Kaur et al v. City of Lodi et al

Filing 46

STIPULATION and ORDER 44 regarding production of person records signed by Magistrate Judge Allison Claire on 10/14/2014. Plaintiffs' counsel hereby agrees that no disclosure of designated materials will occur until either: (a) defense counsel informs them in a timely manner that no protective order will be sought, or (b) a ruling is made on Defendants' 40 Motion for Protective Order. Accordingly, defendants WITHDREW their 40 Motion. (Marciel, M)

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SUKHWINDER KAUR, et al.,
Plaintiffs,

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vs.

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Case No. 2:14-cv-00828-GEB-AC
STIPULATION AND ORDER
REGARDING PRODUCTION OF
PERSONNEL RECORDS

CITY OF LODI, et al.,
Defendants.

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Pursuant to Local Rule 251, the parties have met and conferred prior to Plaintiffs filing a motion

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to compel responses to request for production of documents and regarding Defendant’s Motion for a

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Protective Order regarding Peace Officer personnel records and hereby stipulate to the following:
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STIPULATION AND ORDER REGARDING PRODUCTION OF PERSONNEL RECORDS
87357

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1.

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Defendant’s CITY OF LODI will provide Plaintiffs with documents responsive to their
Request for Production, Set One, including those that are contained within the Peace

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Officers’ personnel files, subject to Defendants objections previously asserted.

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2.

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These documents will bear bates stamps with a range of LODI500000-600000 for ease of
identification as documents that are covered by this stipulation.

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3.

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These specially designated documents may be disclosed only to counsel, parties, and
experts within this litigation.

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4.

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If Plaintiff desires to disclose these specially designated materials identified as Peace
Officer personnel records to individuals or organizations outside of the litigation,

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Plaintiffs’ counsel will notify Defense counsel as to the particular documents they wish to

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disclose.

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5.

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Defense counsel will determine whether or not to seek a protective order regarding the
particular documents at issue. Defense counsel will advise Plaintiff with in five (5) days

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after notification if a protective order will be sought.

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6.

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Plaintiffs’ counsel hereby agrees that no disclosure of these designated materials will
occur until either: (a) defense counsel informs them in a timely manner that no protective

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order will be sought, or (b) a ruling is made on Defendants’ motion for a protective order.

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Accordingly, Defendants withdrew their motion (Docket #40) for a protective order.

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DATED: 10/10/14

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/s/ Mark E. Merin (approved on 10/10/14)
By:__________________________________
Mark E. Merin
Paul H. Masuhara
Attorneys for Plaintiffs

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LAW OFFICE OF MARK E. MERIN

DATED: 10/10/14

ANGELO, KILDAY & KILDUFF

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/s/ Amie McTavish
By:__________________________________
AMIE McTAVISH
Attorneys for Defendants CITY OF LODI;
CITY OF LODI POLICE DEPARTMENT
and CHIEF MARK HELMS
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STIPULATION AND ORDER REGARDING PRODUCTION OF PERSONNEL RECORDS
87357

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DATED: 10/10/14

OFFICE OF THE CITY ATTORNEY

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/s/ Janice D. Magdich (approved on 10/10/14)
By:__________________________________
JANICE D. MAGDICH
Attorneys for Defendants CITY OF LODI;
CITY OF LODI POLICE DEPARTMENT
and CHIEF MARK HELMS

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DATED: 10/10/14

MAYALL HURLEY, P.C.

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/s/ Mark E. Berry (approved on 10/10/14)
By:__________________________________
MARK E. BERRY
DERICK KONZ
Attorneys for Defendants,
SCOTT BRATTON and ADAM LOCKIE

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ORDER
IT IS SO ORDERED.

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DATED: October 14, 2014

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STIPULATION AND ORDER REGARDING PRODUCTION OF PERSONNEL RECORDS
87357