The opinion
Case 8:17-cv-02263-SSS-JEM Document 63 Filed 10/26/22 Page 1 of 15 Page ID #:323
1 JILL WILLIAMS – State Bar No. 221793
SCOTT J. CARPENTER – State Bar No. 253339
2 CARPENTER, ROTHANS & DUMONT
500 S. Grand Avenue, 19th Floor
3 Los Angeles, CA 90071
(213) 228-0400 / (213) 228-0401 [Fax]
4 jwilliams@crdlaw.com / scarpenter@crdlaw.com
5 Attorneys for Defendants, City of Santa Ana, and
Officer Michael Heitmann
6
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 CHRIS JACKSON, individually, ) Case No.: 8:17-cv-2263-SSS-JEM
)
12 Plaintiff, ) STIPULATED PROTECTIVE
) ORDER
13 v. )
)
14 CITY OF SANTA ANA, a municipal ) [DISCOVERY DOCUMENT:
corporation; MICHAEL ) REFERRED TO MAGISTRATE
15 HEITMANN, individually and in his ) JUDGE JOHN E. MCDERMOTT]
capacity as an officer for the Santa Ana )
16 Police Department; and DOES 1-10, )
inclusive, individually and in their )
17 official capacity as police officers for )
the Santa Ana Police Department, )
18 )
Defendants. )
19 )
)
20
21 IT IS SO STIPULATED BY AND BETWEEN Plaintiff CHRIS JACKSON,
22 and Defendants CITY OF SANTA ANA, Officer MICHAEL HEITMANN, by and
23 through their respective counsel, as follows:
24 1. A. PURPOSES AND LIMITATIONS
25 Discovery in this action involves the production of medical records from
26 Patton State Hospital from public disclosure and from use for any purpose other
27 than prosecuting this litigation may be warranted. Accordingly, the parties hereby
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STIPULATED PROTECTIVE ORDER
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1 stipulate to and petition the Court to enter the following Stipulated Protective
2 Order. The parties acknowledge that this Order does not confer blanket protections
3 on all disclosures or responses to discovery and that the protection it affords from
4 public disclosure and use extends only to the limited information or items that are
5 entitled to confidential treatment under the applicable legal principles. The parties
6 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
7 Protective Order does not entitle them to file confidential information under seal;
8 Civil Local Rule 79-5 sets forth the procedures that must be followed and the
9 standards that will be applied when a party seeks permission from the court to file
10 material under seal.
11 B. GOOD CAUSE STATEMENT
12 This action involves the production of medical records from Patton State
13 Hospital for which special protection from public disclosure and from use for any
14 purpose other than prosecution of this action is warranted. Such confidential and
15 proprietary materials and information consist of private information otherwise
16 generally unavailable to the public, or which may be privileged or otherwise
17 protected from disclosure under state or federal statutes, court rules, case decisions,
18 or common law. The parties will suffer prejudice if the protective order is not
19 granted because the custodian of these records will not release the medical records
20 without a protective order signed by a judge. Accordingly, to expedite the flow of
21 information, to facilitate the prompt resolution of disputes over confidentiality of
22 discovery materials, to adequately protect information the parties are entitled to
23 keep confidential, to ensure that the parties are permitted reasonably necessary
24 uses of such material in preparation for and in the conduct of trial, to address their
25 handling at the end of the litigation, and serve the ends of justice, a protective
26 order for such information is justified in this matter. It is the intent of the parties
27 that information will not be designated as confidential for tactical reasons and that
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1 nothing be so designated without a good faith belief that it has been maintained in
2 a confidential, non-public manner, and there is good cause why it should not be
3 part of the public record of this case.
4 2. DEFINITIONS
5 2.1 Action: Jackson v. City of Santa Ana, et al., 8:17-cv-2263-SSS-JEM.
6 2.2 Challenging Party: A Party or Non-Party that challenges the
7 designation of information or items under this Order.
8 2.3 “CONFIDENTIAL” Information or Items: Information (regardless
9 of how it is generated, stored or maintained) or tangible things that a Designating
10 Party believes is entitled to confidential treatment under Federal Rule of Civil
11 Procedure 26(c), and as specified above in the Good Cause Statement.
12 This also includes (1) any information copied or extracted from the Confidential
13 information; (2) all copies, excerpts, summaries, abstracts or compilations of
14 Confidential information; and (3) any testimony, conversations, or presentations
15 that might reveal Confidential information.
16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
17 support staff).
18 2.5 Designating Party: A Party or Non-Party that designates information
19 or items that it produces in disclosures or in responses to discovery as
20 “CONFIDENTIAL.”
21 2.6 Disclosure or Discovery Material: All items or information, regardless
22 of the medium or manner in which it is generated, stored, or maintained (including,
23 among other things, testimony, transcripts, and tangible things), that are produced
24 or generated in disclosures or responses to discovery in this matter.
25 2.7 Expert: A person with specialized knowledge or experience in a matter
26 pertinent to the litigation who has been retained by a Party or its counsel to serve
27 as an expert witness or as a consultant in this Action.
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1 2.8 House Counsel: Attorneys who are employees of a party to this Action.
2 House Counsel does not include Outside Counsel of Record or any other outside
3 counsel.
4 2.9 Non-Party: Any natural person, partnership, corporation association, or
5 other legal entity not named as a Party to this action.
6 2.10 Outside Counsel of Record: attorneys who are not employees of a party
7 to this Action but are retained to represent or advise a party to this Action and have
8 appeared in this Action on behalf of that party or are affiliated with a law firm
9 which has appeared on behalf of that party, and includes support staff.
10 2.11 Party: any party to this Action, including all of its officers, directors,
11 employees, consultants, retained experts, and Outside Counsel of Record (and their
12 support staffs).
13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
14 Discovery Material in this Action.
15 2.13 Professional Vendors: persons or entities that provide litigation support
16 services (e.g., photocopying, videotaping, translating, preparing exhibits or
17 demonstrations, and organizing, storing, or retrieving data in any form or medium)
18 and their employees and subcontractors.
19 2.14 Protected Material: any Disclosure or Discovery Material that is
20 designated as “CONFIDENTIAL.”
21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
22 from a Producing Party.
23 3. SCOPE
24 The protections conferred by this Stipulation and Order cover not only
25 Protected Material (as defined above), but also (1) any information copied or
26 extracted from Protected Material; (2) all copies, excerpts, abstracts, summaries, or
27 compilations of Protected Material; and (3) any deposition testimony,
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1 conversations, or presentations by Parties or their Counsel that might reveal
2 Protected Material.
3 Any use of Protected Material at trial shall be governed by the orders of the
4 trial judge. This Order does not govern the use of Protected Material at trial.
5 4. DURATION
6 Once a case proceeds to trial, all of the information that was designated as
7 confidential or maintained pursuant to this protective order becomes public and
8 will be presumptively available to all members of the public, including the press,
9 unless compelling reasons supported by specific factual findings to proceed
10 otherwise are made to the trial judge in advance of the trial. See Kamakana v. City
11 and County of Honolulu, 447 F.3d 1172, 1180-81 (9th (distinguishing “good
12 cause” showing for sealing documents produced in discovery from “compelling
13 reasons” standard when merits-related documents are part of court record).
14 Accordingly, the terms of this protective order do not extend beyond the
15 commencement of the trial.
16 5. DESIGNATED PROTECTED MATERIAL
17 5.1 Exercise of Restraint and Care in Designating Material for Protection.
18 Each Party or Non-Party that designates information or items for protection
19 under this Order must take care to limit any such designation to specific material
20 that qualifies under the appropriate standards. The Designating Party must
21 designate for protection only those parts of material, documents, items or oral or
22 written communications that qualify so that other portions of the material,
23 documents, items or communications for which protection is not warranted are not
24 swept unjustifiably within the ambit of this Order.
25 Mass, indiscriminate or routinized designations are prohibited. Designations
26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber the case development process or to
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1 impose unnecessary expenses and burdens on other parties) may expose the
2 Designating Party to sanctions.
3 If it comes to a Designating Party’s attention that information or items that it
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6 5.2 Manner and Timing of Designations.
7 Except as otherwise provided in this Order (see, e.g., second paragraph of
8 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or
9 Discovery Material that qualifies for protection under this Order must be clearly so
10 designated before the material is disclosed or produced.
11 Designation in conformity with this Order requires:
12 (a) for information in documentary form (e.g., paper or electronic
13 documents, but excluding transcripts of depositions or other pretrial or trial
14 proceedings), that the Producing Party affix at a minimum, the legend
15 “CONFIDENTIAL” or words of a similar effect, and that includes the case name
16 and case number (hereinafter “CONFIDENTIAL legend”), to each page that
17 contains protected material. If only a portion of the material on a page qualifies for
18 protection, the Producing Party also must clearly identify the protected portion(s)
19 (e.g., by making appropriate markings in the margins).
20 A Party or Non-Party that makes original documents available for inspection
21 need not designate them for protection until after the inspecting Party has indicated
22 which documents it would like copied and produced. During the inspection and
23 before the designation, all of the material made available for inspection shall be
24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
25 documents it wants copied and produced, the Producing Party must determine
26 which documents, or portions thereof, qualify for protection under this Order.
27 Then, before producing the specified documents, the Producing Party must affix
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1 the “CONFIDENTIAL legend” to each page that contains Protected Material. If
2 only a portion of the material on a page qualifies for protection, the Producing
3 Party also must clearly identify the protected portion(s) (e.g., by making
4 appropriate markings in the margins).
5 (b) for testimony given in depositions that the Designating Party identifies
6 the Disclosure or Discovery Material on the record, before the close of the
7 deposition all protected testimony.
8 (c) for information produced in some form other than documentary and for
9 any other tangible items, that the Producing Party affix in a prominent place on the
10 exterior of the container or containers in which the information is stored the legend
11 “CONFIDENTIAL.” If only a portion or portions of the information warrants
12 protection, the Producing Party, to the extent practicable, shall identify the
13 protected portion(s).
14 5.3 Inadvertent Failures to Designate.
15 If timely corrected, an inadvertent failure to designate qualified information
16 or items does not, standing alone, waive the Designating Party’s right to secure
17 protection under this Order for such material. Upon timely correction of an
18 inadvertent failure to designate, the Receiving Party must make reasonable efforts
19 to assure that the material is treated in accordance with the provisions of this
20 Order.
21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
23 designation of confidentiality at any time that is consistent with the Court’s
24 Scheduling Order.
25 6.2 Meet and Confer. The Challenging Party shall initiate the information
26 dispute resolution process set forth in the Court’s Procedures and Schedules.
27 ///
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1 6.3 The burden of persuasion in any such challenge proceeding shall be
2 on the Designating Party. Frivolous challenges, and those made for an improper
3 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
4 parties) may expose the Challenging Party to sanctions. Unless the Designating
5 Party has waived or withdrawn the confidentiality designation, all parties shall
6 continue to afford the material in question the level of protection to which it is
7 entitled under the Producing Party’s designation until the Court rules on the
8 challenge.
9 7. ACCESS TO AND USE OF PROTECTED MATERIAL
10 7.1 Basic Principles. A Receiving Party may use Protected Material that
11 is disclosed or produced by another Party or by a Non-Party in connection with
12 this Action only for prosecuting, defending or attempting to settle this Action.
13 Such Protected Material may be disclosed only to the categories of persons and
14 under the conditions described in this Order. When the Action has been
15 terminated, a Receiving Party must comply with the provisions of section 13 below
16 (FINAL DISPOSITION).
17 Protected Material must be stored and maintained by a Receiving Party at a
18 location and in a secure manner that ensures that access is limited to the persons
19 authorized under this Order.
20 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
21 otherwise ordered by the court or permitted in writing by the Designating Party, a
22 Receiving Party may disclose any information or item designated
23 “CONFIDENTIAL” only to:
24 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
25 as employees of said Outside Counsel of Record to whom it is reasonably
26 necessary to disclose the information for this Action;
27 (b) the officers, directors, and employees (including House Counsel) of the
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1 Receiving Party to whom disclosure is reasonably necessary for this Action;
2 (c) Experts (as defined in this Order) of the Receiving Party to whom
3 disclosure is reasonably necessary for this Action and who have signed the
4 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
5 (d) the court and its personnel;
6 (e) court reporters and their staff;
7 (f) professional jury or trial consultants, mock jurors, and Professional
8 Vendors to whom disclosure is reasonably necessary for this Action and who have
9 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
10 (g) the author or recipient of a document containing the information or a
11 custodian or other person who otherwise possessed or knew the information;
12 (h) during their depositions, witnesses, and attorneys for witnesses, in the
13 Action to whom disclosure is reasonably necessary provided: (1) the deposing
14 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
15 they will not be permitted to keep any confidential information unless they sign the
16 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
17 agreed by the Designating Party or ordered by the court. Pages of transcribed
18 deposition testimony or exhibits to depositions that reveal Protected Material may
19 be separately bound by the court reporter and may not be disclosed to anyone
20 except as permitted under this Stipulated Protective Order;
21 (i) any mediator or settlement officer, and their supporting personnel,
22 mutually agreed upon by any of the parties engaged in settlement discussions.
23 discussions; and
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
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1 “CONFIDENTIAL,” that Party must:
2 (a) promptly notify in writing the Designating Party. Such notification shall
3 include a copy of the subpoena or court order;
4 (b) promptly notify in writing the party who caused the subpoena or order to
5 issue in the other litigation that some or all of the material covered by the subpoena
6 or order is subject to this Protective Order. Such notification shall include a copy
7 of this Stipulated Protective Order; and
8 (c) cooperate with respect to all reasonable procedures sought to be pursued
9 by the Designating Party whose Protected Material may be affected. If the
10 Designating Party timely seeks a protective order in the action in which the
11 subpoena or order was issued, the Party served with the subpoena or court order
12 shall not produce any information designated in this action as “CONFIDENTIAL”
13 before a determination by the court from which the subpoena or order issued,
14 unless the Party has obtained the Designating Party’s permission. The Designating
15 Party shall bear the burden and expense of seeking protection in that court of its
16 confidential material – and nothing in these provisions should be construed as
17 authorizing or encouraging a Receiving Party in this action to disobey a lawful
18 directive from another court.
19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
20 PRODUCED IN THIS LITIGATION
21 (a) The terms of this Order are applicable to information produced by a Non-
22 Party in this Action and designated as “CONFIDENTIAL.” Such information
23 produced by Non-Parties in connection with this litigation is protected by the
24 remedies and relief provided by this Order. Nothing in these provisions should be
25 construed as prohibiting a Non-Party from seeking additional protections.
26 (b) In the event that a Party is required, by a valid discovery request, to
27 produce a Non-Party’s confidential information in its possession, and the Party is
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1 subject to an agreement with the Non-Party not to produce the Non-Party’s
2 confidential information, then the Party shall:
3 (1) promptly notify in writing the Requesting Party and the Non-Party that
4 some or all of the information requested is subject to a confidentiality agreement
5 with a Non-Party;
6 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
7 Order in this Action, the relevant discovery request(s), and a reasonably specific
8 description of the information requested; and
9 (3) make the information requested available for inspection by the Non-
10 Party, if requested.
11 (c) If the Non-Party fails to seek a protective order from this court within 14
12 days of receiving the notice and accompanying information, the Receiving Party
13 may produce the Non-Party’s confidential information responsive to the discovery
14 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
15 not produce any information in its possession or control that is subject to the
16 confidentiality agreement with the Non-Party before a determination by the court.
17 Absent a court order to the contrary, the Non-Party shall bear the burden and
18 expense of seeking protection in this court of its Protected Material.
19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
20 MATERIAL
21 If a Receiving Party learns that, by inadvertence or otherwise, it has
22 disclosed Protected Material to any person or in any circumstance not authorized
23 under this Stipulated Protective Order, the Receiving Party must immediately (a)
24 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
25 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
26 the person or persons to whom unauthorized disclosures were made of all the terms
27 of this Order, and (d) request such person or persons to execute the
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1 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
2 A.
3 11. INADVERTANT PRODUCTION OF PRIVILEGED OR
4 OTHERWISE PROTECTED MATERIAL
5 When a Producing Party gives notice to Receiving Parties that certain
6 inadvertently produced material is subject to a claim of privilege or other
7 protection, the obligations of the Receiving Parties are those set forth in Federal
8 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
9 whatever procedure may be established in an e-discovery order that provides for
10 production without prior privilege review. Pursuant to Federal Rule of Evidence
11 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
12 of a communication or information covered by the attorney-client privilege or
13 work product protection, the parties may incorporate their agreement in the
14 stipulated protective order submitted to the court.
15 12. MISCELLANEOUS
16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
17 person to seek its modification by the Court in the future.
18 12.2 Right to Assert Other Objections. By stipulating to the entry of this
19 Protective Order, no Party waives any right it otherwise would have to object to
20 disclosing or producing any information or item on any ground not addressed in
21 this Stipulated Protective Order. Similarly, no Party waives any right to object on
22 any ground to use in evidence of any of the material covered by this Protective
23 Order.
24 12.3 Filing Protected Material. A Party that seeks to file under seal any
25 Protected Material must comply with Local Civil Rule 79-5. Protected Material
26 may only be filed under seal pursuant to a court order authorizing the sealing of the
27 specific Protected Material at issue. If a Party’s request to file Protected Material
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1 under seal is denied by the court, then the Receiving Party may file the information
2 in the public record unless otherwise instructed by the court.
3 13. FINAL DISPOSITION
4 After the final disposition of this Action, as defined in paragraph 4, within
5 60 days of a written request by the Designating Party, each Receiving Party must
6 return all Protected Material to the Producing Party or destroy such material. As
7 used in this subdivision, “all Protected Material” includes all copies, abstracts,
8 compilations, summaries, and any other format reproducing or capturing any of the
9 Protected Material. Whether the Protected Material is returned or destroyed, the
10 Receiving Party must submit a written certification to the Producing Party (and, if
11 not the same person or entity, to the Designating Party) by the 60 day deadline that
12 (1) identifies (by category, where appropriate) all the Protected Material that was
13 returned or destroyed and (2) affirms that the Receiving Party has not retained any
14 copies, abstracts, compilations, summaries or any other format reproducing or
15 capturing any of the Protected Material. Notwithstanding this provision, Counsel
16 are entitled to retain an archival copy of all pleadings, motion papers, trial,
17 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
18 and trial exhibits, expert reports, attorney work product, and consultant and expert
19 work product, even if such materials contain Protected Material. Any such archival
20 copies that contain or 28 constitute Protected Material remain subject to this
21 Protective Order as set forth in Section 4 (DURATION).
22 14. Any violation of this Order may be punished by appropriate measures
23 including, without limitation, contempt proceedings and/or monetary sanctions.
24 ///
25 ///
26 ///
27 ///
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1 |} IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
3 |} DATED: October , 2022 LAW OFFICES OF JOHN L. BURRIS
6 By: _/s/
7 John L. Burris
DeWitt M. Lacy
8 Julia N. Quesada
9 Lena P. Andrew
Attorneys for Plaintiff
10
11 |] DATED: October 17, 2022 CARPENTER, ROTHANS & DUMONT
12
13
14 By: /s/ Jill Williams
15 Jill Williams
Scott J. Carpenter
16 Attorneys for Defendant
17 City of Santa Ana
18
19
20
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21
Dated: October 26, 2022 By:
23 HONORABLE JOHN E. MCDERMOTT
24 UNITED STATES MAGISTRATE JUDGE
25
26
27
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1 EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
I__________________________ [print or type full name] of
4
_______________________________________ [print or type full address and
5
telephone number declare under penalty of perjury that I have read in its entirety
6
and understand the Stipulated Protective Order that was issued by the United
7
States District Court for the Central District of California on ________________
8
in the case of Jackson v. City of Santa Ana, et al., 8:17-cv-2263-SSS-JEM. I agree
9
to comply with and to be bound by all the terms of this Stipulated Protective Order
10
and I understand and acknowledge that failure to so comply could expose me to
11
sanctions and punishment in the nature of contempt. I solemnly promise that I will
12
not disclose in any manner any information or item that is subject to this Stipulated
13
Protective Order to any person or entity except in strict compliance with the
14
provisions of this Order.
15
I further agree to submit to the jurisdiction of the United States District
16
Court for the Central District of California for the purpose of enforcing the terms
17
of this Stipulated Protective Order, even if such enforcement proceedings occur
18
after termination of this action. I hereby appoint __________________________
19
[print or type full name] of _______________________________________ [print
20
or type full address and telephone number] as my California agent for service of
21
process in connection with this action or any proceedings related to enforcement of
22
this Stipulated Protective Order.
23
Date: ______________________________________
24
City and State where sworn and signed: ________________________________
25
Printed name: _______________________________
26
Signature: __________________________________
27
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