Opinion
Case No. CV 80-1341 TJH
09-02-2011
SUSAN L. BOUMAN, et al., Plaintiffs, v. LEROY D. BACA, et al., Defendants.
ROBERT H. PHILIBOSIAN, CBN 41515 RONDA D. JAMGOTCHIAN, CBN 200236 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership, IPC ANDREA SHERIDAN ORDIN, Cnty Cnsl JOYCE AIELLO, Asst. Cnty Cnsl MARY WICKHAM, CBN 145664 OFFICE OF COUNTY COUNSEL COUNTY OF LOS ANGELES Attorneys for Defendants DENNIS M. HARLEY, CBN 57230 DENNIS M. HARLEY, A LAW CORPORATION DELLA BAHAN, CBN 88649 BAHAN & ASSOCIATES, INC. Attorneys for Plaintiffs
ROBERT H. PHILIBOSIAN, CBN 41515
RONDA D. JAMGOTCHIAN, CBN 200236
SHEPPARD, MULLIN, RICHTER &
HAMPTON LLP
A Limited Liability Partnership, IPC
ANDREA SHERIDAN ORDIN, Cnty Cnsl
JOYCE AIELLO, Asst. Cnty Cnsl
MARY WICKHAM, CBN 145664
OFFICE OF COUNTY COUNSEL
COUNTY OF LOS ANGELES
Attorneys for Defendants
DENNIS M. HARLEY, CBN 57230
DENNIS M. HARLEY, A LAW
CORPORATION
DELLA BAHAN, CBN 88649
BAHAN & ASSOCIATES, INC.
Attorneys for Plaintiffs
PROTECTIVE ORDER COVERING ENTRY-LEVEL ATTRITION REPORT [1656]
ORDER
HAVING READ AND CONSIDERED THE PARTIES' JOINT STIPULATION REGARDING PROTECTIVE ORDER COVERING ENTRY-LEVEL ATTRITION REPORT ("JOINT STIPULATION"), AND FOR CAUSE SHOWN, IT IS HEREBY ORDERED THAT:
In recognition of the Court's April 3, 2008 Order, which calls for a protective order to be agreed upon by the Parties concerning the Confidential Information (as defined in the Joint Stipulation), IT IS HEREBY ORDERED THAT:
This Protective Order shall apply to the Attrition Report, as well as all drafts prepared by Dr. Lisa Tesvich, and the two prior drafts prepared by the Department;
The Confidential Information and all documents relating or referring to the Confidential Information shall be marked "PRIVATE AND CONFIDENTIAL" or words to that effect;
Access to such Confidential Information shall be limited to counsel for the parties to the Joint Stipulation and the experts and consultants retained to analyze and offer opinions concerning the Department's entry-level recruitment, testing, and training programs. Such Confidential Information shall be used solely for the purpose of analyzing and offering opinions on the Department's entry-level recruitment, testing, and training programs.
In the event that any person or entity violates, or threatens to violate, any of the terms of this Protective Order, the parties agree that Defendants, with appropriate notice to Plaintiffs, may apply to the Court to obtain injunctive relief against any such persons or parties violating or threatening to violate any of the terms of this Protective Order. In the event Defendants apply to the Court, the responding party, person or entity subject to the provisions of this Protective Order shall not employ as a defense thereto a claim that Defendants possess an adequate remedy at law. The parties and any other persons subject to the terms of this Protective Order agree that this Court shall retain jurisdiction over them for the purpose of enforcing this Order.
IT IS SO ORDERED.
THE HONORABLE TERRY HATTER, JR.
UNITED STATES DISTRICT JUDGE