Hughey et al v. Camacho et al

Filing 79

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/11/19 DIRECTING the parties to redact the name of the plaintiff minor child and change the address within 30 days. (Coll, A)

1 Christopher J. Moenig, SBN 267286
MOENIG LAW
2 520 9th Street, Suite 230
Sacramento, California 95814
3 Telephone: [phone]
Facsimile: 916.248.4515
4 E-Mail: [e-mail]
5 Attorneys for Plaintiffs
6
BRUCE A. KILDAY, SB No. 066415
7 Email: [e-mail]
SEAN D. O’DOWD, SB No. 296320
8 Email: [e-mail]
ANGELO, KILDAY & KILDUFF, LLP
9 Attorneys at Law
601 University Avenue, Suite 150
10 Sacramento, CA 95825
Telephone: [phone]
11 Telecopier: [phone]
12 Attorneys for Defendants
13
14

UNITED STATES DISTRICT COURT

15

EASTERN DISTRICT OF CALIFORNIA

16

SACRAMENTO DIVISION

17
18

KEVIN HUGHEY AND JESSICA
HUGHEY, Individually on Behalf of
Themselves and On Behalf of Minor Child G.
H., and G. H.,

19

Case No. 2:13-cv-02665-TLC-AC
JOINT STIPULATION TO REDACT COURT
RECORDS AND ORDER

Plaintiffs,
20
21
22
23
24
25
26

v.
ARTURO CAMACHO, FORMER CHIEF
OF POLICE DAN DRUMMOND,
CURRENT CHIEF OF POLICE THOMAS
MCDONALD, WEST SACRAMENTO
POLICE DEPARTMENT, CITY OF WEST
SACRAMENTO, TOD SOCKMAN, JASON
WINGER, LABIN WILSON, TYLER
RAINEY, ANDREA DONAHUE, CODY
COULTER, CHRIS RICE, MATT
BOUDINOT, RICH BENTLEY, and DOES
1-20,
Defendants.

27
28
1
JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER

1

1.

This stipulation is entered into between Plaintiffs KEVIN HUGHEY, JESSICA

2 HUGHEY, and G. H. (“Plaintiffs”) and Defendants ARTURO CAMACHO, DAN DRUMMOND,
3 THOMAS MCDONALD, WEST SACRAMENTO POLICE DEPARTMENT, CITY OF WEST
4 SACRAMENTO, TOD SOCKMAN, JASON WINGER, LABIN WILSON, TYLER RAINEY,
5 ANDREA DONAHUE, CODY COULTER, CHRIS RICE, MATT BOUDINOT and RICH BENTLEY
6 (collectively “Defendants”), through and by their counsel of record.
7

2.

In early January 2019, Plaintiffs were informed that court records containing private

8 information as to the plaintiff minor child would need to be redacted.
9

THEREFORE, the parties, by and through their counsel, stipulate and agree to:

10

1.

The Court entering an order, pursuant to Federal Rule of Civil Procedure 5.2 and Local

11 Rule 140, permitting the parties to: (i) redact and remove any instance in a document filed with the
12 Court in this proceeding where the full name of the plaintiff minor child is stated and restate only the
13 initials of the plaintiff minor child and (ii) to redact and remove any instance in a document filed with
14 the Court in this proceeding where the full home address of the plaintiff minor child is stated and
15 restate only the city and state where such address is located, in the following documents filed with the
16 Court in this proceeding:
17
18

Docket
No.

Document

Location of Proposed
Redaction
Page 1; lines 12-13, 24, 27, 28
Page 2; line 1
Page 7; lines 9, 17
Page 9; line 11

1

Complaint for Damages

2

Civil Cover Sheet

Top of page; “Plaintiffs” section

5

Decline of Jurisdiction of United States Magistrate
Judge

Bottom of page; “Counsel for …”
section

11

Notice of Related Case

Page 1; lines 14-15

12

Notice of Related Case Order

Page 1; lines 6-7

13

Plaintiffs’ Requests for Entry of Default Judgment

Page 1; lines 10-11, 23

19
20
21
22
23
24
25
26
27
28

2
JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER

1
2

Docket
No.
15

Document
Stipulation to Set Aside Default And [Proposed]
Order

Location of Proposed
Redaction
Page 1; lines 16-17

3
16

Order

Page 1; lines 16-17

17

Defendants’ Notice of Motion and Motion to
Dismiss Plaintiffs’ Complaint Pursuant to Federal
Rule of Civil Procedure 12(B)(6)

Page 1; lines 16-17

17-1

Defendants' Memorandum of Points and Authorities Page 0; lines 16-17
in Support
Page 1; lines 2

9

18

Notice of Withdrawal of Certain Counsel

Page 1; lines 10-11

10

19

Proof of Service

Page 1, lines 11-12

11

20

Notice of Appearance of Co-Counsel

Page 1; lines 11-12, 25

21

Notice of Appearance of Co-Counsel

Page 1; lines 11-12, 25

22

Plaintiffs’ Opposition to Defendants’ Motion to
Dismiss

Page 0; lines 10-11
Page 1; line 1

23

Joint Status Report

Page 1; lines 21-22
Page 2, line 15

24

Defendants’ Reply to Plaintiffs’ Opposition to
Motion to Dismiss Plaintiffs’ Complaint

Page 1; lines 16-17

27

Notice of Appearance of Co-Counsel

Page 1; lines 12-13

28

Memorandum and Order

Page 1; lines 13, 27
Page 3; line 9

29

First Amended Complaint for Damages

Page 1; lines 12-13, 23, 26, 28
Page 7; lines 2, 11
Page 9; line 2

30

Defendants’ Notice or Motion and Motion to
Dismiss Plaintiffs’ First Amended Complaint

Page 1; line 15-16

30-1

Memorandum of Points and Authorities in Support

Page 0; lines 15-16
Page 1; line 2

4
5
6
7
8

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3
JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER

2

Docket
No.
30-2

3

32

Defendants’ Reply to Opposition to Motion to
Dismiss Plaintiffs’ First Amended Complaint

Page 1; lines 16-17

33

Plaintiffs’ Opposition to Defendants’ Motion to
Dismiss Plaintiffs’ First Amended Complaint

Page 1; lines 12-13, 23
Page 3; line 10

33-1

Declaration of Christopher J. Moenig In Support

Page 1; lines 12-13

35

Defendants’ Substantive Reply to Opposition to
Motion to Dismiss Plaintiffs’ First Amended
Complaint

Page 1; lines 17-18

37

Memorandum and Order

Page 1; lines 13-14,
Page 2; line 3
Page 3; line 20

38

Second Amended Complaint For
Damages

Page 1, lines 12-13, 23, 26, 28
Page 7; lines 2,11
Page 9; lines 2

42

Defendants’ Answer to Second Amended Complaint Page 1; lines 15-16
Page 2, line 6

43

Defendant Tod Sockman’s Notice of Motion and
Motion to Dismiss Plaintiffs’ Second Amended
Complaint

Page 1; lines 15-16

44

Notice of Association of Counsel

Page 1; lines 13-14, 28
Page 2; lines 15, 19

45

Notice of Withdrawal of Former Counsel

Page 1; lines 12-13

46

Notice of Withdrawal of Former Counsel

Page 1; lines 12-13

23

47

Notice of Withdrawal of Former Counsel

Page 1; lines 12-13

24

48

Plaintiffs’ Opposition to Defendant Tod Sockman’s
Motion to Dismiss Plaintiffs’ Second Amended
Complaint

Page 1; lines 15-16, 17
Page 3; line 13

48-1

Declaration of Christopher J. Moenig In Support

Page 1; lines 15-16
Page 2; line 5

1

4
5

Document
[Proposed] Order

Location of Proposed
Redaction
Page 1; lines 15-16

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

25
26
27
28

4
JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER

1
2

Docket
No.
49

3
4

Document
Reply to Opposition to Defendant Tod Sockman’s
Motion to Dismiss Plaintiffs’ Second Amended
Complaint

Location of Proposed
Redaction
Page 1; lines 15-16

51

Order Granting Defendant Tod Sockman’s Motion
to Dismiss Plaintiffs’ Second Amended Complaint

Page 1; lines 12, 24
Page 3; lines 7

52

Third Amended Complaint for Damages

Page 1; lines 15-16, 26
Page 2; lines 2, 3, 4, 7, 11
Page 9; line 2
Page 23; line 21

53

Defendant Tod Sockman’s Answer to Third
Amended Complaint

Page 1; lines 15-16
Page 2; line 2

57

Updated Joint Status Report

Page 2; line 15
Page 3; line 13

62

Joint Stipulation to Extend Deadline for Expert
Discovery

Page 1; lines 15-16

63

Order RE Joint Stipulation to Extend Deadline for
Expert Discovery

Page 1; lines 15-16

16

64

Notice of Motion and Motion for Consolidation

Page 1; lines 9, 16-17

17

64-1

Memorandum of Points & Authorities in Support

Page 1; lines 9, 16-17

18

64-2

Declaration of Jesse Ortiz in Support

Page 1; lines 9, 16-17

64-3

Proposed] Order Re: Consolidation of Actions

Page 1; lines 9, 16-17

65

Defendants’ Notice of Non-Opposition to Plaintiff’s Page 1; lines 15-16
Motion to Consolidate

67

Stipulation And [Proposed] Order to Modify the
Pretrial Scheduling Order

Page 1; lines 19-20

70

Ex Parte Application for Order Shortening Time for
Notice of Motion and Motion for Approval of
Settlement and Compromise of Minor’s Claims;
Memorandum of Points & Authorities in Support

Page 1; lines 14-15
Page 2; lines 2, 10, 19, 22

70-1

Petition and Order for Appointment of Guardian Ad
Litem

Page 1; lines 14-15, 25

5
6
7
8
9
10
11
12
13
14
15

19
20
21
22
23
24
25
26
27
28

5
JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER

1
2

Docket
No.
70-2

3
4

Document
Notice of Motion and Motion for Approval of
Settlement and Compromise of Minor’s Claims;
Memorandum of Points & Authorities in Support

Location of Proposed
Redaction
Page 1; lines 14-15
Page 2; line 5

70-3

Memorandum of Points & Authorities in Support of
Motion for Approval of Settlement and
Compromise of Minor’s Claims

Page 0; lines14-15
Page 1; line 5

70-4

Declaration of Kevin Hughey In Support

Page 1; lines 14-15, 28

70-5

Proof of Service

Page 1; lines 14-15

71

Petition and Order for Appointment of Guardian Ad
Litem

Page 1; lines 14-15, 25

72

Notice of Motion and Motion for Approval of
Settlement and Compromise of Minor’s Claims;
Memorandum of Points & Authorities in Support

Page 1; lines 14-15
Page 2, line 5

72-1

Memorandum of Points & Authorities in Support of
Motion for Approval of Settlement and
Compromise of Minor’s Claims

Page 0; lines 14-15
Page 1; line 5

72-2

Declaration of Kevin Hughey in Support

Page 1; lines 14-15, 28

72-3

Proof of Service

Page 1; lines 14-15

74

Notice of Conditional Settlement

Page 1; lines 23, 24

76

Order RE Petition for Appointment of Guardian Ad
Litem

Page 1; lines 14-15, 24

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

2.

The Court entering an order requiring the name of the plaintiff minor child be changed

23 to G. H. and changing the address of the plaintiff minor child to the applicable city and state where it
24 appears on the Court’s public docket.
25

3.

The Court entering an order permitting the parties to redact any instance in any publicly

26 filed document where the name and/or address of the plaintiff minor child are stated, but which instance
27 was inadvertently omitted from the list of 76 documents included in this Stipulation.
28
6
JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER

1

4.

The parties further agree to complete the redactions contemplated by this Stipulation

2 within 30 days of the entry of an Order approving this Stipulation.
3

5.

Plaintiffs’ counsel shall provide to Defendants’ counsel by email electronic copies of

4 proposed redacted versions of those documents that were initially filed by Defendants for approval
5 prior to submitting such redacted documents to the Court (whether electronically or otherwise). If
6 Defendants’ counsel fail to respond to such an email inquiry within five (5) days of the date that it was
7 sent, such failure to respond shall be conclusively deemed to constitute approval to submit such
8 proposed redacted versions of the documents to the Court.
9

SO STIPULATED.

10
11 DATED: February 11, 2019

MOENIG LAW

12

_/s/_ Christopher J. Moenig_
Christopher J. Moenig
Attorney for Plaintiffs

13
14
15 DATED: February 11, 2019

ANGELO, KILDAY & KILDUFF, LLP

16
____/s/ Bruce A. Kilday____________
BRUCE A. KILDAY
SEAN D. O’DOWD
Attorneys for Defendants

17
18
19
20

IT IS SO ORDERED.

21
22 Dated: February 11, 2019
23
24
25

Troy L. Nunley
United States District Judge

26
27
28
7
JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER