Gabriela Koutantos v. County of Los Angeles

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12 UNITED STATES DISTRICT COURT

13 CENTRAL DISTRICT OF CALIFORNIA

14 GABRIELA KOUTANTOS and Case No.: 2:23-cv-08592-HDV (RAOx)

BARBARA KAPPOS,

15 [Assigned to the Honorable Hernán D.

Vera - Department 5B]

16 Plaintiff,

17 v. STIPULATED PROTECTIVE ORDER1

18 COUNTY OF LOS ANGELES; and

DOES 1- 10. Complaint Filed: October 12, 2023

19 Discovery Cut-Off: Not Set

Defendants. Motion Cut-Off: Not Set

20 Trial: Not Set

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1 This Stipulated Protective Order is substantially based on the model protective order

28 provided under Magistrate Judge Rozella A. Oliver’s Procedures.

1 1. A. PURPOSES AND LIMITATIONS

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

3 proprietary or private information for which special protection from public disclosure

4 and from use for any purpose other than prosecuting this litigation may be warranted.

5 Accordingly, the parties hereby stipulate to and petition the Court to enter the following

6 Stipulated Protective Order. The parties acknowledge that this Order does not confer

7 blanket protections on all disclosures or responses to discovery and that the protection it

8 affords from public disclosure and use extends only to the limited information or items

9 that are entitled to confidential treatment under the applicable legal principles.

10 B. GOOD CAUSE STATEMENT

11 1. This action involves the County of Los Angeles and members of the Los

12 Angeles County Sheriff’s Department. Plaintiffs intend to seek materials and

13 information that Defendant contends are confidential, such as personnel files of the

14 deputies involved in the incident. Defendant contends that this action is likely to

15 involve confidential, proprietary, official, and/or private law enforcement and police

16 personnel information for which special protection from public disclosure and from use

17 for any purpose other than prosecution of this action is warranted. Defendant contends

18 that such confidential and proprietary materials and information consist of, among other

19 things, confidential proprietary information/or private personnel police information,

20 regarding confidential contained in police personnel files, official law enforcement

21 investigative information, information otherwise generally unavailable to the public, or

22 which may be privileged or otherwise protected from disclosure under state or federal

23 statutes, court rules, case decisions, or common law.

24 Defendant may seek information such as Plaintiffs’ medical records that

25 Plaintiffs believe are highly sensitive, confidential, and are legally protected from

26 disclosure. See Wooden v. Comprehensive Health Mgmt., No. 20-00053 LEK-WRP,

27 2021 U.S. Dist. LEXIS 101889, at *3 (D. Haw. May 28, 2021) (“[M]edical records are

28 confidential, as recognized under the Health Insurance Portability and Accountability

1 Act of 1996.”); Pratt v. Gamboa, No. 17-CV-04375-LHK, 2020 U.S. Dist. LEXIS

2 90913, at *5 (N.D. Cal. May 22, 2020) (same). Plaintiffs contend that the undue

3 disclosure of such information creates a specific risk of embarrassment, emotional

4 harm, reputational harm, and professional harm.

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

6 resolution of disputes over confidentiality of discovery materials, to adequately protect

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

8 permitted reasonable necessary uses of such material in preparation for and in the

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

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

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

12 reasons and that nothing be so designated without a good faith belief that it has been

13 maintained in a confidential, non-public manner, and there is good cause why it should

14 not be part of the public record of this case.

15 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

16 The parties further acknowledge, as set forth in Section 12.3, below, that this

17 Stipulated Protective Order does not entitle them to file confidential information under

18 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the

19 standards that will be applied when a party seeks permission from the court to file

20 material under seal.

21 There is a strong presumption that the public has a right of access to judicial

22 proceedings and records in civil cases. In connection with non-dispositive motions,

23 good cause must be shown to support a filing under seal. See Kamakana v. City and

24 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors

25 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc.,

26 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

27 cause showing), and a specific showing of good cause or compelling reasons with

28 proper evidentiary support and legal justification, must be made with respect to

1 Protected Material that a party seeks to file under seal. The parties’ mere designation of

2 Disclosure or Discovery Material as CONFIDENTIAL does not—without the

3 submission of competent evidence by declaration, establishing that the material sought

4 to be filed under seal qualifies as confidential, privileged, or otherwise protectable—

5 constitute good cause.

6 Further, if a party requests sealing related to a dispositive motion or trial, then

7 compelling reasons, not only good cause, for the sealing must be shown, and the relief

8 sought shall be narrowly tailored to serve the specific interest to be protected. See

9 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item

10 or type of information, document, or thing sought to be filed or introduced under seal in

11 connection with a dispositive motion or trial, the party seeking protection must

12 articulate compelling reasons, supported by specific facts and legal justification, for the

13 requested sealing order. Again, competent evidence supporting the application to file

14 documents under seal must be provided by declaration.

15 Any document that is not confidential, privileged, or otherwise protectable in its

16 entirety will not be filed under seal if the confidential portions can be redacted. If

17 documents can be redacted, then a redacted version for public viewing, omitting only

18 the confidential, privileged, or otherwise protectable portions of the document shall be

19 filed. Any application that seeks to file documents under seal in their entirety should

20 include an explanation of why redaction is not feasible.

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22 2. DEFINITIONS

23 2.1 Action: Koutantos v. County of Los Angeles, 2:23-cv-08592-HDV (RAOx)

24 2.2 Challenging Party: a Party or Non-Party that challenges the designation of

25 information or items under this Order.

26 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how

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

28 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

1 Statement.

2 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

3 support staff).

4 2.5 Designating Party: a Party or Non-Party that designates information or

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

6 “CONFIDENTIAL.”

7 2.6 Disclosure or Discovery Material: all items or information, regardless of

8 the medium or manner in which it is generated, stored, or maintained (including, among

9 other things, testimony, transcripts, and tangible things) that are produced or generated

10 in disclosures or responses to discovery in this matter.

11 2.7 Expert: a person with specialized knowledge or experience in a matter

12 pertinent to the litigation who has been retained by a Party or its counsel to serve as an

13 expert witness or as a consultant in this Action.

14 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

16 counsel.

17 2.9 Non-Party: any natural person, partnership, corporation, association or

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

19 2.10 Outside Counsel of Record: attorneys who are not employees of a party to

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

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

22 appeared on behalf of that party, and includes support staff.

23 2.11 Party: any party to this Action, including all of its officers, directors,

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

25 support staffs).

26 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

27 Discovery Material in this Action.

28 2.13 Professional Vendors: persons or entities that provide litigation support

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

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

3 their employees and subcontractors.

4 2.14 Protected Material: any Disclosure or Discovery Material that is

5 designated as “CONFIDENTIAL.”

6 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

7 from a Producing Party.

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9 3. SCOPE

10 The protections conferred by this Stipulation and Order cover not only Protected

11 Material (as defined above), but also (1) any information copied or extracted from

12 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

13 Material; and (3) any testimony, conversations, or presentations by Parties or their

14 Counsel that might reveal Protected Material.

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

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

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18 4. DURATION

19 Once a case proceeds to trial, information that was designated as

20 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as

21 an exhibit at trial becomes public and will be presumptively available to all members of

22 the public, including the press, unless compelling reasons supported by specific factual

23 findings to proceed otherwise are made to the trial judge in advance of the trial. See

24 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing

25 documents produced in discovery from “compelling reasons” standard when merits-

26 related documents are part of court record). Accordingly, the terms of this protective

27 order do not extend beyond the commencement of the trial.

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1 5. DESIGNATING PROTECTED MATERIAL

2 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

5 under the appropriate standards. The Designating Party must designate for protection

6 only those parts of material, documents, items or oral or written communications that

7 qualify so that other portions of the material, documents, items or communications for

8 which protection is not warranted are not swept unjustifiably within the ambit of this

9 Order.

10 Mass, indiscriminate or routinized designations are prohibited. Designations that

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

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

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

14 to sanctions.

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

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

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

18 5.2 Manner and Timing of Designations. Except as otherwise provided in this

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

20 ordered, Disclosure or Discovery Material that qualifies for protection under this Order

21 must be clearly so designated before the material is disclosed or produced.

22 Designation in conformity with this Order requires:

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

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

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

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

27 portion of the material on a page qualifies for protection, the Producing Party also must

28 clearly identify the protected portion(s) (e.g., by making appropriate markings in the

1 margins).

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

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

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

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

6 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

7 copied and produced, the Producing Party must determine which documents, or portions

8 thereof, qualify for protection under this Order. Then, before producing the specified

9 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page

10 that contains Protected Material. If only a portion of the material on a page qualifies for

11 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,

12 by making appropriate markings in the margins).

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

14 Disclosure or Discovery Material on the record, before the close of the deposition all

15 protected testimony.

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

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

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

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

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

21 portion(s).

22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

25 timely correction of a designation, the Receiving Party must make reasonable efforts to

26 assure that the material is treated in accordance with the provisions of this Order.

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1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

4 Order.

5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

6 resolution process under Local Rule 37.1 et seq.

7 6.3 The burden of persuasion in any such challenge proceeding shall be on the

8 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

9 to harass or impose unnecessary expenses and burdens on other parties) may expose the

10 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

11 the confidentiality designation, all parties shall continue to afford the material in

12 question the level of protection to which it is entitled under the Producing Party’s

13 designation until the Court rules on the challenge.

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15 7. ACCESS TO AND USE OF PROTECTED MATERIAL

16 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

21 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

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

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

24 authorized under this Order.

25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

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

27 may disclose any information or item designated “CONFIDENTIAL” only to:

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

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

2 disclose the information for this Action;

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

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

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

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

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

8 (d) the court and its personnel;

9 (e) court reporters and their staff;

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

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

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

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

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

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

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

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

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

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

20 by the Designating Party or ordered by the court. Pages of transcribed deposition

21 testimony or exhibits to depositions that reveal Protected Material may be separately

22 bound by the court reporter and may not be disclosed to anyone except as permitted

23 under this Stipulated Protective Order; and

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

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

26 / / /

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1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

2 IN OTHER LITIGATION

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

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

5 “CONFIDENTIAL,” that Party must:

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

7 include a copy of the subpoena or court order;

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

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

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

11 Stipulated Protective Order; and

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

13 by the Designating Party whose Protected Material may be affected.

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

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

16 “CONFIDENTIAL” before a determination by the court from which the subpoena or

17 order issued, unless the Party has obtained the Designating Party’s permission. The

18 Designating Party shall bear the burden and expense of seeking protection in that court

19 of its confidential material and nothing in these provisions should be construed as

20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

21 directive from another court.

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

24 IN THIS LITIGATION

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

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

27 by Non-Parties in connection with this litigation is protected by the remedies and relief

28 provided by this Order. Nothing in these provisions should be construed as prohibiting

1 a Non-Party from seeking additional protections.

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

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

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

5 information, then the Party shall:

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

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

8 Non-Party;

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

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

11 specific description of the information requested; and

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

13 Party, if requested.

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

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

16 produce the Non-Party’s confidential information responsive to the discovery request.

17 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

18 any information in its possession or control that is subject to the confidentiality

19 agreement with the Non-Party before a determination by the court. Absent a court order

20 to the contrary, the Non-Party shall bear the burden and expense of seeking protection

21 in this court of its Protected Material.

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23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

27 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

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

1 whom unauthorized disclosures were made of all the terms of this Order, and (d)

2 request such person or persons to execute the “Acknowledgment and Agreement to Be

3 Bound” that is attached hereto as Exhibit A.

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5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

6 PROTECTED MATERIAL

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

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

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

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

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

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

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

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

15 parties may incorporate their agreement in the stipulated protective order submitted to

16 the court.

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18 12. MISCELLANEOUS

19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

21 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

26 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

1 Protected Material at issue. If a Party’s request to file Protected Material under seal is

2 denied by the court, then the Receiving Party may file the information in the public

3 record unless otherwise instructed by the court.

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5 13. FINAL DISPOSITION

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

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

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

9 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

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

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

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

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

14 category, where appropriate) all the Protected Material that was returned or destroyed

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

16 compilations, summaries or any other format reproducing or capturing any of the

17 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

18 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,

19 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney

20 work product, and consultant and expert work product, even if such materials contain

21 Protected Material. Any such archival copies that contain or constitute Protected

22 Material remain subject to this Protective Order as set forth in Section 4 (DURATION).

23 / / /

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25 / / /

26 / / /

27 / / /

28 / / /

1 | 14. VIOLATION

2 Any violation of this Order may be punished by appropriate measures including,

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

4

5 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

6

7 | DATED: 2/28/2024

8

9 /s/ Brian Olney

10 | Attorneys for Plaintiffs

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12

13 | DATED: 2/28/2024

14

15 /s/ Janet Keuper

16 | Attorneys for Defendant

17

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

20

21 | DATED: 2/28/2024

22 .

»| Rapehis, a.

24 | HON. ROZELLA A. OLIVER

25 | United States Magistrate Judge

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JOINT RIT E26/M REPORT..~— -|4-

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

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

5 [print or type full address], declare under penalty of perjury that I have read in its

6 entirety and understand the Stipulated Protective Order that was issued by the United

7 States District Court for the Central District of California on [date] in the case of

8 Gabriela Koutantos, et al. v County of Los Angeles, et al.; Case No.: 2:23-cv-08592-

9 HDV (RAOx). 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 comply

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

12 promise that I will not disclose in any manner any information or item that is subject to

13 this Stipulated Protective Order to any person or entity except in strict compliance with

14 the provisions of this Order.

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

16 Central District of California for enforcing the terms of this Stipulated Protective Order,

17 even if such enforcement proceedings occur after termination of this action. I hereby

18 appoint __________________________ [print or type full name] of

19 _______________________________________ [print or type full address and

20 telephone number] as my California agent for service of process in connection with this

21 action or any proceedings related to enforcement of this Stipulated Protective Order.

22 Date: ______________________________________

23 City and State where sworn and signed: _________________________________

24

25 Printed name: _______________________________

26

27 Signature: __________________________________

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