Case 8:20-cv-01772-MEMF-JDE Document 68 Filed 05/11/22 Page 1 of 15 Page ID #:871

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

9 10 MICHAEL GEORGE TATER, ) Case No. 8:20-cv-01772-MEMF ) individually; KYLA SKYE STANISKIS, ) (JDEx) 11 individually and as Personal ) ) 12 Representative of the Estate of ) PROTECTIVE ORDER 13 SHANNON MICHELLE TATER, ) )

) 14 Plaintiffs, ) 15 vs. ) ) 16 CITY OF HUNTINGTON BEACH, a ) ) Governmental Entity; STEPHANI ) 17 WILLIAMS, individually; MICHAEL ) ) 18 WAGNER, individually; NICOLE ) SHOGREN, individually; KELLI ) 19 HERRERA, individually; and DOES 1 ) ) 20 through 10, inclusive, ) 21 ) ) 22 Defendants. ) 23 Based on the Stipulation between Plaintiff Kyla Skye Staniskis (“Plaintiff”) 24 and Defendants City Of Huntington Beach ("City"), Stephani Williams, Michael 25 Wagner, Nicole Shogren and Kelli Herrera (collectively “Defendants”) and for good 26 cause shown therein, the Court finds and order as follows, as to Plaintiff and 27 Defendant. 28

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1 1. 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 4 disclosure and from use for any purpose other than pursuing this litigation may be 5 warranted. Plaintiff and Defendants acknowledge that this Order does not confer 6 blanket protections on all disclosures or responses to discovery and that the 7 protection it affords from public disclosure and use extends only to the limited 8 information or items that are entitled to confidential treatment under the applicable 9 legal principles. 10 2. GOOD CAUSE STATEMENT 11 This action is likely to involve sensitive private information (including 12 information implicating privacy rights of third parties), information otherwise 13 generally unavailable to the public, or which may be privileged or otherwise 14 protected from disclosure under state or federal statutes, court rules, case decisions, 15 or common law. Accordingly, to expedite the flow of information, to facilitate the 16 prompt resolution of disputes over confidentiality of discovery materials, to 17 adequately protect information the parties are entitled to keep confidential, to ensure 18 that the parties are permitted reasonable necessary uses of such material in 19 preparation for and in the conduct of trial, to address their handling at the end of the 20 litigation, and serve the ends of justice, a protective order for such information is 21 justified in this matter. It is the intent of the parties that information will not be 22 designated as confidential for tactical reasons and that nothing be so designated 23 without a good faith belief that it has been maintained in a confidential, non-public 24 manner, and there is good cause why it should not be part of the public record of this 25 case. 26 3. ACKNOWLEDGMENT OF UNDER SEAL FILINGPROCEDURE 27 Plaintiff and Defendants acknowledge, as set forth in Section 14.3, below, 28 that this Protective Order does not entitle them to file confidential information under

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1 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 2 standards that will be applied when a party seeks permission from the court to file 3 material under seal. There is a strong presumption that the public has a right of 4 access to judicial proceedings and records in civil cases. In connection with non- 5 dispositive motions, good cause must be shown to support a filing under seal. See 6 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), 7 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar- 8 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even 9 stipulated protective orders require good cause showing), and a specific showing of 10 good cause or compelling reasons with proper evidentiary support and legal 11 justification, must be made with respect to Protected Material that a party seeks to 12 file under seal. The parties’ mere designation of Disclosure or Discovery Material as 13 CONFIDENTIAL does not— without the submission of competent evidence by 14 declaration, establishing that the material sought to be filed under seal qualifies as 15 confidential, privileged, or otherwise protectable—constitute good cause. 16 Further, if a party requests sealing related to a dispositive motion or trial, then 17 compelling reasons, not only good cause, for the sealing must be shown, and the 18 relief sought shall be narrowly tailored to serve the specific interest to be protected. 19 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For 20 each item or type of information, document, or thing sought to be filed or introduced 21 under seal, the party seeking protection must articulate compelling reasons, 22 supported by specific facts and legal justification, for the requested sealing order. 23 Again, competent evidence supporting the application to file documents under seal 24 must be provided by declaration. 25 Any document that is not confidential, privileged, or otherwise protectable in 26 its entirety will not be filed under seal if the confidential portions can be redacted. If 27 documents can be redacted, then a redacted version for public viewing, omitting 28 only the confidential, privileged, or otherwise protectable portions of the document,

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1 shall be filed. Any application that seeks to file documents under seal in their 2 entirety should include an explanation of why redaction is not feasible. 3 4. DEFINITIONS 4 4.1 Action: this pending federal lawsuit. 5 4.2 Challenging Party: a Party or Non-Party that challenges the 6 designation of information or items under this Order. 7 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 8 how it is generated, stored or maintained) or tangible things that qualify for 9 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 10 the Good Cause Statement. 11 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 12 their support staff). 13 4.5 Designating Party: a Party or Non-Party that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 4.6 Disclosure or Discovery Material: all items or information, regardless 17 of the medium or manner in which it is generated, stored, or maintained (including, 18 among other things, testimony, transcripts, and tangible things), that are produced or 19 generated in disclosures or responses to discovery. 20 4.7 Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel to serve as 22 an expert witness or as a consultant in this Action. 23 4.8 House Counsel: attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 4.9 Non-Party: any natural person, partnership, corporation, association or 27 other legal entity not named as a Party to this action. 28

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1 4.10 Outside Counsel of Record: attorneys who are not employees of a party 2 to this Action but are retained to represent a party to this Action and have appeared 3 in this Action on behalf of that party or are affiliated with a law firm that has 4 appeared on behalf of that party, and includes support staff. 5 4.11 Party: any party to this Action, including all of its officers, directors, 6 employees, consultants, retained experts, and Outside Counsel of Record (and their 7 support staffs). 8 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 9 Discovery Material in this Action. 10 4.13 Professional Vendors: persons or entities that provide litigation support 11 services (e.g., photocopying, videotaping, translating, preparing exhibits or 12 demonstrations, and organizing, storing, or retrieving data in any form or medium) 13 and their employees and subcontractors. 14 4.14 Protected Material: any Disclosure or Discovery Material that is 15 designated as “CONFIDENTIAL.” 16 4.15 Receiving Party: a Party that receives Disclosure or Discovery 17 Material from a Producing Party. 18 5. SCOPE 19 The protections conferred by this Stipulation and Order cover not only 20 Protected Material (as defined above), but also (1) any information copied or 21 extracted from Protected Material; (2) all copies, excerpts, summaries, or 22 compilations of Protected Material; and (3) any testimony, conversations, or 23 presentations by Parties or their Counsel that might reveal Protected Material. 24 Any use of Protected Material at trial shall be governed by the orders of the 25 trial judge and other applicable authorities. This Order does not govern the use of 26 Protected Material at trial. 27 / / / 28 / / /

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1 6. DURATION 2 Once a case proceeds to trial, information that was designated as 3 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 4 as an exhibit at trial becomes public and will be presumptively available to all 5 members of the public, including the press, unless compelling reasons supported by 6 specific factual findings to proceed otherwise are made to the trial judge in advance 7 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 8 showing for sealing documents produced in discovery from “compelling reasons” 9 standard when merits-related documents are part of court record). Accordingly, the 10 terms of this protective order do not extend beyond the commencement of the trial. 11 7. DESIGNATING PROTECTED MATERIAL 12 7.1 Exercise of Restraint and Care in Designating Material for 13 Protection. Each Party or Non-Party that designates information or 14 items for protection under this Order must take care to limit any such designation to 15 specific material that qualifies under the appropriate standards. The Designating 16 Party must designate for protection only those parts of material, documents, items or 17 oral or written communications that qualify so that other portions of the material, 18 documents, items or communications for which protection is not warranted are not 19 swept unjustifiably within the ambit of this Order. 20 Mass, indiscriminate or routinized designations are prohibited. Designations 21 that are shown to be clearly unjustified or that have been made for an improper 22 purpose (e.g., to unnecessarily encumber the case development process or to impose 23 unnecessary expenses and burdens on other parties) may expose the Designating 24 Party to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 26 designated for protection do not qualify for protection, that Designating Party must 27 promptly notify all other Parties that it is withdrawing the inapplicable designation. 28

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1 7.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 3 that qualifies for protection under this Order must be clearly so designated before 4 the material is disclosed or produced. 5 Designation in conformity with this Order requires: 6 (a) for information in documentary form (e.g., paper or electronic 7 documents, but excluding transcripts of depositions or other pretrial or trial 8 proceedings), that the Producing Party affix at a minimum, the legend 9 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 10 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) 12 (e.g., by making appropriate markings in the margins). 13 A Party or Non-Party that makes original documents available for inspection 14 need not designate them for protection until after the inspecting Party has indicated 15 which documents it would like copied and produced. During the inspection and 16 before the designation, all of the material made available for inspection shall be 17 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 18 documents it wants copied and produced, the Producing Party must determine which 19 documents, or portions thereof, qualify for protection under this Order. Then, before 20 producing the specified documents, the Producing Party must affix the 21 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 22 portion of the material on a page qualifies for protection, the Producing Party also 23 must clearly identify the protected portion(s) (e.g., by making appropriate markings 24 in the margins). 25 (b) for testimony given in depositions that the Designating Party 26 identifies the Disclosure or Discovery Material on the record, before the close of the 27 deposition all protected testimony. 28

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1 (c) for information produced in some form other than documentary and 2 for any other tangible items, that the Producing Party affix in a prominent place on 3 the exterior of the container or containers in which the information is stored the 4 legend “CONFIDENTIAL.” If only a portion or portions of the information 5 warrants protection, the Producing Party, to the extent practicable, shall identify the 6 protected portion(s). 7 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 failure to designate qualified information or items does not, standing alone, waive 9 the Designating Party’s right to secure protection under this Order for such material. 10 Upon timely correction of a designation, the Receiving Party must make reasonable 11 efforts to assure that the material is treated in accordance with the provisions of this 12 Order. 13 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 15 designation of confidentiality at any time that is consistent with the Court’s 16 Scheduling Order. 17 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 18 resolution process under Local Rule 37-1 et seq. 19 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 20 stipulation pursuant to Local Rule 37-2. 21 8.4 The burden of persuasion in any such challenge proceeding shall be on the 22 Designating Party. Frivolous challenges, and those made for an improper purpose 23 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 24 expose the Challenging Party to sanctions. Unless the Designating Party has waived 25 or withdrawn the confidentiality designation, all parties shall continue to afford the 26 material in question the level of protection to which it is entitled under the 27 Producing Party’s designation until the Court rules on the challenge. 28 / / /

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1 9. ACCESS TO AND USE OF PROTECTED MATERIAL 2 9.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 Action only for prosecuting, defending or attempting to settle this Action. Such 5 Protected Material may be disclosed only to the categories of persons and under the 6 conditions described in this Order. When the Action has been terminated, a 7 Receiving Party must comply with the provisions of section 15 below (FINAL 8 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 9.2 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 17 well 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 20 the 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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1 (g) the author or recipient of a document containing the information or 2 a custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses, and attorneys for witnesses, in 4 the 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 except 11 as permitted under this Protective Order; and 12 (i) any mediators or settlement officers and their supporting personnel, 13 mutually agreed upon by any of the parties engaged in settlement discussions. 14 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation 17 that compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL,” that Party must: 19 (a) promptly notify in writing the Designating Party. Such notification 20 shall include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or 22 order to issue in the other litigation that some or all of the material covered by the 23 subpoena or order is subject to this Protective Order. Such notification shall include 24 a copy of this Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be 26 pursued by the Designating Party whose Protected Material may be affected. If the 27 Designating Party timely seeks a protective order, the Party served with the 28 subpoena or court order shall not produce any information designated in this action

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1 as “CONFIDENTIAL” before a determination by the court from which the 2 subpoena or order issued, unless the Party has obtained the Designating Party’s 3 permission. The Designating Party shall bear the burden and expense of seeking 4 protection in that court of its confidential material and nothing in these provisions 5 should be construed as authorizing or encouraging a Receiving Party in this Action 6 to disobey a lawful directive from another court. 7 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TOBE 8 PRODUCED IN THIS LITIGATION 9 (a) The terms of this Order are applicable to information produced by a 10 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 11 produced by Non-Parties in connection with this litigation is protected by the 12 remedies and relief provided by this Order. Nothing in these provisions should be 13 construed as prohibiting a Non-Party from seeking additional protections. 14 (b) In the event that a Party is required, by a valid discovery request, to 15 produce a Non-Party’s confidential information in its possession, and the Party is 16 subject to an agreement with the Non-Party not to produce the Non-Party’s 17 confidential information, then the Party shall: 18 (1) promptly notify in writing the Requesting Party and the Non-Party 19 that some or all of the information requested is subject to a confidentiality 20 agreement with a Non-Party; 21 (2) promptly provide the Non-Party with a copy of the Protective Order 22 in this Action, the relevant discovery request(s), and a reasonably specific 23 description of the information requested; and 24 (3) make the information requested available for inspection by the Non- 25 Party, if requested. 26 (c) If the Non-Party fails to seek a protective order from this court 27 within 14 days of receiving the notice and accompanying information, the Receiving 28 Party may produce the Non-Party’s confidential information responsive to the

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1 discovery request. If the Non-Party timely seeks a protective order, the Receiving 2 Party shall not produce any information in its possession or control that is subject to 3 the confidentiality agreement with the Non-Party before a determination by the 4 court. Absent a court order to the contrary, the Non-Party shall bear the burden and 5 expense of seeking protection in this court of its Protected Material. 6 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Protective Order, the Receiving Party must immediately (a) notify in writing the 10 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 11 all unauthorized copies of the Protected Material, (c) inform the person or persons to 12 whom unauthorized disclosures were made of all the terms of this Order, and (d) 13 request such person or persons to execute the “Acknowledgment an Agreement to 14 Be Bound” attached hereto as Exhibit A. 15 13. INADVERTENT PRODUCTION OF PRIVILEGED 16 OROTHERWISE PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil\ 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 21 may be established in an e-discovery order that provides for production without 22 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 23 as the parties reach an agreement on the effect of disclosure of a communication or 24 information covered by the attorney-client privilege or work product protection, the 25 parties may incorporate their agreement in the stipulated protective order submitted 26 to the court. 27 / / / 28 / / /

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1 14. MISCELLANEOUS 2 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 person to seek its modification by the Court in the future. 4 14.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order, no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Protective Order. Similarly, no Party waives any right to object on any ground to use 8 in evidence of any of the material covered by this Protective Order. 9 14.3 Filing Protected Material. A Party that seeks to file under seal any 10 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 11 only be filed under seal pursuant to a court order authorizing the sealing of the 12 specific Protected Material. If a Party’s request to file Protected Material under seal 13 is denied by the court, then the Receiving Party may file the information in the 14 public record unless otherwise instructed by the court. 15 15. FINAL DISPOSITION 16 After the final disposition of this Action, as defined in paragraph 6, within 60 17 days of a written request by the Designating Party, each Receiving Party must return 18 all Protected Material to the Producing Party or destroy such material. As used in 19 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 20 summaries, and any other format reproducing or capturing any of the Protected 21 Material. Whether the Protected Material is returned or destroyed, the Receiving 22 Party must submit a written certification to the Producing Party (and, if not the same 23 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies 24 (by category, where appropriate) all the Protected Material that was returned or 25 destroyed and (2) affirms that the Receiving Party has not retained any copies, 26 abstracts, compilations, summaries or any other format reproducing or capturing any 27 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 28 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

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1 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 2 ||reports, attorney work product, and consultant and expert work product, even if such 3 materials contain Protected Material. Any such archival copies that contain or 4 ||constitute Protected Material remain subject to this Protective Order as set forth in 5 □□ Section 6 (DURATION). 6 16. VIOLATION 7 Any violation of this Order may be punished by appropriate measures 8 || including, without limitation, contempt proceedings and/or monetary sanctions. 10 || IT IS SO ORDERED. 11 12 13 ||} DATED: May 11, 2022 Lb Ke AG 14 J D. EARLY 15 nited States Magistrate Judge 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 4 I, ______________________ declare under penalty of perjury that I have read 5 in its entirety and understand the Protective Order that was entered by the 6 United States District Court for the Central District of California in the case titled 7 Tater/Staniskis v. Huntington Beach California Police Department, et al., Case No. 8 8:20-cv-01772-MEMF (JDEx). I agree to comply with and to be bound by all the 9 terms of this Protective Order and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that 12 is subject to this Protective Order to any person or entity except in strict compliance 13 with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Protective Order, even if such enforcement proceedings occur after termination of 17 the case, or after the member cases in which I am involved have terminated or been 18 remanded. 19 Dated: __________________________________ 20 City and State: ___________________________ 21 Signature: _______________________________ 22 Title: ___________________________________ 23 Address: ________________________________ 24 ________________________________________ 25 ________________________________________ 26 27 28

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