Stoll v. County of Kern et al

Filing 102

STIPULATION for PROTECTIVE ORDER re Peace Officer Personnel Records; ORDER signed by Judge Sandra M. Snyder on 4/27/2009. (Herman, H)

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OFFICE OF KERN COUNTY COUNSEL COUNTY OF KERN, STATE OF CALIFORNIA By Mark L. Nations, Chief Deputy (Bar # 101838) Administrative Center 1115 Truxtun Avenue, Fourth Floor Bakersfield, California 93301 Telephone: [phone] Attorney for Defendants, COUNTY OF KERN, et al.

UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION The parties, by and through their attorneys of record, hereby stipulate: 1. Plaintiff has requested the production of peace officer personnel records in JOHN STOLL, Plaintiff, v. COUNTY OF KERN, EDWARD LAWRENCE KLEIER, deceased, and his surviving spouse, BARBARA B. KLEIER, VELDA MURILLO, BRADFORD JAMES DARLING, CONNY ERICSSON, CAROL DARLING, and DOES 1 - 30, inclusive, Defendants. STIPULATION FOR PROTECTIVE ORDER RE PEACE OFFICER PERSONNEL RECORDS; ORDER CASE NO. 1:05-CV-01059 OWW SMS

the form of training records for certain individuals who served as investigators of child sexual abuse in the Kern County Sheriff's Department. 2. Defendant County of Kern is willing to disclose such records provided an

appropriate protective order is issued by the court. 3. records. 4. The parties agree that the training records to be produced by defendant for Plaintiff is willing to enter into a protective order with respect to the training

inspection and copying by plaintiff shall be subject to the protective order stated below.

Stipulation and Protective Order

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Dated: April 21, 2009

Office of Kern County Counsel

By

/s/ Mark L. Nations Mark L. Nations, Chief Deputy Attorney for defendants Kern County, Lawrence Kleier, Brad Darling and Carol Darling

Dated: April 20, 2009 7 8

Robinson and Kellar, Attorneys

By 9 10 11 Dated: April 20, 2009 12 13 14 15 16

/s/ Oliver U. Robinson Oliver U. Robinson, Esq. Attorney for defendants Velda Murillo and Conny Ericsson

Law Office of Laurence O. Masson

By /s/ Laurence O. Masson Laurence O. Masson, Esq. Attorney for Plaintiff

PROTECTIVE ORDER 17 The parties having stipulated thereto and good cause appearing therefore, IT IS 18 HEREBY ORDERED, that the training records (Records) identified by defendant in 19 discovery shall be produced for inspection and copying by plaintiff subject to the following 20 protections: 21 1. 22 office except for review by retained experts whose opinions depend to some degree on the 23 content of the subject Records. 24 2. 25 attorneys, the attorneys' office staff, retained experts, court staff and parties to the action. 26 3. 27 conclusion of the litigation. 28 All copies of the Records shall be returned to counsel for defendant at the The only persons who shall be authorized to view the Records will be the The Records shall not be copied or disseminated outside of any attorney's

Stipulation and Protective Order

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4.

The Records shall not be used for any purpose outside this litigation and

neither the Records nor their contents shall be disclosed to the news media. 5. The records to be produced do not need to be lodged, submitted or filed

under seal for purposes of motions or trial. 6. Any person violating this order shall be subject to sanctions.

IT IS SO ORDERED. Dated: icido3 April 27, 2009 /s/ Sandra M. Snyder UNITED STATES MAGISTRATE JUDGE

Stipulation and Protective Order

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