PROTECTIVE ORDER

DOUGLAS F. McCORMICK, Magistrate Judge.

Plaintiffs WENDI OPPENHEIMER, VANNES OPPENHEIMER and JEFFREY PEREA, through their counsel of record herein, Brown White & Osborn LLP, and defendants CITY OF LA HABRA, TANNA WILLIAMS, and G4S SECURE SOLUTIONS (USA) INC., through their counsel of record herein, Manning & Kass, Ellrod, Ramirez and Trester, LLP, submitted a Joint Stipulation for Protective Order before this Court.

The Court has read and considered all of the papers filed in support of this stipulation. Good cause appearing, this Court makes the following orders.

IT IS THEREFORE ORDERED that the Joint Stipulation for Protective Order Thereon is GRANTED as follows:

TERMS OF THE PROTECTIVE ORDER

The parties' counsel shall have sole custody and control over the documents identified in paragraph 1 of the Stipulation and Order.

Documents set forth in paragraph 1 of the Stipulation and Order are deemed confidential, except to the extent set forth in that document, and shall be used solely in connection with this litigation and the preparation and trial of this case, or any related appellate proceedings, and not for any other purpose, including any other litigation, and may not be disclosed or disseminated to other persons, including any other counsel other than as set forth herein;

The parties' counsel alone will have custody, control and access to the documents, reports and writings, and will be prohibited from releasing or disseminating the reports or files, or the information contained within the reports or files to other persons including legal counsel other than set forth in paragraph 12 of the Stipulation and Order;

The parties' counsel may make copies of the reports and files, but counsel will be prohibited from releasing or disseminating such copies or the information contained within such copies other than as set forth herein;

The documents identified in paragraph 1 may be submitted in all law and motion proceedings if done so pursuant to Local Rule 79-5. This Order does not apply to those exhibits deemed admissible at trial (as those will be merely lodged and not made part of the public record), though it does apply to any motion or pleading filed during the duration of the lawsuit.

All disputes regarding this Order shall be handled pursuant to Local Rule 37.

The documents may be disclosed to the following persons:

(c) court personnel including stenographic reporters engaged in such proceedings as are necessary incident to preparation for the trial in this action;

(d) any outside expert or consultant retained in connection with this action, and not otherwise employed by either parties (including jury consultants);

(e) any "in-house" or outside experts designated by the defendants to testify at trial in this matter;

(f) any party to this action or employees of any party, the sole exception being the documents from the G4S and City of Long Beach personnel files of Tanna Williams which may not be shown to the plaintiffs.

Any documents so disclosed will explicitly require inclusion of a copy of the Stipulation and Order and this Order and written instructions from counsel directing compliance with same.

If, in connection with any deposition taken in this action, counsel for the parties question a witness regarding materials subject to this Order, or uses confidential material as deposition exhibits, at the request of the opposing counsel, the transcripts of such deposition testimony and the attached exhibits shall be designated as confidential material and shall be subject to the provisions of this Order.

The parties' decision to enter into this Stipulation and Protective Order is made without waiver of the privileges and rights afforded to them, including, but not limited to, the right to privacy embodied by the United States Constitution or the right to object at the time of trial to the admissibility of such or to preclude any party from filing pre-trial motions with regard to the admissibility thereof or the information contained therein.

The parties' counsel agree to maintain the documents in agreement with the terms of this Stipulation and Order.

The provisions of this Order shall be in effect until further Order of the Court or Stipulation by counsel for the parties.

IT IS SO ORDERED.