Opinion

Zeeshan H. Khan v. City of Los Angeles

Court: District Court, C.D. California
Filed: Jan 7, 2022
Cited by: 0 cases
Authority: More cited than 16.3%

distinguishing "good cause" showing for sealing documents produced in discovery from "compelling reasons" standard when merits-related documents are part of court record

How later courts described this case

distinguishing "good cause" showing for sealing documents produced in discovery from "compelling reasons" standard when merits-related documents are part of court record

Written by the judges who cited it.

The opinion

Case 2:21-cv-03289-CAS-MAR Document 45 Filed 01/07/22 Page 1 of 16 Page ID #:185

1 Office of the Los Angeles City Attorney

DENISE C. MILLS, Deputy City Attorney (SBN 191992)

2 denise.mills@lacity.org

200 North Main Street, 6th Floor, City Hall East

3 Los Angeles, California 90012

Phone: 213-978-6954

DANIEL S. ROBERTS, Bar No. 205535

5 droberts@colehuber.com

NICOLE R. ROGGEVEEN, Bar No. 252587

6 nroggeveen@colehuber.com

ADRIAN VERDUZCO, Bar No. 336027

7 averduzco@colehuber.com

COLE HUBER LLP

8 3401 Centrelake Drive, Suite 670

Ontario, California 91761

9 Telephone: (909) 230-4209

Facsimile: (909) 937-2034

Attorneys for Defendants City of Los

11 Angeles, Los Angeles Police Department,

and Chief Michel Moore

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

ZEESHAN H. KHAN, CHRISTINA Case No. 2:21-cv-03289 CAS (MARx)

16 ASTORGA, and RINGO CHIU,

17 Plaintiffs, STIPULATED PROTECTIVE

ORDER

18 v.

Referred for Discovery Purposes to the

19 CITY OF LOS ANGELES, LOS Honorable Margo A. Rocconi

ANGELES POLICE DEPARTMENT, ;

20 CHIEF MICHEL MOORE, OFFICER

AARON GREEN, and DOES 1-10,

Defendants.

23 1. A. PURPOSES AND LIMITATIONS

24 Discovery in this action is likely to involve production of confidential,

25 proprietary, or private information for which special protection from public

26 disclosure and from use for any purpose other than prosecuting this litigation may

27 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

28 enter the following Stipulated Protective Order. The parties acknowledge that this

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Order does not confer blanket protections on all disclosures or responses to

discovery and that the protection it affords from public disclosure and use extends

only to the limited information or items that are entitled to confidential treatment

under the applicable legal principles. The parties further acknowledge, as set forth in

Section 12.3, below, that this Stipulated Protective Order does not entitle them to

file confidential information under seal; Civil Local Rule 79-5 sets forth the

procedures that must be followed and the standards that will be applied when a party

seeks permission from the court to file material under seal.

B. GOOD CAUSE STATEMENT

This action involves the City of Los Angeles and members of the Los Angeles

Police Department on the one side and on the other side Plaintiffs Zeeshan Khan,

Christina Astorga, and Ringo Chiu ("Plaintiffs"), private citizens, who are claiming

damages from the City and its police officer for past and future medical expenses,

loss of earnings, emotional distress, mental suffering, and other unspecified general

damages allegedly caused by Defendants. Defendants will seek in this action

discovery of various information relating to Plaintiffs' damages claims, including

employment and medical information that may be very personal, private, and

potentially embarrassing to them if it were to be unnecessarily disseminated.

Plaintiffs are seeking materials and information that Defendant the City of Los

Angeles (including its Police Department) maintains as confidential, such as

personnel files of police officers, Internal Affairs materials and information, Force

Investigation Division materials and information and other administrative materials

and information currently in the possession of the City and which the City believes

need special protection from public disclosure and from use for any purpose other

than prosecuting this litigation. Some of this information may also implicate the

privacy rights of persons not party to this lawsuit. Plaintiff is also seeking official

information contained in the personnel files of the police officers involved in the

subject incident, which the City maintains as strictly confidential and which the City

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believes needs special protection from public disclosure and from use for any

purpose other than prosecuting this litigation.

The parties therefore stipulate that some of the information into which

discovery will be sought in this case is protected by various parties' and (third

parties') privacy rights under state and federal law. In addition, the confidentiality

of the materials and information sought by Plaintiff is recognized by California and

federal law. The City has not publicly released such materials except under

protective order or pursuant to a court order, if at all. These materials and

information are of the type that has been used to initiate disciplinary action against

Los Angeles Police Department ("LAPD") officers, and has been used as evidence

in disciplinary proceedings, where the officers' conduct was considered to be

contrary to LAPD policy.

THIS STIPULATED PROTECTIVE ORDER EXPRESSLY EXCLUDES

RECORDINGS FROM OFFICERS' BODY-WORN CAMERAS UNLESS

OTHERWISE SPECIFICALLY AGREED BY THE PARTIES IN A SEPARATE

WRITING, OR AS OTHERWISE ORDERED BY THE COURT.

Absent a protective order delineating the responsibilities of nondisclosure on

the part of the parties hereto, there is a specific risk of unnecessary and undue

disclosure by one or more of the many attorneys, secretaries, law clerks, paralegals

and expert witnesses involved in this case, as well as the corollary risk of

embarrassment, harassment and professional and legal harm on the part of Plaintiffs,

Defendants, other LAPD officers, and non-party civilians who may be referenced in

the materials and information.

Accordingly, to expedite the flow of information, to facilitate the prompt

resolution of disputes over confidentiality of discovery materials, to adequately

protect information the parties are entitled to keep confidential, to ensure that the

parties are permitted reasonable necessary uses of such material in preparation for

and in the conduct of trial, to address their handling at the end of the litigation, and

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serve the ends of justice, a protective order for such information is justified in this

matter. It is the intent of the parties that information will not be designated as

confidential for tactical reasons and that nothing be so designated without a good

faith belief that it has been maintained in a confidential, non-public manner, and

there is good cause why it should not be part of the public record of this case.

2. DEFINITIONS

2.1 Action: The above-captioned suit.

2.2 Challenging Party: a Party or Non-Party that challenges the designation of

information or items under this Order.

2.3 “CONFIDENTIAL” Information or Items: information (regardless of how

it is generated, stored or maintained) or tangible things that qualify for

protection under Federal Rule of Civil Procedure 26(c), and as specified

above in the Good Cause Statement.

2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

support staff).

2.5 Designating Party: a Party or Non-Party that designates information or

items that it produces in disclosures or in responses to discovery as

“CONFIDENTIAL.”

2.6 Disclosure or Discovery Material: all items or information, regardless of

the medium or manner in which it is generated, stored, or maintained

(including, among other things, testimony, transcripts, and tangible

things), that are produced or generated in disclosures or responses to

discovery in this matter.

2.7 Expert: a person with specialized knowledge or experience in a matter

pertinent to the litigation who has been retained by a Party or its counsel

to serve as an expert witness or as a consultant in this Action.

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2.8 House Counsel: attorneys who are employees of a party to this Action.

House Counsel does not include Outside Counsel of Record or any other

outside counsel.

2.9 Non-Party: any natural person, partnership, corporation, association, or

other legal entity not named as a Party to this action.

2.10 Outside Counsel of Record: attorneys who are not employees of a party

to this Action but are retained to represent or advise a party to this Action

and have appeared in this Action on behalf of that party or are affiliated

with a law firm which has appeared on behalf of that party, and includes

support staff.

2.11 Party: any party to this Action, including all of its officers, directors,

employees, consultants, retained experts, and Outside Counsel of Record

(and their support staffs).

2.12 Producing Party: a Party or Non-Party that produces Disclosure or

Discovery Material in this Action.

2.13 Professional Vendors: persons or entities that provide litigation support

services (e.g., photocopying, videotaping, translating, preparing exhibits

or demonstrations, and organizing, storing, or retrieving data in any form

or medium) and their employees and subcontractors.

2.14 Protected Material: any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL.”

2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

from a Producing Party.

3. SCOPE

The protections conferred by this Stipulation and Order cover not only

Protected Material (as defined above), but also (1) any information copied or

extracted from Protected Material; (2) all copies, excerpts, summaries, or

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compilations of Protected Material; and (3) any testimony, conversations, or

presentations by Parties or their Counsel that might reveal Protected Material.

Any use of Protected Material at trial shall be governed by the orders of the

trial judge. This Order does not govern the use of Protected Material at trial.

4. DURATION

Once trial commences in this action, all of the information that was

designated as CONFIDENTIAL or maintained pursuant to this protective order and

that is introduced or admitted at trial becomes public and will be presumptively

available to all members of the public, including the press, unless compelling

reasons supported by specific factual findings to proceed otherwise are made to the

trial judge in advance of the trial. See Kamakana v. City and County of Honolulu,

447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing "good cause" showing for

sealing documents produced in discovery from "compelling reasons" standard when

merits-related documents are part of court record). Accordingly, the terms of this

protective order do not extend beyond the commencement of the trial as to the

CONFIDENTIAL information and materials introduced or admitted as an exhibit at

trial.

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for Protection.

Each Party or Non-Party that designates information or items for protection under

this Order must take care to limit any such designation to specific material that

qualifies under the appropriate standards. The Designating Party must designate for

protection only those parts of material, documents, items, or oral or written

communications that qualify so that other portions of the material, documents,

items, or communications for which protection is not warranted are not swept

unjustifiably within the ambit of this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

that are shown to be clearly unjustified or that have been made for an improper

purpose (e.g., to unnecessarily encumber the case development process or to impose

unnecessary expenses and burdens on other parties) may expose the Designating

Party to sanctions.

If it comes to a Designating Party's attention that information or items that it

designated for protection do not qualify for protection, that Designating Party must

promptly notify all other Parties that it is withdrawing the inapplicable designation.

5.2 Manner and Timing of Designations. Except as otherwise provided in this

Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

under this Order must be clearly so designated before the material is disclosed or

produced.

Designation in conformity with this Order requires:

(a) for information in documentary form (e.g., paper or electronic documents,

but excluding transcripts of depositions or other pretrial or trial proceedings), that

the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

“CONFIDENTIAL legend”), to each page that contains protected material. If only a

portion or portions of the material on a page qualifies for protection, the Producing

Party also must clearly identify the protected portion(s) (e.g., by making appropriate

markings in the margins). Any such designation should not obscure the text or

image on the item being produced.

A Party or Non-Party that makes original documents available for inspection

need not designate them for protection until after the inspecting Party has indicated

which documents it would like copied and produced. During the inspection and

before the designation, all of the material made available for inspection shall be

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deemed "CONFIDENTIAL." After the inspecting Party has identified the

documents it wants copied and produced, the Producing Party must determine which

documents, or portions thereof, qualify for protection under this Order. Then, before

producing the specified documents, the Producing Party must affix the

"CONFIDENTIAL legend" to each page that contains Protected Material. If only a

portion or portions of the material on a page qualifies for protection, the Producing

Party also must clearly identify the protected portion(s) (e.g., by making appropriate

markings in the margins).

(b) for testimony given in depositions that the Designating Party identify

the Disclosure or Discovery Material on the record, before the close of the

deposition all protected testimony.

any other tangible items, that the Producing Party affix in a prominent place on the

exterior of the container or containers in which the information is stored the legend

"CONFIDENTIAL." If only a portion or portions of the information warrants

protection, the Producing Party, to the extent practicable, shall identify the protected

portion(s). Any such designation should not obscure the text or image on the item

being produced.

5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

failure to designate qualified information or items does not, standing alone, waive

the Designating Party’s right to secure protection under this Order for such material.

Upon timely correction of a designation, the Receiving Party must make reasonable

efforts to assure that the material is treated in accordance with the provisions of this

Order.

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6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

6.1 Timing of Challenges. Any Party or Non-Party may challenge a

designation of confidentiality at any time that is consistent with the Court's

Scheduling Order.

6.2 Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.

6.3 The burden of persuasion in any such challenge proceeding shall be on the

Designating Party. Frivolous challenges, and those made for an improper purpose

(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

expose the Challenging Party to sanctions. Unless the Designating Party has waived

or withdrawn the confidentiality designation, all parties shall continue to afford the

material in question the level of protection to which it is entitled under the

Producing Party’s designation until the Court rules on the challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

7.1 Basic Principles. A Receiving Party may use Protected Material that is

disclosed or produced by another Party or by a Non-Party in connection with this

Action only for prosecuting, defending, or attempting to settle this Action. Such

Protected Material may be disclosed only to the categories of persons and under the

conditions described in this Order. When the Action has been terminated, a

Receiving Party must comply with the provisions of section 13 below (FINAL

DISPOSITION).

Protected Material must be stored and maintained by a Receiving Party at a

location and in a secure manner that ensures that access is limited to the persons

authorized under this Order.

7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless otherwise

ordered by the court or permitted in writing by the Designating Party, a Receiving

Party may disclose any information or item designated "CONFIDENTIAL" only to:

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(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

employees of said Outside Counsel of Record to whom it is reasonably necessary to

disclose the information for this Action;

(b) the officers, directors, and employees (including House Counsel) of the

Receiving Party to whom disclosure is reasonably necessary for this Action;

disclosure is reasonably necessary for this Action and who have signed the

"Acknowledgment and Agreement to Be Bound" (Exhibit A);

(d) the court and its personnel;

(e) court reporters and their staff;

(f) professional jury or trial consultants, mock jurors, and Professional

Vendors to whom disclosure is reasonably necessary for this Action and who have

signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A);

(g) the author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information;

(h) during their depositions, witnesses, and attorneys for witnesses, in the

Action to whom disclosure is reasonably necessary provided: (1) the deposing party

requests that the witness sign the form attached as Exhibit A hereto; and (2) they

will not be permitted to keep any confidential information unless they sign the

"Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise

agreed by the Designating Party or ordered by the court. Pages of transcribed

deposition testimony or exhibits to depositions that reveal Protected Material may

be separately bound by the court reporter and may not be disclosed to anyone except

as permitted under this Stipulated Protective Order; and

(i) any mediator or settlement officer, and their supporting personnel,

mutually agreed upon by any of the parties engaged in settlement discussions.

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8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

OTHER LITIGATION

If a Party is served with a subpoena or a court order issued in other litigation

that compels disclosure of any information or items designated in this Action as

"CONFIDENTIAL," that Party must:

(a) promptly notify in writing the Designating Party. Such notification shall

include a copy of the subpoena or court order;

(b) promptly notify in writing the party who caused the subpoena or order to

issue in the other litigation that some or all of the material covered by the subpoena

or order is subject to this Protective Order. Such notification shall include a copy of

this Stipulated Protective Order; and

by the Designating Party whose Protected Material may be affected.

If the Designating Party timely seeks a protective order, the Party served with the

subpoena or court order shall not produce any information designated in this action

as "CONFIDENTIAL" before a determination by the court from which the

subpoena or order issued, unless the Party has obtained the Designating Party’s

permission. The Designating Party shall bear the burden and expense of seeking

protection in that court of its confidential material and nothing in these provisions

should be construed as authorizing or encouraging a Receiving Party in this Action

to disobey a lawful directive from another court.

9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

(a) The terms of this Order are applicable to information produced by a Non-

Party in this Action and designated as "CONFIDENTIAL." Such information

produced by Non-Parties in connection with this litigation is protected by the

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remedies and relief provided by this Order. Nothing in these provisions should be

construed as prohibiting a Non-Party from seeking additional protections.

(b) In the event that a Party is required, by a valid discovery request, to

produce a Non-Party's confidential information in its possession, and the Party is

subject to an agreement with the Non-Party not to produce the Non-Party's

confidential information, then the Party shall:

(1) promptly notify in writing the Requesting Party and the Non-Party that

some or all of the information requested is subject to a confidentiality agreement

with a Non-Party;

(2) promptly provide the Non-Party with a copy of the Stipulated Protective

Order in this Action, the relevant discovery request(s), and a reasonably specific

description of the information requested; and

(3) make the information requested available for inspection by the Non-Party,

if requested.

days of receiving the notice and accompanying information, the Receiving Party

may produce the Non-Party’s confidential information responsive to the discovery

request. If the Non-Party timely seeks a protective order, the Receiving Party shall

not produce any information in its possession or control that is subject to the

confidentiality agreement with the Non-Party before a determination by the court.

Absent a court order to the contrary, the Non-Party shall bear the burden and

expense of seeking protection in this court of its Protected Material.

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

Protected Material to any person or in any circumstance not authorized under this

Stipulated Protective Order, the Receiving Party must immediately (a) notify in

writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

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to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

persons to whom unauthorized disclosures were made of all the terms of this Order,

and (d) request such person or persons to execute the "Acknowledgment and

Agreement to Be Bound" that is attached hereto as Exhibit A.

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

inadvertently produced material is subject to a claim of privilege or other protection,

the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

may be established in an e-discovery order that provides for production without

prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar

as the parties reach an agreement on the effect of disclosure of a communication or

information covered by the attorney-client privilege or work product protection, the

parties may incorporate their agreement in the stipulated protective order submitted

to the court.

12. MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Order abridges the right of any

person to seek its modification by the Court in the future.

12.2 Right to Assert Other Objections. By stipulating to the entry of this

Protective Order no Party waives any right it otherwise would have to object to

disclosing or producing any information or item on any ground not addressed in this

Stipulated Protective Order. Similarly, no Party waives any right to object on any

ground to use in evidence of any of the material covered by this Protective Order.

12.3 Filing Protected Material. A Party that seeks to file under seal any

Protected Material must comply with Civil Local Rule 79-5. Protected Material may

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only be filed under seal pursuant to a court order authorizing the sealing of the

specific Protected Material at issue. If a Party's request to file Protected Material

under seal is denied by the court, then the Receiving Party may file the information

in the public record unless otherwise instructed by the court.

13. FINAL DISPOSITION

After the final disposition of this Action, as defined in paragraph 4, within 60

days of a written request by the Designating Party, each Receiving Party must return

all Protected Material to the Producing Party or destroy such material. As used in

this subdivision, "all Protected Material" includes all copies, abstracts, compilations,

summaries, and any other format reproducing or capturing any of the Protected

Material. Whether the Protected Material is returned or destroyed, the Receiving

Party must submit a written certification to the Producing Party (and, if not the same

person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

(by category, where appropriate) all the Protected Material that was returned or

destroyed and (2) affirms that the Receiving Party has not retained any copies,

abstracts, compilations, summaries or any other format reproducing or capturing any

of the Protected Material. Notwithstanding this provision, Counsel are entitled to

retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

reports, attorney work product, and consultant and expert work product, even if such

materials contain Protected Material. Any such archival copies that contain or

constitute Protected Material remain subject to this Protective Order as set forth in

Section 4 (DURATION).

/ / /

Case 2:21-cv-03289-CAS-MAR Document 45 Filed 01/07/22 Page15o0f16 Page ID #:199

1 || 14. Any violation of this Order may be punished by any and all appropriate

2 || measures including, without limitation, contempt proceedings and/or monetary

3 || sanctions.

5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

6 || Dated: December 29, 2021 THE LAW OFFICES OF JOHN BURTON

7 THE LAW OFFICE OF THOMAS C. SEABAUGH

9 By: /s/ John Burton

John Burton

10 Attorneys for Plaintiffs

11)!Dated: Jaunary 3, 2022 COLE HUBER LLP

S 12

se 3

2% By: /s/ Daniel S. Roberts

z 14 Daniel S. Roberts

5 w 5 15 Attorneys for Defendants City of Los Angeles,

43 S Los Angeles Police Department, and Chief

ofe 16 Michel Moore

s° !7\'Dated: December 30,2021 | STONE BUSAILAH, LLP

By: /s/ Muna Busailah

20 Muna Busailah

7] Attorneys for Defendant Aaron Green

22 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

23||DATED: January 7, 2022

24) BRR

25 || Honorable Margo A. Rocconi

46 United States Magistrate Judge

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EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, _____________________________ [print or type full name], of

_________________ [print or type full address], declare under penalty of perjury

that I have read in its entirety and understand the Stipulated Protective Order that

was issued by the United States District Court for the Central District of California

on [date] in the case of Zeeshan Khan, et al. v. City of Los Angeles, et al., Central

District of California Case No. 2:21-cv-3289 CAS (MARx). I agree to comply with

and to be bound by all the terms of this Stipulated Protective Order and I understand

and acknowledge that failure to so comply could expose me to sanctions and

punishment in the nature of contempt. I solemnly promise that I will not disclose in

any manner any information or item that is subject to this Stipulated Protective

Order to any person or entity except in strict compliance with the provisions of this

Order.

I further agree to submit to the jurisdiction of the United States District Court for the

Central District of California for the purpose of enforcing the terms of this

Stipulated Protective Order, even if such enforcement proceedings occur after

termination of this action. I hereby appoint __________________________ [print or

type full name] of _______________________________________ [print or type

full address and telephone number] as my California agent for service of process in

connection with this action or any proceedings related to enforcement of this

Stipulated Protective Order.

Date: ______________________________________

City and State where sworn and signed: ________________________________

Printed name: _______________________________

Signature: __________________________________

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