation.
18

5.2 Manner and Timing of Designations. Except as otherwise provided in this

19 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
21 under this Order must be clearly so designated before the material is disclosed or
22 produced.
23

Designation in conformity with this Order requires:

24

(a) for information in documentary form (e.g., paper or electronic documents,

25 but excluding transcripts of depositions or other pretrial or trial proceedings), that
26 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
27 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
28 portion or portions of the material on a page qualifies for protection, the Producing
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1 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
2 markings in the margins).
3

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

4 need not designate them for protection until after the inspecting Party has indicated
5 which documents it would like copied and produced. During the inspection and
6 before the designation, all of the material made available for inspection shall be
7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
8 documents it wants copied and produced, the Producing Party must determine which
9 documents, or portions thereof, qualify for protection under this Order. Then, before
10 producing the specified documents, the Producing Party must affix the
11 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
12 portion or portions of the material on a page qualifies for protection, the Producing
13 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
14 markings in the margins).
15

(b) for testimony given in depositions that the Designating Party identify the

16 Disclosure or Discovery Material on the record, before the close of the deposition all
17 protected testimony.
18

(c) for information produced in some form other than documentary and for

19 any other tangible items, that the Producing Party affix in a prominent place on the
20 exterior of the container or containers in which the information is stored the legend
21 “CONFIDENTIAL.” If only a portion or portions of the information warrants
22 protection, the Producing Party, to the extent practicable, shall identify the protected
23 portion(s).
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
24
25 failure to designate qualified information or items does not, standing alone, waive
26 the Designating Party’s right to secure protection under this Order for such material.
27 Upon timely correction of a designation, the Receiving Party must make reasonable
28 efforts to assure that the material is treated in accordance with the provisions of this
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1 Order.
2

6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

3

6.1

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

4 designation of confidentiality at any time that is consistent with the Court’s
5 Scheduling Order.
6

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

7 resolution process under Local Rule 37.1 et seq.
8

6.3

The burden of persuasion in any such challenge proceeding shall be on

9 the Designating Party. Frivolous challenges, and those made for an improper
10 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
11 parties) may expose the Challenging Party to sanctions. Unless the Designating
12 Party has waived or withdrawn the confidentiality designation, all parties shall
13 continue to afford the material in question the level of protection to which it is
14 entitled under the Producing Party’s designation until the Court rules on the
15 challenge.
16

7.

ACCESS TO AND USE OF PROTECTED MATERIAL

17

7.1

Basic Principles. A Receiving Party may use Protected Material that is

18 disclosed or produced by another Party or by a Non-Party in connection with this
19 Action only for prosecuting, defending, or attempting to settle this Action. Such
20 Protected Material may be disclosed only to the categories of persons and under the
21 conditions described in this Order. When the Action has been terminated, a
22 Receiving Party must comply with the provisions of section 13 below (FINAL
23 DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a
24
25 location and in a secure manner that ensures that access is limited to the persons
26 authorized under this Order.
27

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

28 otherwise ordered by the court or permitted in writing by the Designating Party, a
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1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only to:
3

(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

4 employees of said Outside Counsel of Record to whom it is reasonably necessary to
5 disclose the information for this Action;
6

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

7 the Receiving Party to whom disclosure is reasonably necessary for this Action;
8

(c) Experts (as defined in this Order) of the Receiving Party to whom

9 disclosure is reasonably necessary for this Action and who have signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
11

(d)

the court and its personnel;

12

(e)

court reporters and their staff;

13

(f)

professional jury or trial consultants, mock jurors, and Professional

14 Vendors to whom disclosure is reasonably necessary for this Action and who have
15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16

(g) the author or recipient of a document containing the information or a

17 custodian or other person who otherwise possessed or knew the information;
18

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

19 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
20 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
21 not be permitted to keep any confidential information unless they sign the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
23 agreed by the Designating Party or ordered by the court. Pages of transcribed
24 deposition testimony or exhibits to depositions that reveal Protected Material may
25 be separately bound by the court reporter and may not be disclosed to anyone except
26 as permitted under this Stipulated Protective Order; and
27

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

28 mutually agreed upon by the parties engaged in settlement discussions.
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1

8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED

2 PRODUCED IN OTHER LITIGATION
3

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

4 that compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6

(a) promptly notify in writing the Designating Party. Such notification shall

7 include a copy of the subpoena or court order;
8

(b) promptly notify in writing the party who caused the subpoena or order to

9 issue in the other litigation that some or all of the material covered by the subpoena
10 or order is subject to this Protective Order. Such notification shall include a copy of
11 this Stipulated Protective Order; and
12

(c) cooperate with respect to all reasonable procedures sought to be pursued

13 by the Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with the
15 subpoena or court order shall not produce any information designated in this action
16 as “CONFIDENTIAL” before a determination by the court from which the
17 subpoena or order issued, unless the Party has obtained the Designating Party’s
18 permission. The Designating Party shall bear the burden and expense of seeking
19 protection in that court of its confidential material and nothing in these provisions
20 should be construed as authorizing or encouraging a Receiving Party in this Action
21 to disobey a lawful directive from another court.
9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
22
23 PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a
24
25 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
26 produced by Non-Parties in connection with this litigation is protected by the
27 remedies and relief provided by this Order. Nothing in these provisions should be
28 construed as prohibiting a Non-Party from seeking additional protections.
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(b) In the event that a Party is required, by a valid discovery request, to

2 produce a Non-Party’s confidential information in its possession, and the Party is
3 subject to an agreement with the Non-Party not to produce the Non-Party's
4 confidential information, then the Party shall:
(1) promptly notify in writing the Requesting Party and the Non-Party

5

6 that some or all of the information requested is subject to a confidentiality
7 agreement with a Non-Party;
(2) promptly provide the Non-Party with a copy of this Order, the

8

9 relevant discovery request(s), and a reasonably specific description of the
10 information requested; and
(3) make the information requested available for inspection by the Non-

11

12 Party, if requested.
13

(c) If the Non-Party fails to seek a protective order from this court within 14

14 days of receiving the notice and accompanying information, the Receiving Party
15 may produce the Non-Party’s confidential information responsive to the discovery
16 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
17 not produce any information in its possession or control that is subject to the
18 confidentiality agreement with the Non-Party before a determination by the court.
19 Absent a court order to the contrary, the Non-Party shall bear the burden and
20 expense of seeking protection in this court of its Protected Material.
21

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

22

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

23 Protected Material to any person or entity that is in any circumstance not authorized
24 to receive such disclosure pursuant to this Order, the Receiving Party must
25 immediately: (a) notify in writing the Designating Party of the unauthorized
26 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
27 Protected Material, (c) inform the person or entity to whom unauthorized disclosures
28 were made of all the terms and conditions of this Order, and (d) request such person
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1 or entity execute the “Acknowledgment and Agreement to Be Bound” that is
2 attached hereto as Exhibit A.
3

11.

INADVERTENT PRODUCTION OF PRIVILEGED OR

4 OTHERWISE PROTECTED MATERIAL
5

When a Producing Party gives notice to Receiving Parties that certain

6 inadvertently produced material is subject to a claim of privilege or other protection,
7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
9 may be established in an e-discovery order that provides for production without
10 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
11 as the parties reach an agreement on the effect of disclosure of a communication or
12 information covered by the attorney-client privilege or work product protection, the
13 parties may incorporate their agreement in the stipulated protective order submitted
14 to the court.
15

12.

MISCELLANEOUS

16

12.1 Right to Further Relief. Nothing in this Order abridges the right of any

17 person to seek its modification by the Court in the future.
18

12.2

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

19 Order no Party waives any right it otherwise would have to object to disclosing or
20 producing any information or item on any ground not addressed in this Order.
21 Similarly, no Party waives any right to object on any ground to the use in evidence
22 of any of the documents or relevant information covered by this Order.
23

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

24 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
25 only be filed under seal pursuant to a court order authorizing the sealing of the
26 specific Protected Material at issue. If a Party’s request to file Protected Material
27 under seal is denied by the court, then the Receiving Party may file the information
28 in the public record unless otherwise instructed by the court.
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13.

2

After the final disposition of this Action, as defined in paragraph 4, within 60

FINAL DISPOSITION

3 days of a written request by the Designating Party, each Receiving Party must return
4 all Protected Material to the Producing Party or destroy such material. As used in
5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
6 summaries, and any other format reproducing or capturing any of the Protected
7 Material. Whether the Protected Material is returned or destroyed, the Receiving
8 Party must submit a written certification to the Producing Party (and, if not the same
9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
10 (by category, where appropriate) all the Protected Material that was returned or
11 destroyed and (2) affirms that the Receiving Party has not retained any copies,
12 abstracts, compilations, summaries or any other format reproducing or capturing any
13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
16 reports, attorney work product, and consultant and expert work product, even if such
17 materials contain Protected Material. Any such archival copies that contain or
18 constitute Protected Material remain subject to this Protective Order as set forth in
19 Section 4 (DURATION).
20

14. Any violation of this Order may be punished by any and all appropriate

21 measures including, without limitation, contempt proceedings and/or monetary
22 sanctions.
23
24 IT IS SO ORDERED.
25
26

DATED: June 6, 2024

__________________________________
Magistrate Judge Sheri Pym

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1 SO STIPULATED.
2
3

DATED: __May 31, 2024

4

BURKE, WILLIAMS & SORENSEN, LLP
By:

5

Nathan A. Oyster
Michaela B. Sozio
Caylin W. Jones
Attorneys for Defendants
COUNTY OF RIVERSIDE, SHERIFF
CHAD BIANCO, JEFFREY ANTHONY
VAN WAGENEN, AND JOSE TRUJILLO
VILLASENOR

6
7
8
9
10
11 DATED:
12
13

May 31, 2024

MORROW LAW GROUP INC.
By: /s/
Gregory J. Morrow
Attorney for Plaintiffs
PRESTON MCCORMICK AND EAST
WINDS AG

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EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, _____________________________ [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 __________ in the case of Preston McCormick et al. v. County of Riverside, et
8 al, case number 5:23-cv-02569-SSS (SPx). I agree to comply with and to be bound
9 by all the terms of this Stipulated Protective Order and I understand and
10 acknowledge that failure to so comply could expose me to sanctions and punishment
11 in the nature of contempt. I solemnly promise that I will not disclose in any manner
12 any information or item that is subject to this Stipulated Protective Order to any
13 person or entity except in strict compliance with the provisions of this Order. I
14 further agree to submit to the jurisdiction of the United States District Court for the
15 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 __________________________ [print
18 or type full name] of _______________________________________ [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 Date: ______________________________________
23 City and State where sworn and signed: _________________________________
24 Printed name: _______________________________
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