The opinion
Case 5:18-cv-00560-RGK-AGR Document 136 Filed 05/11/22 Page1of16 Page ID#:797
1 | RoB BONTA
Attorney General of California
2 | PAMELA J. HOLMES
Supervising Deputy Attorney General
3 | BETTY CHU-FUJITA
Deputy Attorney General
4 | State Bar No. 236976
300 South Spring Street, Suite 1702
5 Los Angeles, CA 90013-1230
Telephone: O13) 269-6141
6 Fax: (916) 7 1-2120 |
E-mail: Betty.Chuf'ujita@do}.ca.gov
7 | Attorneys for Defendants G. Lizaola and
D. Cruz
9 IN THE UNITED STATES DISTRICT COURT
10 FOR THE CENTRAL DISTRICT OF CALIFORNIA
1 CENTRAL DISTRICT
12
13 | GLEN CHARLES KLEMENT, EDCV-18-00560-RGK (AGRx)
14 Plaintiff, | STIPULATION REGARDING
PROTECTIVE ORDER RELATED
15 v. TO RECORDS OF THE
CALIFORNIA HIGHWAY
16 PATROL; }PROPOSED} ORDER
7 G. LIZAOLA, ET AL.,
Defendants. | Courtroom: 850
18 judge: The R. Gary Klausner
Trial Date: | Not Set
19 Action Filed: 3/19/2018
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Case 5:18-cv-00560-RGK-AGR Document 136 Filed 05/11/22 Page 2 of 16 Page ID #:798
1 Plaintiff Glen Charles Klement and Defendants G. Lizaola and D. Cruz of the
2 California Highway Patrol (CHP), by and through their respective counsel, hereby
3 stipulate and agree as follows:
4 1. A. PURPOSES AND LIMITATIONS
5 Discovery in this action is likely to involve production of confidential,
6 proprietary or private information for which special protection from public
7 disclosure and from use for any purpose other than prosecuting this litigation may
8 be warranted.
9 Accordingly, the parties hereby stipulate to and petition the Court to enter the
10 following Stipulated Protective Order. The parties acknowledge that this Order does
11 not confer blanket protections on all disclosures or responses to discovery and that
12 the protection it affords from public disclosure and use extends only to the limited
13 information or items that are entitled to confidential treatment under the applicable
14 legal principles.
15 The parties further acknowledge, as set forth in Section 12.3, below, that this
16 Stipulated Protective Order does not automatically entitle them to file confidential
17 information under seal and that Local Civil Rule 79-5 sets forth the procedures that
18 must be followed and the standards that will be applied when a party seeks
19 permission from the Court to file material under seal. The parties agree that this
20 protective order does not waive the parties’ rights to object to discovery demands or
21 requests for documents and/or information.
22 B. GOOD CAUSE STATEMENT
23 Defendants G. Lizaola and D. Cruz are peace officers employed by the CHP.
24 CHP is not a Defendant in this action. As a public entity, CHP has a privilege to
25 refuse to disclose official information acquired in confidence by its employees in
26 the course of his or her duty and not open, or officially disclosed, to the public prior
27 to the time the claim of privilege is made. The Court may, in any case or
28 proceeding permitting the disclosure or discovery of any peace or custodial officer
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1 records requested order that the records disclosed or discovered may not be used for
2 any purpose other than a court proceeding pursuant to applicable law. Defendants
3 anticipate Plaintiff will be seeking disclosures of peace officer records and any
4 video and audio recordings and photo images related to the traffic enforcement stop
5 and arrest at issue in this Action, which is generally unavailable to the public.
6 Additionally, Defendants may be producing investigation reports leading up to
7 Plaintiff’s arrest and criminal conviction, which are generally unavailable to the
8 public. Accordingly, to expedite the flow of information, to facilitate the prompt
9 resolution of disputes over confidentiality of discovery materials, to adequately
10 protect information the parties are entitled to keep confidential, to ensure that the
11 parties are permitted reasonable necessary uses of such material in preparation for
12 and in the conduct of trial, to address their handling at the end of the litigation, and
13 serve the ends of justice, a protective order for such information is justified in this
14 matter. It is the intent of the parties that information will not be designated as
15 confidential for tactical reasons and that nothing be so designated without a good
16 faith belief that it has been maintained in a confidential, non-public manner, and
17 there is good cause why it should not be part of the public record of this case.
18 2. DEFINITIONS
19 2.1 Action: Glen Charles Klement v. G. Lizaola, et al. Case No. EDCV-18-
20 00560-RGK (AGR)
21 2.2 Challenging Party: A Party or Non-Party that challenges the designation
22 of information or items under this Order.
23 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of
24 how it is generated, stored or maintained) or tangible things that qualify for
25 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
26 the Good Cause Statement. This also includes: (1) any information copied or
27 extracted from the Confidential Information; (2) all copies, excerpts, summaries,
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1 abstracts or compilations of Confidential Information; and (3) any testimony,
2 conversations, or presentations that might reveal Confidential Information.
3 2.4 Counsel: Counsel of record for the parties to this civil litigation and their
4 support staff.
5 2.5 Designating Party: A Party or Non-Party that designates information or
6 items that it produces in disclosures, in responses to discovery, or pursuant to court
7 order as “CONFIDENTIAL.”
8 2.6 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), that are produced
11 or generated in disclosures or responses to discovery in this matter.
12 2.7 Expert: A person with specialized knowledge or experience in a matter
13 pertinent to the litigation who has been retained by a Party or its counsel to serve as
14 an expert witness, or as a consultant in this Action.
15 2.8 Final Disposition: Final disposition shall be deemed to be the later of (1)
16 dismissal of all claims and defenses in this Action, with or without prejudice; or (2)
17 final judgment herein after the completion and exhaustion of all appeals, rehearings,
18 remands, trials, or reviews of this Action, including the time limits for filing any
19 motions or applications for extension of time pursuant to applicable law.
20 2.9 Non-Party: Any natural person, partnership, corporation, association or
21 other legal entity not named as a Party to this action.
22 2.10 Outside Counsel of Record: Attorneys who are not employees of a
23 party to this Action but are retained to represent or advise a party to this Action and
24 have appeared in this Action on behalf of that party or are affiliated with a law firm
25 that has appeared on behalf of that party, and includes support staff.
26 2.11 Party: Any party to this Action, including all of its officers, directors,
27 boards, departments, divisions, employees, consultants, retained experts, and
28 Outside Counsel of Record and their support staffs.
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1 2.12 Producing Party: A Party or Non-Party that produces Disclosure or
2 Discovery Material in this Action.
3 2.13 Professional Vendors: Persons or entities that provide litigation support
4 services (e.g., photocopying, videotaping, translating, preparing exhibits or
5 demonstrations, and organizing, storing, or retrieving data in any form or medium)
6 and their employees and subcontractors.
7 2.14 Protected Material: Any Disclosure or Discovery Material that is
8 designated as “CONFIDENTIAL.”
9 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material
10 from a Producing Party.
11 3. SCOPE
12 The protections conferred by this Stipulation and Order cover not only
13 Protected Material, as defined above, but also: (1) any information copied or
14 extracted from Protected Material; (2) all copies, excerpts, abstracts, summaries, or
15 compilations of Protected Material; and (3) any deposition testimony,
16 conversations, or presentations by Parties or their Counsel that might reveal
17 Protected Material.
18 Any use of Protected Material at trial shall be governed by the orders of the
19 trial judge. This Order does not govern the use of Protected Material at trial.
20 4. DURATION
21 Once a trial commences in this Action, and subject to any court order stating
22 otherwise, information that was designated as “CONFIDENTIAL” or maintained
23 pursuant to this protective order, and admitted at trial becomes public and will be
24 presumptively available to all members of the public, including the press, unless
25 compelling reasons supported by specific factual findings to proceed otherwise are
26 made to the trial judge in advance of the trial. See Kamakana v. City and County of
27 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
28 showing for sealing documents produced in discovery from “compelling reasons”
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1 standard when merits-related documents are part of court record). Accordingly, the
2 terms of this protective order do not extend beyond the commencement of the trial
3 as to the “CONFIDENTIAL” information and materials admitted as an exhibit at
4 trial. As to all other information designated as “CONFIDENTIAL,” even after the
5 FINAL DISPOSITION of this litigation, the confidentiality obligations imposed by
6 this protective order shall remain in effect even after FINAL DISPOSITION of this
7 litigation as defined in Section 2.8, until a Designating Party agrees otherwise in
8 writing or a court otherwise directs.
9 5. DESIGNATING PROTECTED MATERIAL
10 5.1 Exercise of Restraint and Care in Designating Material for
11 Protection.
12 Each Party or Non-Party that designates information or items for protection
13 under this Order must take care to limit any such designation to specific material
14 that qualifies under the appropriate standards. The Designating Party must
15 designate for protection only those parts of material, documents, items or oral or
16 written communications that qualify so that other portions of the material,
17 documents, items or communications for which protection is not warranted are not
18 swept unjustifiably within the ambit of this Order.
19 Mass, indiscriminate or routinized designations are prohibited. Designations
20 that are shown to be clearly unjustified or that have been made for an improper
21 purpose (e.g., to unnecessarily encumber the case development process or to
22 impose unnecessary expenses and burdens on other parties) may expose the
23 Designating Party to sanctions.
24 If it comes to a Designating Party’s attention that information or items that it
25 designated for protection do not qualify for protection that Designating Party must
26 promptly notify all other Parties that it is withdrawing the inapplicable designation.
27 5.2 Manner and Timing of Designations. Except as otherwise provided in
28 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
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1 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
2 under this Order must be clearly so designated before the material is disclosed or
3 produced.
4 Designation in conformity with this Order requires:
5 (a) for information in documentary form (e.g., paper or electronic documents,
6 but excluding transcripts of depositions or other pretrial or trial proceedings), that
7 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” or words
8 of a similar effect, and that includes the case name and case number (hereinafter
9 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
10 portion of the material on a page qualifies for protection, the Producing Party also
11 must clearly identify the protected portion(s) (e.g., by making appropriate markings
12 in the margins).
13 A Party or Non-Party that makes original documents available for inspection
14 need not designate them for protection until after the inspecting Party has indicated
15 which documents it would like copied and produced. During the inspection and
16 before the designation, all of the material made available for inspection shall be
17 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
18 documents it wants copied and produced, the Producing Party must determine
19 which documents, or portions thereof, qualify for protection under this Order. Then,
20 before producing the specified documents, the Producing Party must affix the
21 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
22 portion of the material on a page qualifies for protection, the Producing Party also
23 must clearly identify the protected portion(s), e.g., by making appropriate markings
24 in the margins.
25 (b) for testimony given in depositions that the Designating Party identifies the
26 Disclosure or Discovery Material on the record, before the close of the deposition
27 all protected testimony.
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1 (c) for information produced in some form other than documentary and for any
2 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 is stored the legend
4 “CONFIDENTIAL.” If only a portion or portions of the information warrants
5 protection, the Producing Party, to the extent practicable, shall identify the
6 protected 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
10 material. Upon timely correction of a designation, the Receiving Party must make
11 reasonable efforts to assure that the material is treated in accordance with the
12 provisions of this Order.
13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
14 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
15 designation of confidentiality at any time that is consistent with the Court’s
16 Scheduling Order.
17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
18 resolution process under Local Rule 37.1 et seq.
19 6.3 The burden of persuasion in any such challenge proceeding shall be
20 on the Designating Party. Frivolous challenges, and those made for an improper
21 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
22 parties) may expose the Challenging Party to sanctions. Unless the Designating
23 Party has waived or withdrawn the confidentiality designation, all parties shall
24 continue to afford the material in question the level of protection to which it is
25 entitled under the Producing Party’s designation until the Court rules on the
26 challenge.
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1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected Material that is
3 disclosed or produced by another Party or by a Non-Party in connection with this
4 Action only for prosecuting, defending or attempting to settle this Action. Such
5 Protected Material may be disclosed only to the categories of persons and under the
6 conditions described in this Order. When the Action has been terminated, a
7 Receiving Party must comply with the provisions of Section 13 below (FINAL
8 DISPOSITION).
9 Protected Material must be stored and maintained by a Receiving Party at a
10 location and in a secure manner that ensures that access is limited to the persons
11 authorized under this Order.
12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
13 otherwise ordered by the court or permitted in writing by the Designating Party, a
14 Receiving Party may disclose any information or item designated
15 “CONFIDENTIAL” only to:
16 (a) the Receiving Party’s Counsel of Record in this Action, as well as
17 employees of said Counsel of Record to whom it is reasonably necessary to
18 prosecute or defend this Action;
19 (b) Experts (as defined in this Order) of the Receiving Party to whom
20 disclosure is reasonably necessary to prosecute or defend this Action, and who have
21 signed the “Acknowledgment and Agreement to Be Bound” (Ex. A);
22 (c) the court and its personnel;
23 (e) court reporters and their staff;
24 (f) professional jury or trial consultants, mock jurors, and Professional
25 Vendors to whom disclosure is reasonably necessary for this Action and who have
26 signed the “Acknowledgment and Agreement to Be Bound” (Ex. A);
27 (g) the author or recipient of a document containing the information, or a
28 custodian or other person who otherwise possessed or knew the information;
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1 (h) witnesses and attorneys for witnesses during their depositions, in the
2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
3 requests that the witness sign the form attached as Exhibit “A” hereto; and (2) they
4 will not be permitted to keep any confidential information unless they sign the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit “A”), unless otherwise
6 agreed by the Designating Party or ordered by the court. Pages of transcribed
7 deposition testimony or exhibits to depositions that reveal Protected Material may
8 be separately bound by the court reporter, and may not be disclosed to anyone,
9 except as permitted under this Stipulated Protective Order; and
10 (i) any mediator or settlement officer, and their supporting personnel, mutually
11 agreed upon by any of the parties engaged in settlement discussions and who have
12 signed the “Acknowledgment and Agreement to Be Bound” (Ex. A).
13 7.3. Counsel making the disclosure to any qualified person described herein
14 shall retain the original executed copy of the Nondisclosure Agreement until sixty
15 (60) days after this litigation has become final, including any appellate review, and
16 monitoring of an injunction. Counsel for the Receiving Party shall maintain all
17 signed Nondisclosure Agreements and shall produce the original or electronic
18 signature page upon reasonable written notice from opposing counsel. If an issue
19 arises regarding a purported unauthorized disclosure of Confidential Information,
20 upon noticed motion of contempt filed by the Designating Party, counsel for the
21 Receiving Party may be required to file the signed Nondisclosure Agreements, as
22 well as a list of the disclosed materials, in camera with the Court having jurisdiction
23 of the Stipulation.
24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
25 PRODUCED IN OTHER LITIGATION
26 If a Party is served with a subpoena or a court order issued in other litigation
27 that compels disclosure of any information or items designated in this Action as
28 “CONFIDENTIAL,” that Party must:
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1 (a) promptly notify in writing the Designating Party. Such notification shall
2 include a copy of the subpoena or court order;
3 (b) promptly notify in writing the party who caused the subpoena or order to
4 issue in the other litigation that some or all of the material covered by the subpoena
5 or order is subject to this Protective Order. Such notification shall include a copy of
6 this Stipulated Protective Order; and
7 (c) cooperate with respect to all reasonable procedures sought to be pursued by
8 the Designating Party whose Protected Material may be affected.
9 The Party served with the subpoena or court order shall not produce any
10 information designated in this action as “CONFIDENTIAL”, unless the Party has
11 obtained the Designating Party’s permission or an order from the court from which
12 the subpoena or order issued. Nothing in these provisions should be construed as
13 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
14 directive from another court.
15 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
16 PRODUCED IN THIS LITIGATION
17 (a) The terms of this Order are applicable to information produced by a Non-
18 Party in this Action and designated as “CONFIDENTIAL.” Such information
19 produced by Non-Parties in connection with this litigation is protected by the
20 remedies and relief provided by this Order. Nothing in these provisions should be
21 construed as prohibiting a Non-Party from seeking additional protections.
22 (b) In the event that a Party is required, by a valid discovery request, to
23 produce a Non-Party’s confidential information in its possession, and the Party is
24 subject to an agreement with the Non-Party not to produce the Non-Party’s
25 confidential information, then the Party shall:
26 (1) promptly notify in writing the Requesting Party and the Non-Party that
27 some or all of the information requested is subject to a confidentiality agreement
28 with a Non-Party;
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1 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
2 Order in this Action, the relevant discovery request(s), and a reasonably specific
3 description of the information requested; and
4 (3) make the information requested available for inspection by the Non-Party,
5 if requested.
6 (c) If the Non-Party fails to seek a protective order from this court within 14
7 days of receiving the notice and accompanying information, the Receiving Party
8 may produce the Non-Party’s confidential information responsive to the discovery
9 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
10 not produce any information in its possession or control that is subject to the
11 confidentiality agreement with the Non-Party before a determination by the court.
12 Absent a court order to the contrary, the Non-Party shall bear the burden and
13 expense of seeking protection in this court of its Protected Material.
14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
16 Protected Material to any person or in any circumstance not authorized under this
17 Stipulated Protective Order, the Receiving Party must immediately: (a) notify in
18 writing the Designating Party of the unauthorized disclosures, (b) use its best
19 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
20 person or persons to whom unauthorized disclosures were made of all the terms of
21 this Order, and (d) confer with the Designating Party on a resolution to recall the
22 inadvertent disclosure and determine if executing the “Acknowledgment and
23 Agreement to Be Bound” is sufficient.
24 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
25 OTHERWISE PROTECTED MATERIAL
26 When a Producing Party gives notice to Receiving Parties that certain
27 inadvertently produced material is subject to a claim of privilege or other
28 protection, the obligations of the Receiving Parties are those set forth in Fed. R. C.
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1 P. 26(b)(5)(B). This provision is not intended to modify whatever procedure may be
2 established in an e-discovery order that provides for production without prior
3 privilege review. Pursuant to Fed. R. Evid. 502(d) and (e), insofar as the parties
4 reach an agreement on the effect of disclosure of a communication or information
5 covered by the attorney-client privilege or work product doctrine, the parties may
6 incorporate their agreement in the stipulated protective order submitted to the court.
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
13 this Stipulated Protective Order. Similarly, no Party waives any right to object on
14 any ground to use in evidence of any of the material covered by this Protective
15 Order.
16 12.3 Filing Protected Material. A Party that seeks to file under seal any
17 Protected Material must comply with L.R. 79-5. Protected Material may only be
18 filed under seal pursuant to a court order authorizing the sealing of the specific
19 Protected Material at issue. If a Party’s request to file Protected Material under seal
20 is denied by the court, then the Receiving Party may file the information in the
21 public record unless otherwise instructed by the court.
22 13. FINAL DISPOSITION
23 After the FINAL DISPOSITION of this Action, as defined in Section 2.8,
24 within 30 days of a written request by the Designating Party, each Receiving Party
25 must return all Protected Material to the Producing Party. As used in this
26 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
27 summaries, and any other format reproducing or capturing any of the Protected
28 Material. The Receiving Party must submit a written certification to the Producing
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1 | Party (and, if not the same person or entity, to the Designating Party) by the 30-day
2 | deadline that: (1) identifies (by category, where appropriate) all the Protected
3 | Material that was returned and (2) affirms that the Receiving Party has not retained
4 | any copies, abstracts, compilations, summaries or any other format reproducing or
5 | capturing any of the Protected Material.
6 14. VIOLATION
7 Any violation of this Order may be punished by appropriate measures
8 | including, without limitation, contempt proceedings and/or monetary sanctions,
9 | following a written motion and court order.
10 | IT ISSO STIPULATED, THROUGH COUNSEL OF RECORD.
11 Pursuant to local 5-4.3.4, the parties’ counsel concur with the content of this
12 | Stipulation for a Protective Order and have authorized the filing of the same.
Dated: April 6 , 2022 B 4% he Fugéta
BETTY CHU-FUJITA
15 DEPUTY ATTORNEY GENERAL,
Attorney for Defendants G. Lizaola and D.
16 Cruz of the California Highway Patrol
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Dated: April (po, 2022 EB □
19 TRENT THOMPSON, ESQ., Attorney for
20 Plaintiff Glen Charles Klement
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l {PROPOSED} ORDER
2 Glen Charles Klement v. G. Lizaola, et al.,
3 Case No. □□□□□□□□□□□□□□□□□□□□□□
4 | ITIS SO ORDERED.
6 | Dated: May 11, 2022 By: Mba. Ake
7 THE HONORABLE ALICIA G. ROSENBERG
UNITED STATES MAGISTRATE COURT JUDG
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1 EXHIBIT A
2 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
6 United States District Court for the Central District of California on
in the case of Glen Charles Klement v. G. Lizaola, et al., United
States District Court Case No. 5:18-cv-00560-RGK-—AGR. I agree to comply with
and to be bound by all the terms of this Stipulated Protective Order and I
10 understand and acknowledge that failure to so comply could expose me to sanctions
tI and punishment in the nature of contempt. I solemnly promise that I will not
2 disclose in any manner any information or item that is subject to this Stipulated
IS Protective Order to any person or entity except in strict compliance with the
4 provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
i Stipulated Protective Order, even if such enforcement proceedings occur after
Is termination of this action. I hereby appoint [print or type full
9 name] of [print or type full
20 address and telephone number] as my California agent for service of process in
71 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date:
24 City and State where sworn and signed:
2 Printed name:
76 Signature:
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