The opinion
1 MARIO U. ZAMORA, #258721
CHRISTINA G. Di FILIPPO, #327255
2 GRISWOLD, LaSALLE, COBB,
DOWD & GIN, L.L.P.
3 111 E. Seventh Street
Hanford, CA 93230
4
Telephone: (559) 584-6656
5 Facsimile: (559) 582-3106
E-mails: zamora@griswoldlasalle.com; difilippo@griswoldlasalle.com
6 Attorneys for: Defendants, City of Hanford, Hanford Police Department, Parker Sever, Jeff
7
Davis, Stephanie Huddleston
8 UNITED STATES DISTRICT COURT
9 EASTERN DISTRICT OF CALIFORNIA
10
11 JASON STINGLEY, Case No.: 1:23-cv-00089-BAM
12 Plaintiff,
vs. [PROPOSED] STIPULATED
13 PROTECTIVE ORDER
CITY OF HANFORD, CITY OF HANFORD
14 POLICE DEPARTMENT, PARKER SEVER,
in his individual capacity; JEFF DAVIS, in his
15 individual capacity; STEPHANIE
HUDDLESTON, in her individual capacity;
16 AND DOES 1 THROUGH 50, INCLUSIVE,
17 Defendants.
18 1. STIPULATION
19 IT IS HEREBY STIPULATED, by and between the Parties hereto, by and through their
20 respective counsel of record, that in order to facilitate the exchange of information and documents
21 which may be subject to confidentiality limitations on disclosure due to federal laws, state laws,
22 and privacy rights, the Parties stipulate as follows:
23 2. DEFINITIONS
24 2.1. “Challenging Party”: a Party or Non-Party that challenges the designation of information
25 or items under this Order.
26 2.2. “Confidential”: information (regardless of how it is generated, stored or maintained) or
27 tangible things in the possession of a Designating Party who believes in good faith that
28 such information qualifies for protection under Federal Rule of Civil Procedure 26(c).
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1 2.3. “Confidential Materials”: any Documents, Testimony or Information as defined below
2 designated as “Confidential” pursuant to the provisions of this Stipulation and Protective
3 Order.
4 2.4. “Counsel” (without qualifier): any attorney with a firm who has appeared as the attorney
5 of record in this action (as well as their support staff).
6 2.5. “Designating Party”: a Party or Non-Party that designates information or items that it
7 produces in disclosures or in responses to discovery as “confidential”.
8 2.6. “Disclose” or “Disclosure” or “Discovery Material”: all items or information, regardless
9 of the medium or manner in which it is generated, stored, or maintained (including,
10 among other things, testimony, transcripts, and tangible things), produced or generated in
11 disclosures or responses to discovery in this matter.
12 2.7. “Document”: all “Writings” and “Records” as those terms are defined in Rule 34 of the
13 Federal Rules of Civil Procedure and Rule 1001 of the Federal Rules of Evidence,
14 including, but not limited to, all writings and records of every type and description
15 including, but not limited to, contracts, agreements, correspondence, memoranda, letters,
16 facsimiles, electronic mail (“e-mail”), records of telephone conversations, handwritten
17 and typewritten notes of any kind, statements, reports, minutes, recordings, transcripts
18 and summaries of meetings, voice recordings, pictures, photographs, drawings, computer
19 cards, tapes, discs, printouts and records of all types, studies, instruction manuals, policy
20 manuals and statements, books, pamphlets, invoices, canceled checks and every other
21 device or medium by which or through which information of any type is transmitted,
22 recorded or preserved which have been produced in discovery in this Proceeding by any
23 person. Without any limitation on the foregoing, the term “DOCUMENT” shall include
24 all copies that differ in any respect from the original or other versions of the
25 DOCUMENT, including, but not limited to, all drafts, reproductions, summaries, and
26 copies of such drafts or originals containing initials, comments, notations, insertions,
27 corrections, marginal notes, amendments or any other variation of any kind.
28 2.8. “Expert”: a person with specialized knowledge or experience in a matter pertinent to the
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1 litigation who has been retained by a Party or its counsel to serve as an expert witness or
2 as a consultant in this action.
3 2.9. “Information”: means the content of Documents or Testimony.
4 2.10. “Non-Party”: any natural person, partnership, corporation, association, or other legal
5 entity not named as a party to this action
6 2.11. “Outside Counsel of Record”: attorneys who are not employees of a party to this action
7 but are retained to represent or advise a party to this action and have appeared in this
8 action on behalf of that party or are affiliated with a law firm which has appeared on
9 behalf of that party.
10 2.12. “Party”: any party to this action, including all of its officers, directors, employees,
11 consultants, retained experts, and Outside Counsel of Record (and their support staffs).
12 2.13. “Proceeding”: the above-entitled proceeding (Case No. 1:23-cv-0089).
13 2.14. “Producing Party”: a Party or Non-Party that produces Disclosure or Discovery Material
14 in this action.
15 2.15. “Professional Vendors”: persons or entities that provide litigation support services (e.g.,
16 photocopying, videotaping, translating, preparing exhibits or demonstrations, and
17 organizing, storing, or retrieving data in any form or medium) and their employees and
18 subcontractors.
19 2.16. “Protected Material”: any Disclosure or Discovery Material that is designated as
20 “CONFIDENTIAL.”
21 2.17. “Receiving Party”: a Party that receives Disclosure or Discovery Material from a
22 Producing Party.
23 2.18. “Testimony”: means all depositions, declarations or other testimony taken or used in this
24 Proceeding.
25 3. SCOPE
26 This Order does not confer blanket protections on all disclosures or responses to
27 discovery, and the protection it affords from public disclosure and use extends only to the limited
28 information or items that are entitled to confidential treatment under the applicable legal
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1 principles. The parties further acknowledge, as set forth in Section 12.3, below, that this
2 Stipulated Protective Order does not entitle them to file confidential information under seal;
3 Local Rule 141 sets forth the procedures that must be followed and the standards that will be
4 applied when a party seeks permission from the court to file material under seal.
5 The protections conferred by this Stipulation and Order cover not only Protected Material
6 (as defined above), but also (1) any information copied or extracted from Protected Material; (2)
7 all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
8 conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
9 However, the protections conferred by this Stipulation and Order do not cover the following
10 information: (a) any information that is in the public domain at the time of disclosure to a
11 Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as
12 a result of publication not involving a violation of this Order, including becoming part of the
13 public record through trial or otherwise; and (b) any information known to the Receiving Party
14 prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who
15 obtained the information lawfully and under no obligation of confidentiality to the Designating
16 Party. Use of Protected Material at trial shall be governed by a separate agreement or order.
17 4. DURATION
18 Even after final disposition of this litigation, the confidentiality obligations imposed by
19 this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court
20 order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all
21 claims and defenses in this action, with or without prejudice; and (2) final judgment herein after
22 the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this
23 action, including the time limits for filing any motions or applications for extension of time
24 pursuant to applicable law.
25 5. DESIGNATING PROTECTED MATERIAL
26 5.1. Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-
27 Party that designates information or items for protection under this Order must take care
28 to limit any such designation to specific material that qualifies under the appropriate
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1 standards. The Designating Party must designate for protection only those parts of
2 material, documents, items, or oral or written communications that qualify – so that other
3 portions of the material, documents, items, or communications for which protection is not
4 warranted are not swept unjustifiably within the ambit of this Order.
5 Mass, indiscriminate, or routinized designations are prohibited. Designations shown to
6 be clearly unjustified or have been made for an improper purpose (e.g., to unnecessarily
7 encumber or retard the case development process or to impose unnecessary expenses and
8 burdens on other parties) expose the Designating Party to sanctions.
9 If it comes to a Designating Party’s attention that information or items that it designated
10 for protection do not qualify for protection, that Designating Party must, in writing,
11 promptly notify all other Parties that it is withdrawing the mistaken designation.
12 5.2. Manner and Timing of Designations. Except as otherwise provided in this Order (see,
13 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
14 Disclosure or Discovery Material that qualifies for protection under this Order must be
15 clearly so designated before the material is disclosed or produced. All designations in
16 conformity with this Order should not obscure or interfere with the legibility of the
17 designated Information and requires:
18 5.2.1. for information in documentary form (e.g., paper or electronic documents, but
19 excluding transcripts of depositions or other pretrial or trial proceedings), that the
20 Producing Party affix the legend “CONFIDENTIAL” to each page that contains
21 protected material. If only a portion or portions of the material on a page qualifies for
22 protection, the Producing Party also must clearly identify the protected portion(s)
23 (e.g., by making appropriate markings in the margins).
24 A Party or Non-Party that makes original documents or materials available for
25 inspection need not designate them for protection until after the inspecting Party
26 has indicated which material it would like copied and produced. During the
27 inspection and before the designation, all of the material made available for
28 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
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1 identified the documents it wants copied and produced, the Producing Party must
2 determine which documents, or portions thereof, qualify for protection under this
3 Order. Then, before producing the specified documents, the Producing Party must
4 affix the “CONFIDENTIAL” legend to each page that contains Protected
5 Material. If only a portion or portions of the material on a page qualifies for
6 protection, the Producing Party also must clearly identify the protected portion(s)
7 (e.g., by making appropriate markings in the margins).
8 5.2.2. For Testimony given in depositions the Designating Party may either:
9 5.2.2.1. specify all portions of the Testimony that qualify as “Confidential;” or
10 5.2.2.2. designate the entirety of the Testimony at the deposition as “Confidential” (before
11 the deposition is concluded) with the right to identify more specific portions of
12 the Testimony as to which protection is sought within 7 days following receipt of
13 the deposition transcript. Where portions of the deposition Testimony are
14 designated for protection, the transcript pages containing “Confidential”
15 Information may be separately bound by the court reporter, who must affix to the
16 top of each page the legend “Confidential,” as instructed by the Designating Party.
17 5.2.3. for information produced in some form other than documentary and for any other
18 tangible items, including, without limitation, compact discs or DVDS, that the
19 Producing Party affix in a prominent place on the exterior of the container or
20 containers in which the information or item is stored the legend “CONFIDENTIAL.”
21 If only a portion or portions of the information or item warrant protection, the
22 Producing Party, to the extent practicable, shall identify the protected portion(s).
23 5.3. Inadvertent Failures to Designate. The inadvertent production by any of the undersigned
24 Parties or non-Parties to the Proceedings of any Document, Testimony or Information
25 during discovery in this Proceeding without a “Confidential” designation, shall be
26 without prejudice to any claim that such item is “Confidential” and such Party shall not
27 be held to have waived any rights by such inadvertent production. If any Document,
28 Testimony or Information that is subject to a “Confidential” designation is inadvertently
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1 produced without such designation, the Party that inadvertently produced the document
2 shall give written notice of such inadvertent production within ten (10) days of discovery
3 of the inadvertent production, together with a further copy of the subject Document,
4 Testimony or Information designated as “Confidential” (the “Inadvertent Production
5 Notice”). Upon receipt of such Inadvertent Production Notice, the Party that received the
6 inadvertently produced Document, Testimony or Information shall promptly destroy the
7 inadvertently produced Document, Testimony or Information and all copies thereof, or,
8 at the expense of the producing Party, return such together with all copies of such
9 Document, Testimony or Information to counsel for the producing Party and shall retain
10 only the “Confidential” designated Materials. Should the receiving Party choose to
11 destroy such inadvertently produced Document, Testimony or Information, the receiving
12 Party shall notify the producing Party in writing of such destruction within ten (10) days
13 of receipt of written notice of the inadvertent production. This provision is not intended
14 to apply to any inadvertent production of any Information protected by attorney-client or
15 work product privileges. If this provision conflicts with any applicable law regarding
16 waiver of confidentiality through the inadvertent production of Documents, Testimony
17 or Information, such law shall govern.
18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19 6.1. Timing of Challenges. Any Party or Non-Party may challenge a designation of
20 confidentiality at any time. Unless a prompt challenge to a Designating Party’s
21 confidentiality designation is necessary to avoid foreseeable, substantial unfairness,
22 unnecessary economic burdens, or a significant disruption or delay of the litigation, a
23 Party does not waive its right to challenge a confidentiality designation by electing not to
24 mount a challenge promptly after the original designation is disclosed.
25 6.2. In the event that counsel for a Party receiving Documents, Testimony or Information in
26 discovery designated as “Confidential” objects to such designation with respect to any or
27 all of such items, said counsel shall advise counsel for the Designating Party, in writing,
28 of such objections, the specific Documents, Testimony or Information to which each
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1 objection pertains, and the specific reasons and support for such objections (the
2 “Designation Objections”). Counsel for the Designating Party shall have ten (10) days
3 from receipt of the written Designation Objections to either (a) agree in writing to de-
4 designate Documents, Testimony or Information pursuant to any or all of the Designation
5 Objections and/or (b) file a motion with the Court seeking to uphold any or all
6 designations on Documents, Testimony or Information addressed by the Designation
7 Objections (the “Designation Motion”). Pending a resolution of the Designation Motion
8 by the Court, any and all existing designations on the Documents, Testimony or
9 Information at issue in such Motion shall remain in place. The Designating Party shall
10 have the burden on any Designation Motion of establishing the applicability of its
11 “Confidential” designation. In the event that the Designation Objections are neither
12 timely agreed to nor timely addressed in the Designation Motion, then such Documents,
13 Testimony or Information shall be de-designated in accordance with the Designation
14 Objection applicable to such material.
15 7. ACCESS TO AND USE OF PROTECTED MATERIAL
16 7.1. Basic Principles. A Receiving Party may use Protected Material that is disclosed or
17 produced by another Party or by a Non-Party in connection with this case only for
18 prosecuting, defending, or attempting to settle litigation related to the underlying events
19 alleged in this Action. Such Protected Material may be disclosed only to the categories
20 of persons and under the conditions described in this Order. When the litigation has been
21 terminated, a Receiving Party must comply with the provisions of section 12 below
22 (FINAL DISPOSITION).
23 Protected Material must be stored and maintained by a Receiving Party at a location and
24 in a secure manner that ensures that access is limited to the persons authorized under this
25 Order.
26 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the
27 court or permitted in writing by the Designating Party, a Receiving Party may disclose
28 any information or item designated “CONFIDENTIAL” only to:
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1 7.2.1. the Receiving Party’s Counsel, as well as employees of said Counsel to whom it is
2 reasonably necessary to disclose the information\;
3 7.2.2. the Receiving Party and its officers, directors, and employees\;
4 7.2.3. Experts (as defined in this Order) of the Receiving Party to whom disclosure is
5 reasonably necessary for this litigation;
6 7.2.4. the court and its personnel;
7 7.2.5. court reporters and their staff, professional jury or trial consultants, mock jurors, and
8 Professional Vendors to whom disclosure is reasonably necessary;
9 7.2.6. during their depositions, witnesses in the action to whom disclosure is reasonably
10 necessary, unless otherwise agreed by the Designating Party or ordered by the court.
11 Pages of transcribed deposition testimony or exhibits to depositions that reveal
12 Protected Material must be separately bound by the court reporter and may not be
13 disclosed to anyone except as permitted under this Stipulated Protective Order.
14 7.2.7. the author or recipient of a document containing the information or a custodian or
15 other person who otherwise possessed or knew the information.
16 8. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
17 LITIGATION
18 8.1. The terms of this Order are applicable to information produced by a Non-Party in this
19 action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties
20 in connection with this litigation is protected by the remedies and relief provided by this
21 Order. Nothing in these provisions should be construed as prohibiting a Non-Party from
22 seeking additional protections.
23 8.2. In the event that a Party is required, by a valid discovery request, to produce a Non-Party’s
24 confidential information in its possession, and the Party is subject to an agreement with
25 the Non-Party not to produce the Non-Party’s confidential information, then the Party
26 shall:
27 8.2.1. promptly notify in writing the Requesting Party and the Non-Party that some or all of
28 the information requested is subject to a confidentiality agreement with a Non-Party;
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1 8.2.2. promptly provide the Non-Party with a copy of the Stipulated Protective Order in this
2 litigation, the relevant discovery request(s), and a reasonably specific description of
3 the information requested; and
4 8.2.3. make the information requested available for inspection by the Non-Party.
5 8.3. If the Non-Party fails to object or seek a protective order from this court within 7 days of
6 receiving the notice and accompanying information, the Receiving Party may produce
7 the Non-Party’s confidential information responsive to the discovery request. If the Non-
8 Party timely seeks a protective order, the Receiving Party shall not produce any
9 information in its possession or control that is subject to the confidentiality agreement
10 with the Non-Party before a determination by the court. Absent a court order to the
11 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
12 court of its Protected Material.
13 9. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
15 Material to any person or in any circumstance not authorized under this Stipulated Protective
16 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the
17 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
18 Protected Material, and (c) inform the person or persons to whom unauthorized disclosures were
19 made of all the terms of this Order.
20 10. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
21 MATERIAL
22 When a Producing Party gives notice to Receiving Parties that certain inadvertently
23 produced material is subject to a claim of privilege or other protection, the obligations of the
24 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
25 provision is not intended to modify whatever procedure may be established in an e-discovery
26 order that provides for production without prior privilege review. Pursuant to Federal Rule of
27 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of
28 a communication or information covered by the attorney-client privilege or work product
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1 protection, the parties may incorporate their agreement in the stipulated protective order
2 submitted to the court.
3 11. MISCELLANEOUS
4 11.1. Right to Further Relief. Nothing in this Order abridges the right of any person to seek its
5 modification by the court in the future.
6 11.2. Right to Assert Other Objections. By stipulating to the entry of this Protective Order no
7 Party waives any right it otherwise would have to object to disclosing or producing any
8 information or item on any ground not addressed in this Stipulated Protective Order.
9 Similarly, no Party waives any right to object on any ground to use in evidence of any of
10 the material covered by this Protective Order.
11 11.3. Filing Protected Material. Without written permission from the Designating Party or a
12 court order secured after appropriate notice to all interested persons, a Party may not file
13 in the public record any Protected Material. This Stipulated Protective Order does not
14 limit the admissibility or relevance of any Protected Material or limit the jurisdiction of
15 any court that may be asked to determine whether Protected Material may be used in any
16 other action. A Party that seeks to file under seal any Protected Material must comply
17 with Civil Local Rule 141. Protected Material may only be filed under seal pursuant to a
18 court order authorizing the sealing of the specific Protected Material at issue. If a
19 Receiving Party's request to file Protected Material under seal is denied by the court, then
20 the Receiving Party may file the information in the public record unless otherwise
21 instructed by the court.
22 11.4. This Stipulation and Protective Order is entered into without prejudice to the right of any
23 Party to knowingly waive the applicability of this Stipulation and Protective Order to any
24 Confidential Materials designated by that Party. If the Designating Party uses
25 Confidential Materials in a non-Confidential manner, then the Designating Party shall
26 advise that the designation no longer applies.
27 11.5. This Stipulation and Protective Order was negotiated by the Parties who have agreed to
28 the following further limitations:
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1 11.5.1. Defendants shall produce copies of Defendant Parker Sever, Jeff Davis and Stephanie
2 Huddleston’s personnel files with redactions to protect personal information of said
3 defendants, including but not limited to address, social security numbers, phone
4 numbers, medical information of said defendants and their family members or as
5 otherwise agreed to by the parties;
6 11.5.2. Defendants shall produce any internal affairs investigation files for each of the said
7 defendants responsive to Plaintiff’s request subject to redactions for confidential
8 informant information;
9 11.5.3. All information produced during discovery pursuant to this Order shall be used only
10 for the purposes of this civil case.
11 11.5.4. Information or documents produced shall not be provided to any person other than
12 counsel for Plaintiff in this matter and Plaintiff;
13 11.5.5. All information produced during discovery shall only be available for viewing to
14 Plaintiff while incarcerated; and
15 11.5.6. This order takes no position on the admissibility of any information or documents
16 subject to this order in Plaintiff’s criminal actions in the Superior Court of the State
17 of California.
18 12. FINAL DISPOSITION
19 Within 90 days after the final disposition of this action, as defined in paragraph 4, each
20 Receiving Party must return all Protected Material to the Producing Party or destroy such
21 material. As used in this subdivision, “all Protected Material” includes all copies, abstracts,
22 compilations, summaries, and any other format reproducing or capturing any of the Protected
23 Material. Whether the Protected Material is returned or destroyed, the Receiving Party must
24 submit a written certification to the Producing Party (and, if not the same person or entity, to the
25 Designating Party) by the 90 day deadline that (1) identifies (by category, where appropriate) all
26 the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party
27 has not retained any copies, abstracts, compilations, summaries or any other format reproducing
28 or capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled
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1 to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
2 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports,
3 attorney work product, and consultant and expert work product, even if such materials contain
4 Protected Material. Any such archival copies that contain or constitute Protected Material remain
5 subject to this Protective Order as set forth in Section 4 (DURATION).
6
7 Dated: May 3, 2024 GRISWOLD, LaSALLE, COBB,
DOWD & GIN, L.L.P.
8
9 By: /s/ Christina G. Di Filippo
CHRISTINA G. DI FILIPPO
10 Attorneys for: Defendants, City of Hanford,
11 Hanford Police Department, Parker Sever, Jeff
Davis, Stephanie Huddleston
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13 Dated: May 3, 2024 Law Offices of Bonner and Bonner
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By: /s/ A. Cabral Bonner
15 CHARLES A. BONNER
A. CABRAL BONNER
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Attorneys for: Plaintiff, Jason Stingley
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CERTIFICATE OF SERVICE
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I hereby certify that on May 3, 2024, a copy of the foregoing was electronically filed
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using the CM/ECF system, which will automatically send e-mail notification of such filing to all
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attorneys of record who are deemed to have consented to electronic service:
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Charles A. Bonner, cbonner799@aol.com Attorneys for Plaintiffs
6 A. Cabral Bonner, cabral@bonnerlaw.com
Law Offices of Bonner & Bonner
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By: /s/ Daniela Beccari
9 DANIELA BECCARI
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ORDER
1
2 Having considered the above stipulation and finding good cause, the Court adopts the
3 signed stipulated protective order.
4 The parties are advised that pursuant to the Local Rules of the United States District
5 Court, Eastern District of California, any documents subject to the protective order to be filed
6 under seal must be accompanied by a written request which complies with Local Rule 141 prior
7
to sealing. The party making a request to file documents under seal shall be required to show
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good cause for documents attached to a non-dispositive motion or compelling reasons for
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documents attached to a dispositive motion. Pintos v. Pacific Creditors Ass’n, 605 F.3d 665,
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677-78 (9th Cir. 2009). Within five (5) days of any approved document filed under seal, the
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party shall file a redacted copy of the sealed document. The redactions shall be narrowly
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tailored to protect only the information that is confidential or was deemed confidential.
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Additionally, the parties shall consider resolving any dispute arising under the
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protective order according to the Court’s informal discovery dispute procedure.
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17 IT IS SO ORDERED.
18 Dated: May 3, 2024 /s/ Barbara A. McAuliffe _
19 UNITED STATES MAGISTRATE JUDGE
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