# Continental Casualty Company v. Guzman

> District Court, E.D. California · August 20, 2020

URL: https://www.frixlaw.com/law-library/cases/10021375

## Case

- **Court:** District Court, E.D. California
- **Decided:** August 20, 2020
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 CNA COVERAGE LITIGATION GROUP
ROBERT C. CHRISTENSEN (SBN 151296)
2 Email: robert.christensen@cna.com
555 12th Street, Suite 600
3 Oakland, CA 94607
Telephone: 510.645.2306
4 Facsimile: 510.645.2323

5 Attorneys for Plaintiff
CONTINENTAL CASUALTY COMPANY
6
7
8 UNITED STATES DISTRICT COURT
9 FOR THE EASTERN DISTRICT OF CALIFORNIA
10 CONTINTENTAL CASUALTY CASE NO.: 2:19-cv-01975-KJM-CKD
COMPANY,
11
Plaintiff, STIPULATED PROTECTIVE ORDER
12
vs.

13
LETHESIA GUZMAN; FAAFETAI AND
14 RACHEL TALIAOA; L. M., a minor by and
Complaint Filed: 9/27/19
through her Guardian Ad Litem THOMAS
15 NICHOLS; D. M., and N. M., by and through
their Guardian Ad Litem, Patricia Montejano,

16 and DOES 1-10, inclusive,
17 Defendants.
18
19 1. A. PURPOSES AND LIMITATIONS
20 Discovery in this action is likely to involve production of confidential, proprietary or
21 private information for which special protection from public disclosure and from use for any
22 purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby
23 stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties
24 acknowledge that this Order does not confer blanket protections on all disclosures or responses to
25 discovery and that the protection it affords from public disclosure and use extends only to the
26 limited information or items that are entitled to confidential treatment under the applicable legal
27 principles.
28 / / /
1 B. GOOD CAUSE STATEMENT
2 This action is likely to involve disclosure of proprietary information from non-parties
3 including, but not limited to, Sprint Corporation for which special protection from public
4 disclosure and from use for any purpose other than prosecution of this action is warranted. Such
5 confidential and proprietary materials and information consist of, among other things, automobile
6 fleet management policies, guidelines and other related materials that is not otherwise generally
7 unavailable to the public, or which may be privileged or otherwise protected from disclosure
8 under state or federal statutes, court rules, case decisions, or common law. Accordingly, to
9 expedite the flow of information, to facilitate the prompt resolution of disputes over
10 confidentiality of discovery materials, to adequately protect information the parties are entitled to
11 keep confidential, to ensure that the parties are permitted reasonable necessary uses of such
12 material in preparation for and in the conduct of trial, to address their handling at the end of the
13 litigation, and serve the ends of justice, a protective order for such information is justified in this
14 matter. It is the intent of the parties that information will not be designated as confidential for
15 tactical reasons and that nothing be so designated without a good faith belief that it has been
16 maintained in a confidential, non-public manner, and there is good cause why it should not be
17 part of the public record of this case.
18 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
19 The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated
20 Protective Order does not entitle them to file confidential information under seal; Local Civil
21 Rule 141 sets forth the procedures that must be followed and the standards that will be applied
22 when a party seeks permission from the court to file material under seal.
23 There is a strong presumption that the public has a right of access to judicial proceedings
24 and records in civil cases. In connection with non-dispositive motions, good cause must be shown
25 to support a filing under seal. See Kamakana v. City and County of Honolulu, 447 F.3d 1172,
26 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002),
27 Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
28 protective orders require good cause showing), and a specific showing of good cause or
1 compelling reasons with proper evidentiary support and legal justification, must be made with
2 respect to Protected Material that a party seeks to file under seal. The parties’ mere designation of
3 Disclosure or Discovery Material as CONFIDENTIAL does not—without the submission of
4 competent evidence by declaration, establishing that the material sought to be filed under seal
5 qualifies as confidential, privileged, or otherwise protectable—constitute good cause.
6 Further, if a party requests sealing related to a dispositive motion or trial, then compelling
7 reasons, not only good cause, for the sealing must be shown, and the relief sought shall be
8 narrowly tailored to serve the specific interest to be protected. See Pintos v. Pacific Creditors
9 Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of information, document, or
10 thing sought to be filed or introduced under seal in connection with a dispositive motion or trial,
11 the party seeking protection must articulate compelling reasons, supported by specific facts and
12 legal justification, for the requested sealing order. Again, competent evidence supporting the
13 application to file documents under seal must be provided by declaration.
14 Any document that is not confidential, privileged, or otherwise protectable in its entirety
15 will not be filed under seal if the confidential portions can be redacted. If documents can be
16 redacted, then a redacted version for public viewing, omitting only the confidential, privileged, or
17 otherwise protectable portions of the document, shall be filed. Any application that seeks to file
18 documents under seal in their entirety should include an explanation of why redaction is not
19 feasible.
20 2. DEFINITIONS
21 2.1 Action: this pending federal lawsuit, Case No. 2:19-cv-01975-KJM-CKD.
22 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
23 information or items under this Order.
24 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is
25 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule
26 of Civil Procedure 26(c), and as specified above in the Good Cause Statement.
27 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support
28 staff).
1 2.5 Designating Party: a Party or Non-Party that designates information or items that it
2 produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
3 2.6 Disclosure or Discovery Material: all items or information, regardless of the
4 medium or manner in which it is generated, stored, or maintained (including, among other things,
5 testimony, transcripts, and tangible things), that are produced or generated in disclosures or
6 responses to discovery in this matter.
7 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to
8 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
9 consultant in this Action.
10 2.8 House Counsel: attorneys who are employees of a party to this Action. House
11 Counsel does not include Outside Counsel of Record or any other outside counsel.
12 2.9 Non-Party: any natural person, partnership, corporation, association or other legal
13 entity not named as a Party to this action.
14 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this
15 Action but are retained to represent or advise a party to this Action and have appeared in this
16 Action on behalf of that party or are affiliated with a law firm that has appeared on behalf of that
17 party, and includes support staff.
18 2.11 Party: any party to this Action, including all of its officers, directors, employees,
19 consultants, retained experts, and Outside Counsel of Record (and their support staffs).
20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
21 Material in this Action.
22 2.13 Professional Vendors: persons or entities that provide litigation support services
23 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
24 organizing, storing, or retrieving data in any form or medium) and their employees and
25 subcontractors.
26 2.14 Protected Material: any Disclosure or Discovery Material that is designated as
27 “CONFIDENTIAL.”
28
1 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a
2 Producing Party.
3 3. SCOPE
4 The protections conferred by this Stipulation and Order cover not only Protected Material
5 (as defined above), but also (1) any information copied or extracted from Protected Material; (2)
6 all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
7 conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
8 Any use of Protected Material at trial shall be governed by the orders of the trial judge.
9 This Order does not govern the use of Protected Material at trial.
10 4. DURATION
11 Once a case proceeds to trial, information that was designated as CONFIDENTIAL or
12 maintained pursuant to this protective order used or introduced as an exhibit at trial becomes
13 public and will be presumptively available to all members of the public, including the press,
14 unless compelling reasons supported by specific factual findings to proceed otherwise are made
15 to the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing
16 “good cause” showing for sealing documents produced in discovery from “compelling reasons”
17 standard when merits-related documents are part of court record). Accordingly, the terms of this
18 protective order do not extend beyond the commencement of the trial.
19 5. DESIGNATING PROTECTED MATERIAL
20 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party
21 or Non-Party that designates information or items for protection under this Order must take care
22 to limit any such designation to specific material that qualifies under the appropriate standards.
23 The Designating Party must designate for protection only those parts of material, documents,
24 items or oral or written communications that qualify so that other portions of the material,
25 documents, items or communications for which protection is not warranted are not swept
26 unjustifiably within the ambit of this Order.
27 Mass, indiscriminate or routinized designations are prohibited. Designations that are
28 shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
1 unnecessarily encumber the case development process or to impose unnecessary expenses and
2 burdens on other parties) may expose the Designating Party to sanctions.
3 If it comes to a Designating Party’s attention that information or items that it designated
4 for protection do not qualify for protection, that Designating Party must promptly notify all other
5 Parties that it is withdrawing the inapplicable designation.
6 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order
7 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
8 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
9 designated before the material is disclosed or produced.
10 Designation in conformity with this Order requires:
11 (a) for information in documentary form (e.g., paper or electronic documents, but
12 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing
13 Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL
14 legend”), to each page that contains protected material. If only a portion of the material on a page
15 qualifies for protection, the Producing Party also must clearly identify the protected portion(s)
16 (e.g., by making appropriate markings in the margins).
17 A Party or Non-Party that makes original documents available for inspection need not
18 designate them for protection until after the inspecting Party has indicated which documents it
19 would like copied and produced. During the inspection and before the designation, all of the
20 material made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting
21 Party has identified the documents it wants copied and produced, the Producing Party must
22 determine which documents, or portions thereof, qualify for protection under this Order. Then,
23 before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL
24 legend” to each page that contains Protected Material. If only a portion of the material on a page
25 qualifies for protection, the Producing Party also must clearly identify the protected portion(s)
26 (e.g., by making appropriate markings in the margins).
27
28
1 (b) for testimony given in depositions that the Designating Party identifies the
2 Disclosure or Discovery Material on the record, before the close of the deposition all protected
3 testimony.
4 (c) for information produced in some form other than documentary and for any
5 other tangible items, that the Producing Party affix in a prominent place on the exterior of the
6 container or containers in which the information is stored the legend “CONFIDENTIAL.” If only
7 a portion or portions of the information warrants protection, the Producing Party, to the extent
8 practicable, shall identify the protected portion(s).
9 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
10 designate qualified information or items does not, standing alone, waive the Designating Party’s
11 right to secure protection under this Order for such material. Upon timely correction of a
12 designation, the Receiving Party must make reasonable efforts to assure that the material is
13 treated in accordance with the provisions of this Order.
14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
15 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
16 confidentiality at any time that is consistent with the Court’s Scheduling Order.
17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
18 process under Local Rule 141.
19 6.3 The burden of persuasion in any such challenge proceeding shall be on the
20 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass
21 or impose unnecessary expenses and burdens on other parties) may expose the Challenging Party
22 to sanctions. Unless the Designating Party has waived or withdrawn the confidentiality
23 designation, all parties shall continue to afford the material in question the level of protection to
24 which it is entitled under the Producing Party’s designation until the Court rules on the challenge.
25 7. ACCESS TO AND USE OF PROTECTED MATERIAL
26 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or
27 produced by another Party or by a Non-Party in connection with this Action only for prosecuting,
28 defending or attempting to settle this Action. Such Protected Material may be disclosed only to
1 the categories of persons and under the conditions described in this Order. When the Action has
2 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
3 DISPOSITION).
4 Protected Material must be stored and maintained by a Receiving Party at a location and
5 in a secure manner that ensures that access is limited to the persons authorized under this Order.
6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered
7 by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
8 information or item designated “CONFIDENTIAL” only to:
9 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
10 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the
11 information for this Action;
12 (b) the officers, directors, and employees (including House Counsel) of the
13 Receiving Party to whom disclosure is reasonably necessary for this Action;
14 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
15 reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement
16 to Be Bound” (Exhibit A);
17 (d) the court and its personnel;
18 (e) court reporters and their staff;
19 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to
20 whom disclosure is reasonably necessary for this Action and who have signed the
21 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22 (g) the author or recipient of a document containing the information or a custodian
23 or other person who otherwise possessed or knew the information;
24 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action
25 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that the
26 witness sign the form attached as Exhibit 1 hereto; and (2) they will not be permitted to keep any
27 confidential information unless they sign the “Acknowledgment and Agreement to Be Bound”
28 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of
1 transcribed deposition testimony or exhibits to depositions that reveal Protected Material may be
2 separately bound by the court reporter and may not be disclosed to anyone except as permitted
3 under this Stipulated Protective Order; and
4 (i) any mediator or settlement officer, and their supporting personnel, mutually
5 agreed upon by any of the parties engaged in settlement discussions.
6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
7 OTHER LITIGATION
8 If a Party is served with a subpoena or a court order issued in other litigation that compels
9 disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that
10 Party must:
11 (a) promptly notify in writing the Designating Party. Such notification shall include a
12 copy of the subpoena or court order;
13 (b) promptly notify in writing the party who caused the subpoena or order to issue in the
14 other litigation that some or all of the material covered by the subpoena or order is subject to this
15 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and
16 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
17 Designating Party whose Protected Material may be affected.
18 If the Designating Party timely seeks a protective order, the Party served with the
19 subpoena or court order shall not produce any information designated in this action as
20 “CONFIDENTIAL” before a determination by the court from which the subpoena or order
21 issued, unless the Party has obtained the Designating Party’s permission. The Designating Party
22 shall bear the burden and expense of seeking protection in that court of its confidential material
23 and nothing in these provisions should be construed as authorizing or encouraging a Receiving
24 Party in this Action to disobey a lawful directive from another court.
25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN
26 THIS LITIGATION
27 (a) The terms of this Order are applicable to information produced by a Non-Party in this
28 Action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in
1 connection with this litigation is protected by the remedies and relief provided by this Order.
2 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking
3 additional protections.
4 (b) In the event that a Party is required, by a valid discovery request, to produce a Non-
5 Party’s confidential information in its possession, and the Party is subject to an agreement with
6 the Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
7 (1) promptly notify in writing the Requesting Party and the Non-Party that some or all of
8 the information requested is subject to a confidentiality agreement with a Non-Party;
9 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in this
10 Action, the relevant discovery request(s), and a reasonably specific description of the information
11 requested; and
12 (3) make the information requested available for inspection by the Non-Party, if
13 requested.
14 (c) If the Non-Party fails to seek a protective order from this court within 14 days of
15 receiving the notice and accompanying information, the Receiving Party may produce the Non-
16 Party’s confidential information responsive to the discovery request. If the Non-Party timely
17 seeks a protective order, the Receiving Party shall not produce any information in its possession
18 or control that is subject to the confidentiality agreement with the Non-Party before a
19 determination by the court. Absent a court order to the contrary, the Non-Party shall bear the
20 burden and expense of seeking protection in this court of its Protected Material.
21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
23 Material to any person or in any circumstance not authorized under this Stipulated Protective
24 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the
25 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
26 Protected Material, (c) inform the person or persons to whom unauthorized disclosures were
27 made of all the terms of this Order, and (d) request such person or persons to execute the
28 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A.
1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
2 PROTECTED MATERIAL
3 When a Producing Party gives notice to Receiving Parties that certain inadvertently
4 produced material is subject to a claim of privilege or other protection, the obligations of the
5 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
6 provision is not intended to modify whatever procedure may be established in an e-discovery
7 order that provides for production without prior privilege review. Pursuant to Federal Rule of
8 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a
9 communication or information covered by the attorney-client privilege or work product
10 protection, the parties may incorporate their agreement in the stipulated protective order
11 submitted to the court.
12 12. MISCELLANEOUS
13 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to
14 seek its modification by the Court in the future.
15 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
16 Order, no Party waives any right it otherwise would have to object to disclosing or producing any
17 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
18 Party waives any right to object on any ground to use in evidence of any of the material covered
19 by this Protective Order.
20 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
21 Material must comply with Local Civil Rule 141. Protected Material may only be filed under seal
22 pursuant to a court order authorizing the sealing of the specific Protected Material at issue. If a
23 Party’s request to file Protected Material under seal is denied by the court, then the Receiving
24 Party may file the information in the public record unless otherwise instructed by the court.
25 13. FINAL DISPOSITION
26 After the final disposition of this Action, as defined in paragraph 4, within 60 days of a
27 written request by the Designating Party, each Receiving Party must return all Protected Material
28 to the Producing Party or destroy such material. As used in this subdivision, “all Protected
1 Material” includes all copies, abstracts, compilations, summaries, and any other format
2 reproducing or capturing any of the Protected Material. Whether the Protected Material is
3 returned or destroyed, the Receiving Party must submit a written certification to the Producing
4 Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline that
5 (1) identifies (by category, where appropriate) all the Protected Material that was returned or
6 destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts,
7 compilations, summaries or any other format reproducing or capturing any of the Protected
8 Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
9 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
10 correspondence, deposition and trial exhibits, expert reports, attorney work product, and
11 consultant and expert work product, even if such materials contain Protected Material. Any such
12 archival copies that contain or constitute Protected Material remain subject to this Protective
13 Order as set forth in Section 4 (DURATION).
14 14. VIOLATION
15 Any violation of this Order may be punished by appropriate measures including, without
16 limitation, contempt proceedings and/or monetary sanctions.
17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
18
19
20 DATED: July 23, 2020 CNA COVERAGE LITIGATION GROUP

21

22 By: /s/ Robert C. Christensen
ROBERT C. CHRISTENSEN
23 Attorneys for Plaintiff CONTINENTAL
CASUALTY COMPANY
24
25
26
27
28
1 DATED: July 23, 2020 POWERS MILLER

2

By: /s/ R. James Miller
3
R. JAMES MILLER (SBN 170312)
4 Attorneys for Defendant LETHESIA GUZMAN

5 DATED: July 23, 2020 DREYER, BABICH, BUCCOLA, WOOD,
CAMPORA, LLP
6

7
By: /s/ Marshall R. Way
8 MARSHALL R. WAY (SBN 305082)
Attorneys for Defendant FAAFETIA TALIAOA
9

10
DATED: July 23, 2020 ELLIOT M. REINER, APC
11

12
By: /s/Eliot M. Reiner
13 ELIOT M. REINER (SBN 142239)
Attorneys for Defendant RACHEL TALIAOA
14

15
DATED: July 23, 2020 LARI-JONI & BASSELL, LLP
16

17 By: /s/Torsten M. Bassell
TORSTEN M. BASSELL (SBN 249331)
18 Attorneys for Defendant L. M., a minor by and
through her Guardian Ad Litem THOMAS
19 NICHOLS

20
DATED: July 23, 2020 WILCOXEN CALLAHAM, LLP
21

22
By: /s/Drew M. Widders
23 BLAIR H. WIDDERS (SBN 301741)
DREW M. WIDDERS (SBN 245439)
24 Attorneys for Defendants D. M., and N. M., by and
through their Guardian Ad Litem, PATRICIA
25 MONTEJANO

26

27

28
MASS □□□ □□□ ESE SUING INT INEZ MAUI OOP VO ee PAY IT I A

1 IT IS SO ORDERED, with the following amendments and clarifications:
2 1. The parties shall comply with the provisions and procedures of Local Rules 140 and
3 | 141 with respect to sealing or redaction requests. To the extent that the parties’ stipulation
4 | conflicts with the Local Rules, the Local Rules shall govern.
5 2. Prior to filing any motion related to this stipulated protective order or other discovery
6 | motion, the parties shall first exhaust informal meet-and-confer efforts and otherwise comply with
7 | Local Rule 251.
8 3. Nothing in this order limits the testimony of parties or non-parties, or the use of certain
9 | documents, at any court hearing or trial—such determinations will only be made by the court at
10 | the hearing or trial, or upon an appropriate motion.
11 4. Pursuant to Local Rule 141.1(f), the court will not retain jurisdiction over enforcement
12 | of the terms of this stipulated protective order after the action is terminated.
Dated: August 19, 2020 bh rdf ht / {a—
CAROLYN K. DELANEY :
15 UNITED STATES MAGISTRATE JUDGE
16
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18 | 16.1975.po
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-14-
Stipulated Protective Order

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on [date] in the case of Continental Casualty Company v. Lethesia Guzman, et al.,
8 U.S.D.C., E.D. of Cal., Case No. 2:19-cv-01975-KJM-CKD . I agree to comply
9 with and to be bound by all the terms of this Stipulated Protective Order and I
10 understand and acknowledge that failure to so comply could expose me to sanctions
11 and punishment in the nature of contempt. I solemnly promise that I will not
12 disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the
14 provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of
18 this action. I hereby appoint __________________________ [print or type full
19 name] of _______________________________________ [print or type full
20 address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date: ______________________________________
24 City and State where sworn and signed:
25 _________________________________
26 Printed name: _______________________________
27 Signature: __________________________________
28

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10021375. Public record. Not legal advice.