1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 1

EM ILY RO BIN SO N, et a l. v. S AC RA M EN TO CO UNTY , et a l. USDC, Eastern District, Case No. CIV.S-04-1617 FCD DAD

KIM BERL Y KO ZLOWSK I, et al. v. SA CR AM EN TO CO UNTY , et a l. USDC, Eastern District, Case No. CIV.S-04-2381 FCD DAD

00441678.WPD PROTECTIVE ORDER

LAW OFFICE OF MARK E. MERIN

Mark E. Merin, SBN 043849

Jeffrey I. Schwarzschild, SBN 192086 

2001 P Street, Suite 100

Sacramento, CA 95814

Telephone: 916/443-6911

Facsimile: 916/447-8336

Attorneys for Plaintiffs

PORTER, SCOTT, WEIBERG & DELEHANT

Terence J. Cassidy, SBN 099180

350 University Avenue, Suite 200

Sacramento, CA 95825

Telephone: 916/929-1481

Facsimile: 916/927-3706

Attorneys for Defendants

—o0o—

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

—o0o—

EMILY ROBINSON, et al., 

Plaintiffs,

vs.

SACRAMENTO COUNTY, et al., 

Defendants.

CASE NO: CIV.S-04-1617 FCD/PAN

PROTECTIVEORDERFORDISCLOSURE

OF JUVENILE RECORDS

KIMBERLY KOZLOWSKI, et al., 

Plaintiffs,

vs.

SACRAMENTO COUNTY, et al., 

Defendants.

CASE NO: CIV.S-04-2381 FCD/DAD

///

///

Case 2:04-cv-01617-FCD-EFB Document 65 Filed 08/11/06 Page 1 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 2

EM ILY RO BIN SO N, et a l. v. S AC RA M EN TO CO UNTY , et a l. USDC, Eastern District, Case No. CIV.S-04-1617 FCD DAD

KIM BERL Y KO ZLOWSK I, et al. v. SA CR AM EN TO CO UNTY , et a l. USDC, Eastern District, Case No. CIV.S-04-2381 FCD DAD

00441678.WPD PROTECTIVE ORDER - 2 -

Based on the Stipulated Motion for Preliminary Approval of Provisional Settlement Class

and Settlement of Class Action and Order thereon, and good cause appearing therefor:

IT IS HEREBY ORDERED that personnel of the Sacramento County Probation Department

who are authorized to access juvenile records in the databases maintained by Sacramento County

Probation Department, Sacramento County Sheriff’s Department, the Inmate Profile System (IPS)

or in the Criminal Justice Information System (CJIS) may access those records for the purposes of

determining the identities of the individual members of the settlement class, the last known addresses

(including persons incarcerated at juvenile or adult facilities in the state of California), date of birth,

social security number, dates of booking, charges and information reflecting whether the settlement

class member was on searchable probation at the time of booking, of all settlement class members

arrested during the class period, as well as the name(s), last known address(es) and social security

numbers of all parents and/or guardians of settlement class members arrested during the class period.

ITIS FURTHERORDERED that personnel of the Sacramento CountyProbationDepartment

are hereby authorized to disclose to Class Counsel the name and last known address of all settlement

class members and to disclose to the duly appointed Claims Administrator in the above-captioned

cases all information set forth in the previous paragraph in order to provide notice to settlement class

members, to assist with efforts to update and verify addresses, including but not limited to addresses

of settlement class members who are incarcerated, and to apply the reduction categories set forth in

the Stipulation of Settlement and Order for Preliminary Approval of Settlement of Class Action. The

Claims Administrator shall not disclose that information to any third party save and except to assist

with efforts to update and verify addresses to provide notice to settlement class members.

IT IS FURTHER ORDERED that any access by personnel of the Sacramento County

Probation Department to the juvenile records in databases maintained by Sacramento County

Probation Department, Sacramento County Sheriff’s Department, the Inmate Profile System (IPS)

or in the Criminal Justice Information System (CJIS) to the Claims Administrator pursuant to this

order shall not be a violation of the California Penal Code section 11105, et seq., the right to privacy

of settlement class members and/or their parents or any other provision of law which would

otherwise deem that information privileged and confidential.

Case 2:04-cv-01617-FCD-EFB Document 65 Filed 08/11/06 Page 2 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 3

EM ILY RO BIN SO N, et a l. v. S AC RA M EN TO CO UNTY , et a l. USDC, Eastern District, Case No. CIV.S-04-1617 FCD DAD

KIM BERL Y KO ZLOWSK I, et al. v. SA CR AM EN TO CO UNTY , et a l. USDC, Eastern District, Case No. CIV.S-04-2381 FCD DAD

00441678.WPD PROTECTIVE ORDER - 3 -

IT IS SO ORDERED.

Dated: August 11, 2006 

/s/ Frank C. Damrell Jr. 

United States District Judge

Eastern District of California

Case 2:04-cv-01617-FCD-EFB Document 65 Filed 08/11/06 Page 3 of 3