PROPOSED PROTECTIVE ORDER

VICTOR B. KENTON, Magistrate Judge.

Pursuant to Stipulation entered into by Plaintiff Armando Barajas and Defendants The County of San Bernardino Sheriff's Department and Deputy Colin McKenzie, through their respective counsel, and pursuant to Local Rule 7-1 of the United States District Court for the Central District of California,

IT IS ORDERED that the following Protective Order shall govern the depositions of Sheriff Personnel in this action:

1. The depositions of any Sheriff Personnel will be taken in the City of San Bernardino either at County Counsel's Offices or the Sheriff's Department, to be determined following receipt of the deposition notice by County Counsel.

2. With respect to Sheriff Personnel, only the Depositions of Deputy Colin McKenzie, Lt. Hector Gomez, Deputy David Lara, Deputy Eric Justman, Nurse Beltz and Dr. Liong may be videotaped.

3. Any such video recording subject to this Protective Order shall be taken by the personal appearance of a videographer and shall not be "live streamed" or taken by any other mechanism other than a live recording taken by video in real time during the deposition.

4. The videotaped recordings of the deputies subject to this protective order will be deposited with Plaintiff's counsel following the completion of the deposition testimony and shall be marked as "Confidential Material."

5. Plaintiff Armando Barajas agrees that he will not view the video recordings of San Bernardino Sheriff Personnel, but is not limited in any way in his review of the written deposition transcripts.

6. Other than the Court (including court reporters, stenographic reporters and videographers, and court personnel), the "Confidential Material" (hereafter "Material") may be disclosed only to the four primary attorneys Richard W. Buckner, Natalie J. Schachner, Matthew R. Cowan, Brittany Rogers, and one paralegal, Karen Ezell, working on this matter at O'Melveny & Myers LLP, counsel for Armando Barajas. Plaintiff's legal staff, referenced above, agrees that the videos of Sheriff Personnel will Case 2:09-cv-08981-JAK-VBK Document 73 Filed 04/30/14 Page 3 of 3 Page ID #:525 not be disclosed to Barajas or to any other person without the prior written stipulation of Defendants or authorization from the Court.

7. The Material shall be used solely in connection with this litigation in the preparation and trial of this case, and not for any other purpose or litigation. To the extent material that is a subject matter of this protective order is disclosed before trial, it is subject to the terms of this protective order. To the extent Barajas's counsel seeks to use the material at trial or public hearing in this action, it will not be subject to the terms of the protective order, but rather such use shall be determined by the trial judge.

8. At the conclusion of the trial or upon other termination of this litigation, the Confidential Material shall be immediately destroyed except for any portion of the material necessary to maintain an appellate record.

9. The foregoing is without prejudice to the right of any parties:

a) to apply to the Court for a further protective order relating to any confidential material, or relating to discovery in this litigation;

b) to apply to the Court for an order removing the "Confidential Material" designation from the videotape;

c) to apply to the Court for an order compelling videotaped depositions or modification of this order or for any order permitting disclosure of confidential material beyond the terms of this order.