Los Angeles Superior Court Sealing & Redaction Procedures

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Documents submitted conditionally under seal are to be emailed unredacted directly to Department E's email address for review. Please see the Court's email address above.

Summary: Conditionally sealed documents must be emailed unredacted directly to Department E's email address (tordepte@lacourt.ca.gov) for review.

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If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the SCLAC in its website.

Summary: A party seeking protection for the ordered discovery must serve and file a proposed protective order within 5 days of the order and meet and confer on language, with the standard SCLAC protective order as the default.

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If a party believes any of this information should be subject to a protective order, that party shall serve ad file a proposed protective order within 5 days of this Order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the SCLAC in its website.

Summary: A party seeking protection for the ordered discovery information must serve and file a proposed protective order within 5 days of the Order, and the parties must meet and confer on language, with the SCLAC standard Protective Order as the default.

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Sealed documents. Strict compliance with CRC, rule 2.551 et. seq. is required.

Summary: Strict compliance with CRC, rule 2.551 et seq. is required for sealed documents.

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If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this Order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the LASC in its website.

Summary: A party who believes the information disclosed under this Order should be protected must serve and file a proposed protective order within 5 days of the Order, the parties must meet and confer on agreeable language, and the default is the standard LASC Protective Order from its website.

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The list provided by Defendant may be in a chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and text of the other customers' reported complaint, but shall not include the other customers' names, addresses, phone numbers, e-mail addresses, or other personal identifying information.

Summary: The customer complaint list must include the VIN, repair visit date, reporting location, and complaint text, but must exclude other customers' names, addresses, phone numbers, e-mail addresses, and any other personal identifying information.

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The list provided by defendant may be in the chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and text of the other customers’ reported complaint, but shall not include the other customers’ names, addresses, phone numbers, e-mail addresses, or other personal identifying information.

Summary: Defendant's list of other customers' repair visits must include the VIN, repair date, location, and complaint text but must exclude all other customers' personal identifying information.

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If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this Order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the LASC on its website.

Summary: A party believing produced information needs protection must serve and file a proposed protective order within 5 days of the order and meet and confer, with the default being the standard LASC Protective Order.

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If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within five (5) days of serving discovery responses

Summary: A party who believes Song-Beverly discovery material should be subject to a protective order must serve and file a proposed protective order within five days of serving discovery responses.

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If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.

Summary: Materials submitted in support of a motion under seal must strictly comply with California Rules of Court Rule 2.551 et seq.

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Counsel must familiarize themselves with the requirements for sealing documents pursuant to CRC 2.550 and 2.551. Failure to comply with the CRC may result in rejection of the submission and delay any hearing related to the sealed documents.

Summary: Counsel must comply with the sealing requirements of CRC 2.550 and 2.551 or the submission may be rejected and related hearings delayed.

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It is the submitting party’s responsibility to redact confidential information so that confidential information shall not be publicly disclosed.

Summary: Submitting parties are responsible for redacting confidential information so that it is not publicly disclosed.

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Civil cases

The Designating Party shall have the right to designate as "Highly Confidential" only the non-public Documents, Testimony, or Information that the Designating Party in good faith believes would create a substantial risk of serious financial or other injury, if Disclosed to another Party or non-Party, and that such risk cannot be avoided by less restrictive means.

Summary: A party may designate material as 'Highly Confidential' only if the material is non-public and the party in good faith believes disclosure would create a substantial risk of serious financial or other injury that cannot be avoided by less restrictive means.

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Civil cases

Upon receipt of such Inadvertent Production Notice, the Party that received the inadvertently produced Document, Testimony, or Information shall promptly destroy the inadvertently produced Document, Testimony, or Information and all copies thereof, or, at the expense of the producing Party, return such together with all copies of such Document, Testimony or Information to counsel for the producing Party and shall retain only the "Confidential" or "Highly Confidential" materials.

Summary: Upon receipt of an Inadvertent Production Notice, the receiving party must promptly destroy or return the inadvertently produced material and all copies.

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Civil cases

In the event that the Designation Objections are neither timely agreed to nor timely addressed in the Designation Motion, then such Documents, Testimony, or Information shall be de-designated in accordance with the Designation Objection applicable to such material.

Summary: Confidential material whose designation objections are neither timely resolved by agreement nor timely addressed in a Designation Motion will be de-designated.

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Civil cases

Access to and/or Disclosure of Confidential Materials shall be permitted only to the following persons or entities:

Summary: Confidential Materials may be accessed or disclosed only to the enumerated persons/entities: the Court; attorneys of record and their affiliated staff; in-house counsel and staff; officers, directors, partners, members, employees and agents of non-designating parties; court reporters; certain witnesses; mock jury participants; and outside experts or expert consultants.

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Civil cases

provided, however, that prior to the Disclosure of Confidential Materials to any such officer, director, partner, member, employee or agent, counsel for the Party making the Disclosure shall deliver a copy of this Protective Order to such person, shall explain that such person is bound to follow the terms of such Order, and shall secure the signature of such person on a statement in the form attached hereto as Exhibit A

Summary: Before disclosing Confidential Materials to an officer, director, partner, member, employee, or agent of a non-designating party, counsel must deliver a copy of the Protective Order to the person, explain that they are bound by it, and obtain their signature on the Exhibit A acknowledgment.

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Civil cases

mock jury participants, provided, however, that prior to the Disclosure of Confidential Materials to any such mock jury participant, counsel for the Party making the Disclosure shall deliver a copy of this Protective Order to such person, shall explain that such person is bound to follow the terms of such Order, and shall secure the signature of such person on a statement in the form attached hereto as Exhibit A.

Summary: Before disclosing Confidential Materials to mock jury participants, counsel must deliver a copy of the Protective Order, explain that the participant is bound by its terms, and obtain a signed Exhibit A acknowledgment.

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Civil cases

outside experts or expert consultants consulted by the undersigned Parties or their counsel in connection with the Proceeding, whether or not retained to testify at any oral hearing; provided, however, that prior to the Disclosure of Confidential Materials to any such expert or expert consultant, counsel for the Party making the Disclosure shall deliver a copy of this Protective Order to such person, shall explain its terms to such person, and shall secure the signature of such person on a statement in the form attached hereto as Exhibit A.

Summary: Before disclosing Confidential Materials to outside experts or expert consultants, counsel must deliver a copy of the Protective Order, explain its terms, and obtain a signed Exhibit A acknowledgment.

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Civil cases

It shall be the obligation of counsel, upon learning of any breach or threatened breach of this Protective Order by any such

Summary: Counsel has an affirmative obligation upon learning of any breach or threatened breach of the Protective Order by a person given access to Confidential Materials (provision continues beyond this excerpt).

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Civil cases

Access to and/or Disclosure of Highly Confidential Materials shall be permitted only to the following persons or entities:

Summary: Access to and disclosure of Highly Confidential Materials is restricted to trial counsel (outside retained counsel, excluding in-house counsel) and their staff, outside experts who have signed the protective order acknowledgment, persons previously familiar with the designated materials, court reporters, and the Court.

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Civil cases

Confidential Materials and Highly Confidential Materials shall be used by the persons or entities receiving them only for the purposes of preparing for, conducting, participating in the conduct of, and/or prosecuting and/or defending the Proceeding, and not for any business or other purpose whatsoever.

Summary: Confidential and Highly Confidential Materials may be used only for preparing for, conducting, and participating in this Proceeding, and not for any business or other purpose.

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Civil cases

Where any Confidential Materials or Highly Confidential Materials, or Information derived therefrom, is included in any motion or other proceeding governed by California Rules of Court, Rules 2.550 and 2.551, the Parties and any involved non-party shall follow those rules.

Summary: Motions or proceedings containing confidential materials that are governed by California Rules of Court Rules 2.550 and 2.551 must follow those sealing rules.

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Civil cases

If Confidential Materials, Highly Confidential Materials, or Information derived therefrom are submitted to or otherwise disclosed to the Court in connection with discovery motions and proceedings, the same shall be separately filed under seal with the clerk of the Court in an envelope marked: "CONFIDENTIAL – FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER AND WITHOUT ANY FURTHER SEALING ORDER REQUIRED."

Summary: Confidential materials submitted to the Court in connection with discovery motions must be separately filed under seal with the clerk in an envelope marked 'CONFIDENTIAL – FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER AND WITHOUT ANY FURTHER SEALING ORDER REQUIRED.'

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Civil cases

damages trial phase shall be aggregated by the defendant, placed in a sealed package, and lodged with the trial court on the first day of trial. The trial court shall permit access to such information as applicable under Civil Code section 3295, or as otherwise ordered.

Summary: Financial information for the punitive damages trial phase must be aggregated by the defendant, placed in a sealed package, and lodged with the trial court on the first day of trial, with access governed by Civil Code section 3295 or other court order.

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Civil cases

If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.

Summary: Materials submitted in support of a motion under seal must strictly comply with California Rules of Court, rule 2.551 et seq.

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It is the submitting party's responsibility to redact confidential information so that confidential information shall not be publicly disclosed.

Summary: Submitting parties are responsible for redacting confidential information so that it is not publicly disclosed.

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Civil cases

Sealed documents. Strict compliance with CRC. rule 2.551 et. seq. is required.

Summary: Strict compliance with CRC rule 2.551 et seq. is required for sealed documents.

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If a party believes any of the information described in sections 2 or 3 of this Order should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the LASC in its website.

Summary: A party seeking protection for information covered by sections 2 or 3 must serve and file a proposed protective order within 5 days and meet and confer on language, with the standard LASC protective order as the default.

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If a party believes any of this information should be subject to a protective order, that party shall first meet and confer as to agreeable language for the order. Absent a stipulation, the requesting party shall file a motion for a protective order.

Summary: A party seeking a protective order for court-ordered discovery information must first meet and confer on agreeable language, and absent a stipulation must file a motion for a protective order.

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If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the SCLAC on its website.

Summary: A party seeking protection for exchanged discovery information must serve and file a proposed protective order within 5 days of the order, meet and confer on language, and the default is the standard SCLAC protective order from its website.

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No exhibit that contains sensitive personal information is to be displayed to the jury or shown to a witness unless the Court rules that the information shall remain on the exhibit. Examples of sensitive personal information include but are not limited to: social security number, home address, phone number(s) and email address. Before redacting personal identifying information on a document, a party who wishes to use the document shall show the document to opposing counsel and the portion to be redacted. If there is any objection to redacting any information on the document, counsel is to take up the issue with the court.

Summary: Exhibits containing sensitive personal information (e.g., Social Security number, home address, phone numbers, email) may not be displayed to the jury or shown to a witness unless the Court rules the information stays on the exhibit; before redacting, the party must show the document and proposed redaction to opposing counsel, and any objection is taken to the Court.

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If a party believes any of this information should be subject to protective order, that party shall serve and file a proposed protective order within five (5) days of this Order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the Superior Court of Los Angeles County on its website.

Summary: A party seeking protective order protection for produced Song-Beverly documents must serve and file a proposed protective order within five days of the Order after meet and confer, with the default being the Los Angeles County standard Protective Order.

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Civil cases

If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this Order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the Superior Court of Los Angeles in its website.

Summary: A party who believes the ordered discovery information needs protection must serve and file a proposed protective order within 5 days of this Order and meet and confer on its language, with the Los Angeles Superior Court standard Protective Order as the default.

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Civil cases

If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this Order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the LASC in its website.

Summary: A party who believes produced discovery information should be protected must serve and file a proposed protective order within 5 days of the order and meet and confer on language, with the LASC standard protective order as the default.

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If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the SCLAC in its website.

Summary: A party who believes exchanged discovery information needs protection must serve and file a proposed protective order within 5 days of this order and meet and confer on language, with the standard SCLAC Protective Order applying by default.

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Civil cases

All parties must comply with California Rules of Court 2.550 and 2.551. The court cannot seal documents filed in Court merely because the parties agree they should be sealed.

Summary: All parties must comply with CRC 2.550 and 2.551 to file documents under seal; the court cannot seal documents merely because the parties agree and must make specific findings supporting sealing.

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Civil cases

must be persuaded that there is a legal justification for sealing. The sealing order must be narrowly tailored to seal only the specific information that is protected by the right to privacy, trade secrets law, or other applicable protections.

Summary: The court must be persuaded there is a legal justification for sealing, and any sealing order must be narrowly tailored to only information protected by privacy rights, trade secrets law, or other applicable protections.

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Civil cases

To file confidential material in connection with a discovery motion, the parties should (a) narrowly identify and redact the confidential information from the confidential document; (b) submit an unredacted version in a sealed envelope stapled behind the caption page of the document (making sure that the caption page states that the submission is for a discovery motion); and (c) file a redacted version of the document (making it available to the public in the court file).

Summary: To file confidential material with a discovery motion, parties must narrowly redact the confidential information, submit the unredacted version in a sealed envelope stapled behind a caption page that states the submission is for a discovery motion, and file a redacted public version.

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If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.

Summary: Counsel submitting motion materials under seal must strictly comply with California Rules of Court Rule 2.551 et seq.

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For this reason, in many cases, the Court will not rule on a request for dismissal under CRC 3.770 until it is presented with a fully executed unredacted version of the parties' settlement agreement, which may be filed conditionally under seal along with an application for a sealing order under CRC 2.500.

Summary: The Court generally will not rule on a CRC 3.770 dismissal request until presented with a fully executed unredacted settlement agreement, which may be filed conditionally under seal with an application for a sealing order under CRC 2.500.

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All parties must strictly comply with Rules of Court, Rules 2.550 and 2.551 when submitting documents to be filed under seal. Because there is a public right of access to court records, the Court must make specific findings as to each part of every document that a party wishes to file under seal. Parties should therefore use the sealing process only when absolutely necessary.

Summary: Parties must strictly comply with California Rules of Court 2.550 and 2.551 when filing under seal and should seal only when absolutely necessary because the Court must make specific findings for each part of every sealed document.

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Any confidential filings (including documents filed under a protective order and documents lodged conditionally) submitted on eCourt must have their unredacted versions emailed to the department resource account at smcdept506@lacourt.ca.gov with a cc to all Counsel/parties involved. However, copying the opposing party is not required for confidential documents related to Certificates of Merit or confidential Mandatory Settlement Conference (MSC) statements.

Summary: Unredacted versions of confidential filings submitted on eCourt must be emailed to the department resource account with a cc to all counsel/parties, except that copying the opposing party is not required for Certificates of Merit or confidential MSC statements.

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Confidentiality: If a party believes any of the disclosure of information under this Order should be subject to a protective order, that party shall serve and file a proposed protective order within five days of this order and the parties shall meet and confer as to agreeable language for the same. The default protective order will be the standard protective order provided by the Los Angeles Superior Court on its website.

Summary: A party seeking protection for disclosed information must serve and file a proposed protective order within five days and meet and confer on agreeable language; otherwise the default is the Los Angeles Superior Court's standard protective order.

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Civil cases

For unredacted copies of documents filed with the Court, please email them directly to WCC-Dept1@lacourt.org.

Summary: Unredacted versions of documents filed with the Court must be emailed directly to WCC-Dept1@lacourt.org.

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Civil cases

Upon review, should plaintiff determine in good faith that any part of the records are not subject to disclosure and/or are privileged based upon privacy objections or then-existing privilege under California law, plaintiff shall serve a Notice of Redacted Records to all parties via FSX, and to Vendor via email.

Summary: Redaction of produced medical records is triggered when the records are privileged or not subject to disclosure based on privacy objections or privilege under California law.

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Civil cases

"Confidential" or "Highly Confidential" (before the deposition is concluded) with the right to identify more specific portions of the Testimony as to which protection is sought within 30 days following receipt of the deposition transcript.

Summary: Testimony designated for protection before the deposition concludes may have more specific protected portions identified within 30 days after receipt of the deposition transcript.

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Civil cases

For Information produced in some form other than Documents, and for any other tangible items, including, without limitation, compact discs or DVDs, the Designating Party must affix in a prominent place on the exterior of the container or containers in which the Information or item is stored the legend "Confidential" or "Highly Confidential." If only portions of the Information or item warrant protection, the Designating Party, to the extent practicable, shall identify the "Confidential" or "Highly Confidential" portions.

Summary: Tangible items and non-document Information must be marked 'Confidential' or 'Highly Confidential' on the exterior of their containers, with specific protected portions identified where practicable.

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Civil cases

Pending a resolution of the Designation Motion by the Court, any and all existing designations on the Documents, Testimony, or Information at issue in such Motion shall

Summary: Existing confidentiality designations remain in effect pending the Court's resolution of the Designation Motion.

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Civil cases

The Designating Party shall have the burden on any Designation Motion of establishing the applicability of its "Confidential" or "Highly Confidential" designation.

Summary: The Designating Party bears the burden of proving that its "Confidential" or "Highly Confidential" designation applies in any Designation Motion.

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Civil cases

Provided, however, that each non-lawyer given access to Confidential Materials shall be advised that such materials are being Disclosed pursuant to, and are subject to, the terms of this Stipulation and Protective Order and that they may not be Disclosed other than pursuant to its terms

Summary: Each non-lawyer given access to Confidential Materials must first be advised that the materials are disclosed under, and subject to, the Protective Order and may not be disclosed other than pursuant to its terms.

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Civil cases

any deposition or non-trial hearing witness in the Proceeding who previously did not have access to the Confidential Materials; provided, however, that each such witness given access to Confidential Materials shall be advised that such materials are being Disclosed pursuant to, and are subject to, the terms of this Protective Order and that they may not be Disclosed other than pursuant to its terms

Summary: Deposition or non-trial hearing witnesses without prior access to Confidential Materials may receive them only after being advised that the materials are governed by the Protective Order and may not be disclosed outside its terms.

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For unredacted copies of documents filed with the Court, please email them directly to WCC-Dept6@lacourt.org, or deliver a flash drive to the Courtroom Assistant or Judicial Assistant.

Summary: Unredacted copies of documents filed with the Court must be emailed directly to WCC-Dept6@lacourt.org or delivered on a flash drive to the Courtroom Assistant or Judicial Assistant.

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Civil cases

Confidential documents submitted in connection with discovery motions are not governed by Rules 2.550 and 2.551.

Summary: Confidential documents submitted with discovery motions are exempt from California Rules of Court 2.550 and 2.551 and instead follow this court's own procedure.

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In the Court's view, the private interest for sealing a document must generally involve something more than a confidentiality agreement between the parties to outweigh the public interest in open court files.

Summary: A private interest in sealing must generally involve more than a confidentiality agreement between the parties to outweigh the public interest in open court files.

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Civil cases

If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the LASC in its website.

Summary: A party seeking protection for produced discovery information must serve and file a proposed protective order within 5 days of the order and meet and confer on its language, with the standard LASC Protective Order applying by default.

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Civil cases

The inadvertent production by any of the undersigned Parties or non-Parties to the Proceedings of any Document, Testimony, or Information during discovery in this Proceeding without a "Confidential" or "Highly Confidential" designation, shall be without prejudice to any claim that such item is "Confidential" or "Highly Confidential" and such Party shall not be held to have waived any rights by such inadvertent production.

Summary: Inadvertent production of material without a confidentiality designation does not waive claims that the material is 'Confidential' or 'Highly Confidential.'

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Civil cases

This provision is not intended to apply to any inadvertent production of any Document, Testimony, or Information protected by attorney-client or work product privileges.

Summary: The inadvertent production procedure does not apply to material protected by attorney-client or work product privileges.

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Documents Filed Under Seal. Documents submitted conditionally under seal are to be emailed unredacted directly to Department E’s email address for review. Please see the Court’s email address above.

Summary: Conditionally sealed documents must be emailed unredacted to Dept E for review.

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Application or Motion. The actual application or motion to submit documents under seal must be electronically filed and comply with Cal. Rules of Court (“CRC”), Rules 2.550-2.551.

Summary: Motion to seal must be e-filed and comply with CRC 2.550-2.551.

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If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.

Summary: Materials filed under seal must strictly comply with CRC Rule 2.551 et seq.

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Civil cases

If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.

Summary: Materials in support of a motion filed under seal must comply with California Rules of Court Rule 2.551 et seq.

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Civil cases

Sealed documents. Strict compliance with CRC. rule 2.551 et. seq. is required.

Summary: Strict compliance with CRC rule 2.551 et seq. required for sealed documents.

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Civil cases

If counsel seek to submit materials in support of a motion under seal, counsel must strictly comply with CRC 2.551, et seq. Pursuant to the General Order Mandatory Electronic Filing for Civil, documents submitted conditionally under seal are exempt from eFiling. A separate reservation for the motion to file documents under seal must be made via CRS. The actual motion shall be eFiled. A courtesy copy of the eFiled motion, with the documents submitted conditionally under seal must be provided to Department 310.

Summary: Motions to file documents under seal must comply with CRC 2.551; the motion is eFiled with a courtesy copy to Department 310, while conditionally sealed documents are exempt from eFiling.

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Exhibits with Personal Information: No exhibit that contains sensitive personal information is to be displayed to the jury or shown to a witness unless the Court rules that the information shall remain on the exhibit. Examples of sensitive personal information include but are not limited to: social security number, home address, phone number(s) and email address. Before redacting personal identifying information on a document, a party who wishes to use the document shall show the document to opposing counsel and the portion to be redacted. If there is any objection to redacting any information on the document, counsel is to take up the issue with the court.

Summary: Exhibits with sensitive personal information must be redacted unless the court rules otherwise, with redaction approved by opposing counsel first.

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If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.

Summary: Motion support materials submitted under seal must comply with California Rules of Court Rule 2.551 et seq.