# Murad Clark v. City of Los Angeles

> District Court, C.D. California · February 9, 2021

URL: https://www.frixlaw.com/law-library/cases/10040173

## Case

- **Court:** District Court, C.D. California
- **Decided:** February 9, 2021
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 || Murad Clark
2355 Westwood Blvd.
2 || Los Angeles, CA 90064
Telephone: (323) 907-5475
3 || E-mail: murade ark(@email.com
4 Plaintiff & Plaintiffin Pro Se
MICHAEL N. FEUER, City Attorney - SBN 111529
5 || KATHLEEN A. KENEALY, Chief De uty City Attorney — SBN 212289
SCOTT MARCUS, Senior Assistant City ttorney - SBN 184980
6 || CORY M. BRENTE. Senior Assistant City Attorney — SBN 115453
NICHOLAS LAUBER, Deputy City Attorney — SBN 288499
7 || 200 North Main Street, 6th Floor, City Hall East
Los Angeles, CA 90012
8 || Phone No. 13) 978-7025
Fax No.: (213) 978-8785
9 || Email: Nicholas.Lauber@lacity.org
10 ditorneys for Defendants, CITY OF LOS ANGELES, MOISES
COV UBIAS, JOSE ZAVALA, and CHRISTOPHER BURKE
UNITED STATES DISTRICT COURT
12
CENTRAL DISTRICT OF CALIFORNIA
13
14
Case No. CV20-10768-CAS-PVC
15 MURAD CLARK, Hon. Christina A. Snyder
16 Plaintiff, Hon. Pedro V. Castillo
17 Vv.
18
STIPULATED PROTECTIVE
19 CITY OF LOS ANGELES ET AL ORDER
20 Defendants. (PVC VERSION 4/20)
21 Check if submitted without
material modifications to PVC form
23
24 | 1. INTRODUCTION
25 1.1 PURPOSES AND LIMITATIONS
26 Discovery in this action is likely to involve production of confidential,
27 || proprietary, or private information for which special protection from public
28 || disclosure and from use for any purpose other than prosecuting this litigation may

1 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
2 || enter the following Stipulated Protective Order. The parties acknowledge that this
3 || Order does not confer blanket protections on all disclosures or responses to
4 || discovery and that the protection it affords from public disclosure and use extends
5 || only to the limited information or items that are entitled to confidential treatment
6 || under the applicable legal principles. The parties further acknowledge, as set forth
7 || in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
8 || file confidential information under seal; Civil Local Rule 79-5 sets forth the
9 || procedures that must be followed and the standards that will be applied when a party
10 || seeks permission from the court to file material under seal.
1.2 GOOD CAUSE STATEMENT
12 This action involves the City of Los Angeles and Los Angeles Police
13 || Department officers. Plaintiff 1s seeking materials and information that Defendants
14 || the City of Los Angeles (“the City”) and Los Angeles Police Department officers
15 || (collectively “Defendants”) maintain as confidential, such as personnel files of the
16 || police officers involved in this incident, Internal Affairs materials and information,
17 || and other administrative materials and information currently in the possession of the
18 || City and which Defendants believe need special protection from public disclosure
19 || and from use for any purpose other than prosecuting this litigation. Plaintiff is also
20 || seeking official information contained in the personnel files of the police officers
21 || involved in the subject incident, which the City maintains as strictly confidential and
22 || which Defendants believe need special protection from public disclosure and from
23 || use for any purpose other than prosecuting this litigation. Specifically Plaintiff is
24 || seeking police body worn video from the incident date, police internal affairs
25 || investigation materials, and police administrative materials, and which Defendants
26 || believe need special protection from public disclosure and from use for any purpose
27 || other than prosecuting this litigation.
28

1 Defendants assert that the confidentiality of the materials and
2 || information sought by Plaintiff is recognized by California and federal law, as
3 || evidenced inter alia by California Penal Code section 832.7 and Kerr v. United
4 || States Dist. Ct. for N.D. Cal., 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394
5 || (1976). The City has not publicly released the materials and information referenced
6 || above except under protective order or pursuant to a court order, if at all. These
7 || materials and information are of the type that has been used to initiate disciplinary
8 || action against Los Angeles Police Department officers, and has been used as
9 || evidence in disciplinary proceedings, where the officers’ conduct was considered to
10 || be contrary to LAPD policy.
11 The City contends that absent a protective order delineating the
12 || responsibilities of nondisclosure on the part of the parties hereto, there is a specific
13 || risk of unnecessary and undue disclosure by one or more of the many attorneys,
14 || secretaries, law clerks, paralegals and expert witnesses involved in this case, as well
15 || as the corollary risk of embarrassment, harassment and professional and legal harm
16 || on the part of the LAPD officers referenced in the materials and information.
17 The City also contends that the unfettered disclosure of the materials
18 || and information, absent a protective order, would allow the media to share this
19 || information with potential jurors in the area, impacting the rights of the City herein
20 || to receive a fair trial.
21 Accordingly, to expedite the flow of information, to facilitate the
22 || prompt resolution of disputes over confidentiality of discovery materials, to
23 || adequately protect information the parties are entitled to keep confidential, to ensure
24 || that the parties are permitted reasonable necessary uses of such material in
25 || preparation for and in the conduct of trial, to address their handling at the end of the
26 || litigation, and serve the ends of justice, a protective order for such information is
27 || justified in this matter. It is the intent of the parties that information will not be
28 || designated as confidential for tactical reasons and that nothing be so designated

1 || without a good faith belief that it has been maintained in a confidential, non-public
2 || manner, and there is good cause why it should not be part of the public record of this
3 || case.
4 || 2. DEFINITIONS
5 2.1 Action: Murad Clark v. City of Los Angeles et al; Case No. CV20-
6 || 10768-CAS-PVC
7 2.2 Challenging Party: a Party or Non-Party that challenges the
8 || designation of information or items under this Order.
9 2.3. “CONFIDENTIAL” Information or Items: information (regardless of
10 || how it is generated, stored or maintained) or tangible things that qualify for
11 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in
12 || the Good Cause Statement.
13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
14 || their support staff).
15 2.5 Designating Party: a Party or Non-Party that designates information or
16 || items that 1t produces in disclosures or in responses to discovery as
17 || “CONFIDENTIAL.”
18 2.6 Disclosure or Discovery Material: all items or information, regardless
19 || of the medium or manner in which it is generated, stored, or maintained (including,
20 || among other things, testimony, transcripts, and tangible things), that are produced or
21 || generated in disclosures or responses to discovery in this matter.
22 2.7. Expert: a person with specialized knowledge or experience in a matter
23 || pertinent to the litigation who has been retained by a Party or its counsel to serve as
24 || an expert witness or as a consultant in this Action.
25 2.8 House Counsel: attorneys who are employees of a party to this Action.
26 || House Counsel does not include Outside Counsel of Record or any other outside
27 || counsel.
28

1 2.9 Non-Party: any natural person, partnership, corporation, association, or
2 || other legal entity not named as a Party to this action.
3 2.10 Outside Counsel of Record: attorneys who are not employees of a
4 || party to this Action but are retained to represent or advise a party to this Action and
5 || have appeared in this Action on behalf of that party or are affiliated with a law firm
6 || which has appeared on behalf of that party, and includes support staff.
7 2.11 Party: any party to this Action, including all of its officers, directors,
8 || employees, consultants, retained experts, and Outside Counsel of Record (and their
9 || support staffs).
10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
11 || Discovery Material in this Action.
12 2.13 Professional Vendors: persons or entities that provide litigation
13 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or
14 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
15 || and their employees and subcontractors.
16 2.14 Protected Material: any Disclosure or Discovery Material that is
17 || designated as “CONFIDENTIAL.”
18 2.15 Receiving Party: a Party that receives Disclosure or Discovery
19 || Material from a Producing Party.
20
21 || 3. SCOPE
22 The protections conferred by this Stipulation and Order cover not only
23 || Protected Material (as defined above), but also (1) any information copied or
24 || extracted from Protected Material; (2) all copies, excerpts, summaries, or
25 || compilations of Protected Material; and (3) any testimony, conversations, or
26 || presentations by Parties or their Counsel that might reveal Protected Material.
27 Any use of Protected Material at trial will be governed by the orders of the
28 || trial judge. This Order does not govern the use of Protected Material at trial.

1
2 || 4. DURATION
3 Even after final disposition of this litigation, the confidentiality obligations
4 || imposed by this Order will remain in effect until a Designating Party agrees
5 || otherwise in writing or a court order otherwise directs. Final disposition will be
6 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
7 || or without prejudice; and (2) final judgment herein after the completion and
8 || exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
9 || including the time limits for filing any motions or applications for extension of time
10 || pursuant to applicable law.
11
12 || 5. DESIGNATING PROTECTED MATERIAL
13 5.1 Exercise of Restraint and Care in Designating Material for Protection.
14 || Each Party or Non-Party that designates information or items for protection under
15 || this Order must take care to limit any such designation to specific material that
16 || qualifies under the appropriate standards. The Designating Party must designate for
17 || protection only those parts of material, documents, items, or oral or written
18 || communications that qualify so that other portions of the material, documents,
19 || 1tems, or communications for which protection 1s not warranted are not swept
20 || unjustifiably within the ambit of this Order.
21 Mass, indiscriminate, or routinized designations are prohibited. Designations
22 || that are shown to be clearly unjustified or that have been made for an improper
23 || purpose (e.g., to unnecessarily encumber the case development process or to impose
24 || unnecessary expenses and burdens on other parties) may expose the Designating
25 || Party to sanctions.
26 If it comes to a Designating Party’s attention that information or items that it
27 || designated for protection do not qualify for protection, that Designating Party must
28 || promptly notify all other Parties that it is withdrawing the inapplicable designation.

1 5.2. Manner and Timing of Designations. Except as otherwise provided in
2 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
3 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
4 |} under this Order must be clearly so designated before the material is disclosed or
5 || produced.
6 Designation in conformity with this Order requires:
7 (a) for information in documentary form (e.g., paper or electronic documents,
8 || but excluding transcripts of depositions or other pretrial or trial proceedings), that
9 || the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
10 || “CONFIDENTIAL legend”), to each page that contains protected material. If only a
11 || portion or portions of the material on a page qualifies for protection, the Producing
12 || Party also must clearly identify the protected portion(s) (e.g., by making appropriate
13 || markings in the margins).
14 A Party or Non-Party that makes original documents available for
15 || inspection need not designate them for protection until after the inspecting Party has
16 || indicated which documents it would like copied and produced. During the
17 || inspection and before the designation, all of the material made available for
18 || inspection will be deemed “CONFIDENTIAL.” After the inspecting Party has
19 || identified the documents it wants copied and produced, the Producing Party must
20 || determine which documents, or portions thereof, qualify for protection under this
21 || Order. Then, before producing the specified documents, the Producing Party must
22 || affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
23 || If only a portion or portions of the material on a page qualifies for protection, the
24 || Producing Party also must clearly identify the protected portion(s) (e.g., by making
25 || appropriate markings in the margins).
26 (b) for testimony given in depositions that the Designating Party identify the
27 || Disclosure or Discovery Material on the record, before the close of the deposition all
28 || protected testimony.

1 (c) for information produced in some form other than documentary and for
2 || any other tangible items, that the Producing Party affix in a prominent place on the
3 || exterior of the container or containers in which the information 1s stored the legend
4 || “CONFIDENTIAL.” If only a portion or portions of the information warrants
5 || protection, the Producing Party, to the extent practicable, will identify the protected
6 || portion(s).
7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
8 || failure to designate qualified information or items does not, standing alone, waive
9 || the Designating Party’s right to secure protection under this Order for such material.
10 || Upon timely correction of a designation, the Receiving Party must make reasonable
11 || efforts to assure that the material is treated in accordance with the provisions of this
12 || Order.
13
14 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
15 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
16 || designation of confidentiality at any time that is consistent with the Court’s
17 || Scheduling Order.
18 6.2 Meet and Confer. The Challenging Party will initiate the dispute
19 || resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1
20 || et seq.
21 6.3. The burden of persuasion in any such challenge proceeding will be on
22 || the Designating Party. Frivolous challenges, and those made for an improper
23 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other
24 || parties) may expose the Challenging Party to sanctions. Unless the Designating
25 || Party has waived or withdrawn the confidentiality designation, all parties will
26 || continue to afford the material in question the level of protection to which it is
27 || entitled under the Producing Party’s designation until the Court rules on the
28 || challenge.

1
2 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL
3 7.1 Basic Principles. A Receiving Party may use Protected Material that is
4 || disclosed or produced by another Party or by a Non-Party in connection with this
5 || Action only for prosecuting, defending, or attempting to settle this Action. Such
6 || Protected Material may be disclosed only to the categories of persons and under the
7 || conditions described in this Order. When the Action has been terminated, a
8 || Receiving Party must comply with the provisions of section 13 below (FINAL
9 || DISPOSITION).
10 Protected Material must be stored and maintained by a Receiving Party ata
11 || location and in a secure manner that ensures that access is limited to the persons
12 || authorized under this Order.
13 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless
14 || otherwise ordered by the court or permitted in writing by the Designating Party, a
15 || Receiving Party may disclose any information or item designated
16 || “CONFIDENTIAL” only to:
17 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
18 || well as employees of said Outside Counsel of Record to whom it is reasonably
19 || necessary to disclose the information for this Action;
20 (b) the officers, directors, and employees (including House Counsel) of
21 || the Receiving Party to whom disclosure is reasonably necessary for this Action;
22 (c) Experts (as defined in this Order) of the Receiving Party to whom
23 || disclosure is reasonably necessary for this Action and who have signed the
24 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (d) the Court and its personnel;
26 (e) court reporters and their staff;
27
28

1 (f) professional jury or trial consultants, mock jurors, and Professional
2 || Vendors to whom disclosure is reasonably necessary for this Action and who have
3 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (g) the author or recipient of a document containing the information ora
5 || custodian or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses ,and attorneys for witnesses, in the
7 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party
8 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they
9 || will not be permitted to keep any confidential information unless they sign the
10 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
11 || agreed by the Designating Party or ordered by the court. Pages of transcribed
12 || deposition testimony or exhibits to depositions that reveal Protected Material may
13 || be separately bound by the court reporter and may not be disclosed to anyone except
14 || as permitted under this Stipulated Protective Order; and
15 (i) any mediator or settlement officer, and their supporting personnel,
16 || mutually agreed upon by any of the parties engaged in settlement discussions.
17
18 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
19 || INOTHER LITIGATION
20 If a Party is served with a subpoena or a court order issued in other litigation
21 || that compels disclosure of any information or items designated in this Action as
22 || “CONFIDENTIAL,” that Party must:
23 (a) promptly notify in writing the Designating Party. Such notification
24 || will include a copy of the subpoena or court order;
25 (b) promptly notify in writing the party who caused the subpoena or order
26 || to issue in the other litigation that some or all of the material covered by the
27 || subpoena or order is subject to this Protective Order. Such notification will include
28 || acopy of this Stipulated Protective Order; and

1 (c) cooperate with respect to all reasonable procedures sought to be
2 || pursued by the Designating Party whose Protected Material may be affected.
3 If the Designating Party timely seeks a protective order, the Party served with
4 || the subpoena or court order will not produce any information designated in this
5 || action as “CONFIDENTIAL” before a determination by the court from which the
6 || subpoena or order issued, unless the Party has obtained the Designating Party’s
7 || permission. The Designating Party will bear the burden and expense of seeking
8 || protection in that court of its confidential material and nothing in these provisions
9 || should be construed as authorizing or encouraging a Receiving Party in this Action
10 || to disobey a lawful directive from another court.
11
12 || 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
13 || PRODUCED IN THIS LITIGATION
14 (a) The terms of this Order are applicable to information produced by a
15 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
16 || produced by Non-Parties in connection with this litigation is protected by the
17 || remedies and relief provided by this Order. Nothing in these provisions should be
18 || construed as prohibiting a Non-Party from seeking additional protections.
19 (b) In the event that a Party is required, by a valid discovery request, to
20 || produce a Non-Party’s confidential information in its possession, and the Party is
21 || subject to an agreement with the Non-Party not to produce the Non-Party’s
22 || confidential information, then the Party will:
23 (1) promptly notify in writing the Requesting Party and the Non-Party
24 || that some or all of the information requested is subject to a confidentiality
25 || agreement with a Non-Party;
26 (2) promptly provide the Non-Party with a copy of the Stipulated
27 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
28 || specific description of the information requested; and

1 (3) make the information requested available for inspection by the
2 || Non-Party, if requested.
3 (c) If the Non-Party fails to seek a protective order from this court within
4 || 14 days of receiving the notice and accompanying information, the Receiving Party
5 || may produce the Non-Party’s confidential information responsive to the discovery
6 || request. If the Non-Party timely seeks a protective order, the Receiving Party will
7 || not produce any information in its possession or control that is subject to the
8 || confidentiality agreement with the Non-Party before a determination by the court.
9 || Absent a court order to the contrary, the Non-Party will bear the burden and expense
10 || of seeking protection in this court of its Protected Material.
11
12 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
14 || Protected Material to any person or in any circumstance not authorized under this
15 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in
16 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
17 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
18 || persons to whom unauthorized disclosures were made of all the terms of this Order,
19 || and (d) request such person or persons to execute the “Acknowledgment and
20 || Agreement to Be Bound” that is attached hereto as Exhibit A.
21
22 |} ll. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
23 || PROTECTED MATERIAL
24 When a Producing Party gives notice to Receiving Parties that certain
25 || inadvertently produced material is subject to a claim of privilege or other protection,
26 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
27 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever
28 || procedure may be established in an e-discovery order that provides for production

1 || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
2 || (e), insofar as the parties reach an agreement on the effect of disclosure of a
3 || communication or information covered by the attorney-client privilege or work
4 || product protection, the parties may incorporate their agreement in the stipulated
5 || protective order submitted to the court.
6
7 || 12. MISCELLANEOUS
8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
9 || person to seek its modification by the Court in the future.
10 12.2 Right to Assert Other Objections. By stipulating to the entry of this
11 || Protective Order no Party waives any right it otherwise would have to object to
12 || disclosing or producing any information or item on any ground not addressed in this
13 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
14 || ground to use in evidence of any of the material covered by this Protective Order.
15 12.3 Filing Protected Material. A Party that seeks to file under seal any
16 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may
17 || only be filed under seal pursuant to a court order authorizing the sealing of the
18 || specific Protected Material at issue. If a Party's request to file Protected Material
19 || under seal is denied by the court, then the Receiving Party may file the information
20 || in the public record unless otherwise instructed by the court.
21
22 || 13. FINAL DISPOSITION
23 After the final disposition of this Action, as defined in paragraph 4, within 60
24 || days of a written request by the Designating Party, each Receiving Party must return
25 || all Protected Material to the Producing Party or destroy such material. As used in
26 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
27 || summaries, and any other format reproducing or capturing any of the Protected
28 || Material. Whether the Protected Material is returned or destroyed, the Receiving

1 || Party must submit a written certification to the Producing Party (and, if not the same
2 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
3 || (by category, where appropriate) all the Protected Material that was returned or
4 || destroyed and (2) affirms that the Receiving Party has not retained any copies,
5 || abstracts, compilations, summaries or any other format reproducing or capturing any
6 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to
7 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
8 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
9 || reports, attorney work product, and consultant and expert work product, even if such
10 || materials contain Protected Material. Any such archival copies that contain or
11 || constitute Protected Material remain subject to this Protective Order as set forth in
12 || Section 4 (DURATION).
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1 || 14. Any willful violation of this Order may be punished by civil or criminal
2 || contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
3 || authorities, or other appropriate action at the discretion of the Court.
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22 || FOR GOOD CAUSE SHOWN BY THE PARTIES' STIPULATION, IT IS SO
23 || ORDERED.
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25 | DATED: February 9. 2021 ful.
26 HON. PEDRO V. CASTILLO
United States Magistrate Judge
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15

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, [full name], of
5 || [full address], declare under penalty of perjury that I have read in its entirety and
6 || understand the Stipulated Protective Order that was issued by the United States
7 || District Court for the Central District of California on [date] in the case of
8 [insert case name and number]. I agree to comply with and to be
9 || bound by all the terms of this Stipulated Protective Order and I understand and
10 || acknowledge that failure to so comply could expose me to sanctions and punishment
11 || in the nature of contempt. I solemnly promise that I will not disclose in any manner
12 || any information or item that is subject to this Stipulated Protective Order to any
13 || person or entity except in strict compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court
15 || for the Central District of California for the purpose of enforcing the terms of this
16 || Stipulated Protective Order, even if such enforcement proceedings occur after
17 || termination of this action. I hereby appoint [full
18 || name] of [full address and
19 || telephone number] as my California agent for service of process in connection with
20 || this action or any proceedings related to enforcement of this Stipulated Protective
21 || Order.
22 || Date:
23 || City and State where signed:
24
25 || Printed name:
26
27 || Signature:
28

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10040173. Public record. Not legal advice.