Opinion
STIPULATED PROTECTIVE ORDER and ORDER
SHEILA K. OBERTO, Magistrate Judge.
IT IS HEREBY STIPULATED by and between the attorneys for the parties in the above-entitled action to enter into the following protective order regarding the exchange of documents during the discovery process.
Protective Order:
2. Counsel for the Plaintiff shall not convey, transfer, publish, distribute, copy, duplicate or disseminate the information so provided except as may be reasonably necessary for the prosecution of this litigation, by communicating with Plaintiff, or investigators, consultants and experts retained on behalf of the plaintiff in this matter.
4. Plaintiff, Plaintiff's counsel, and Plaintiff's investigators, consultants and experts, are expressly prohibited from utilizing the disclosed information for any purpose other than the prosecution of Mario Peralez v. Former Fresno Police Officer Gregory Catton; Fresno Police Officer Robert Martinez; Fresno Police Officer Robert Thompson; the City of Fresno; Does 3-20, Case No. 1:14-cv-00436 SKO, and the information disclosed shall not be utilized in any other proceeding or litigation, or for any other purpose.
5. Plaintiff, Plaintiff's counsel, and Plaintiff's investigators, consultants and experts, are expressly prohibited from disclosing orally or otherwise the information subject to this Protective Order to any person other than those who are reasonably necessary for the prosecution of Mario Peralez v. Former Fresno Police Officer Gregory Catton; Fresno Police Officer Robert Martinez; Fresno Police Officer Robert Thompson; the City of Fresno; Does 3-20, Case No. 1:14-cv-00436 SKO.
6. Plaintiff, Plaintiff's counsel, and Plaintiff's investigators, consultants and experts, are expressly prohibited from duplicating, copying or otherwise distributing or disseminating any of the disclosed information to any person or entity.
7. Counsel for each party shall take reasonable precaution to prevent the unauthorized or inadvertent disclosure of any of the protected information.
8. In the event anyone shall violate or threaten to violate any terms of this Protective Order, the aggrieved party may immediately apply to obtain relief to this court against any such person violating or threatening to violate any of the terms of this order. This Court shall retain jurisdiction over the parties and any other persons subject to the terms of this order for the purpose of enforcing this order. The Court shall have the power to impose whatever penalties it deems appropriate for the violation of said order, including, but not limited to, monetary and judicial sanctions and contempt.
Bruce D. Praet, FERGUSON, PRAET & SHERMAN, Santa Ana, California, Attorneys for Defendants.
Law Offices of Kevin G. Little, Kevin G. Little, Attorneys for Plaintiff.
1. Counsel for Defendants, City of Fresno, Officer Robert Marting Officer Robert Thompson and former Officer Gregory Catton, shall disclose to counsel for Plaintiff, records containing personnel matters, including records of this incident and records of police practices and procedures.
3. Prior to the dissemination of any such information pursuant to this order, counsel for the Plaintiff shall inform such person of the terms and conditions of this order and secure such person's agreement to be bound by it.
9. At the final conclusion of this action, all disclosed materials will be returned to the counsel for the Defendants without request and within 60 days of the final judgment, including any appeals, if any.
10. This order shall survive the final termination of this action, to the extent that the information disclosed remains confidential and does not become known to the public, and the court shall retain jurisdiction to resolve any dispute concerning the use of the information disclosed herein.
ORDER
IT IS SO ORDERED.