Case: Nee v. County of L.A.

Nee v. County of Los Angeles

ACLU Southern California

COMPLAINT against Defendants Bayes, County of Los Angeles, Does 1 through 10 inclusive, Richard Gylfie, Maurice Hill, Los Angeles County Sheriffs Department.Case assigned to Judge Dean D. Pregerson for all further proceedings. Discovery referred to Magistrate Judge Jay C. Gandhi. (Filing fee $ 350 Paid.) Jury Demanded., filed by Plaintiffs Greggory Moore, Shane Quentin, Shawn Nee, National Photographers Rights Organization. (et) (yl). (Entered: 10/28/2011)

NOTICE of Interested Parties filed by Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. (et) (yl). (Entered: 10/28/2011)

NOTICE of Related Case(s) filed by Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. Related Case(s): Not Indicated. (et) (yl). (Entered: 10/28/2011)

NOTICE TO PARTIES OF ADR PROGRAM filed. (et) (Entered: 10/28/2011)

21 DAY Summons Issued re Complaint - (Discovery) 1 as to Defendants Bayes, County of Los Angeles, Richard Gylfie, Maurice Hill, Los Angeles County Sheriffs Department. (et)

PROOF OF SERVICE Executed by Plaintiff Greggory Moore, Shane Quentin, Shawn Nee, National Photographers Rights Organization, upon Defendant County of Los Angeles served on 10/28/2011, answer due 11/18/2011. Service of the Summons and Complaint were executed upon Tammy Johnson, County Clerk in compliance with Federal Rules of Civil Procedure by service on a domestic corporation, unincorporated association, or public entity. Original Summons NOT returned. (Bibring, Peter) (Entered: 11/08/2011)

PROOF OF SERVICE Executed by Plaintiff Greggory Moore, Shane Quentin, Shawn Nee, National Photographers Rights Organization, upon Defendant Los Angeles County Sheriffs Department served on 10/31/2011, answer due 11/21/2011. Service of the Summons and Complaint were executed upon Lashawn Tillman, Risk Management in compliance with Federal Rules of Civil Procedure by service on a domestic corporation, unincorporated association, or public entity. Original Summons NOT returned. (Bibring, Peter) (Entered: 11/08/2011)

PROOF OF SERVICE filed by Plaintiff Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin, re Service of Summons and Complaint Returned Executed (21 days), Service of Summons and Complaint Returned Executed (21 days) 5, Service of Summons and Complaint Returned Executed (21 days), Service of Summons and Complaint Returned Executed (21 days) 6 served on November 9, 2011. (Bibring, Peter) (Entered: 11/09/2011)

MINUTES OF IN CHAMBERS ORDER held before Judge Dean D. Pregerson: This action has been assigned to the calendar of Judge Dean D Pregerson. Counsel are referred to the courts website for additional information. It is not necessary to clear motion date with court clerk prior to filing the motion. Court hears motions only on Mondays at 10:00 AM. The Court requires two non-blue backed courtesy copies of only the following manual and electronic filed documents: (1) All noticed motions and related documents; and (2) All ex parte applications and related documents (3) all exhibits and attachments must be separately tabbed. [Refer to the Court's General Order No. 10-07 regarding ECF Courtesy Paper Copies and re location of Chambers Email address. (lc) (Entered: 11/17/2011)

STIPULATION Extending Time to Answer the complaint as to County of Los Angeles answer now due 11/28/2011; Los Angeles County Sheriffs Department answer now due 11/28/2011, re Complaint - (Discovery), Complaint - (Discovery) 1 filed by Defendants County of Los Angeles; Los Angeles County Sheriffs Department.(Davis-Tinkham, Nicole) (Entered: 11/18/2011)

ANSWER to Complaint - (Discovery), Complaint - (Discovery) 1 with JURY DEMAND filed by Defendants County of Los Angeles, Los Angeles County Sheriffs Department.(Mathers, Catherine) (Entered: 11/28/2011)

Certification and Notice of Interested Parties filed by Defendants County of Los Angeles, Los Angeles County Sheriffs Department, (Mathers, Catherine) (Entered: 11/28/2011)

PROOF OF SERVICE Executed by Plaintiff Greggory Moore, Shane Quentin, Shawn Nee, National Photographers Rights Organization, upon Defendant Richard Gylfie served on 1/18/2012, answer due 2/8/2012. Service of the Summons and Complaint were executed upon Sergeant Orr, authorized to accept service on behalf of Deputy Richard Gylfie in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Gettings, Sarah) (Entered: 01/19/2012)

PROOF OF SERVICE Executed by Plaintiff Greggory Moore, Shane Quentin, Shawn Nee, National Photographers Rights Organization, upon Defendant Maurice Hill served on 1/18/2012, answer due 2/8/2012. Service of the Summons and Complaint were executed upon Sergeant Maurice Hill, in his individual capacity in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Gettings, Sarah) (Entered: 01/19/2012)

PROOF OF SERVICE Executed by Plaintiff Greggory Moore, Shane Quentin, Shawn Nee, National Photographers Rights Organization, upon Defendant Bayes served on 1/26/2012, answer due 2/16/2012. Service of the Summons and Complaint were executed upon Deputy Francisco, authorized to accept service on behalf of Deputy Bayes in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Gettings, Sarah) (Entered: 01/26/2012)

ANSWER filed by DEFENDANT Richard Gylfie, Maurice Hill.(Davis-Tinkham, Nicole) (Entered: 02/08/2012)

NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Richard Gylfie, Maurice Hill Answer to Complaint 15 . The following error(s) was found: Local Rule 7.1-1 No Certification of Interested Parties. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (lc) (Entered: 02/09/2012)

Certification and Notice of Interested Parties filed by Defendants Richard Gylfie, Maurice Hill, (Mathers, Catherine) (Entered: 02/10/2012)

ORDER setting a scheduling conference on Thursday, May 10, 2012 at 3:00 p.m. by Judge Dean D. Pregerson. The parties are reminded of their obligations to disclose information and confer on a discovery plan not later than twenty-one (21) days prior to the scheduling conference and file a report with the Court entitled "Rule 26(f) Report", not later than fourteen (14) days after they confer as required by Federal Rule of Civil Procedure 26 and the Local Rules of this Court. (cch) (Entered: 02/15/2012)

ANSWER to Complaint - (Discovery), Complaint - (Discovery) 1 filed by DEFENDANT Bayes. (Attachments: # 1 CERTIFICATE OF INTERESTED PARTIES)(Davis-Tinkham, Nicole) (Entered: 02/16/2012)

1 CERTIFICATE OF INTERESTED PARTIES

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NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: ONLY the attachment of the Notice of interested party ( to the Answer to Complaint (Discovery) 19 ). The following error(s) was found: Certificate of interested party should not have been an attachment, but should have been docketed under its own specific event: Notice: Certificate/Notice of Interested Parties. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (lc) (Entered: 02/17/2012)

RULE 26 JOINT REPORT OF COUNSEL REPORT of COUNSEL filed by Defendants Bayes, County of Los Angeles, Richard Gylfie, Maurice Hill, Los Angeles County Sheriffs Department. (Davis-Tinkham, Nicole) (Entered: 04/17/2012)

NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Rule 26 Joint Report of Counsel 21 . The following error(s) was found: Incorrect event selected. The correct event is: Joint Rule 26(f) Discovery Plan. Other error(s) with document(s): Please use the correct specific event to satisfy the filing requirement of the Rule 26 (f) report. The correct event will prompt the required information missing on the entry. (Please use the SEARCH option on the CM/ECF blue taskbar to assist in finding and using the correct event. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (jp) (Entered: 04/18/2012)

JOINT REPORT Rule 26(f) Discovery Plan Joint Report of Counsel ; estimated length of trial 7, filed by Defendants Bayes, County of Los Angeles, Richard Gylfie, Maurice Hill, Los Angeles County Sheriffs Department.. (Davis-Tinkham, Nicole) (Entered: 04/18/2012)

MINUTES OF Scheduling Conference held before Judge Dean D. Pregerson. Held scheduling conference. Court and counsel confer re case status. Court sets trial dates. (Refer to the SCHEDULING ORDER to be issued hereafter.) (cch) (Entered: 05/21/2012)

ORDER/REFERRAL to ADR Procedure No 1 by Judge Dean D. Pregerson. Case ordered to Magistrate Judge Jay C. Gandhi for Settlement Conference. (cch) (Entered: 05/21/2012)

SCHEDULING ORDER by Judge Dean D. Pregerson. The Court sets the following dates: LAST DAY TO JOIN OTHER PARTIES AND TO AMEND THE PLEADINGS: 09-10-12; FACT DISCOVERY CUT-OFF: 02-11-13; EXPERT DISCOVERY CUT-OFF: 04-12-13; LAST DAY TO FILE MOTIONS: 05-13-13; FINAL PRE TRIAL CONFERENCE 08-12-13 at 11:00 a.m.; 5 DAY JURY TRIAL 08-20-13 at 9:00 a.m. See order for details. (cch) (Entered: 05/21/2012)

Joint STIPULATION for Leave to File First Amended Complaint filed by plaintiff Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. (Attachments: # 1 Exhibit First Amended Complaint, # 2 Proposed Order)(Bibring, Peter) (Entered: 06/15/2012)

1 Exhibit First Amended Complaint

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2 Proposed Order

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ORDER by Judge Dean D. Pregerson, re Stipulation 27 allows Plaintiffs to filetheir First Amended Complaint, pursuant to Federal Rule of Civil Procedure 15(a)(2), the Court ORDERS the First Amended Complaint filed within 15 days from the date of this order in accordance with the Clerks Office filing procedures. (lc) (Entered: 06/18/2012)

FIRST AMENDED COMPLAINT against defendants Bayes, County of Los Angeles, Does 1-30, Richard Gylfie, Maurice Hill, Los Angeles County Sheriffs Department amending Complaint - (Discovery) 1,filed by plaintiff Greggory Moore, Shane Quentin, Shawn Nee, National Photographers Rights Organization (lc) (lc). (Entered: 06/20/2012)

ANSWER to Amended Complaint, 29 filed by DEFENDANTS Bayes, County of Los Angeles, Does, Richard Gylfie, Maurice Hill, Los Angeles County Sheriffs Department.(Davis-Tinkham, Nicole) (Entered: 07/05/2012)

CERTIFICATION AND NOTICE of Interested Parties filed by DEFENDANTS Bayes, County of Los Angeles, Richard Gylfie, Maurice Hill, Los Angeles County Sheriffs Department, (Davis-Tinkham, Nicole) (Entered: 07/05/2012)

Joint STIPULATION for Protective Order filed by Plaintiff Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. (Attachments: # 1 Proposed Order)(Bibring, Peter) (Entered: 08/16/2012)

1 Proposed Order

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NOTICE OF ERRATA filed by Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. correcting Stipulation for Protective Order 32 (Attachments: # 1 Proposed Order)(Bibring, Peter) (Entered: 08/16/2012)

1 Proposed Order

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PROTECTIVE ORDER by Magistrate Judge Jay C. Gandhi re Stipulation for Protective Order 32 . ( See Order for details) (bem) (Entered: 08/20/2012)

STIPULATION to Amend Amended Complaint, 29 filed by Plaintiff Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. (Attachments: # 1 Exhibit Second Amended Complaint, # 2 Proposed Order)(Bibring, Peter) (Entered: 09/10/2012)

1 Exhibit Second Amended Complaint

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2 Proposed Order

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ORDER by Judge Dean D. Pregerson, re Stipulation 35 that because the parties have been unable to ascertain the identities of three defendants named as Does, despite their efforts, the Court extends their deadline for amending their complaint to add those remaining three defendants by 60 days, to November 9, 2012. (lc) (Entered: 09/13/2012)

SECOND AMENDED COMPLAINT against defendants Bayes, County of Los Angeles, Does, Richard Gylfie, Maurice Hill, Los Angeles County Sheriffs Department, Salvador Becerra, D'Andre Lampkin, Lashon O'Bannon, Carlos L Sanchez, Jason Cartagena, Michael A Chacon, Marina Garcia, Ryck Burwell, Gustavo Carranza, Ernie King, Anthony Paez, Jose Carbajal, Jr. Does 1-30 amending Amended Complaint 29 filed by plaintiffs Greggory Moore, Shane Quentin, Shawn Nee, National Photographers Rights Organization (lc) (lc). (Additional attachment(s) added on 11/30/2012: # 1 issued summons) (lc). (Entered: 09/21/2012)

1 issued summons

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ANSWER to Amended Complaint,, 37 filed by DEFENDANTS Bayes, County of Los Angeles, Richard Gylfie, Maurice Hill, Los Angeles County Sheriffs Department.(Davis-Tinkham, Nicole) (Entered: 10/05/2012)

21 DAY Summons Issued re Second Amended Complaint,, 37 as to defendants Bayes, Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Does, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez. (lc)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Lashon O'Bannon served on 12/6/2012, answer due 12/27/2012. Service of the Summons and Complaint were executed upon Deputy Kennedy, person in charge in compliance with Federal Rules of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/07/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Gustavo Carranza served on 12/5/2012, answer due 12/26/2012. Service of the Summons and Complaint were executed upon Gustavo Carranza in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/07/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Ryck Burwell served on 12/5/2012, answer due 12/26/2012. Service of the Summons and Complaint were executed upon Ryck Burwell in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/07/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Ernie King served on 12/5/2012, answer due 12/26/2012. Service of the Summons and Complaint were executed upon Ernie King in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/07/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Jason Cartagena served on 12/7/2012, answer due 12/28/2012. Service of the Summons and Complaint were executed upon Sergeant Johnson, person in charge in compliance with Federal Rules of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/10/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Marina Garcia served on 12/7/2012, answer due 12/28/2012. Service of the Summons and Complaint were executed upon Sergeant Johnson, person in charge in compliance with Federal Rules of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/10/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Michael A Chacon served on 12/7/2012, answer due 12/28/2012. Service of the Summons and Complaint were executed upon Sergeant Johnson, person in charge, in compliance with Federal Rules of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/10/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Carlos L Sanchez served on 12/7/2012, answer due 12/28/2012. Service of the Summons and Complaint were executed upon Sergeant Johnson, person in charge, in compliance with Federal Rules of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/10/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Salvador Becerra served on 12/7/2012, answer due 12/28/2012. Service of the Summons and Complaint were executed upon Sergeant Burse, person in charge, in compliance with Federal Rules of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/11/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant D'Andre Lampkin served on 12/7/2012, answer due 12/28/2012. Service of the Summons and Complaint were executed upon Sergeant Burse, person in charge, in compliance with Federal Rules of Civil Procedure by substituted service at business address and by also mailing a copy. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/11/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Jose Carbajal, Jr served on 12/3/2012, answer due 12/24/2012. Service of the Summons and Complaint were executed upon Nicole Davis Tinkham, attorney for Jose Carbajal, Jr., in compliance with Federal Rules of Civil Procedure by method of service not specified. Original Summons NOT returned. (Gettings, Sarah) (Entered: 12/11/2012)

Joint STIPULATION to Extend Discovery Cut-Off Date to 4/12/2013 filed by Plaintiff Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. (Attachments: # 1 Proposed Order)(Bibring, Peter) (Entered: 12/12/2012)

1 Proposed Order

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ORDER CONTINUING TRIAL DATES 50 by Judge Dean D. Pregerson. Having reviewed the parties' stipulation, pursuant to Federal Rule of Civil Procedure 16(b)(4), to modify the Scheduling Order in order to extend the fact discovery period by 60 days, the Court finds that there is good cause and enters a modified scheduling order extending that date and subsequent dates as follows: FACT DISCOVERY CUT-OFF 4-12-13; EXPERT DISCOVERY CUT-OFF 6-11-13; LAST DAY TO FILE MOTIONS 7-12-13; FINAL PRE TRIAL CONFERENCE 10-07-13 at 11:00 a.m.; 5 DAY JURY TRIAL 10-22-13 at 9:00 a.m. (jre) (Entered: 12/19/2012)

ANSWER to Amended Complaint,, 37 filed by Defendants Ryck Burwell, Gustavo Carranza, Ernie King.(Mathers, Catherine) (Entered: 12/26/2012)

NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE:Burwell, Carranza, Ernie defendants Answer to Complaint 52 . The following error(s) was found: Local Rule 7.1-1 No Certification of Interested Parties. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (lc) (Entered: 12/27/2012)

ANSWER to Amended Complaint,, 37 filed by Defendants Salvador Becerra, Jose Carbajal, Jr, Jason Cartagena, Michael A Chacon, Marina Garcia, Lashon O'Bannon, Carlos L Sanchez.(Mathers, Catherine) (Entered: 12/27/2012)

Certification and Notice of Interested Parties filed by Defendants Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, Marina Garcia, Ernie King, Lashon O'Bannon, Carlos L Sanchez, (Mathers, Catherine) (Entered: 12/27/2012)

ANSWER to Amended Complaint,, 37 filed by defendant D'Andre Lampkin.(Davis Tinkham, Nicole) (Entered: 12/28/2012)

Certification and Notice of Interested Parties filed by defendant D'Andre Lampkin, (Davis Tinkham, Nicole) (Entered: 12/28/2012)

PROOF OF SERVICE Executed by Plaintiff Shane Quentin, Shawn Nee, National Photographers Rights Organization, Greggory Moore, upon Defendant Anthony Paez served on 1/3/2013, answer due 1/24/2013. Service of the Summons and Complaint were executed upon Catie Mathers, attorney for Anthony Paez in compliance with Federal Rules of Civil Procedure by method of service not specified. Original Summons NOT returned. (Fahimy, Geelan) (Entered: 01/10/2013)

NOTICE of Change of Attorney Information for attorney Geelan Fahimy counsel for Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. Adding Geelan Fahimy as attorney as counsel of record for Plaintiffs for the reason indicated in the G-06 Notice. Filed by Plaintiffs Attorney (Fahimy, Geelan) (Entered: 01/17/2013)

ANSWER to Amended Complaint,, 37 filed by Defendant Anthony Paez.(Davis Tinkham, Nicole) (Entered: 01/24/2013)

CERTIFICATION AND NOTICE of Interested Parties filed by Defendant Anthony Paez, (Davis Tinkham, Nicole) (Entered: 01/25/2013)

NOTICE of Change of Attorney Information for attorney Peter Bibring counsel for Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. Adding Yaman Salahi as attorney as counsel of record for Shawn Nee; Greggory Moore; Shane Quentin; The National Photographers' Rights Organization for the reason indicated in the G-06 Notice. Filed by Plaintiff Nee; Moore; Quentin; The Photographers' Rights Organization (Bibring, Peter) (Entered: 01/29/2013)

Joint STIPULATION to Continue Fact and Expert Discovery Cutoff and Last Day to File Motions from Fact Discovery 4/12/13; Expert Discovery 6/11/13; Motion Filing 7/12/13 to Fact Discovery 6/12/13; Expert Discovery 8/1/13; Motion Filing 8/9/13 Re: Order, Set/Reset Deadlines/Hearings,,,, 51 filed by Defendants Bayes, Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez. (Attachments: # 1 Proposed Order)(Mathers, Catherine) (Entered: 03/05/2013)

1 Proposed Order

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NOTICE of Manual Filing filed by Plaintiff National Photographers Rights Organization of (1) Plaintiff's Application to Seal; (2) [Proposed] Order re Application to Seal; (3) Unredacted Joint Stipulation re Plaintiff NPRO's Motion to Compel; (4) Exhibits N-T to Declaration of Sarah Gettings re Plaintiff NPRO's Motion to Compel. (Gettings, Sarah) (Entered: 03/07/2013)

ORDER by Judge Dean D. Pregerson, re Stipulation 63 the fact discovery cut-off is hereby continued from April 12, 2013 to June 12, 2013; the expert discovery cut-off is hereby continued from June 11, 2013 to August 1, 2013; and the last day to file motions is hereby continued from July 12, 2013 to August 9, 2013. No other dates currently set in the scheduling order are continued. (lc) (Entered: 03/07/2013)

NOTICE OF MOTION AND MOTION to Compel (1) Further Responses to Document Requests and Interrogatories; (2) Motion to Compel FRCP 30(b)(6) Deponent on Document Search Efforts; and (3) Request for Sanctions filed by Plaintiff National Photographers Rights Organization. Motion set for hearing on 4/2/2013 at 02:00 PM before Magistrate Judge Jay C. Gandhi. (Attachments: # 1 REDACTED Joint Stipulation Re Plaintiff National Photographers Rights Organization's Motion to Compel, # 2 Declaration of Sarah Gettings in support of Plaintiff's Motion to Compel, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Exhibit L, # 15 Exhibit M, # 16 Exhibits N - T Filed Under Seal, # 17 Exhibit U, # 18 Exhibit V, # 19 Exhibit W, # 20 Exhibit X, # 21 Exhibit Y, # 22 Exhibit Z, # 23 Exhibit AA, # 24 Exhibit BB, # 25 Exhibit CC, # 26 Exhibit DD, # 27 Exhibit EE, # 28 Exhibit FF, # 29 Exhibit GG, # 30 Exhibit HH, # 31 Exhibit II, # 32 Declaration of Nicole Davis Tinkham in Opposition to Plaintiff's Motion to Compel, # 33 Exhibits A - X, # 34 Proposed Order Granting Plaintiff's Motion to Compel)(Gettings, Sarah) (Attachment 6 replaced on 3/21/2013) (lmh). (Entered: 03/07/2013)

1 REDACTED Joint Stipulation Re Plaintiff National Photographers Rights Organizat

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2 Declaration of Sarah Gettings in support of Plaintiff's Motion to Compel

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3 Exhibit A

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4 Exhibit B

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5 Exhibit C

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6 Exhibit D

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7 Exhibit E

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8 Exhibit F

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9 Exhibit G

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10 Exhibit H

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11 Exhibit I

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12 Exhibit J

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13 Exhibit K

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14 Exhibit L

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15 Exhibit M

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16 Exhibits N - T Filed Under Seal

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17 Exhibit U

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18 Exhibit V

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19 Exhibit W

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20 Exhibit X

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21 Exhibit Y

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22 Exhibit Z

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23 Exhibit AA

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24 Exhibit BB

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25 Exhibit CC

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26 Exhibit DD

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27 Exhibit EE

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28 Exhibit FF

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29 Exhibit GG

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30 Exhibit HH

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31 Exhibit II

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32 Declaration of Nicole Davis Tinkham in Opposition to Plaintiff's Motion to

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33 Exhibits A - X

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34 Proposed Order Granting Plaintiff's Motion to Compel

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APPLICATION to Seal documents in connection with Plaintiff's 1. Motion to Compel further responses to document requests and interrogatories; 2. Motion to Compel FRCP 30(b)(60 Deponent on document search efforts; and 3. Request for Sanctions filed by Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. (Lodged Proposed Order) (lmh) (Entered: 03/11/2013)

PROOF OF SERVICE filed by Plaintiff National Photographers Rights Organization, of Plaintiff's Application to Seal Documents re Motion to Compel, [Proposed] Order; Unredacted Joint Stipulation and Exhibits N-T to Decl. of Sarah Gettings in support of Motion to Compel served on March 7, 2013. (Gettings, Sarah) (Entered: 03/08/2013)

SUPPLEMENT to MOTION to Compel (1) Further Responses to Document Requests and Interrogatories; (2) Motion to Compel FRCP 30(b)(6) Deponent on Document Search Efforts; and (3) Request for Sanctions 66 filed by Plaintiff National Photographers Rights Organization. (Attachments: # 1 Declaration of Peter Bibring, # 2 Exhibits A-AA to Declaration of Peter Bibring, # 3 Supplemental Declaration of Sarah Gettings, # 4 Exhibits A-D to Declaration of Sarah Gettings, # 5 Declaration of Geelan Fahimy)(Gettings, Sarah) (Entered: 03/19/2013)

1 Declaration of Peter Bibring

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2 Exhibits A-AA to Declaration of Peter Bibring

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3 Supplemental Declaration of Sarah Gettings

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4 Exhibits A-D to Declaration of Sarah Gettings

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5 Declaration of Geelan Fahimy

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APPLICATION for Order for to Seal Exhibit D to the Declaration of Sarah Gettings in support of Plaintiff's Motion to Compel filed by Plaintiff National Photographers Rights Organization. (Attachments: # 1 Proposed Order Granting Application to Seal Exhibit D to the Declaration of Sarah Gettings)(Gettings, Sarah) (Entered: 03/19/2013)

1 Proposed Order Granting Application to Seal Exhibit D to the Declaration of Sara

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SUPPLEMENT Memorandum in Opposition to Plaintiffs' Motion to Compel filed by Defendant County of Los Angeles. (Attachments: # 1 Declaration Decl. Gastelum in support of Supplemental Memorandum in Opposition to Motion to Compel, # 2 Declaration Decl. Naimi in support of Supplemental Memorandum in Opposition to Motion to Compel)(Davis Tinkham, Nicole) (Entered: 03/19/2013)

1 Declaration Decl. Gastelum in support of Supplemental Memorandum in Opposition t

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2 Declaration Decl. Naimi in support of Supplemental Memorandum in Opposition to M

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ORDER GRANTING PLAINTIFF'S APPLICATION TO SEAL DOCUMENTS IN CONNECTION WITH PLAINTIFF'S (1) MOTION TO COMPEL FURTHER RESPONSES TO DOCUMENT REQUESTS AND INTERROGATORIES; (2) MOTION TO COMPEL FRCP 30(b)(6) DEPONENT ON DOCUMENT SEARCH EFFORTS; AND (3) REQUEST FOR SANCTIONS by Magistrate Judge Jay C. Gandhi: IT IS HEREBY ORDERED that the Application is GRANTED. Pursuant to Local Rule 79-5.1 and the parties' Stipulated Protective Order, the following documents shall be filed under seal. (See Order for details)granting 68 Application to Seal (bem) (Entered: 03/26/2013)

SEALED DOCUMENT-UNREDACTED JOINT STIPULATION Re Plaintiff the National Photographers Rights Organization's 1) Motion to Compel Further Responses; 2) Motion to Compel FRCP 30(b)(6) Deponent on Document Search Efforts; and 3) Request for Sanctions (mg) (Entered: 04/03/2013)

SEALED DOCUMENT-EXHIBITS N-T to Declaration of Sarah Gettings in Support of Plaintiff The National Photographers Rights Organization's 1) MOTION to Compel Further Responses; 2) Motion to Compel FRCP 30(b)(6) Deponent on Document Search Efforts and 3) Request for Sanctions. (Attachments: # 1 Part 2)(mg) (Entered: 04/03/2013)

ORDER GRANTING PLAINTIFFS APPLICATION TO SEAL EXHIBIT D TO THE DECLARATION OF SARAH GETTINGS IN SUPPORT OF PLAINTIFFS (1) MOTION TO COMPEL FURTHER RESPONSES TO DOCUMENT REQUESTS AND INTERROGATORIES; (2) MOTION TO COMPEL FRCP 30(b)(6) DEPONENT ON DOCUMENT SEARCH EFFORTS; AND (3) REQUEST FOR SANCTIONS by Magistrate Judge Jay C. Gandhi, After considering Plaintiffs Application to Seal Exhibit D to the Declaration of Sarah Gettings in support of Plaintiffs Motion to Compel and Request for Sanctions ("Application"): IT IS HEREBY ORDERED that the Application is GRANTED. Pursuant to Local Rule 79-5.1 and the parties Stipulated Protective Order, Exhibit D to the Declaration of Sarah Gettings filed at ECF No. 66-6 shall be removed from public view, shall no longer be viewable on PACER, and shall be filed under seal. 70 Application for Order (lmh) (Entered: 03/21/2013)

MINUTES (IN CHAMBERS) ORDER DIRECTING FURTHER MEET AND CONFER EFFORTS by Magistrate Judge Jay C. Gandhi: The Court has reviewed plaintiff National Photographers Rights Organization's ("NPRO") motion to compel further responses to document requests and interrogatories, motion to compel a Rule 30(b)(6) deponent on document search efforts, and request for sanctions, along with the parties' supplemental memoranda now. [See Dkt. Nos. 66, 68, 69, 71.] On its own motion, the Court now DIRECTS the parties to further meet and confer, fully and diligently and in person, on the relief sought by this motion, including whether mutually-acceptable, reasonable compromises cannot be achieved here, such as, without prejudging any matter. (See Order for details) 66, 69 71, (bem) (Entered: 03/25/2013)

NOTICE OF MOTION AND MOTION for Protective Order for Preventing Public Disclosure of Internal Affairs Investigation and Personnel Files filed by Defendants Bayes, Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez. Motion set for hearing on 4/30/2013 at 02:00 PM before Magistrate Judge Jay C. Gandhi. (Attachments: # 1 Joint Stipulation, # 2 Declaration, # 3 Declaration, # 4 Declaration, # 5 Proposed Order)(Mathers, Catherine) (Entered: 03/27/2013)

1 Joint Stipulation

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2 Declaration

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3 Declaration

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4 Declaration

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5 Proposed Order

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NOTICE of Manual Filing filed by Defendants Bayes, Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez of DEFENDANTS' APPLICATION TO SEAL DOCUMENTS IN CONNECTION WITH DEFENDANTS' MOTION FOR PROTECTIVE ORDER; DECLARATION OF DENISSE GASTELUM; (PROPOSED) ORDER. (Mathers, Catherine) (Entered: 03/28/2013)

Notice of Withdrawal of Motion to Compel,,,,, 66 filed by Plaintiff National Photographers Rights Organization. (Gettings, Sarah) (Entered: 04/01/2013)

Joint STIPULATION for Order Re: Plaintiff's Motion to Compel filed by Plaintiff National Photographers Rights Organization. (Attachments: # 1 Proposed Order)(Gettings, Sarah) (Entered: 04/01/2013)

1 Proposed Order

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JOINT STIPULATED DISCOVERY ORDER RE: PLAINTIFFS MOTION TO COMPEL by Magistrate Judge Jay C. Gandhi, Plaintiff National Photographers Rights Organization ("Plaintiff") and defendant County of Los Angeles ("Defendant"), by and through their counsel of record, held an in-person conference at the offices of Akin Gump Strauss Hauer & Feld LLP, 2029 Century Park East, Los Angeles, California 90067 on March 28, 2013 pursuant to the Courts March 25, 2013 Order (ECF No. 73) requiring an in-person conference in connection with Plaintiffs Motion to Compel and Request for Sanctions (ECF No. 66), and reached certain mutually-acceptable compromises regarding discovery. IT IS HEREBY STIPULATED, by and between the parties, through their counsel of record, as described herein. re Stipulation for Order 78 (SEE ORDER FOR FURTHER DETAILS) (lmh) (Entered: 04/02/2013)

MINUTES (IN CHAMBERS) ORDER DIRECTING FURTHER MEET AND CONFER EFFORTS by Magistrate Judge Jay C. Gandhi: The Court has reviewed Defendants' motion for a protective order preventing public disclosure of (1) internal affairs investigation report and testimony thereon; and (2) LASD deputy personnel files. [Dkt. No. 75.] The Court has also carefully reviewed Exhibits E, F, and G to the Declaration of Denise O. Gastelum, specifically the copies of reports generated by the Internal Affairs Bureau, the LASD deputy personnel records, and the testimony of Patrick Jordan. On its own motion, the Court now DIRECTS the parties to further meet and confer, fully and diligently and in person, on the relief sought by this motion, including whether mutually- acceptable, reasonable compromises cannot be achieved here, such as, without prejudging any matter. If the parties are able to resolve their discovery dispute, as the Court now anticipates, Plaintiff shall so advise the Courtroom Deputy Clerk on or before April 23, 2013 and file a notice of withdrawal of the motion to compel. It is so ordered. (See Order for details) 75 . (bem) (Entered: 04/02/2013)

APPLICATION to Seal Documents in Connection with Defendants' Motion for a Protective Order Preventing Public Disclosure of (1) INTERNAL AFFAIRS INVESTIGATION REPORT AND TESTIMONY THEREON (2) LASD DEPUTY PERSONNEL FILES filed by Defendant Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez. (bem) (Entered: 04/05/2013)

ORDER GRANTING DEFENDANTS' APPLICATION TO SEAL DOCUMENTS IN CONNECTION WITH DEFENDANTS' MOTION FOR A PROTECTIVE ORDER PREVENTING PUBLIC DISCLOSURE OF (1) INTERNAL AFFAIRS INVESTIGATION REPORT AND TESTIMONY THEREON (2) LASD DEPUTY PERSONNEL FILES by Magistrate Judge Jay C. Gandhi: IT IS HEREBY ORDERED that the Application is GRANTED. Pursuant to Local Rule 79-5.1 and the parties' Stipulated Protective Order, the following documents shall be filed under seal: Exhibits E, F, and G to the Declaration of Denisse O. Gastlum in Support of Defendants' Motion for a Protective Order Preventing Public Disclosure of (1) Internal Affairs Investigation Report and Testimony Thereon; (2) LASD Deputy Personnel Files granting 83 . (bem) (Entered: 04/05/2013)

SEALED DOCUMENT- DECLARATION of Denisse O. Gatelum in Support of Joints Stipulation Re: Defendants' Motion for Protective Order and Exhibits E, F, and G. (Attachments: Part 2, Part 3)(mat) (Entered: 04/08/2013)

JOINT STIPULATION to MOTION for Protective Order for Preventing Public Disclosure of Internal Affairs Investigation and Personnel Files 75 (pursuant to Courts April 2, 2013 Order) filed by Defendants Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez. (Mathers, Catherine) (Entered: 04/17/2013)

JOINT STIPULATED DISCOVERY ORDER RE: DEFENDANTS MOTION FOR A PROTECTIVE ORDER; ORDER by Magistrate Judge Jay C. Gandhi, IT IS HEREBY STIPULATED, by and between the parties, through their counsel of record, that there is good cause to continue the hearing set for Defendants Motion for a Protective Order Preventing Public Disclosure of (1) Internal Affairs Investigation Report and Testimony Thereon and (2) LASD Deputy Personnel Files currently scheduled for April 30, 2013 to May 21, 2013. re Joint Stipulation re Discovery Motion 86 (SEE ORDER FOR FURTHER DETAILS) (lmh) Modified on 4/19/2013 (lmh). (Entered: 04/18/2013)

NOTICE of Manual Filing filed by Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin of Application for Under Seal Filing, Proposed Order, Plaintiffs' Supplemental Brief in Opposition to Defendants' Motion for Protective Order. (Bibring, Peter) (Entered: 05/07/2013)

NOTICE of Manual Filing filed by Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin of Notice of Lodging of Exhibit A (Compact Disc). (Bibring, Peter) (Entered: 05/07/2013)

DECLARATION of Yaman Salahi in Opposition to MOTION for Protective Order for Preventing Public Disclosure of Internal Affairs Investigation and Personnel Files 75 filed by Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. (Attachments: # 1 Exhibits)(Bibring, Peter) (Entered: 05/07/2013)

1 Exhibits

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NOTICE OF LODGING filed Exhibit A (CD-Rom) re Declaration (Motion related), 90 (Bibring, Peter) (Entered: 05/07/2013)

NOTICE OF MOTION AND Supplemental MOTION for Protective Order for Preventing Public Disclosure of Internal Affairs Investigation Report and Testimony Thereon and LASD Deputy Personnel Files filed by Defendants Bayes, Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Does, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez. Motion set for hearing on 5/21/2013 at 02:00 PM before Magistrate Judge Jay C. Gandhi. (Attachments: # 1 Declaration Declaration of Gastelum in Support of Defendants' Supplemental Memorandum in Support of Defendants' Motion for Protective Order)(Davis Tinkham, Nicole) (Entered: 05/07/2013)

1 Declaration Declaration of Gastelum in Support of Defendants' Supplemental

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NOTICE OF MOTION AND Supplemental MOTION for Protective Order for Notice of Manual Filing of Defendants' Application to Seal Documents in Connection with Defendants' Supplemental Memorandum in Support of Defendants' Motion for Protective Order; Declaration of Gastelum in Support of Joint Stipulation Re: Defendants' Motion for Protective Order; Exhibits A, B and C; [Proposed] Order filed by Defendants Bayes, Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Does, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez. Motion set for hearing on 5/21/2013 at 02:00 PM before Magistrate Judge Jay C. Gandhi. (Davis Tinkham, Nicole) (Entered: 05/07/2013)

APPLICATION to File Under Seal a Supplemental Brief in Opposition to Defendants' Motion for Protective Order filed by Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin. (Lodged Proposed Order) (lmh) (Entered: 05/08/2013)

NOTICE OF LODGING filed Amended Lodging of Exhibit A re Declaration (Motion related), 90, Notice of Lodging 91 (Bibring, Peter) (Entered: 05/08/2013)

NOTICE of Manual Filing filed by Plaintiffs Greggory Moore, National Photographers Rights Organization, Shawn Nee, Shane Quentin of Exhibit A: CD-Rom to Declaration of Yaman Salahi, Dkt. 90. (Bibring, Peter) (Entered: 05/08/2013)

NOTICE OF ERRATA filed by Defendants Bayes, Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez. correcting Supplemental MOTION for Protective Order for Notice of Manual Filing of Defendants' Application to Seal Documents in Connection with Defendants' Supplemental Memorandum in Support of Defendants' Motion for Protective Order; Declaration o 93 (Mathers, Catherine) (Entered: 05/08/2013)

NOTICE OF ERRATA filed by Defendants Bayes, Salvador Becerra, Ryck Burwell, Jose Carbajal, Jr, Gustavo Carranza, Jason Cartagena, Michael A Chacon, County of Los Angeles, Marina Garcia, Richard Gylfie, Maurice Hill, Ernie King, D'Andre Lampkin, Los Angeles County Sheriffs Department, Lashon O'Bannon, Anthony Paez, Carlos L Sanchez. correcting Supplemental MOTION for Protective Order for Preventing Public Disclosure of Internal Affairs Investigation Report and Testimony Thereon and LASD Deputy Personnel Files 92 (Mathers, Catherine) (Entered: 05/08/2013)