On July 31, 2020 a
Order
was filed
involving a dispute between
Flores, Sergio Lee Andrew,
and
Jasper Auto Group, Inc.,
Kessenger, Ashley,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
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MICHAEL N. FEUER,
City Attorney (SBN 111529)
CARLOS DE LA GUERRA,
Senior Assistant City Attorney (SBN 164046)
ANNETTE Y. LEE,
Assistant City Attorney (SBN 146783) NO FEE GOV’T CODE §6103
FRANCINE RICKS,
Deputy City Attorney (SBN 165269)
200 North Spring Street, Suite 1400
Los Angeles, California 90012 F LE ' B
Telephone: (2 1 3) 978-21 18
COUNTSYUSEFRS'RPJ gEOAJSATRDINO
Email: Francine.Ricks@lacity.org SAN BERNARDINO DISTHlCT
Attomeys for Real Party in Interest JUL 2 0 2022
LOS ANGELES POLICE DEPARTMENT 3y
Z
,
CUSTODIAN 0F RECORDS
10 EAL'RAMOS.
DEPUTY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
l2
COUNTY OF SAN BERNARDINO
l3 SERGIO LEE ANDREW FLORES ) CASE N0. CIVDSZOISSIS
. _ ) [Assigned to the Hon. Donald Alvarez, Dept. 823]
l4 Plamtlff,
)
15 v. )
) {-RROFGSEDi-PROTECTIVE
l6
ASHLEY KESSENGER; JASPER AUTO
GROUP, INC; and DOES to 100, Inclusive,
1
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gggggggfici‘gsgfikfiffiw
l7
18
Defendants,
DATE: July 20 2022
l9 TIME: 9:00 a.m.
LOS ANGELES POLICE DEPARTMENT PLACE; Depamnent $23
20 CUSTODIAN OF RECORDS, VVVVVVVVV
21
Real Party in Interest.
22
23
24
25
26
IT IS HEREBY ORDERED:
27
The following Protective Order shall govern the disclosure of documents and/or information
produced in accordance with the Court’s order on July 20, 2022 regarding defendant’s Ashley
28
1
[PROPOSED] PROTECTIVE ORDER RE: DISCLOSURE OF CONFIDENTIAL INFORMATION
Kessenger and Jasper Auto Group Pitchess motion for disclosure of plaintiff Sergio Lee Andrew Flores’
peace officer personnel records from the Los Angeles Police Department (hereinafter, the “protected
docments”):
1. The Designating Party shall have the right to designate as “Confidential” any documents,
testimony, or information that the Designating Party believes in good faith to contain non-public
information that is entitled to confidential treatment under applicable law.
2. Use 0f the protected materials and the information contained therein is limited t0
authorized persons working for the parties, and as provided by the Court 0n this specific civil matter.
3. Access to and/ or disclosure 0f confidential materials designated as “Confidential” is
limited to authorized persons working for the parties, and as provided by the Court on this specific civil
matter.
4. Counsel to any party to this action shall advise those individuals t0 whom disclosure is
made in accordance with this Protective Order 0f the contents of this Protective Order and that the
14 documents are confidential.
15 5. If the protected information is included in any coun documents, those documents should
16 be submitted under seal.
17 6. Provisions of this Order insofar as they restrict disclosure and the use of material shall be
18 in effect until further order of the Court.
l9 7. N0 more than thirty (30) calendar days after o the final disposition of an appeal, counsel
20 shall return all copies of all disclosed LAPD records to: Attn: Discovery Section, Legal Affairs
21 Division, Los Angeles Police Department, 200 N. Spring St. 19th FL, Los Angeles, CA 90012.
22 8. This Court shall retain jurisdiction after the conclusion 0f this proceeding to enforce the
23 provisions 0f this Stipulation and Protective Order.
24 9. Provisions of this Order insofar as they restrict disclosure and the use of material shall be
25 in effect until further order of the Court.
26 IT Is so ORDERED.
27
Dated: 7/40 ,
2022
28 JUDGE 0F THE SUPERI§§
C(?T
m, g “5».
2
[PROPOSED] PROTECTIVE ORDER RE: DISCLOSURE OF CONFIDENTIAL INFORMATION
Document Filed Date
July 20, 2022
Case Filing Date
July 31, 2020
Category
Personal Injury Motor Vehicle Unlimited
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MICHAEL N. FEUER, City Attorney (SBN 111529) CARLOS DE LA GUERRA, Senior Assistant City Attorney (SBN 164046) ANNETTE Y. LEE, Assistant City Attorney (SBN 146783) NO FEE GOV’T CODE §6103 FRANCINE RICKS, Deputy City Attorney (SBN 165269) 200 North Spring Street, Suite 1400 Los Angeles, California 90012 F LE ' B Telephone: (2 1 3) 978-21 18 COUNTSYUSEFRS'RPJ gEOAJSATRDINO Email: Francine.Ricks@lacity.org SAN BERNARDINO DISTHlCT Attomeys for Real Party in Interest JUL 2 0 2022 LOS ANGELES POLICE DEPARTMENT 3y Z , CUSTODIAN 0F RECORDS 10 EAL'RAMOS. DEPUTY SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 l2 COUNTY OF SAN BERNARDINO l3 SERGIO LEE ANDREW FLORES ) CASE N0. CIVDSZOISSIS . _ ) [Assigned to the Hon. Donald Alvarez, Dept. 823] l4 Plamtlff, ) 15 v. ) ) {-RROFGSEDi-PROTECTIVE l6 ASHLEY KESSENGER; JASPER AUTO GROUP, INC; and DOES to 100, Inclusive, 1 g gggggggfici‘gsgfikfiffiw l7 18 Defendants, DATE: July 20 2022 l9 TIME: 9:00 a.m. LOS ANGELES POLICE DEPARTMENT PLACE; Depamnent $23 20 CUSTODIAN OF RECORDS, VVVVVVVVV 21 Real Party in Interest. 22 23 24 25 26 IT IS HEREBY ORDERED: 27 The following Protective Order shall govern the disclosure of documents and/or information produced in accordance with the Court’s order on July 20, 2022 regarding defendant’s Ashley 28 1 [PROPOSED] PROTECTIVE ORDER RE: DISCLOSURE OF CONFIDENTIAL INFORMATION Kessenger and Jasper Auto Group Pitchess motion for disclosure of plaintiff Sergio Lee Andrew Flores’ peace officer personnel records from the Los Angeles Police Department (hereinafter, the “protected docments”): 1. The Designating Party shall have the right to designate as “Confidential” any documents, testimony, or information that the Designating Party believes in good faith to contain non-public information that is entitled to confidential treatment under applicable law. 2. Use 0f the protected materials and the information contained therein is limited t0 authorized persons working for the parties, and as provided by the Court 0n this specific civil matter. 3. Access to and/ or disclosure 0f confidential materials designated as “Confidential” is limited to authorized persons working for the parties, and as provided by the Court on this specific civil matter. 4. Counsel to any party to this action shall advise those individuals t0 whom disclosure is made in accordance with this Protective Order 0f the contents of this Protective Order and that the 14 documents are confidential. 15 5. If the protected information is included in any coun documents, those documents should 16 be submitted under seal. 17 6. Provisions of this Order insofar as they restrict disclosure and the use of material shall be 18 in effect until further order of the Court. l9 7. N0 more than thirty (30) calendar days after o the final disposition of an appeal, counsel 20 shall return all copies of all disclosed LAPD records to: Attn: Discovery Section, Legal Affairs 21 Division, Los Angeles Police Department, 200 N. Spring St. 19th FL, Los Angeles, CA 90012. 22 8. This Court shall retain jurisdiction after the conclusion 0f this proceeding to enforce the 23 provisions 0f this Stipulation and Protective Order. 24 9. Provisions of this Order insofar as they restrict disclosure and the use of material shall be 25 in effect until further order of the Court. 26 IT Is so ORDERED. 27 Dated: 7/40 , 2022 28 JUDGE 0F THE SUPERI§§ C(?T m, g “5». 2 [PROPOSED] PROTECTIVE ORDER RE: DISCLOSURE OF CONFIDENTIAL INFORMATION