Opinion

Leodegario Chavez v. City of Los Angeles t al

Court
District Court, C.D. California
Filed
Oct 1, 2019
Cited by
0 cases
Authority
More cited than 17.9%

distinguishing “good cause” showing for sealing documents produced in 9 discovery from “compelling reasons” standard when merits-related documents are part 10 of court record

How later courts described this case

  • distinguishing “good cause” showing for sealing documents produced in 9 discovery from “compelling reasons” standard when merits-related documents are part 10 of court record

Written by the judges who cited it.

The opinion

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7 UNITED STATES DISTRICT COURT

8 CENTRAL DISTRICT OF CALIFORNIA

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10 LEODEGARIO CHAVEZ, TRINIDAD CASE NO: CV18-09684-CJC (PLAx)

BARRAGAN, Plaintiffs and as Hon. CarmacJ. Carney, Ctrm. 7C, 7thF., 1stStreet

11 successor in interest for Decedent JOSE Mag. Paul L. Abrams, Ctrm. 780, 7thFl., Roybal

CHAVEZ

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ORDER RE:

Plaintiffs,

13 STIPULATED PROTECTIVE ORDER

vs.

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15 CITY OF LOS ANGELES and DOES

1-10, inclusive,

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Defendants.

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20 ORDER ON STIPULATION

The Court, finding good cause, Orders as follows:

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22 1. A. PURPOSES AND LIMITATIONS

23 Discovery in this action is likely to involve production of confidential,

24 proprietary or private information for which special protection from public disclosure

25 and from use for any purpose other than prosecuting this litigation may be warranted.

26 Accordingly, the parties hereby stipulate to and petition the Court to enter the following

27 Stipulated Protective Order. The parties acknowledge that this Order does not confer

28 blanket protections on all disclosures or responses to discovery and that the protection

1 it affords from public disclosure and use extends only to the limited information or

2 items that are entitled to confidential treatment under the applicable legal principles.

3 B. GOOD CAUSE STATEMENT

4 This action involves the City of Los Angeles and members of the Los Angeles

5 Police Department. Plaintiff is seeking materials and information that Defendants the

6 City of Los Angeles et al. (“City”) maintains as confidential, such as certain policies

7 and procedures, video recordings, audio recordings, Force Investigation Division

8 materials and information, and other administrative materials and information currently

9 in the possession of the City and which the City believes need special protection from

10 public disclosure and from use for any purpose other than prosecuting this litigation.

11 Plaintiff is also seeking official information contained in the personnel files of the police

12 officers involved in the subject incident, which the City maintains as strictly

13 confidential and which the City believes need special protection from public disclosure

14 and from use for any purpose other than prosecuting this litigation.

15 The City asserts that the confidentiality of the materials and information sought

16 by Plaintiff is recognized by California and federal law, as evidenced inter alia by

17 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal.,

18 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City has not publicly

19 released the materials and information referenced above except under protective order

20 or pursuant to a court order, if at all. These materials and information are of the type

21 that has been used to initiate disciplinary action against Los Angeles Police Department

22 (“LAPD”) officers, and has been used as evidence in disciplinary proceedings, where

23 the officers’ conduct was considered to be contrary to LAPD policy.

24 The City contends that absent a protective order delineating the responsibilities

25 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary

26 and undue disclosure by one or more of the many attorneys, secretaries, law clerks,

27 paralegals and expert witnesses involved in this case, as well as the corollary risk of

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1 embarrassment, harassment and professional and legal harm on the part of the LAPD

2 officers referenced in the materials and information.

3 The City also contends that the unfettered disclosure of the materials and

4 information, absent a protective order, would allow the media to share this information

5 with potential jurors in the area, impacting the rights of the City herein to receive a fair

6 trial.

7 Accordingly, to expedite the flow of information, to facilitate the prompt

8 resolution of disputes over confidentiality of discovery materials, to adequately protect

9 information the parties are entitled to keep confidential, to ensure that the parties are

10 permitted reasonable necessary uses of such material in preparation for and in the

11 conduct of trial, to address their handling at the end of the litigation, and serve the ends

12 of justice, a protective order for such information is justified in this matter. It is the

13 intent of the parties that information will not be designated as confidential for tactical

14 reasons and that nothing be so designated without a good faith belief that it has been

15 maintained in a confidential, non-public manner, and there is good cause why it should

16 not be part of the public record of this case.

17 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

18 SEAL

19 The parties agree that any pleadings, motions, briefs, declarations, stipulations,

20 exhibits or other written submissions to the Court in this litigation which contain or

21 incorporate Confidential Material shall be lodged with an application and/or joint

22 stipulation to file the papers or the portion thereof containing the Confidential Material,

23 under seal.

24 The parties further acknowledge, as set forth in Section 12.3, below, that this

25 Stipulated Protective Order does not automatically entitle them to file confidential

26 information under seal and that Local Civil Rule 79-5 sets forth the procedures that

27 must be followed and the standards that will be applied when a party seeks permission

28 from the Court to file material under seal.

1 2. DEFINITIONS

2 2.1 Action: Leodegario Chavez, et al. v. City of Los Angeles, et al.CV18-

3 09684-CJC (PLAx).

4 2.2 Challenging Party: a Party or Non-Party that challenges the designation

5 of information or items under this Order.

6 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

7 how it is generated, stored or maintained) or tangible things that qualify for protection

8 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

9 Statement. This also includes (1) any information copied or extracted from the

10 Confidential information; (2) all copies, excerpts, summaries, abstracts or compilations

11 of Confidential information; and (3) any testimony, conversations, or presentations that

12 might reveal Confidential information.

13 2.4 Counsel: Counsel of record for the parties to this civil litigation and their

14 support staff.

15 2.5 Designating Party: a Party or Non-Party that designates information or

16 items that it produces in disclosures or in responses to discovery as

17 “CONFIDENTIAL.”

18 2.6 Disclosure or Discovery Material: all items or information, regardless

19 of the medium or manner in which it is generated, stored, or maintained (including,

20 among other things, testimony, transcripts, and tangible things), that are produced or

21 generated in disclosures or responses to discovery in this matter.

22 2.7 Expert: a person with specialized knowledge or experience in a matter

23 pertinent to the litigation who has been retained by a Party or its counsel to serve as an

24 expert witness or as a consultant in this Action.

25 2.8 Final Disposition: when this Action has been fully and completely

26 terminated by way of settlement, dismissal, trial and/or appeal.

27 2.9 House Counsel: attorneys other than Counsel (as defined in paragraph

28 2.4) and who are employees of a party to this Action.

1 2.10 Non-Party: any natural person, partnership, corporation, association or

2 other legal entity not named as a Party to this action.

3 2.11 Outside Counsel of Record: attorneys who are not employees of a party

4 to this Action but are retained to represent or advise a party to this Action and have

5 appeared in this Action on behalf of that party or are affiliated with a law firm that has

6 appeared on behalf of that party, and includes support staff.

7 2.12 Party: any party to this Action, including all of its officers, directors,

8 boards, departments, divisions, employees, consultants, retained experts, and Outside

9 Counsel of Record (and their support staffs).

10 2.13 Producing Party: a Party or Non-Party that produces Disclosure or

11 Discovery Material in this Action.

12 2.14 Professional Vendors: persons or entities that provide litigation support

13 services (e.g., photocopying, videotaping, translating, preparing exhibits or

14 demonstrations, and organizing, storing, or retrieving data in any form or medium) and

15 their employees and subcontractors.

16 2.15 Protected Material: any Disclosure or Discovery Material that is

17 designated as “CONFIDENTIAL.”

18 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material

from a Producing Party.

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3. SCOPE

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The protections conferred by this Stipulation and Order cover not only Protected

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Material (as defined above), but also (1) any information copied or extracted from

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Protected Material; (2) all copies, excerpts, abstracts, summaries, or compilations of

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Protected Material; and (3) any deposition testimony, conversations, or presentations

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by Parties or their Counsel that might reveal Protected Material.

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Any use of Protected Material at trial shall be governed by the orders of the trial

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judge. This Order does not govern the use of Protected Material at trial.

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1 4. DURATION

2 Once a trial commences in this Action, information that was designated as

3 CONFIDENTIAL or maintained pursuant to this protective order and that is introduced

4 or admitted as an exhibit at trial becomes public and will be presumptively available to

5 all members of the public, including the press, unless compelling reasons supported by

6 specific factual findings to proceed otherwise are made to the trial judge in advance of

7 the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th

8 Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in

9 discovery from “compelling reasons” standard when merits-related documents are part

10 of court record). Accordingly, the terms of this protective order do not extend beyond

11 the commencement of the trial as to the CONFIDENTIAL information and materials

12 introduced or admitted as an exhibit at trial.

13 5. DESIGNATING PROTECTED MATERIAL

14 5.1 Exercise of Restraint and Care in Designating Material for Protection.

15 Each Party or Non-Party that designates information or items for protection under

16 this Order must take care to limit any such designation to specific material that qualifies

17 under the appropriate standards. The Designating Party must designate for protection

18 only those parts of material, documents, items or oral or written communications that

19 qualify so that other portions of the material, documents, items or communications for

20 which protection is not warranted are not swept unjustifiably within the ambit of this

21 Order.

22 Mass, indiscriminate or routinized designations are prohibited. Designations that

23 are shown to be clearly unjustified or that have been made for an improper purpose

24 (e.g., to unnecessarily encumber the case development process or to impose

25 unnecessary expenses and burdens on other parties) may expose the Designating Party

26 to sanctions.

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1 If it comes to a Designating Party’s attention that information or items that it

2 designated for protection do not qualify for protection, that Designating Party must

3 promptly notify all other Parties that it is withdrawing the inapplicable designation.

4 5.2 Manner and Timing of Designations. Except as otherwise provided in

5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

7 under this Order must be clearly so designated before the material is disclosed or

8 produced.

9 Designation in conformity with this Order requires:

10 (a) for information in documentary form (e.g., paper or electronic documents,

11 but excluding transcripts of depositions or other pretrial or trial proceedings), that the

12 Producing Party affix at a minimum, the legend “CONFIDENTIAL” or words of a

13 similar effect, and that includes the case name and case number (hereinafter

14 “CONFIDENTIAL legend”), to each page that contains protected material. If only a

15 portion of the material on a page qualifies for protection, the Producing Party also must

16 clearly identify the protected portion(s) (e.g., by making appropriate markings in the

17 margins).

18 A Party or Non-Party that makes original documents available for inspection

19 need not designate them for protection until after the inspecting Party has indicated

20 which documents it would like copied and produced. During the inspection and before

21 the 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

24 portions thereof, qualify for protection under this Order. Then, before producing the

25 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to

26 each page that contains Protected Material. If only a portion of the material on a page

27 qualifies for protection, the Producing Party also must clearly identify the protected

28 portion(s) (e.g., by making appropriate markings in the margins).

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

3 protected 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

6 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

8 protection, the Producing Party, to the extent practicable, shall identify the protected

9 portion(s).

10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

11 failure to designate qualified information or items does not, standing alone, waive the

12 Designating Party’s right to secure protection under this Order for such material. Upon

13 timely correction of a designation, the Receiving Party must make reasonable efforts to

14 assure that the material is treated in accordance with the provisions of this Order.

15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

17 designation of confidentiality at any time that is consistent with the Court’s Scheduling

18 Order.

19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

20 resolution process under Local Rule 37.1 et seq.

21 6.3 The burden of persuasion in any such challenge proceeding shall be on the

22 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

23 to harass or impose unnecessary expenses and burdens on other parties) may expose the

24 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

25 the confidentiality designation, all parties shall continue to afford the material in

26 question the level of protection to which it is entitled under the Producing Party’s

27 designation until the Court rules on the challenge.

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1 7. ACCESS TO AND USE OF PROTECTED MATERIAL

2 7.1 Basic Principles. A Receiving Party may use Protected Material that is

3 disclosed or produced by another Party or by a Non-Party in connection with this Action

4 only for prosecuting, defending or attempting to settle this Action. Such Protected

5 Material may be disclosed only to the categories of persons and under the conditions

6 described in this Order. When the Action has been terminated, a Receiving Party must

7 comply with the provisions of section 13 below (FINAL DISPOSITION).

8 Protected Material must be stored and maintained by a Receiving Party at a

9 location and in a secure manner that ensures that access is limited to the persons

10 authorized under this Order.

11 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

12 otherwise ordered by the court or permitted in writing by the Designating Party, a

13 Receiving Party may disclose any information or item designated “CONFIDENTIAL”

14 only to:

15 (a) the Receiving Party’s Counsel of Record in this Action, as well as employees

16 of said Counsel of Record to whom it is reasonably necessary to disclose the

17 information for this Action;

18 (b) Experts (as defined in this Order) of the Receiving Party to whom disclosure

19 is reasonably necessary for this Action and who have signed the “Acknowledgment and

20 Agreement to Be Bound” (Exhibit A);

21 (c) the court and its personnel;

22 (e) court reporters and their staff;

23 (e) professional jury or trial consultants, mock jurors, and Professional Vendors

24 to whom disclosure is reasonably necessary for this Action and who have signed the

25 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

26 (f) the author or recipient of a document containing the information or a

27 custodian or other person who otherwise possessed or knew the information;

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1 (g) during their depositions, witnesses, and attorneys for witnesses, in the Action

2 to whom disclosure is reasonably necessary provided: (1) the deposing party requests

3 that the witness sign the form attached as Exhibit “A” hereto; and (2) they will not be

4 permitted to keep any confidential information unless they sign the “Acknowledgment

5 and Agreement to Be Bound” (Exhibit “A”), unless otherwise agreed by the

6 Designating Party or ordered by the court. Pages of transcribed deposition testimony

7 or exhibits to depositions that reveal Protected Material may be separately bound by the

8 court reporter and may not be disclosed to anyone except as permitted under this

9 Stipulated Protective Order; and

10 (h) any mediator or settlement officer, and their supporting personnel, mutually

11 agreed upon by any of the parties engaged in settlement discussions and who have

12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A).

13 7.3. Counsel making the disclosure to any qualified person described herein

14 shall retain the original executed copy of the Nondisclosure Agreement until sixty (60)

15 days after this litigation has become final, including any appellate review, and

16 monitoring of an injunction. Counsel for the Receiving Party shall maintain all signed

17 Nondisclosure Agreements and shall produce the original signature page upon

18 reasonable written notice from opposing counsel. If an issue arises regarding a

19 purported unauthorized disclosure of Confidential Information, upon noticed motion of

20 contempt filed by the Designating Party, counsel for the Receiving Party may be

21 required to file the signed Nondisclosure Agreements, as well as a list of the disclosed

22 materials, in camera with the Court having jurisdiction of the Stipulation.

23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

24 IN OTHER LITIGATION

25 If a Party is served with a subpoena or a court order issued in other litigation that

26 compels disclosure of any information or items designated in this Action as

27 “CONFIDENTIAL,” that Party must:

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1 (a) promptly notify in writing the Designating Party. Such notification shall

2 include a copy of the subpoena or court order;

3 (b) promptly notify in writing the party who caused the subpoena or order to

4 issue in the other litigation that some or all of the material covered by the

5 subpoena or order is subject to this Protective Order. Such notification shall

6 include a copy of this Stipulated Protective Order; and

7 (c) cooperate with respect to all reasonable procedures sought to be pursued by

8 the Designating Party whose Protected Material may be affected.

9 The Party served with the subpoena or court order shall not produce any

10 information designated in this action as “CONFIDENTIAL”, unless the Party has

11 obtained the Designating Party’s permission or an order from the court from which the

12 subpoena or order issued. Nothing in these provisions should be construed as

13 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

14 directive from another court.

15 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

16 PRODUCED IN THIS LITIGATION

17 (a) The terms of this Order are applicable to information produced by a Non-

18 Party in this Action and designated as “CONFIDENTIAL.” Such information produced

19 by Non-Parties in connection with this litigation is protected by the remedies and relief

20 provided by this Order. Nothing in these provisions should be construed as prohibiting

21 a Non-Party from seeking additional protections.

22 (b) In the event that a Party is required, by a valid discovery request, to produce

23 a Non-Party’s confidential information in its possession, and the Party is subject to an

24 agreement with the Non-Party not to produce the Non-Party’s confidential information,

25 then the Party shall:

26 (1) promptly notify in writing the Requesting Party and the Non-Party that

27 some or all of the information requested is subject to a confidentiality agreement

28 with a Non-Party;

1 (2) promptly provide the Non-Party with a copy of the Stipulated

2 Protective Order in this Action, the relevant discovery request(s), and a

3 reasonably specific description of the information requested; and

4 (3) make the information requested available for inspection by the Non-

5 Party, if requested.

6 (c) If the Non-Party fails to seek a protective order from this court within 14

7 days of receiving the notice and accompanying information, the Receiving Party may

8 produce the Non-Party’s confidential information responsive to the discovery request.

9 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

10 any information in its possession or control that is subject to the confidentiality

11 agreement with the Non-Party before a determination by the court. Absent a court order

12 to the contrary, the Non-Party shall bear the burden and expense of seeking protection

13 in this court of its Protected Material.

14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

16 Protected Material to any person or in any circumstance not authorized under this

17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

18 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

19 all unauthorized copies of the Protected Material, (c) inform the person or persons to

20 whom unauthorized disclosures were made of all the terms of this Order, and (d) request

21 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

22 that is attached hereto as Exhibit A.

23 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

24 PROTECTED MATERIAL

25 When a Producing Party gives notice to Receiving Parties that certain

26 inadvertently produced material is subject to a claim of privilege or other protection,

27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

1 may be established in an e-discovery order that provides for production without prior

2 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

3 parties reach an agreement on the effect of disclosure of a communication or

4 information covered by the attorney-client privilege or work product protection, the

5 parties may incorporate their agreement in the stipulated protective order submitted to

6 the court.

7 12. MISCELLANEOUS

8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

9 person to seek its modification by the Court in the future.

10 12.2 Right to Assert Other Objections. By stipulating to the entry of this

11 Protective Order, no Party waives any right it otherwise would have to object to

12 disclosing or producing any information or item on any ground not addressed in this

13 Stipulated Protective Order. Similarly, no Party waives any right to object on any

14 ground to use in evidence of any of the material covered by this Protective Order.

15 12.3 Filing Protected Material. A Party that seeks to file under seal any

16 Protected Material must comply with Local Civil Rule 79-5. Protected Material may

17 only be filed under seal pursuant to a court order authorizing the sealing of the specific

18 Protected Material at issue. If a Party’s request to file Protected Material under seal is

19 denied by the court, then the Receiving Party may file the information in the public

20 record unless otherwise instructed by the court.

21 13. FINAL DISPOSITION

22 After the FINAL DISPOSITION of this Action, as defined in paragraph 2.8,

23 within 30 days of a written request by the Designating Party, each Receiving Party must

24 return all Protected Material to the Producing Party. As used in this subdivision, “all

25 Protected Material” includes all copies, abstracts, compilations, summaries, and any

26 other format reproducing or capturing any of the Protected Material. The Receiving

27 Party must submit a written certification to the Producing Party (and, if not the same

28 person or entity, to the Designating Party) by the 30 day deadline that (1) identifies (by

1 || category, where appropriate) all the Protected Material that was returned and (2) affirms

2 || that the Receiving Party has not retained any copies, abstracts, compilations, summarics

3 || or any other format reproducing or capturing any of the Protected Material.

4\|14. VIOLATION

5 Any violation of this Order may be punished by appropriate measures including,

6 || without limitation, contempt proceedings and/or monetary sanctions.

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8 |/ IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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10 Dated: September 26, 2019 CARRILLO LAW FIRM, LLP

11

2 By: /S/

MICHAEL S. CARRILLO, Esq.

13

Attorneys for Plaintiffs, LEODEGARIO CHAVEZ

14 and TRINIDAD BARRAGAN

15

16 || Dated: September 26, 2019 MICHAEL N. FEUER, City Attorney

KATHLEEN KENEALY, Chief Asst. City Atty.

17 SCOTT MARCUS, Civil Litigation Branch Chief

18 CORY M. BRENTE, Senior Asst. City Atty.

19 By: /S/

20 J. EDWIN RATHBUN, JR., Deputy City Attorney

21

Attorneys for Defendant, CITY OF LOS

22 ANGELES

23 IT IS SO ORDERED.

24 Gale Means

5 || Dated: October 1 _,2019 By:

HONORABLE PAUL L. ABRAMS

26 UNITED STATES MAGISTRATE JUDGE

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, _____________________________ [print or type full name], of

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_________________________________ [print or type full address], declare under

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penalty of perjury that I have read in its entirety and understand the Stipulated

6

Protective Order that was issued by the United States District Court for the Central

7

District of California on _____________ in the case of Leodegario Chavez, et al. v.

8

City of Los Angeles, et al., United States District Court case no. CV18-09684-CJC

9

(PLAx). I agree to comply with and to be bound by all the terms of this Stipulated

10

Protective Order and I understand and acknowledge that failure to so comply could

11

expose me to sanctions and punishment in the nature of contempt. I solemnly promise

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that I will not disclose in any manner any information or item that is subject to this

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Stipulated Protective Order to any person or entity except in strict compliance with the

14

provisions of this Order.

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I further agree to submit to the jurisdiction of the United States District Court for

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the Central District of California for the purpose of enforcing the terms of this

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action. I hereby appoint __________________________ [print or

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20 type full name] of _______________________________________ [print or type full

21 address and telephone number] as my California agent for service of process in

22 connection with this action or any proceedings related to enforcement of this Stipulated

23 Protective Order.

24 Date: ______________________________________

25 City and State where sworn and signed: _________________________________

26

27 Printed name: _______________________________

28 Signature: _________________________________

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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