Juan Francisco Martinez v. County of Los Angeles, et al

Filing 69

PROTECTIVE ORDER RE PRODUCTION PURSUANT TO SUBPOENA signed by Magistrate Judge Allison Claire on 8/8/18. (Mena-Sanchez, L)

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DONALD W. COOK, SBN 116666
ATTORNEY AT LAW
3435 Wilshire Blvd., Suite 2910
Los Angeles, CA 90010
[phone] / [phone] facsimile
E-mail: [e-mail]

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Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Case No. 2:18-cv-00964-TLNAC

JUAN FRANCISCO MARTINEZ, an
individual,

PROTECTIVE ORDER RE
PRODUCTION PURSUANT
TO SUBPOENA

Plaintiff,

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vs.

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CITY OF STOCKTON; COUNTY OF
SAN JOAQUIN; SAN JOAQUIN
COUNTY SHERIFF’S DEPARTMENT;
and DOES 1-10, both their individual &
official capacities,

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Defendants.

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Upon the stipulation filed by Plaintiff and non-party California Department of

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Justice and good cause appearing therefor, the production by the California

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Department of Justice of the WPS manual and criminal history information,

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including queries and audit trails (all of which was sought by subpoena dated July 9,

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2018 and issued by Plaintiff’s counsel) shall be subject to a protective order under

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the following terms:

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A.

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the Court hearing this matter, the parties’ attorneys, investigators and/or

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consultants or experts, and representatives, in this lawsuit, for defendant the

DONALD W. COOK.
Attorney at Law
3435 Wilshire Blvd., Ste. 2910
Los Angeles, CA 90010
([phone]

The WPS manual and criminal history information may be disclosed to

Protective Order Re Production Pursuant to Subpoena
Case No. 2:18-cv-00964-TLN-AC

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mart0964.18.third party stip PO.knn.docx

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City of Stockton. The manual and criminal history information, however, shall

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not be disclosed to Plaintiff;

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B.

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informatin, or any portion thereof to any person other than those listed in

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Paragraph (A), that party shall give written notice by mail and email to counsel

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for the California Department of Justice so that the Department can make a

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motion to prevent the disclosure. The notice shall inform the Department to

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If any party wishes to disclose the WPS manual, criminal history

whom disclosure is requested and the purpose thereof. The party wishing to
disclose the information will not to do so unless and until agreement with the
Department is reached, or the Department’s motion is ruled on by the court. If
however, the Department, does not file its motion within two weeks of the
notice, the party wishing to disclose the information may deem the issue to
have been abandoned.

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DATED: August 8, 2018

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DONALD W. COOK.
Attorney at Law
3435 Wilshire Blvd., Ste. 2910
Los Angeles, CA 90010
([phone]

Protective Order Re Production Pursuant to Subpoena
Case No. 2:18-cv-00964-TLN-AC

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mart0964.18.third party stip PO.knn.docx