[PROPOSED] ORDER REGARDING STIPULATION FOR PROTECTIVE ORDER RE RECORDS TO BE PRODUCED BY THE CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATION

KAREN L. STEVENSON, Magistrate Judge.

Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and based on the parties' Stipulation for Protective Order ("Stipulation") filed on April 17, 2019, the terms of the protective order to which the parties have agreed are adopted as a protective order of this Court except to the extent, as set forth below, that those terms have been modified by the Court's amendment of the preamble and paragraph 8 of the Stipulation.

AGREED TERMS OF THE PROTECTIVE ORDER AS ADOPTED AND MODIFIED BY THE COURT1

The Court, having received, read, and considered the Stipulation of the Parties and good cause showing therefrom, adopts the Stipulation of the Parties in its entirety with changes as its Order. The Court finds:

1. The only documents and materials to be produced are those requested in the Subpoena Duces Tecum dated February 26, 2019 and served on or around March 4, 2019, which requests the central file documents for Vincent G. Sanders (D.O.B. 6/17/62) beginning in 1975 through current.

2. No documents or images shall be shown, disclosed, displayed, disseminated, or communicated either directly or indirectly to any person or used in any fashion by any party to this action except as may be directly necessary and utilized by counsel, counsel's experts, and/or investigators in the preparation of the defense or prosecution of this action. Any documents produced pursuant to this Protective Order or reference to the contents thereof shall be kept confidential and under seal unless and until allowed by further order of a competent court and only after having provided CDCR reasonable notice of the intent to disclose and afforded a reasonable opportunity to the CDCR to object and/or be heard.

3. Any documents produced pursuant to the Protective Order shall be used solely in connection with the preparation of the defense or prosecution in the UNITED STATES DISTRICT COURT, CENTRAL DISTRICT case of ANDREW WILSON V. CITY OF LOS ANGELES, RICHARD MARKS CASE NO. 2: 18-CV-05775-KS, including associated appellate proceedings and collateral review.

4. All parties, with exception to Los Angeles County Counsel, in this matter are personally prohibited from reviewing the discovered materials except in the direct presence and under the direct supervision of their counsel, investigator, or expert witness as may be necessary for the purposes of assisting in the preparation of this case. Under no circumstances shall the parties personally be given any of the materials or copies of the materials for him to retain in his possession.

5. This Protective Order shall be applicable to all Parties, any attorney for the Parties, and any investigator, expert witness, agent, or representative of the Parties.

6. A copy of this Protective Order shall accompany any copy made of the discovered materials. Parties who have signed this Stipulated Protective Order acknowledge that he/she has read the order and understands the provisions of the order and agree in writing to abide by its terms. Each person to whom disclosure is made, prior to the time of disclosure, shall be provided by the person providing the documents, a copy of this Protective Order, and shall agree in writing that he/she has read and understands this Protective Order.

7. At the conclusion of this matter, all discovered materials or copies of such materials shall be destroyed or returned to the California Department of Corrections and Rehabilitation, regardless of the outcome of the case. All such materials or copies of such materials shall be delivered to the Court if directed. If said documents, or copies thereof are destroyed, notification of their destruction is to be given to CDCR by counsel for Andrew Wilson.

8. Any violation of this order shall may result in sanctions by this Court, including contempt, and may be punishable by state or federal law.

9. This Order shall be continuing in nature, and shall apply whether the case is pending before a trial or appellate court.

IT IS SO ORDERED.