Hammers v. County of Sacramento et al

Filing 10

STIPULATED PROTECTIVE ORDER REGARDING JUVENILE CASE RECORDS signed by Magistrate Judge Allison Claire on 1/25/16. (Becknal, R)

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JOSLYNN HAMMERS and DESIRAE
HAMMERS,
Plaintiffs,

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STIPULATED PROTECTIVE ORDER
REGARDING JUVENILE CASE
RECORDS

vs.

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Case No.: 2:15-cv-01800-KJM-AC

COUNTY OF SACRAMENTO, JENNIFER
RAUZY, SEIHDI KLOH, CYNTHIA
MARSHALL, JENNIFER LAMB, KELSEY
JOHNSON, MARGO POREMBSKI,
COUNTY OF YOLO, DAVID YENNE,
BONNIE CHRISTEN, RYAN MEZ, and
DOES 1-15 inclusive,

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Defendants.

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/

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Based upon the Stipulation Regarding Juvenile Case Records, submitted by ECF on

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January 21, 2016 by counsel for Sacramento County Defendants, on behalf of Defendants, Plaintiffs, and

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the Yolo County Defendants, the Court, having found GOOD CAUSE APPEARING, does hereby Order

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as follows:

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I.

JUVENILE CASE FILES

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Plaintiffs shall produce to Yolo County Defendants any and all documents produced pursuant to

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the juvenile dependency court’s order: joinder to disclosure of juvenile records after judicial review

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dated June 5, 2015 within 10 days of the attached (proposed) order. The documents shall be Bates
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STIPULATED PROTECTIVE ORDER REGARDING JUVENILE CASE RECORDS
{01500360.DOCX}

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stamped with the prefix “SACJV.” The Bates stamping will be done by use of conversion of the

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documents to PDF, and use of Adobe Acrobat’s numbering method. Plaintiffs will also provide a

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courtesy copy of the documents to Sacramento County Defendants in an effort to maintain uniformity.
All parties’ use of the documents is subject to the terms and restrictions described below.

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II.

COUNTY OF SACRAMENTO SHERIFF’S DEPARTMENT’S RECORDS

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Defendant County of Sacramento shall produce to all other parties all documents in the County

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of Sacramento Sheriff’s Department’s possession related to this matter within 20 days after service of

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its initial Rule 26 disclosures. The Bates stamping will be done by use of conversion of the documents

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to PDF, and use of Adobe Acrobat’s numbering method. The documents shall be Bates stamped with

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the prefix “SACSD.”
All parties’ use of the documents is subject to the terms and restrictions described below.

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III.

COUNTY OF YOLO’S SHERIFF DEPARTMENT’S RECORDS

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Defendant County of Yolo shall produce to all other parties all documents in the

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County of Yolo Sheriff’s Department’s possession related to this matter within 20 days after service of

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its initial Rule 26 disclosures. The Bates stamping will be done by use of conversion of the documents

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to PDF, and use of Adobe Acrobat’s numbering method. The documents shall be Bates stamped with

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the prefix “YCSD.” The “documents” with regard to County of Yolo should also include dispatch

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recordings taken the morning of July 19, 2014, when Plaintiff’s minor child was detained and given to

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a representative of the County of Sacramento’s Child Protective Services.

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IV.

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METHOD OF PRODUCTION
All documents described above that are produced by the parties shall be produced in Adobe

Acrobat PDF format on a flash memory stick or CD, as the producing party shall elect.

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If either party decides to withhold any document that is described above, that party shall

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produce a privilege log wherein each document withheld is described with sufficient specificity and

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particularity to allow the parties and/or the Court in this action to discern the time, date,

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author/recipient, and relationship of the document to the matter, and to a sufficient degree to allow

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identification of the document in a motion to compel. Further, the privilege log shall identify the

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factual and/or legal basis for any claim of privilege or confidentiality as to each document withheld
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STIPULATED PROTECTIVE ORDER REGARDING JUVENILE CASE RECORDS
{01500360.DOCX}

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from production pursuant to the attached (proposed) order. The privilege log shall be placed as the

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very first document in the production of documents produced pursuant to the attached (proposed) order.

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The documents withheld, in the case of actual documents, shall be replaced in the production

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where located in the originals with blank pages in an amount of pages equal to the original document

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being withheld, and bearing the statement “Privilege Claimed” in not less than 12 point font centered in

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the footer of the page, which are the sequentially Bates stamped as if they were the originals in

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sequence in the production. That Bates stamp number should be used for identification and stating the

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basis of the claimed privilege for the document(s) in the privilege log discussed above. Should the item

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or tangible thing in question be a physical item such as an audio tape, a single page which is also

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marked “Privilege Claimed” per directions above, with a brief description of the item, and that single

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page shall be inserted into the production in sequence. If there is a claim of privilege such item(s), that

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should also be included in the privilege log.

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V.

USE OF DOCUMENTS

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The documents produced pursuant to the attached (proposed) order shall only be used for the

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limited purpose of the subject civil litigation. Prior to filing any juvenile records under this (proposed)

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protective order, the party seeking to file will comply with Local Rule 141.

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Except as necessary in the civil case, the released documents shall not be disclosed to anyone

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other than the parties, their counsel (including investigators and adjusters), experts, and if applicable,

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Defendants’ insurance carrier. Upon conclusion of these proceedings and expiration of all appeal

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periods, documents produced pursuant to the attached (proposed) order shall be destroyed.

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IT IS SO ORDERED.

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DATED: January 25, 2016

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STIPULATED PROTECTIVE ORDER REGARDING JUVENILE CASE RECORDS
{01500360.DOCX}