Filed: Feb. 12, 2019
Latest Update: Feb. 12, 2019
Summary: JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER TROY L. NUNLEY , District Judge . 1. This stipulation is entered into between Plaintiffs KEVIN HUGHEY, JESSICA HUGHEY, and G. H. ("Plaintiffs") and Defendants ARTURO CAMACHO, DAN DRUMMOND, THOMAS MCDONALD, WEST SACRAMENTO POLICE DEPARTMENT, CITY OF WEST SACRAMENTO, TOD SOCKMAN, JASON WINGER, LABIN WILSON, TYLER RAINEY, ANDREA DONAHUE, CODY COULTER, CHRIS RICE, MATT BOUDINOT and RICH BENTLEY (collectively "Defendants"), through and by their
Summary: JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER TROY L. NUNLEY , District Judge . 1. This stipulation is entered into between Plaintiffs KEVIN HUGHEY, JESSICA HUGHEY, and G. H. ("Plaintiffs") and Defendants ARTURO CAMACHO, DAN DRUMMOND, THOMAS MCDONALD, WEST SACRAMENTO POLICE DEPARTMENT, CITY OF WEST SACRAMENTO, TOD SOCKMAN, JASON WINGER, LABIN WILSON, TYLER RAINEY, ANDREA DONAHUE, CODY COULTER, CHRIS RICE, MATT BOUDINOT and RICH BENTLEY (collectively "Defendants"), through and by their ..
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JOINT STIPULATION TO REDACT COURT RECORDS AND ORDER
TROY L. NUNLEY, District Judge.
1. This stipulation is entered into between Plaintiffs KEVIN HUGHEY, JESSICA HUGHEY, and G. H. ("Plaintiffs") and Defendants ARTURO CAMACHO, DAN DRUMMOND, THOMAS MCDONALD, WEST SACRAMENTO POLICE DEPARTMENT, CITY OF WEST SACRAMENTO, TOD SOCKMAN, JASON WINGER, LABIN WILSON, TYLER RAINEY, ANDREA DONAHUE, CODY COULTER, CHRIS RICE, MATT BOUDINOT and RICH BENTLEY (collectively "Defendants"), through and by their counsel of record.
2. In early January 2019, Plaintiffs were informed that court records containing private information as to the plaintiff minor child would need to be redacted.
THEREFORE, the parties, by and through their counsel, stipulate and agree to:
1. The Court entering an order, pursuant to Federal Rule of Civil Procedure 5.2 and Local Rule 140, permitting the parties to: (i) redact and remove any instance in a document filed with the Court in this proceeding where the full name of the plaintiff minor child is stated and restate only the initials of the plaintiff minor child and (ii) to redact and remove any instance in a document filed with the Court in this proceeding where the full home address of the plaintiff minor child is stated and restate only the city and state where such address is located, in the following documents filed with the Court in this proceeding:
Docket Document Location of Proposed
No. Redaction
1 Complaint for Damages Page 1; lines 12-13, 24, 27, 28
Page 2; line 1
Page 7; lines 9, 17
Page 9; line 11
2 Civil Cover Sheet Top of page; "Plaintiffs" section
5 Decline of Jurisdiction of United States Magistrate Bottom of page; "Counsel for . . ."
Judge section
11 Notice of Related Case Page 1; lines 14-15
12 Notice of Related Case Order Page 1; lines 6-7
13 Plaintiffs' Requests for Entry of Default Judgment Page 1; lines 10-11, 23
15 Stipulation to Set Aside Default And [Proposed] Page 1; lines 16-17
Order
16 Order Page 1; lines 16-17
17 Defendants' Notice of Motion and Motion to Page 1; lines 16-17
Dismiss Plaintiffs' Complaint Pursuant to Federal
Rule of Civil Procedure 12(B)(6)
17-1 Defendants' Memorandum of Points and Authorities Page 0; lines 16-17
in Support Page 1; lines 2
18 Notice of Withdrawal of Certain Counsel Page 1; lines 10-11
19 Proof of Service Page 1, lines 11-12
20 Notice of Appearance of Co-Counsel Page 1; lines 11-12, 25
21 Notice of Appearance of Co-Counsel Page 1; lines 11-12, 25
22 Plaintiffs' Opposition to Defendants' Motion to Page 0; lines 10-11
Dismiss Page 1; line 1
23 Joint Status Report Page 1; lines 21-22
Page 2, line 15
24 Defendants' Reply to Plaintiffs' Opposition to Page 1; lines 16-17
Motion to Dismiss Plaintiffs' Complaint
27 Notice of Appearance of Co-Counsel Page 1; lines 12-13
28 Memorandum and Order Page 1; lines 13, 27
Page 3; line 9
29 First Amended Complaint for Damages Page 1; lines 12-13, 23, 26, 28
Page 7; lines 2, 11
Page 9; line 2
30 Defendants' Notice or Motion and Motion to Page 1; line 15-16
Dismiss Plaintiffs' First Amended Complaint
30-1 Memorandum of Points and Authorities in Support Page 0; lines 15-16
Page 1; line 2
30-2 [Proposed] Order Page 1; lines 15-16
32 Defendants' Reply to Opposition to Motion to Page 1; lines 16-17
Dismiss Plaintiffs' First Amended Complaint
33 Plaintiffs' Opposition to Defendants' Motion to Page 1; lines 12-13, 23
Dismiss Plaintiffs' First Amended Complaint Page 3; line 10
33-1 Declaration of Christopher J. Moenig In Support Page 1; lines 12-13
35 Defendants' Substantive Reply to Opposition to Page 1; lines 17-18
Motion to Dismiss Plaintiffs' First Amended
Complaint
37 Memorandum and Order Page 1; lines 13-14,
Page 2; line 3
Page 3; line 20
38 Second Amended Complaint For Page 1, lines 12-13, 23, 26, 28
Damages Page 7; lines 2,11
Page 9; lines 2
42 Defendants' Answer to Second Amended Complaint Page 1; lines 15-16
Page 2, line 6
43 Defendant Tod Sockman's Notice of Motion and Page 1; lines 15-16
Motion to Dismiss Plaintiffs' Second Amended
Complaint
44 Notice of Association of Counsel Page 1; lines 13-14, 28
Page 2; lines 15, 19
45 Notice of Withdrawal of Former Counsel Page 1; lines 12-13
46 Notice of Withdrawal of Former Counsel Page 1; lines 12-13
47 Notice of Withdrawal of Former Counsel Page 1; lines 12-13
48 Plaintiffs' Opposition to Defendant Tod Sockman's Page 1; lines 15-16, 17
Motion to Dismiss Plaintiffs' Second Amended Page 3; line 13
Complaint
48-1 Declaration of Christopher J. Moenig In Support Page 1; lines 15-16
Page 2; line 5
49 Reply to Opposition to Defendant Tod Sockman's Page 1; lines 15-16
Motion to Dismiss Plaintiffs' Second Amended
Complaint
51 Order Granting Defendant Tod Sockman's Motion Page 1; lines 12, 24
to Dismiss Plaintiffs' Second Amended Complaint Page 3; lines 7
52 Third Amended Complaint for Damages Page 1; lines 15-16, 26
Page 2; lines 2, 3, 4, 7, 11
Page 9; line 2
Page 23; line 21
53 Defendant Tod Sockman's Answer to Third Page 1; lines 15-16
Amended Complaint Page 2; line 2
57 Updated Joint Status Report Page 2; line 15
Page 3; line 13
62 Joint Stipulation to Extend Deadline for Expert Page 1; lines 15-16
Discovery
63 Order RE Joint Stipulation to Extend Deadline for Page 1; lines 15-16
Expert Discovery
64 Notice of Motion and Motion for Consolidation Page 1; lines 9, 16-17
64-1 Memorandum of Points & Authorities in Support Page 1; lines 9, 16-17
64-2 Declaration of Jesse Ortiz in Support Page 1; lines 9, 16-17
64-3 Proposed] Order Re: Consolidation of Actions Page 1; lines 9, 16-17
65 Defendants' Notice of Non-Opposition to Plaintiff's Page 1; lines 15-16
Motion to Consolidate
67 Stipulation And [Proposed] Order to Modify the Page 1; lines 19-20
Pretrial Scheduling Order
70 Ex Parte Application for Order Shortening Time for Page 1; lines 14-15
Notice of Motion and Motion for Approval of Page 2; lines 2, 10, 19, 22
Settlement and Compromise of Minor's Claims;
Memorandum of Points & Authorities in Support
70-1 Petition and Order for Appointment of Guardian Ad Page 1; lines 14-15, 25
Litem
70-2 Notice of Motion and Motion for Approval of Page 1; lines 14-15
Settlement and Compromise of Minor's Claims; Page 2; line 5
Memorandum of Points & Authorities in Support
70-3 Memorandum of Points & Authorities in Support of Page 0; lines14-15
Motion for Approval of Settlement and Page 1; line 5
Compromise of Minor's Claims
70-4 Declaration of Kevin Hughey In Support Page 1; lines 14-15, 28
70-5 Proof of Service Page 1; lines 14-15
71 Petition and Order for Appointment of Guardian Ad Page 1; lines 14-15, 25
Litem
72 Notice of Motion and Motion for Approval of Page 1; lines 14-15
Settlement and Compromise of Minor's Claims; Page 2, line 5
Memorandum of Points & Authorities in Support
72-1 Memorandum of Points & Authorities in Support of Page 0; lines 14-15
Motion for Approval of Settlement and Page 1; line 5
Compromise of Minor's Claims
72-2 Declaration of Kevin Hughey in Support Page 1; lines 14-15, 28
72-3 Proof of Service Page 1; lines 14-15
74 Notice of Conditional Settlement Page 1; lines 23, 24
76 Order RE Petition for Appointment of Guardian Ad Page 1; lines 14-15, 24
Litem
2. The Court entering an order requiring the name of the plaintiff minor child be changed to G. H. and changing the address of the plaintiff minor child to the applicable city and state where it appears on the Court's public docket.
3. The Court entering an order permitting the parties to redact any instance in any publicly filed document where the name and/or address of the plaintiff minor child are stated, but which instance was inadvertently omitted from the list of 76 documents included in this Stipulation.
4. The parties further agree to complete the redactions contemplated by this Stipulation within 30 days of the entry of an Order approving this Stipulation.
5. Plaintiffs' counsel shall provide to Defendants' counsel by email electronic copies of proposed redacted versions of those documents that were initially filed by Defendants for approval prior to submitting such redacted documents to the Court (whether electronically or otherwise). If Defendants' counsel fail to respond to such an email inquiry within five (5) days of the date that it was sent, such failure to respond shall be conclusively deemed to constitute approval to submit such proposed redacted versions of the documents to the Court.
SO STIPULATED.
IT IS SO ORDERED.
