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Stipulation for Entry of A Protective Order; Order 1

GARY BRICKWOOD, State Bar No. 94892

MONIQUE GRANDAW, State Bar No. 162451

BRICKWOOD LAW OFFICE

1135 Pine Street, Suite 210

Redding, CA 96001

(530) 245-1877

(530) 245-1879 (fax)

Attorneys for Defendants, COUNTY OF SHASTA,

JIM POPE, PAT LANHAM, CITY OF REDDING, 

LEONARD MOTY (erroneously sued herein as 

LARRY F. MOTY), Officer REBECCA ZUFALL, 

Officer KRISTEN FREDRICK, Officer JASON BEEMAN, 

Corporal WALT BULLINGTON, Officer BRIAN MAGLEBY, 

Officer MATT ZALESNY, Officer GREG WILKES, 

Officer DAVID SCHULZ (erroneously sued herein as 

Officer Schultz), Sergeant STEVE MORAVEC, and 

Sergeant JOHN OSTROWSKI

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF CALIFORNIA

LONNY L. HODGES,

Plaintiff,

vs.

COUNTY OF SHASTA; CITY OF REDDING;

LARRY F. MOTY, Chief of Police; JIM

POPE, Shasta County Sheriff, Deputy

PAT LANHAM; Officer ZUFALL; Officer

FREDRICK; Officer BEEMAN Corporal

BULLINGTON; Officer MAGLEBY;

Officer ZALES, Officer ZALESNY;

Officer WILKES Officer SCHULTZ;

Officer MORAVEC; Officer FREDRICK;

Officer OSTROWSKI; DOES OFFICERS 1-

15, inclusive,

Defendants.

 / 

Case No. CIV.S-04-2535 GEB KJM

STIPULATION FOR ENTRY OF A

PROTECTIVE ORDER

Plaintiff has requested discovery of certain materials contained

in the personnel file of defendant Police Officer MATTHEW ZALESNY

which includes the Internal Affairs Investigation of a complaint

against Officer Zalesny arising out of an earlier incident.

Defendants have agreed to produce the Internal Affairs Investigation

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Stipulation for Entry of A Protective Order; Order 2

on the condition that the disclosure shall be subject to a protective

order that defendants shall not distribute the Internal Affairs

Investigation materials to anyone and shall return those materials

upon the conclusion of this lawsuit as more fully set forth in the

attached proposed order.

The parties hereby stipulate that the court may enter the

attached proposed order and that it shall be effective from this date

forward.

DATED: February 21, 2006. BRICKWOOD LAW OFFICE

 /s/ MONIQUE GRANDAW 

MONIQUE GRANDAW

Attorneys for Defendants

DATED: February 9, 2006. 

/s/ LARRY LAVERNE BAUMBACH 

LARRY LAVERNE BAUMBACH

Attorneys for Plaintiff

PROTECTIVE ORDER

The Court has reviewed the Stipulation for a Protective Order and

good cause appearing makes the following Order:

IT IS ORDERED:

To plaintiff LONNY L. HODGES, your agents, employees, attorneys

and anyone acting on your behalf, YOU ARE ORDERED AS FOLLOWS: 

1. You may not copy, duplicate or reproduce any part of the

Internal Affairs Investigation arising out of the complaint against

Zalesny as referred to in response to plaintiff's Request for

Production of Documents Set No. 1, Request No. 20, except as necessary

to exchange information between the parties to these proceedings or

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Stipulation for Entry of A Protective Order; Order 3

their respective attorneys or agents during the pendency of this case.

2. You may not convey, transfer, publish or distribute the

documents or information in the Internal Affairs Investigation or

authorize another to do so except between the parties to the

proceedings or their respective attorneys or agents during the

pendency of this case. 

YOU ARE FURTHER ORDERED to return all copies of the Internal

Affairs Investigation provided to you at the final conclusion of the

present proceeding to the attorney for the City of Redding and Zalesny

in this action, Gary Brickwood, at 1135 Pine Street, Suite 210,

Redding, California 96001.

DATED: March 10, 2006.

______________________________________

UNITED STATES MAGISTRATE JUDGE

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