distinguishing “good cause” showing for sealing 16 documents produced in discovery from “compelling reasons” standard when merits- 17 related documents are part of court record
How later courts described this case
- distinguishing “good cause” showing for sealing 16 documents produced in discovery from “compelling reasons” standard when merits- 17 related documents are part of court record
- even stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 DBraina nS tOolrnmeeyr,, EEssqq.. [[SS..BB.. ##2 19081098697] ]
2 HADSELL STORMER RENICK & DAI LLP
128 N. Fair Oaks Avenue
3 Pasadena, California 91103
Telephone: (626) 585-9600
4 Facsimile: (626) 577-7079
Emails: dstormer@hadsellstormer.com
5 bolney@hadsellstormer.com
6
Attorneys for Plaintiffs
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[Additional Counsel continued on next page]
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UNITED STATES DISTRICT COURT
11 CENTRAL DISTRICT OF CALIFORNIA
12 KARLA GARCIA ARANDA, an Case No.: 19-cv-01770-RGK (RAO)
individual; ALFREDO ARANDA, an
13 individual; and Minor Plaintiff B.A., by [Assigned to the Honorable R. Gary
and through his Guardian ad Litem, Karla Klausner– Courtroom 850]
14 Garcia Aranda,
15 Plaintiffs, STIPULATED PROTECTIVE ORDER
BETWEEN PLAINTIFFS AND NON-
16 v. PARTY BELL POLICE
DEPARTMENT
17 COUNTY OF LOS ANGELES, a public
entity, LOS ANGELES DEPARTMENT
18 OF CHILDREN AND FAMILY Complaint filed: August 15, 2018
SERVICES, a subdivision of the County Discovery Cut-Off: January 2, 2020
19 of Los Angeles; RUBEN JIMENEZ, an Motion Cut-Off: January 16, 2020
individual; MELISSA RAMIREZ, an Trial Date: March 31, 2020
20 individual; LYDIA BUENO, an
individual; ALEXANDRA RONCES, an
21 individual; GLADYS ESCOBEDO, an
individual; EVITA SALAS, an
22 individual, ANTONIA LOPEZ, an
individual; RACHEL SIMONS, an
23 individual; GLORIA MEJIA, an
individual; STEPHANIE MORALES, an
24 individual; LAURA LUNA, an
individual; SANDRA JIMENEZ, an
25 individual; OFFICER PACHECO, an
individual; OFFICER ESPINOZA, an
26 individual, and DOES 1- 10,
27 Defendants.
28
1 [Additional Counsel continued from previous page]
2
Olu K. Orange, Esq. (SBN 213653)
3 o.orange@orangelawoffices.com
ORANGE LAW OFFICES, P.C.
4 3435 Wilshire Boulevard, Suite 2910
Los Angeles, California 90010
5 TEL: (213) 736-9900
FAX: (213) 417-8800
6
7 Rachel Steinback (SBN 310700)
LAW OFFICE OF RACHEL STEINBACK
8 P.O. Box 291253
Los Angeles, CA 90029
9 Telephone: (213) 537-5370
Facsimile: (213) 232-4003
10 Email: steinbacklaw@gmail.com
11
Attorneys for Plaintiffs
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1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential, proprietary
3 or private information for which special protection from public disclosure and from use
4 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the
5 Plaintiffs and non-Party Bell Police Department hereby stipulate to and petition the
6 Court to enter the following Stipulated Protective Order. Plaintiffs and non-Party Bell
7 Police Department acknowledge that this Order does not confer blanket protections on
8 all disclosures or responses to discovery and that the protection it affords from public
9 disclosure and use extends only to the limited information or items that are entitled to
10 confidential treatment under the applicable legal principles.
11 B. GOOD CAUSE STATEMENT
12 This action is likely to involve police reports pertaining to third party witnesses,
13 and SCAR reports (Suspected Child Abuse Reports) filled out by the Bell Police
14 Department to the County of Los Angeles responding to certain of those police reports,
15 for which special protection from public disclosure and from use for any purpose other
16 than prosecution of this action is warranted. Such confidential and proprietary materials
17 and information consist of, among other things, police reports and SCAR reports
18 containing the identity of witnesses and suspected victims, including minors,
19 information implicating privacy rights of third parties and otherwise generally
20 unavailable to the public, or which may be privileged or otherwise protected from
21 disclosure under state or federal statutes, court rules, case decisions, or common law.
22 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of
23 disputes over confidentiality of discovery materials, to adequately protect information
24 the parties are entitled to keep confidential, to ensure that the parties are permitted
25 reasonable necessary uses of such material in preparation for and in the conduct of trial,
26 to address their handling at the end of the litigation, and serve the ends of justice, a
27 protective order for such information is justified in this matter. It is the intent of the
28 Plaintiffs and non-Party Bell Police Department that information will not be designated
1 as confidential for tactical reasons and that nothing be so designated without a good faith
2 belief that it has been maintained in a confidential, non-public manner, and there is good
3 cause why it should not be part of the public record of this case.
4 Plaintiffs are currently meeting and conferring with Defendants regarding a
5 protective order for this case. In the meantime, non-Party Bell Police Department
6 requires a protective order to produce the sensitive information set forth above in
7 response to Plaintiffs' subpoena duces tecum dated August 21, 2019. Production of these
8 documents is necessary for the deposition of a non-party witness scheduled for
9 September 5, 2019.
10 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
11 The parties further acknowledge, as set forth in Section 12.3, below, that this
12 Stipulated Protective Order does not entitle them to file confidential information under
13 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
14 standards that will be applied when a party seeks permission from the court to file
15 material under seal.
16 There is a strong presumption that the public has a right of access to judicial
17 proceedings and records in civil cases. In connection with non-dispositive motions, good
18 cause must be shown to support a filing under seal. See Kamakana v. City and County of
19 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d
20 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576,
21 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing),
22 and a specific showing of good cause or compelling reasons with proper evidentiary
23 support and legal justification, must be made with respect to Protected Material that a
24 party seeks to file under seal. The parties’ mere designation of Disclosure or Discovery
25 Material as CONFIDENTIAL does not— without the submission of competent evidence
26 by declaration, establishing that the material sought to be filed under seal qualifies as
27 confidential, privileged, or otherwise protectable—constitute good cause.
28 Further, if a party requests sealing related to a dispositive motion or trial, then
1 compelling reasons, not only good cause, for the sealing must be shown, and the relief
2 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos
3 v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type
4 of information, document, or thing sought to be filed or introduced under seal in
5 connection with a dispositive motion or trial, the party seeking protection must articulate
6 compelling reasons, supported by specific facts and legal justification, for the requested
7 sealing order. Again, competent evidence supporting the application to file documents
8 under seal must be provided by declaration.
9 Any document that is not confidential, privileged, or otherwise protectable in
10 its entirety will not be filed under seal if the confidential portions can be redacted.
11 If documents can be redacted, then a redacted version for public viewing, omitting
12 only the confidential, privileged, or otherwise protectable portions of the document,
13 shall be filed. Any application that seeks to file documents under seal in their
14 entirety should include an explanation of why redaction is not feasible.
15 2. DEFINITIONS
16 2.1 Action: Karla Garcia Aranda et al. v. County of Los Angeles et al., 19-cv-
17 01770-RGK (RAO)
18 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
19 information or items under this Order.
20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is
21 generated, stored or maintained) or tangible things that qualify for protection under
22 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
23 Statement.
24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
25 support staff).
26 2.5 Designating Party: a Party or Non-Party that designates information or items
27 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
28 2.6 Disclosure or Discovery Material: all items or information, regardless of the
1 medium or manner in which it is generated, stored, or maintained (including, among
2 other things, testimony, transcripts, and tangible things), that are produced or generated
3 in disclosures or responses to discovery in this matter.
4 2.7 Expert: a person with specialized knowledge or experience in a matter
5 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
6 expert witness or as a consultant in this Action.
7 2.8 House Counsel: attorneys who are employees of a party to this Action. House
8 Counsel does not include Outside Counsel of Record or any other outside counsel.
9 2.9 Non-Party: any natural person, partnership, corporation, association or other
10 legal entity not named as a Party to this action.
11 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
12 this Action but are retained to represent or advise a party to this Action and have
13 appeared in this Action on behalf of that party or are affiliated with a law firm that has
14 appeared on behalf of that party, and includes support staff.
15 2.11 Party: any party to this Action, including all of its officers, directors,
16 employees, consultants, retained experts, and Outside Counsel of Record (and their
17 support staffs).
18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
19 Material in this Action.
20 2.13 Professional Vendors: persons or entities that provide litigation support
21 services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
23 their employees and subcontractors.
24 2.14 Protected Material: any Disclosure or Discovery Material that is designated
25 as “CONFIDENTIAL.”
26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from
27 a Producing Party.
28 / / /
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only Protected
3 Material (as defined above), but also (1) any information copied or extracted from
4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
5 Material; and (3) any testimony, conversations, or presentations by Parties or their
6 Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the trial
8 judge. This Order does not govern the use of Protected Material at trial.
9 4. DURATION
10 Once a case proceeds to trial, information that was designated as
11 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as
12 an exhibit at trial becomes public and will be presumptively available to all members of
13 the public, including the press, unless compelling reasons supported by specific factual
14 findings to proceed otherwise are made to the trial judge in advance of the trial. See
15 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
16 documents produced in discovery from “compelling reasons” standard when merits-
17 related documents are part of court record). Accordingly, the terms of this protective
18 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
21 Party or Non-Party that designates information or items for protection under this Order
22 must take care to limit any such designation to specific material that qualifies under the
23 appropriate standards. The Designating Party must designate for protection only those
24 parts of material, documents, items or oral or written communications that qualify so that
25 other portions of the material, documents, items or communications for which protection
26 is not warranted are not swept unjustifiably within the ambit of this Order.
27 Mass, indiscriminate or routinized designations are prohibited. Designations that
28 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
1 to unnecessarily encumber the case development process or to impose unnecessary
2 expenses and 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
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6 5.2 Manner and Timing of Designations. Except as otherwise provided in this
7 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
8 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
9 must be clearly so 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
12 documents, but excluding transcripts of depositions or other pretrial or trial
13 proceedings), that the Producing Party affix at a minimum, the legend
14 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that contains
15 protected material. If only a portion of the material on a page qualifies for protection, the
16 Producing Party also must clearly identify the protected portion(s) (e.g., by making
17 appropriate markings in the margins).
18 A Party or Non-Party that makes original documents available for inspection need
19 not designate them for protection until after the inspecting Party has indicated which
20 documents it would like copied and produced. During the inspection and before the
21 designation, all of the material made available for inspection shall be deemed
22 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
23 copied and produced, the Producing Party must determine which documents, or portions
24 thereof, qualify for protection under this Order. Then, before producing the specified
25 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
26 that contains Protected Material. If only a portion of the material on a page qualifies for
27 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
28 by making appropriate markings in the margins).
1 (b) for testimony given in depositions that the Designating Party identifies
2 the Disclosure or Discovery Material on the record, before the close of the deposition all
3 protected testimony.
4 (c) for information produced in some form other than documentary and for
5 any other tangible items, that the Producing Party affix in a prominent place on the
6 exterior of the container or containers in which the information is stored the legend
7 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,
8 the Producing Party, to the extent practicable, shall identify the protected portion(s).
9 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
10 to designate qualified information or items does not, standing alone, waive the
11 Designating Party’s right to secure protection under this Order for such material. Upon
12 timely correction of a designation, the Receiving Party must make reasonable efforts to
13 assure that the material is 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 37.1 et seq.
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.,
21 to harass or impose unnecessary expenses and burdens on other parties) may expose the
22 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
23 the confidentiality designation, all parties shall continue to afford the material in
24 question the level of protection to which it is entitled under the Producing Party’s
25 designation until the Court rules on the challenge.
26 7. ACCESS TO AND USE OF PROTECTED MATERIAL
27 7.1 Basic Principles. A Receiving Party may use Protected Material that is
28 disclosed or produced by another Party or by a Non-Party in connection with this Action
1 only for prosecuting, defending or attempting to settle this Action. Such Protected
2 Material may be disclosed only to the categories of persons and under the conditions
3 described in this Order. When the Action has been terminated, a Receiving Party must
4 comply with the provisions of section 13 below (FINAL DISPOSITION).
5 Protected Material must be stored and maintained by a Receiving Party at a
6 location and in a secure manner that ensures that access is limited to the persons
7 authorized under this Order.
8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
9 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
10 may disclose any information or item designated “CONFIDENTIAL” only to:
11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
12 as employees of said Outside Counsel of Record to whom it is reasonably necessary to
13 disclose the information for this Action;
14 (b) the Receiving party, including its officers, directors, and employees
15 (including House Counsel) to whom disclosure is reasonably necessary for this Action;
16 (c) Experts (as defined in this Order) of the Receiving Party to whom
17 disclosure is reasonably necessary for this Action and who have signed the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
19 (d) the court and its personnel;
20 (e) court reporters and their staff;
21 (f) professional jury or trial consultants, mock jurors, and Professional
22 Vendors to whom disclosure is reasonably necessary for this Action and who have
23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
24 (g) the author or recipient of a document containing the information or a
25 custodian or other person who otherwise possessed or knew the information;
26 (h) during their depositions, witnesses, and attorneys for witnesses, in the
27 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
28 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not
1 be permitted to keep any confidential information unless they sign the
2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
3 by the Designating Party or ordered by the court. Pages of transcribed deposition
4 testimony or exhibits to depositions that reveal Protected Material may be separately
5 bound by the court reporter and may not be disclosed to anyone except as permitted
6 under this Stipulated Protective Order; and
7 (i) any mediator or settlement officer, and their supporting personnel,
8 mutually agreed upon by any of the parties engaged in settlement discussions.
9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
10 IN OTHER LITIGATION
11 If a Party is served with a subpoena or a court order issued in other litigation that
12 compels disclosure of any information or items designated in this Action as
13 “CONFIDENTIAL,” that Party must:
14 (a) promptly notify in writing the Designating Party. Such notification shall
15 include a copy of the subpoena or court order;
16 (b) promptly notify in writing the party who caused the subpoena or order
17 to issue in the other litigation that some or all of the material covered by the
18 subpoena or order is subject to this Protective Order. Such notification shall include
19 a copy of this Stipulated Protective Order; and
20 (c) cooperate with respect to all reasonable procedures sought to be pursued
21 by the Designating Party whose Protected Material may be affected. If the Designating
22 Party timely seeks a protective order, the Party served with the subpoena or court order
23 shall not produce any information designated in this action as “CONFIDENTIAL”
24 before a determination by the court from which the subpoena or order issued, unless the
25 Party has obtained the Designating Party’s permission. The Designating Party shall bear
26 the burden and expense of seeking protection in that court of its confidential material
27 and nothing in these provisions should be construed as authorizing or encouraging a
28 Receiving Party in this Action to disobey a lawful directive from another court.
1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
2 IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by a
4 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
5 produced by Non-Parties in connection with this litigation is protected by the remedies
6 and relief provided by this Order. Nothing in these provisions should be construed as
7 prohibiting a Non-Party from seeking additional protections.
8 (b) In the event that a Party is required, by a valid discovery request, to
9 produce a Non-Party’s confidential information in its possession, and the Party is subject
10 to an agreement with the Non-Party not to produce the Non-Party’s confidential
11 information, then the Party shall:
12 (1) promptly notify in writing the Requesting Party and the Non-
13 Party that some or all of the information requested is subject to a confidentiality
14 agreement with a Non-Party;
15 (2) promptly provide the Non-Party with a copy of the Stipulated
16 Protective Order in this Action, the relevant discovery request(s), and a reasonably
17 specific description of the information requested; and
18 (3) make the information requested available for inspection by the
19 Non-Party, if requested.
20 (c) If the Non-Party fails to seek a protective order from this court within 14
21 days of receiving the notice and accompanying information, the Receiving Party may
22 produce the Non-Party’s confidential information responsive to the discovery request. If
23 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any
24 information in its possession or control that is subject to the confidentiality agreement
25 with the Non-Party before a determination by the court. Absent a court order to the
26 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
27 court of its Protected Material.
28 / / /
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
3 Protected Material to any person or in any circumstance not authorized under this
4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
6 all unauthorized copies of the Protected Material, (c) inform the person or persons to
7 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
8 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
9 that is attached hereto as Exhibit A.
10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
11 PROTECTED MATERIAL
12 When a Producing Party gives notice to Receiving Parties that certain
13 inadvertently produced material is subject to a claim of privilege or other protection, the
14 obligations of the Receiving Parties are those set forth in Federal Rule of Civil
15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
16 may be established in an e-discovery order that provides for production without prior
17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
18 parties reach an agreement on the effect of disclosure of a communication or information
19 covered by the attorney-client privilege or work product protection, the parties may
20 incorporate their agreement in the stipulated protective order submitted to the court.
21 12. MISCELLANEOUS
22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
23 person to seek its modification by the Court in the future.
24 12.2 Right to Assert Other Objections. By stipulating to the entry of this
25 Protective Order, no Party waives any right it otherwise would have to object to
26 disclosing or producing any information or item on any ground not addressed in this
27 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground
28 to use in evidence of any of the material covered by this Protective Order.
1 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
2 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed
3 under seal pursuant to a court order authorizing the sealing of the specific Protected
4 Material at issue. If a Party’s request to file Protected Material under seal is denied by
5 the court, then the Receiving Party may file the information in the public record unless
6 otherwise instructed by the court.
7 13. FINAL DISPOSITION
8 After the final disposition of this Action, as defined in paragraph 4, within 60 days
9 of a written request by the Designating Party, each Receiving Party must return all
10 Protected Material to the Producing Party or destroy such material. As used in this
11 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
12 summaries, and any other format reproducing or capturing any of the Protected Material.
13 Whether the Protected Material is returned or destroyed, the Receiving Party must
14 submit a written certification to the Producing Party (and, if not the same person or
15 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category,
16 where appropriate) all the Protected Material that was returned or destroyed and (2)
17 affirms that the Receiving Party has not retained any copies, abstracts, compilations,
18 summaries or any other format reproducing or capturing any of the Protected Material.
19 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
20 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
21 correspondence, deposition and trial exhibits, expert reports, attorney work product, and
22 consultant and expert work product, even if such materials contain Protected Material.
23 Any such archival copies that contain or constitute Protected Material remain subject to
24 this Protective Order as set forth in Section 4 (DURATION).
25 14. VIOLATION
26 Any violation of this Order may be punished by appropriate measures including,
27 without limitation, contempt proceedings and/or monetary sanctions.
28 / / /
Ly ///
2] ///
3 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
4
| DATED _ 09/03/2019
6
7 /s/ Brian Olney
Attorneys for Plaintiff
8
9
9 |DATED: 4/2/19
)
1] .
12 VA WY. f
fofneys for Non-Party BellPolice Department, by and through
13 | its City Attorneys, Aleshire & Wynder, LLP
14
15
16 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
17
18 | DATED: September 5, 2019
19 Q O 7
20 t On.
21 | HON. ROZELLA A. OLIVER
United States Magistrate Judge
23
24
25
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STIPUT ATED PROTECTIVE ORDER -]3-
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 Karla Garcia Aranda et al. v. County of Los Angeles et al.,
8 19-cv-01770-RGK (RAO). I agree to comply with and to be bound by all the terms
9 of this Stipulated Protective Order and I understand and acknowledge that failure to
10 so comply could expose me to sanctions and punishment in the nature of contempt.
11 I solemnly promise that I will not disclose in any manner any information or item
12 that is subject to this Stipulated Protective Order to any person or entity except in
13 strict compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court for the
15 Central District of California for enforcing the terms of this Stipulated Protective
16 Order, even if such enforcement proceedings occur after termination of this action.
17 I hereby appoint __________________________ [print or type full name] of
18 _______________________________________ [print or type full address and
19 telephone number] as my California agent for service of process in connection with
20 this action or any proceedings related to enforcement of this Stipulated Protective
21 Order.
22
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27
28 Signature: __________________________________