Christina Gonzalez et al. v. State of California

Filing 14

MODIFIED STIPULATED PROTECTIVE ORDER #13 , signed by Magistrate Judge Jennifer L. Thurston on 10/16/2020. (Hall, S)

Case 1:20-cv-00912-NONE-JLT Document 13 Filed 10/16/20 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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CHRISTINA GONZALEZ, ANJELICA
GONZALEZ, and VICTORIA
GONZALEZ, individually and as successors
in interest to JASON GONZALEZ,
deceased,

Case No. 1:20-cv-00912-NONE-JLT
STIPULATION AND PROPOSED ORDER
MODIFYING PROTECTIVE ORDER
(Doc. 13)

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Plaintiffs,
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v.
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STATE OF CALIFORNIA; and DOE CHP
OFFICERS 1 - 15, inclusive,

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Defendants.
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WHEREAS, a protective order was entered in this case on September 1, 2020 (Dkt. No.

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11);
WHEREAS, Defendant State of California subpoenaed records from the Kern County

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Sheriff – Coroner’s Office;
WHEREAS, the records to be produced in response to the subpoena by the Kern County

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Sheriff – Coroner’s Office include autopsy photographs, which are prohibited from dissemination

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pursuant to California Code of Civil Procedure section 129;

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//
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STIPULATION AND PROPOSED ORDER RE MODIFICATION OF PROTECTIVE ORDER
(1:20-cv-00912-NONE-JLT)

Case 1:20-cv-00912-NONE-JLT Document 13 Filed 10/16/20 Page 2 of 3
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NOW, THEREFORE, the parties stipulate that the protective order entered on September

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1, 2020 (Dkt. No. 11) shall include autopsy photos in its definition of “Confidential Information”

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and that any autopsy photographs produced by the Kern County Sheriff – Coroner’s Office shall

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be subject to the protective order entered on September 1, 2020 (Dkt. No. 11).

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: October 14, 2020

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LAW OFFICES OF YORK AND GARVEY
By:

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Dated: October 14, 2020

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_s/ Darrell J. York__________
DARRELL J. YORK
SARAH L. GARVEY
Attorneys for Plaintiffs

XAVIER BECERRA
Attorney General of California
MARK T. CUMBA
Supervising Deputy Attorney General

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As the filer of this stipulation, I attest that all other
signatories listed, and on whose behalf the filing is
submitted, concur in the filing’s content and have
authorized the filing.

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By:

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_s/ Donna M. Dean__________
DONNA M. DEAN
Deputy Attorney General
Attorneys for Defendant
State of California

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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October 16, 2020
Dated: ___________________

__________________________
Jennifer L. Thurston
United States Magistrate Judge

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STIPULATION AND PROPOSED ORDER RE MODIFICATION OF PROTECTIVE ORDER
(1:20-cv-00912-NONE-JLT)