Marco Antonio Pescina v. City of Santa Ana

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 1 of 14 Page ID #:137

1 JILL WILLIAMS – State Bar No. 221793

KIMBERLY MOROSI – State Bar No. 345641

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 / kmorosi@crdlaw.com

5

Attorneys for Defendants

6

7

8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10

11

MARCO ANTONIO PESCINA, ) Case No.: 8:20-cv-01781-CJC-DFM

12 )

Plaintiff, ) ORDER ON

13 )

v. ) STIPULATED PROTECTIVE

14 ) ORDER

CITY OF SANTA ANA; GERARADO )

15 RAYA; RONALD SANDOVAL; and )

DOES 1-50, et al. )

16 ) [DISCOVERY DOCUMENT:

Defendants. ) REFERRED TO MAGISTRATE

17 ) JUDGE]

)

18 )

)

19

IT IS SO STIPULATED BY AND BETWEEN Plaintiff MARCO

20

ANTONIO PESCINA, and Defendants CITY OF SANTA ANA, DETECTIVE

21

GERARDO RAYA, and DETECTIVE RONALD SANDOVAL, by and through

22

their respective counsel, as follows:

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

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STIPULATED PROTECTIVE ORDER

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 2 of 14 Page ID #:138

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

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

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

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

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

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

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

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

9 party seeks permission from the court to file material under seal.

10 B. GOOD CAUSE STATEMENT

11 This action is likely to involve proprietary and confidential information for

12 which special protection from public disclosure and from use for any purpose other

13 than prosecution of this action is warranted. Such confidential and proprietary

14 materials and information include those not otherwise generally unavailable to the

15 public, or which may be privileged or otherwise protected from disclosure under

16 state or federal statutes, court rules, case decisions, or common law. Accordingly,

17 to expedite the flow of information, to facilitate the prompt resolution of disputes

18 over confidentiality of discovery materials, to adequately protect information the

19 parties are entitled to keep confidential, to ensure that the parties are permitted

20 reasonably necessary uses of such material in preparation for and in the conduct of

21 trial, to address their handling at the end of the litigation, and serve the ends of

22 justice, a protective order for such information is justified in this matter. It is the

23 intent of the parties that information will not be designated as confidential for

24 tactical reasons and that nothing be so designated without a good faith belief that it

25 has been maintained in a confidential, non-public manner, and there is good cause

26 why it should not be part of the public record of this case.

27 ///

28 ///

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STIPULATED PROTECTIVE ORDER

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 3 of 14 Page ID #:139

1 2. DEFINITIONS

2 2.1 Action: Marco Antonio Pescina v. City of Santa Ana, et al., 8:20-cv-

3 01781-CJC-DFM.

4 2.2 Challenging Party: A Party or Non-Party that challenges the

5 designation of information or items under this Order.

6 2.3 “CONFIDENTIAL” Information or Items: Information (regardless

7 of how it is generated, stored or maintained) or tangible things that a Designating

8 Party believes is entitled to confidential treatment under Federal Rule of Civil

9 Procedure 26(c), and as specified above in the Good Cause Statement.

10 This also includes (1) any information copied or extracted from the Confidential

11 information; (2) all copies, excerpts, summaries, abstracts or compilations of

12 Confidential information; and (3) any testimony, conversations, or presentations

13 that might reveal Confidential information.

14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

15 support staff).

16 2.5 Designating Party: A Party or Non-Party that designates information

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

18 “CONFIDENTIAL.”

19 2.6 Disclosure or Discovery Material: All items or information, regardless

20 of the medium or manner in which it is generated, stored, or maintained (including,

21 among other things, testimony, transcripts, and tangible things), that are produced

22 or generated in disclosures or responses to discovery in this matter.

23 2.7 Expert: A person with specialized knowledge or experience in a matter

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

25 as an expert witness or as a consultant in this Action.

26 2.8 House Counsel: Attorneys who are employees of a party to this Action.

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

28 counsel.

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STIPULATED PROTECTIVE ORDER

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1 2.9 Non-Party: Any natural person, partnership, corporation association, or

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

3 2.10 Outside Counsel of Record: attorneys who are not employees of a party

4 to this Action but are retained to represent or advise a party to this Action and have

5 appeared in this Action on behalf of that party or are affiliated with a law firm

6 which has appeared on behalf of that party and includes support staff.

7 2.11 Party: any party to this Action, including all of its officers, directors,

8 employees, consultants, retained experts, and Outside Counsel of Record (and their

9 support staffs).

10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

11 Discovery Material in this Action.

12 2.13 Professional Vendors: persons or entities that provide litigation support

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

14 demonstrations, and organizing, storing, or retrieving data in any form or medium)

15 and their employees and subcontractors.

16 2.14 Protected Material: any Disclosure or Discovery Material that is

17 designated as “CONFIDENTIAL.”

18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

19 from a Producing Party.

20 3. SCOPE

21 The protections conferred by this Stipulation and Order cover not only

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

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

24 compilations of Protected Material; and (3) any deposition testimony,

25 conversations, or presentations by Parties or their Counsel that might reveal

26 Protected Material.

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

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

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STIPULATED PROTECTIVE ORDER

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1 4. DURATION

2 Once a case proceeds to trial, all of the information that was designated as

3 confidential or maintained pursuant to this protective order becomes public and

4 will be presumptively available to all members of the public, including the press,

5 unless compelling reasons supported by specific factual findings to proceed

6 otherwise are made to the trial judge in advance of the trial. See Kamakana v. City

7 and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing

8 “good cause” showing for sealing documents produced in discovery from

9 “compelling reasons” standard when merits-related documents are part of court

10 record). Accordingly, the terms of this protective order do not extend beyond the

11 commencement of the trial.

12 5. DESIGNATED PROTECTED MATERIAL

13 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

16 that qualifies under the appropriate standards. The Designating Party must

17 designate for protection only those parts of material, documents, items or oral or

18 written communications that qualify so that other portions of the material,

19 documents, items or communications for which protection is not warranted are not

20 swept unjustifiably within the ambit of this Order.

21 Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

24 impose unnecessary expenses and burdens on other parties) may expose the

25 Designating Party to sanctions.

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

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

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

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STIPULATED PROTECTIVE ORDER

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 6 of 14 Page ID #:142

1 5.2 Manner and Timing of Designations.

2 Except as otherwise provided in this Order (see, e.g., second paragraph of

3 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or

4 Discovery Material that qualifies for protection under this Order must be clearly so

5 designated before the material is disclosed or produced.

6 Designation in conformity with this Order requires:

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

8 documents, but excluding transcripts of depositions or other pretrial or trial

9 proceedings), that the Producing Party affix at a minimum, the legend

10 “CONFIDENTIAL” or words of a similar effect, and that includes the case name

11 and case number (hereinafter “CONFIDENTIAL legend”), to each page that

12 contains protected material. If only a portion of the material on a page qualifies for

13 protection, the Producing Party also must clearly identify the protected portion(s)

14 (e.g., by making appropriate markings in the margins).

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

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

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

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

19 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

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

21 which documents, or portions thereof, qualify for protection under this Order.

22 Then, before producing the specified documents, the Producing Party must affix

23 the “CONFIDENTIAL legend” to each page that contains Protected Material. If

24 only a portion of the material on a page qualifies for protection, the Producing

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

26 appropriate markings in the margins).

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

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

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STIPULATED PROTECTIVE ORDER

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 7 of 14 Page ID #:143

1 deposition all protected testimony.

2 (c) for information produced in some form other than documentary and for

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

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

5 “CONFIDENTIAL.” If only a portion or portions of the information warrants

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

7 protected portion(s).

8 5.3 Inadvertent Failures to Designate.

9 If timely corrected, an inadvertent failure to designate qualified information

10 or items does not, standing alone, waive the Designating Party’s right to secure

11 protection under this Order for such material. Upon timely correction of an

12 inadvertent failure to designate, the Receiving Party must make reasonable efforts

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

14 Order.

15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

18 Scheduling Order.

19 6.2 Meet and Confer. The Challenging Party shall initiate the information

20 dispute resolution process set forth in the Court’s Procedures and Schedules.

21 6.3 The burden of persuasion in any such challenge proceeding shall be

22 on the Designating Party. Frivolous challenges, and those made for an improper

23 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

24 parties) may expose the Challenging Party to sanctions. Unless the Designating

25 Party has waived or withdrawn the confidentiality designation, all parties shall

26 continue to afford the material in question the level of protection to which it is

27 entitled under the Producing Party’s designation until the Court rules on the

28 challenge.

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STIPULATED PROTECTIVE ORDER

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 8 of 14 Page ID #:144

1 7. ACCESS TO AND USE OF PROTECTED MATERIAL

2 7.1 Basic Principles. A Receiving Party may use Protected Material that

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

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

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

6 under the conditions described in this Order. When the Action has been

7 terminated, a Receiving Party must comply with the provisions of section 13 below

8 (FINAL 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 Outside Counsel of Record in this Action, as well

17 as employees of said Outside Counsel of Record to whom it is reasonably

18 necessary to disclose the information for this Action;

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

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

21 (c) Experts (as defined in this Order) of the Receiving Party to whom

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

23 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

24 (d) the court and its personnel;

25 (e) court reporters and their staff;

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

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

28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

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STIPULATED PROTECTIVE ORDER

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 9 of 14 Page ID #:145

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

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

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

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

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

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

7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

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

9 deposition testimony or exhibits to depositions that reveal Protected Material may

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

11 except as permitted under this Stipulated Protective Order;

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

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

14 discussions; and

15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

16 PRODUCED IN OTHER LITIGATION

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

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

19 “CONFIDENTIAL,” that Party must:

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

21 include a copy of the subpoena or court order;

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

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

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

25 of this Stipulated Protective Order; and

26 (c) cooperate with respect to all reasonable procedures sought to be pursued

27 by the Designating Party whose Protected Material may be affected. If the

28 Designating Party timely seeks a protective order in the action in which the

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STIPULATED PROTECTIVE ORDER

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 10 of 14 Page ID #:146

1 subpoena or order was issued, the Party served with the subpoena or court order

2 shall not produce any information designated in this action as “CONFIDENTIAL”

3 before a determination by the court from which the subpoena or order issued,

4 unless the Party has obtained the Designating Party’s permission. The Designating

5 Party shall bear the burden and expense of seeking protection in that court of its

6 confidential material – and nothing in these provisions should be construed as

7 authorizing or encouraging a Receiving Party in this action to disobey a lawful

8 directive from another court.

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

10 PRODUCED IN THIS LITIGATION

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

12 Party in this Action and designated as “CONFIDENTIAL.” Such information

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

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

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

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

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

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

19 confidential information, then the Party shall:

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

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

22 with a Non-Party;

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

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

25 description of the information requested; and

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

27 Party, if requested.

28 (c) If the Non-Party fails to seek a protective order from this court within 14

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STIPULATED PROTECTIVE ORDER

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 11 of 14 Page ID #:147

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

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

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

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

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

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

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

8 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

10 disclosed Protected Material to any person or in any circumstance not authorized

11 under this Stipulated Protective Order, the Receiving Party must immediately (a)

12 notify in writing the Designating Party of the unauthorized disclosures, (b) use its

13 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform

14 the person or persons to whom unauthorized disclosures were made of all the terms

15 of this Order, and (d) request such person or persons to execute the

16 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

17 A.

18 11. INADVERTANT PRODUCTION OF PRIVILEGED OR

19 OTHERWISE PROTECTED MATERIAL

20 When a Producing Party gives notice to Receiving Parties that certain

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

22 protection, the obligations of the Receiving Parties are those set forth in Federal

23 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

24 whatever procedure may be established in an e-discovery order that provides for

25 production without prior privilege review. Pursuant to Federal Rule of Evidence

26 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

27 of a communication or information covered by the attorney-client privilege or

28 work product protection, the parties may incorporate their agreement in the

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STIPULATED PROTECTIVE ORDER

Case 8:20-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page 12 of 14 Page ID #:148

1 stipulated protective order submitted to the court.

2 12. MISCELLANEOUS

3 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

5 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

10 Order.

11 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

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

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

16 in the public record unless otherwise instructed by the court.

17 13. FINAL DISPOSITION

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

19 60 days of a written request by the Designating Party, each Receiving Party must

20 return all Protected Material to the Producing Party or destroy such material. As

21 used in this subdivision, “all Protected Material” includes all copies, abstracts,

22 compilations, summaries, and any other format reproducing or capturing any of the

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

24 Receiving Party must submit a written certification to the Producing Party (and, if

25 not the same person or entity, to the Designating Party) by the 60 day deadline that

26 (1) identifies (by category, where appropriate) all the Protected Material that was

27 returned or destroyed and (2)affirms that the Receiving Party has not retained any

28 copies, abstracts, compilations, summaries or any other format reproducing or

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STIPULATED PROTECTIVE ORDER

Case 8:40-cv-01781-CJC-DFM Document 29 Filed 02/27/23 Page130f14 Page ID #:149

1 || capturing any of the Protected Material. Notwithstanding this provision, Counsel

2 entitled to retain an archival copy of all pleadings, motion papers, trial,

3 || deposition, and hearing transcripts, legal memoranda, correspondence, deposition

4 |/and trial exhibits, expert reports, attorney work product, and consultant and expert

5 || work product, even if such materials contain Protected Material. Any such archival

6 || copies that contain or 28 constitute Protected Material remain subject to this

7 || Protective Order as set forth in Section 4 (DURATION).

8 14. Any violation of this Order may be punished by appropriate measures

9 ||including, without limitation, contempt proceedings and/or monetary sanctions.

10

11 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

12

13 || DATED: January 25, 2023 GUIZAR, HENDERSON & CARRAZCO, LLP

14

15 By: _/s/ KentHenderson |

Humberto Guizar

16 Kent M. Henderson

17 Angel Carrazco

1g Attorneys for Plaintiff

DATED: January 25,2023 =CARPENTER, ROTHANS & DUMONT

19

50 By:__/s/ Jill Wilhams

Jill Williams

21 Kimberly Morosi

22 Attorneys for Defendants

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

24

Dated: February 27, 2023

25

6 43,2

26 HONORA@LE DOUGLAS F. MCCORMICK

27 UNITED OoTATTIC AAA GSTPATE TTTINGE

28

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STIPULATED PROTECTIVE ORDER

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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 Marco Antonio Pescina v. City of Santa Ana, et al., 8:20-cv-01781-

9

CJC-DFM. I agree to comply with and to be bound by all the terms of this

10

Stipulated Protective Order and I understand and acknowledge that failure to so

11

comply could expose me to sanctions and punishment in the nature of contempt. I

12

solemnly promise that I will not disclose in any manner any information or item

13

that is subject to this Stipulated Protective Order to any person or entity except in

14

strict compliance with the 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

24

Date: ______________________________________

25

City and State where sworn and signed: ________________________________

26

Printed name: _______________________________

27

Signature: __________________________________

28

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STIPULATED PROTECTIVE ORDER