Samuel Nelson v. County of Los Angeles

• Court: District Court, C.D. California
• Decided: September 14, 2022
• Docket: 2:22-cv-00832
• Status: Unknown

Opinion

Case 2:22-cv-00832-DMG-MAA Document 27 Filed 09/14/22 Page 1 of 19 Page ID #:166

1 THE SEHAT LAW FIRM, PLC Cameron Sehat, Esq. (SBN 256535) 2 5100 Campus Dr., Ste. 200 Newport, CA 92660 3 Telephone: (949) 825-5200 4 Facsimile: (949) 313-5001 Email: cameron@sehatlaw.com 5 Attorneys for Plaintiff, Samuel Nelson 6

7 UNITED STATES DISTRICT COURT

8 CENTRAL DISTRICT OF CALIFORNIA

Case No. 2:22-CV-00832-DMG-MAA 10 SAMUEL NELSON, Individually

11 Plaintiff, STIPULATED PROTECTIVE ORDER 12 v.

13 COUNTY OF LOS ANGELES, a 14 governmental entity; DOE 1,

individually, and DOES 2 through 10,

15 Defendants. 16 17 I. PURPOSES AND LIMITATIONS 18 A. Discovery in this action is likely to involve production of confidential, 19 proprietary, or private information for which special protection from public 20 disclosure and from use for any purpose other than prosecuting this litigation 21 may be warranted. Accordingly, the parties hereby stipulate to and petition the 22 Court to enter the following Stipulated Protective Order. The parties 23 acknowledge that this Order does not confer blanket protections on all 24 disclosures or responses to discovery and that the protection it affords from

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1 public disclosure and use extends only to the limited information or items that 2 are entitled to confidential treatment under the applicable legal principles. The 3 parties further acknowledge, as set forth in Section XIII(C), below, that this 4 Stipulated Protective Order does not entitle them to file confidential information 5 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed 6 and the standards that will be applied when a party seeks permission from the

7 Court to file material under seal. 8 II. GOOD CAUSE STATEMENT 9 A. Plaintiffs are seeking materials and information that Respondent County 10 of Los Angeles maintains as confidential, such as personnel files of the sheriff 11 deputies involved in this incident, officer-involved shooting investigation 12 materials and information, Internal Affairs materials and information, video 13 recordings, and other administrative materials and information currently in the 14 possession of the COUNTY and which COUNTY maintains as strictly 15 confidential and which the COUNTY believes need special protection from 16 public disclosure and from use for any purpose other than prosecuting this 17 litigation.

18 B. COUNTY maintains that this action is likely to involve confidential 19 information contained in personnel files, police reports and investigatory files. 20 Such confidential and proprietary materials and information consist of, among 21 other things: police officer personnel records, as codified at California Penal 22 Code section 832.7 (see Kerr v. United States Dist. Ct. for N.D. Cal., 511 F.2d 192, 23 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976); police investigative reports and 24 attorney work product protected under the Official Information Privilege,

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1 California Evidence Code sections 1040 (Official Government Information); 2 Deliberative Process information protected under ACLU v. Superior Court, 202 3 Cal.App.4th 55, 75 (2011) (quoting Regents of University of California v. 4 Superior Court, 20 Cal.4th 509, 540 (1999)); Work Product information 5 protected under California Penal Code Sections 1054.6; State Summary Criminal 6 History Information protected under California Penal Code Sections 11105,

7 11120 et. seq., 11142, 1143, 13302, 13304 and 1203.05 [State Summary Criminal 8 History Information statements ("rap sheets") received by the County from the 9 California State Department of Justice are objected to as constituting a request 10 for the production of Official Information, and as imposing undue burden, 11 annoyance, oppression and expense, by way of potential misdemeanor liability 12 on the County]; and Confidential Witness Information protected under 13 California Penal Code section 841.5 which prevents disclosure of the addresses 14 and telephone numbers of witnesses to an alleged criminal offense to the person 15 who may be a defendant in any prosecution for that offense; all of the foregoing 16 types of information otherwise generally unavailable to the public, or which may 17 be privileged or otherwise protected from disclosure under state or federal

18 statutes, court rules, case decisions, or common law. 19 C. Accordingly, to expedite the flow of information, to facilitate the prompt 20 resolution of disputes over confidentiality of discovery materials, to adequately 21 protect information the parties are entitled to keep confidential, to ensure that 22 the parties are permitted reasonable necessary uses of such material in 23 preparation for and in the conduct of trial, to address their handling at the end 24 of the litigation, and serve the ends of justice, a protective order for such

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1 information is justified in this matter. It is the intent of the parties that 2 information will not be designated as confidential for tactical reasons and that 3 nothing be so designated without a good faith belief that it has been maintained 4 in a confidential, non-public manner, and there is good cause why it should not 5 be part of the public record of this case. 6 III. DEFINITIONS

7 A. Action: This pending federal lawsuit. 8 B. Challenging Party: A Party or Non-Party that challenges the designation 9 of information or items under this Order. 10 C. “CONFIDENTIAL” Information or Items: Information (regardless of how 11 it is generated, stored or maintained) or tangible things that qualify for 12 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 13 the Good Cause Statement. 14 D. Counsel: Outside Counsel of Record and House Counsel (as well as their 15 support staff). 16 E. Designating Party: A Party or Non-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as

18 “CONFIDENTIAL.” 19 F. Disclosure or Discovery Material: All items or information, regardless of 20 the medium or manner in which it is generated, stored, or maintained 21 (including, among other things, testimony, transcripts, and tangible things), that 22 are produced or generated in disclosures or responses to discovery in this 23 matter. 24

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1 G. Expert: A person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to 3 serve as an expert witness or as a consultant in this Action. 4 H. House Counsel: Attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel.

7 I. Non-Party: Any natural person, partnership, corporation, association, or 8 other legal entity not named as a Party to this action. 9 J. Outside Counsel of Record: Attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and 11 have appeared in this Action on behalf of that party or are affiliated with a law 12 firm which has appeared on behalf of that party, and includes support staff. 13 K. Party: Any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and 15 their support staffs). 16 L. Producing Party: A Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action.

18 M. Professional Vendors: Persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or 21 medium) and their employees and subcontractors. 22 N. Protected Material: Any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24

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1 O. Receiving Party: A Party that receives Disclosure or Discovery Material 2 from a Producing Party. 3 IV. SCOPE 4 A. The protections conferred by this Stipulation and Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or 6 extracted from Protected Material; (2) all copies, excerpts, summaries, or

7 compilations of Protected Material; and (3) any testimony, conversations, or 8 presentations by Parties or their Counsel that might reveal Protected Material. 9 B. Any use of Protected Material at trial shall be governed by the orders of 10 the trial judge. This Order does not govern the use of Protected Material at trial. 11 V. DURATION 12 A. Once a case proceeds to trial, all of the information that was designated as 13 confidential or maintained pursuant to this Protective Order becomes public and 14 will be presumptively available to all members of the public, including the press, 15 unless compelling reasons supported by specific factual findings to proceed 16 otherwise are made to the trial judge in advance of the trial. See Kamakana v. 17 City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006)

18 (distinguishing “good cause” showing for sealing documents produced in 19 discovery from “compelling reasons” standard when merits-related documents 20 are part of court record). Accordingly, the terms of this Protective Order do not 21 extend beyond the commencement of the trial. 22 VI. DESIGNATING PROTECTED MATERIAL 23 A. Exercise of Restraint and Care in Designating Material for Protection 24

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1 1. Each Party or Non-Party that designates information or items for 2 protection under this Order must take care to limit any such designation 3 to specific material that qualifies under the appropriate standards. The 4 Designating Party must designate for protection only those parts of 5 material, documents, items, or oral or written communications that 6 qualify so that other portions of the material, documents, items, or

7 communications for which protection is not warranted are not swept 8 unjustifiably within the ambit of this Order. 9 2. Mass, indiscriminate, or routinized designations are prohibited. 10 Designations that are shown to be clearly unjustified or that have been 11 made for an improper purpose (e.g., to unnecessarily encumber the case 12 development process or to impose unnecessary expenses and burdens on 13 other parties) may expose the Designating Party to sanctions. 14 3. If it comes to a Designating Party’s attention that information or 15 items that it designated for protection do not qualify for protection, that 16 Designating Party must promptly notify all other Parties that it is 17 withdrawing the inapplicable designation.

18 B. Manner and Timing of Designations 19 1. Except as otherwise provided in this Order (see, e.g., Section 20 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or 21 Discovery Material that qualifies for protection under this Order must be 22 clearly so designated before the material is disclosed or produced. 23 2. Designation in conformity with this Order requires the following: 24

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1 a. For information in documentary form (e.g., paper or 2 electronic documents, but excluding transcripts of depositions or 3 other pretrial or trial proceedings), that the Producing Party affix 4 at a minimum, the legend “CONFIDENTIAL” (hereinafter 5 “CONFIDENTIAL legend”), to each page that contains protected 6 material. If only a portion or portions of the material on a page

7 qualifies for protection, the Producing Party also must clearly 8 identify the protected portion(s) (e.g., by making appropriate 9 markings in the margins). 10 b. A Party or Non-Party that makes original documents 11 available for inspection need not designate them for protection 12 until after the inspecting Party has indicated which documents it 13 would like copied and produced. During the inspection and before 14 the designation, all of the material made available for inspection 15 shall be deemed “CONFIDENTIAL.” After the inspecting Party has 16 identified the documents it wants copied and produced, the 17 Producing Party must determine which documents, or portions

18 thereof, qualify for protection under this Order. Then, before 19 producing the specified documents, the Producing Party must affix 20 the “CONFIDENTIAL legend” to each page that contains Protected 21 Material. If only a portion or portions of the material on a page 22 qualifies for protection, the Producing Party also must clearly 23 identify the protected portion(s) (e.g., by making appropriate 24 markings in the margins).

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1 c. For testimony given in depositions, that the Designating 2 Party identify the Disclosure or Discovery Material on the record, 3 before the close of the deposition all protected testimony. 4 d. For information produced in form other than document and 5 for any other tangible items, that the Producing Party affix in a 6 prominent place on the exterior of the container or containers in

7 which the information is stored the legend “CONFIDENTIAL.” If 8 only a portion or portions of the information warrants protection, 9 the Producing Party, to the extent practicable, shall identify the 10 protected portion(s). 11 C. Inadvertent Failure to Designate 12 1. If timely corrected, an inadvertent failure to designate qualified 13 information or items does not, standing alone, waive the Designating 14 Party’s right to secure protection under this Order for such material. 15 Upon timely correction of a designation, the Receiving Party must make 16 reasonable efforts to assure that the material is treated in accordance with 17 the provisions of this Order.

18 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 19 A. Timing of Challenges 20 1. Any party or Non-Party may challenge a designation of 21 confidentiality at any time that is consistent with the Court’s Scheduling 22 Order. 23 B. Meet and Confer 24

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1 1. The Challenging Party shall initiate the dispute resolution process 2 under Local Rule 37.1 et seq. 3 C. The burden of persuasion in any such challenge proceeding shall be on 4 the Designating Party. Frivolous challenges, and those made for an improper 5 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 6 parties) may expose the Challenging Party to sanctions. Unless the Designating

7 Party has waived or withdrawn the confidentiality designation, all parties shall 8 continue to afford the material in question the level of protection to which it is 9 entitled under the Producing Party’s designation until the Court rules on the 10 challenge. 11 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL 12 A. Basic Principles 13 1. A Receiving Party may use Protected Material that is disclosed or 14 produced by another Party or by a Non-Party in connection with this 15 Action only for prosecuting, defending, or attempting to settle this Action. 16 Such Protected Material may be disclosed only to the categories of 17 persons and under the conditions described in this Order. When the

18 Action has been terminated, a Receiving Party must comply with the 19 provisions of Section XIV below. 20 2. Protected Material must be stored and maintained by a Receiving 21 Party at a location and in a secure manner that ensures that access is 22 limited to the persons authorized under this Order. 23 B. Disclosure of “CONFIDENTIAL” Information or Items 24

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1 1. Unless otherwise ordered by the Court or permitted in writing by 2 the Designating Party, a Receiving Party may disclose any information or 3 item designated “CONFIDENTIAL” only to: 4 a. The Receiving Party’s Outside Counsel of Record in this 5 Action, as well as employees of said Outside Counsel of Record to 6 whom it is reasonably necessary to disclose the information for this

7 Action; 8 b. The officers, directors, and employees (including House 9 Counsel) of the Receiving Party to whom disclosure is reasonably 10 necessary for this Action; 11 c. Experts (as defined in this Order) of the Receiving Party to 12 whom disclosure is reasonably necessary for this Action and who 13 have signed the “Acknowledgment and Agreement to Be Bound” 14 (Exhibit A); 15 d. The Court and its personnel; 16 e. Court reporters and their staff; 17 f. Professional jury or trial consultants, mock jurors, and

18 Professional Vendors to whom disclosure is reasonably necessary 19 or this Action and who have signed the “Acknowledgment and 20 Agreement to be Bound” attached as Exhibit A hereto; 21 g. The author or recipient of a document containing the 22 information or a custodian or other person who otherwise 23 possessed or knew the information; 24

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1 h. During their depositions, witnesses, and attorneys for 2 witnesses, in the Action to whom disclosure is reasonably 3 necessary provided: (i) the deposing party requests that the 4 witness sign the “Acknowledgment and Agreement to Be Bound;” 5 and (ii) they will not be permitted to keep any confidential 6 information unless they sign the “Acknowledgment and Agreement

7 to Be Bound,” unless otherwise agreed by the Designating Party or 8 ordered by the Court. Pages of transcribed deposition testimony or 9 exhibits to depositions that reveal Protected Material may be 10 separately bound by the court reporter and may not be disclosed to 11 anyone except as permitted under this Stipulated Protective Order; 12 and 13 i. Any mediator or settlement officer, and their supporting 14 personnel, mutually agreed upon by any of the parties engaged in 15 settlement discussions. 16 IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 17 IN OTHER LITIGATION

18 A. If a Party is served with a subpoena or a court order issued in other 19 litigation that compels disclosure of any information or items designated in this 20 Action as “CONFIDENTIAL,” that Party must: 21 1. Promptly notify in writing the Designating Party. Such notification 22 shall include a copy of the subpoena or court order; 23 2. Promptly notify in writing the party who caused the subpoena or 24 order to issue in the other litigation that some or all of the material

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1 covered by the subpoena or order is subject to this Protective Order. Such 2 notification shall include a copy of this Stipulated Protective Order; and 3 3. Cooperate with respect to all reasonable procedures sought to be 4 pursued by the Designating Party whose Protected Material may be 5 affected. 6 B. If the Designating Party timely seeks a protective order, the Party served

7 with the subpoena or court order shall not produce any information designated 8 in this action as “CONFIDENTIAL” before a determination by the Court from 9 which the subpoena or order issued, unless the Party has obtained the 10 Designating Party’s permission. The Designating Party shall bear the burden 11 and expense of seeking protection in that court of its confidential material and 12 nothing in these provisions should be construed as authorizing or encouraging a 13 Receiving Party in this Action to disobey a lawful directive from another court. 14 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 15 PRODUCED IN THIS LITIGATION 16 A. The terms of this Order are applicable to information produced by a Non- 17 Party in this Action and designated as “CONFIDENTIAL.” Such information

18 produced by Non-Parties in connection with this litigation is protected by the 19 remedies and relief provided by this Order. Nothing in these provisions should 20 be construed as prohibiting a Non-Party from seeking additional protections. 21 B. In the event that a Party is required, by a valid discovery request, to 22 produce a Non-Party’s confidential information in its possession, and the Party 23 is subject to an agreement with the Non-Party not to produce the Non-Party’s 24 confidential information, then the Party shall:

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1 1. Promptly notify in writing the Requesting Party and the Non-Party 2 that some or all of the information requested is subject to a 3 confidentiality agreement with a Non-Party; 4 2. Promptly provide the Non-Party with a copy of the Stipulated 5 Protective Order in this Action, the relevant discovery request(s), and a 6 reasonably specific description of the information requested; and

7 3. Make the information requested available for inspection by the 8 Non-Party, if requested. 9 C. If the Non-Party fails to seek a protective order from this court within 14 10 days of receiving the notice and accompanying information, the Receiving Party 11 may produce the Non-Party’s confidential information responsive to the 12 discovery request. If the Non-Party timely seeks a protective order, the 13 Receiving Party shall not produce any information in its possession or control 14 that is subject to the confidentiality agreement with the Non-Party before a 15 determination by the court. Absent a court order to the contrary, the Non-Party 16 shall bear the burden and expense of seeking protection in this court of its 17 Protected Material.

18 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 19 A. If a Receiving Party learns that, by inadvertence or otherwise, it has 20 disclosed Protected Material to any person or in any circumstance not 21 authorized under this Stipulated Protective Order, the Receiving Party must 22 immediately (1) notify in writing the Designating Party of the unauthorized 23 disclosures, (2) use its best efforts to retrieve all unauthorized copies of the 24 Protected Material, (3) inform the person or persons to whom unauthorized

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1 disclosures were made of all the terms of this Order, and (4) request such person 2 or persons to execute the “Acknowledgment and Agreement to be Bound” that is 3 attached hereto as Exhibit A. 4 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5 PROTECTED MATERIAL 6 A. When a Producing Party gives notice to Receiving Parties that certain

7 inadvertently produced material is subject to a claim of privilege or other 8 protection, the obligations of the Receiving Parties are those set forth in Federal 9 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 10 whatever procedure may be established in an e-discovery order that provides for 11 production without prior privilege review. Pursuant to Federal Rule of Evidence 12 502(d) and (e), insofar as the parties reach an agreement on the effect of 13 disclosure of a communication or information covered by the attorney-client 14 privilege or work product protection, the parties may incorporate their 15 agreement in the Stipulated Protective Order submitted to the Court. 16 XIII. MISCELLANEOUS 17 A. Right to Further Relief

18 1. Nothing in this Order abridges the right of any person to seek its 19 modification by the Court in the future. 20 B. Right to Assert Other Objections 21 1. By stipulating to the entry of this Protective Order, no Party waives 22 any right it otherwise would have to object to disclosing or producing any 23 information or item on any ground not addressed in this Stipulated 24 Protective Order. Similarly, no Party waives any right to object on any

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1 ground to use in evidence of any of the material covered by this Protective 2 Order. 3 C. Filing Protected Material 4 1. A Party that seeks to file under seal any Protected Material must 5 comply with Civil Local Rule 79-5. Protected Material may only be filed 6 under seal pursuant to a court order authorizing the sealing of the specific

7 Protected Material at issue. If a Party's request to file Protected Material 8 under seal is denied by the Court, then the Receiving Party may file the 9 information in the public record unless otherwise instructed by the Court. 10 11 12 XIV. FINAL DISPOSITION 13 A. After the final disposition of this Action, as defined in Section V, within 14 sixty (60) days of a written request by the Designating Party, each Receiving 15 Party must return all Protected Material to the Producing Party or destroy such 16 material. As used in this subdivision, “all Protected Material” includes all copies, 17 abstracts, compilations, summaries, and any other format reproducing or

18 capturing any of the Protected Material. Whether the Protected Material is 19 returned or destroyed, the Receiving Party must submit a written certification to 20 the Producing Party (and, if not the same person or entity, to the Designating 21 Party) by the 60 day deadline that (1) identifies (by category, where appropriate) 22 all the Protected Material that was returned or destroyed and (2) affirms that the 23 Receiving Party has not retained any copies, abstracts, compilations, summaries 24 or any other format reproducing or capturing any of the Protected Material.

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1 Notwithstanding this provision, Counsel are entitled to retain an archival copy of 2 all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 3 memoranda, correspondence, deposition and trial exhibits, expert reports, 4 attorney work product, and consultant and expert work product, even if such 5 materials contain Protected Material. Any such archival copies that contain or 6 constitute Protected Material remain subject to this Protective Order as set forth

7 in Section V. 8 B. Any violation of this Order may be punished by any and all appropriate 9 measures including, without limitation, contempt proceedings and/or monetary 10 sanctions. 11 12 13 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 14 Dated: 09/08/2022 /s/ Cameron Sehat 15 Attorney for Plaintiff(s) 16 Dated: 09/08/2022 /s/ James Jardin 17 Attorney for Defendant(s) 18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 September 14, 2022 20 Dated: HONORABLE MARIA A. AUDERO 21 United States Magistrate Judge 22 23 24 17 Case 2:22-cv-00832-DMG-MAA Document 27 Filed 09/14/22 Page 18 of 19 Page ID #:183

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, , of , declare under 4 penalty of perjury that I have read in its entirety and understand the Stipulated 5 Protective Order that was issue by the United States District Court for the Central 6 District of California on [DATE] in the case of . I 7 agree to comply with and to be bound by all the terms of this Stipulated Protective 8 Order and I understand and acknowledge that failure to so comply could expose me to 9 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 10 disclose in any manner any information or item that is subject to this Stipulated 11 Protective Order to any person or entity except in strict compliance with the provisions 12 of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court 14 for the Central District of California for the purpose of enforcing the terms of this 15 Stipulated Protective Order, even if such enforcement proceedings occur after 16 termination of this action. I hereby appoint [print or 17 type full name] of [print or type full address and 18 telephone number] as my California agent for service of process in connection with this 19 action or any proceedings related to enforcement of this Stipulated Protective Order. 20 21 Date: 22 City and State where sworn and signed: 23 Printed Name: 24 Signature:

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