a party’s privacy rights are to be protected through a “carefully 24 crafted protective order.”
How later courts described this case
- a party’s privacy rights are to be protected through a “carefully 24 crafted protective order.”
Written by the judges who cited it.
The opinion
RICKEY IVIE (#76864)
1
rivie@imwlaw.com
2 JACK F. ALTURA (#297314)
jaltura@imwlaw.com
3
IVIE McNEILL WYATT NOTE: CHANGES MADE BY THE COURT
4 PURCELL & DIGGS
444 South Flower Street, Suite 1800
5
Los Angeles, California 90071
6 Telephone: (213) 489-0028
Facsimile: (213) 489-0552
7
8 Attorneys for Defendants
9 COUNTY OF LOS ANGELES, et al.
10 UNITED STATES DISTRICT COURT
11
CENTRAL DISTRICT OF CALIFORNIA
12
13
IGNACIO ESCALANTE, an CASE NO. 2:19-cv-08695-JFW-JPR
14 individual,
15
Plaintiff, [PROPOSED] STIPULATED
16 vs. PROTECTIVE ORDER
17
COUNTY OF LOS ANGELES; LOS
18 ANGELES COUNTY SHERIFF’S
19 DEPARTMENT; DEPUTY HAUSER,
an individual; DEPUTY
20 HERNANDEZ, an individual;
21 DEPUTY PEREZ, an individual;
DEPUTY COVARRUBIAS, an
22 individual; SERGEANT BARRAGAN,
23 an individual; DEPUTY VEGA, an
individual; and DOES 1-50, inclusive,
24
25 Defendants.
26
27
1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary, or private information for which special protection from public
disclosure and from use for any purpose other than prosecuting this litigation maybe
4
warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
5
the following Stipulated Protective Order. The parties acknowledge that this Order
6
does not confer blanket protections on all disclosures or responses to discovery
7
and that the protection it affords from public disclosure and use extends only to the
8
limited information or items that are entitled to confidential treatment under the
9
applicable legal principles. The parties further acknowledge, as set forth in Section
10
12.3, below, that this Stipulated Protective Order does not entitle them to file
11
confidential information under seal; Civil Local Rule 79-5 sets forth the
12
procedures that must be followed and the standards that will be applied when a party
13
seeks permission from the court to file material under seal
14
B. GOOD CAUSE STATEMENT
15 Plaintiff and defendants may produce certain documents in this case that
16 contain personal medical, employment or financial information. Such information
17 may implicate the privacy interests of the parties and are properly protected through
18 a Fed. R. Civ. P. 26(c) protective order. Seattle Times Co. v. Rhinehart, 467 U.S. 20,
19 35 n.21 (1984) (“Rule 26(c) includes among its express purposes the protection of a
20 ‘party or person from annoyance, embarrassment, oppression or undue burden or
21 expense.’ Although the Rule contains no specific reference to privacy or to other
22 rights or interests that may be implicated, such matters are implicit in the broad
purpose and language of the Rule.”); Soto v. City of Concord, 162 F.R.D. 603, 617
23
(N.D. Cal. 1995) (a party’s privacy rights are to be protected through a “carefully
24
crafted protective order.”)
25
This action is also likely to involve the disclosure of documents relating to law
26
enforcement activities and training, which may be confidential and proprietary
27
information for which special protection from public disclosure and from use for any
1 purpose other than prosecution of this action is warranted. The materials and
2 information subject to this stipulated protective order are generally unavailable to the
3 public, or maybe privileged or otherwise protected from disclosure under state or
4 federal statutes, court rules, case decisions, or common law.
Confidential information with respect to the Defendants may include, but is not
5
limited to: personnel files; internal investigative files and documents; email and
6
written correspondence records; and policies and procedures, as well as other
7
information that is not generally available to the public. Confidential information may
8
also include financial records; email and written correspondence records; and
9
psychological and medical notes, evaluations, reports, and treatment plans.
10
Testimony taken at a deposition may be designated as Confidential by making
11
a statement to that effect on the record at the deposition by specifically identifying the
12
portions of the record to be deemed confidential, with an explicit assertion as to how
13
and/or why that portion of the record shall be deemed confidential.
14
Accordingly, to expedite the flow of information, to facilitate the prompt
15 resolution of disputes over confidentiality of discovery materials, to adequately
16 protect information the parties are entitled to keep confidential, to ensure that the
17 parties are permitted reasonable necessary uses of such material in preparation for
18 and in the conduct of trial, to address their handling at the end of the litigation, and
19 serve the ends of justice, a protective order for such information is justified in this
20 matter. It is the intent of the parties that information will not be designated as
21 confidential for tactical reasons and that nothing be so designated without a good
22 faith belief that it has been maintained in a confidential, non-public manner, and there
is good cause why it should not be part of the public record of this case.
23
2. DEFINITIONS
24
2.1 Action: Ignacio Escalante v. County of Los Angeles, et al., Case No.
25
2:19-CV-08695-JFW-JPR.
26
2.2 Challenging Party: a Party or Non-Party that challenges the designation
27
of information or items under this Order.
1 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
2 how it is generated, stored or maintained) or tangible things that qualify for
3 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
4 the Good Cause Statement.
2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
5
their support staff).
6
2.5 Designating Party: a Party or Non-Party that designates information or
7
items that it produces in disclosures or in responses to discovery as
8
“CONFIDENTIAL.”
9
2.6 Disclosure or Discovery Material: all items or information, regardless
10
of the medium or manner in which it is generated, stored, or maintained (including,
11
among other things, testimony, transcripts, and tangible things), that are produced or
12
generated in disclosures or responses to discovery in this matter.
13
2.7 Expert: a person with specialized knowledge or experience in a matter
14
pertinent to the litigation who has been retained by a Party or its counsel to serve as
15 an expert witness or as a consultant in this Action.
16 2.8 House Counsel: attorneys who are employees of a party to this Action.
17 House Counsel does not include Outside Counsel of Record or any other outside
18 counsel.
19 2.9 Non-Party: any natural person, partnership, corporation, association, or
20 other legal entity not named as a Party to this action.
21 2.10 Outside Counsel of Record: attorneys who are not employees of a
22 party to this Action but are retained to represent or advise a party to this Action and
have appeared in this Action on behalf of that party or are affiliated with a law firm
23
which has appeared on behalf of that party, and includes support staff.
24
2.11 Party: any party to this Action, including all of its officers, directors,
25
employees, consultants, retained experts, and Outside Counsel of Record (and their
26
support staffs).
27
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
1 Discovery Material in this Action.
2 2.13 Professional Vendors: persons or entities that provide litigation
3 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
4 demonstrations, and organizing, storing, or retrieving data in any form or medium)
and their employees and subcontractors.
5
2.14 Protected Material: any Disclosure or Discovery Material that is
6
designated as “CONFIDENTIAL.”
7
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
8
from a Producing Party.
9
3. SCOPE
10
The protections conferred by this Stipulation and Order cover not only
11
Protected Material (as defined above), but also (1) any information copied or
12
extracted from Protected Material; (2) all copies, excerpts, summaries, or
13
compilations of Protected Material; and (3) any testimony, conversations, or
14
presentations by Parties or their Counsel that might reveal Protected Material.
15 Any use of Protected Material at trial shall be governed by the orders of the
16 trial judge. This Order does not govern the use of Protected Material at trial.
17 4. DURATION
18 Once a case proceeds to trial, information that was designated as
19 CONFIDENTIAL or maintained pursuant to this Order used or introduced as an
20 exhibit at trial becomes public and will be presumptively available to all members of
21 the public, including the press, unless compelling reasons supported by specific
22 factual findings to proceed otherwise are made to the trial judge in advance of the
trial. See Kamakana, supra, 447 F.3d at 1180-81 (distinguishing “good cause”
23
showing for sealing documents produced in discovery from “compelling reasons”
24
standard when merits-related documents are part of court record). Accordingly, the
25
terms of this Order do not extend beyond the commencement of the trial as to the
26
Protected Material used or introduced as an exhibit at trial.
27
Even after final disposition of this litigation, the confidentiality obligations
1 imposed by this Order shall remain in effect until a Designating Party agrees
2 otherwise in writing or a court order otherwise directs. Final disposition shall be
3 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
4 or without prejudice; and (2) final judgment herein after the completion and
exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
5
including the time limits for filing any motions or applications for extension of time
6
pursuant to applicable law.
7
5. DESIGNATING PROTECTED MATERIAL
8
5.1 Exercise of Restraint and Care in Designating Material for Protection.
9
Each Party or Non-Party that designates information or items for protection
10
under this Order must take care to limit any such designation to specific material that
11
qualifies under the appropriate standards. The Designating Party must designate for
12
protection only those parts of material, documents, items, or oral or written
13
communications that qualify so that other portions of the material, documents, items,
14
or communications for which protection is not warranted are not swept unjustifiably
15 within the ambit of this Order.
16 Mass, indiscriminate, or routinized designations are prohibited. Designations
17 that are shown to be clearly unjustified or that have been made for an improper
18 purpose (e.g., to unnecessarily encumber the case development process or to impose
19 unnecessary expenses and burdens on other parties) may expose the Designating Party
20 to sanctions.
21 If it comes to a Designating Party’s attention that information or items that it
22 designated for protection do not qualify for protection, that Designating Party must
promptly notify all other Parties that it is withdrawing the inapplicable designation.
23
5.2 Manner and Timing of Designations. Except as otherwise provided in
24
this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
25
stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
26
under this Order must be clearly so designated before the material is disclosed or
27
produced.
1 Designation in conformity with this Order requires:
2 (a) for information in documentary form (e.g., paper or electronic
3 documents, but excluding transcripts of depositions or other pretrial or trial
4 proceedings), that the Producing Party affix at a minimum, the legend
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
5
contains protected material. If only a portion or portions of the material on a page
6
qualifies for protection, the Producing Party also must clearly identify the protected
7
portion(s) (e.g., by making appropriate markings in the margins).
8
A Party or Non-Party that makes original documents available for inspection
9
need not designate them for protection until after the inspecting Party has indicated
10
which documents it would like copied and produced. During the inspection and before
11
the designation, all of the material made available for inspection shall be deemed
12
“CONFIDENTIAL.” After the inspecting Party has identified the documents it
13
wants copied and produced, the Producing Party must determine which documents,
14
or portions thereof, qualify for protection under this Order. Then, before producing
15 the specified documents, the Producing Party must affix the “CONFIDENTIAL
16 legend” to each page that contains Protected Material. If only a portion or portions of
17 the material on a page qualifies for protection, the Producing Party also must clearly
18 identify the protected portion(s) (e.g., by making appropriate markings in the
19 margins).
20 (b) for testimony given in depositions that the Designating Party identify the
21 Disclosure or Discovery Material on the record, before the close of the deposition all
22 protected testimony.
(c) for information produced in some form other than documentary and for any
23
other tangible items, that the Producing Party affix in a prominent place on the exterior
24
of the container or containers in which the information is stored the legend
25
“CONFIDENTIAL.” If only a portion or portions of the information warrants
26
protection, the Producing Party, to the extent practicable, shall identify the protected
27
portion(s).
1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
2 failure to designate qualified information or items does not, standing alone, waive the
3 Designating Party’s right to secure protection under this Order for such material.
4 Upon timely correction of a designation, the Receiving Party must make reasonable
efforts to assure that the material is treated in accordance with the provisions of this
5
Order.
6
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
7
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
8
designation of confidentiality at any time that is consistent with the Court’s
9
Scheduling Order.
10
6.2 Meet and Confer. The Challenging Party shall initiate the dispute
11
resolution process under Local Rule 37-1 et seq.
12
6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
13
joint stipulation pursuant to Local Rule 37-2.
14
6.4 The burden of persuasion in any such challenge proceeding shall be on
15 the Designating Party. Frivolous challenges, and those made for an improper purpose
16 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
17 expose the Challenging Party to sanctions. Unless the Designating Party has waived
18 or withdrawn the confidentiality designation, all parties shall continue to afford the
19 material in question the level of protection to which it is entitled under the Producing
20 Party’s designation until the Court rules on the challenge.
21 7. ACCESS TO AND USE OF PROTECTED MATERIAL
22 7.1 Basic Principles. A Receiving Party may use Protected Material that is
disclosed or produced by another Party or by a Non-Party in connection with this
23
Action only for prosecuting, defending, or attempting to settle this Action. Such
24
Protected Material may be disclosed only to the categories of persons and under the
25
conditions described in this Order. When the Action has been terminated, a Receiving
26
Party must comply with the provisions of section 13 below (FINAL
27
DISPOSITION).
1 Protected Material must be stored and maintained by a Receiving Party at a
2 location and in a secure manner that ensures that access is limited to the persons
3 authorized under this Order.
4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
otherwise ordered by the court or permitted in writing by the Designating Party, a
5
Receiving Party may disclose any information or item designated
6
“CONFIDENTIAL” only to:
7
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well
8
as employees of said Outside Counsel of Record to whom it is reasonably necessary
9
to disclose the information for this Action;
10
(b) the officers, directors, and employees (including House Counsel) of
11
the Receiving Party to whom disclosure is reasonably necessary for this Action;
12
(c) Experts (as defined in this Order) of the Receiving Party to whom
13
disclosure is reasonably necessary for this Action and who have signed the
14
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
15 (d) the court and its personnel;
16 (e) court reporters and their staff;
17 (f) professional jury or trial consultants, mock jurors, and Professional
18 Vendors to whom disclosure is reasonably necessary for this Action and who have
19 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20 (g) the author or recipient of a document containing the information or a
21 custodian or other person who otherwise possessed or knew the information;
22 (h) during their depositions, witnesses, and attorneys for witnesses, in the
Action to whom disclosure is reasonably necessary provided: (1) the deposing party
23
requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
24
not be permitted to keep any confidential information unless they sign the
25
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
26
agreed by the Designating Party or ordered by the court. Pages of transcribed
27
deposition testimony or exhibits to depositions that reveal Protected Material maybe
1 separately bound by the court reporter and may not be disclosed to anyone except as
2 permitted under this Stipulated Protective Order; and
3 (i) any mediator or settlement officer, and their supporting personnel,
4 mutually agreed upon by any of the parties engaged in settlement discussions or
appointed by the Court.
5
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
6
PRODUCED IN OTHER LITIGATION
7
If a Party is served with a subpoena or a court order issued in other litigation
8
that compels disclosure of any information or items designated in this Action as
9
“CONFIDENTIAL,” that Party must:
10
(a) promptly notify in writing the Designating Party. Such notification shall
11
include a copy of the subpoena or court order unless prohibited by law;
12
(b) promptly notify in writing the party who caused the subpoena or order to
13
issue in the other litigation that some or all of the material covered by the subpoena
14
or order is subject to this Protective Order. Such notification shall include a copy of
15 this Stipulated Protective Order; and
16 (c) cooperate with respect to all reasonable procedures sought to be
17 pursued by the Designating Party whose Protected Material may be affected.
18 If the Designating Party timely seeks a protective order, the Party served with
19 the subpoena or court order shall not produce any information designated in this action
20 as “CONFIDENTIAL” before a determination by the court from which the subpoena
21 or order issued, unless the Party has obtained the Designating Party’s permission. The
22 Designating Party shall bear the burden and expense of seeking protection in that court
of its confidential material and nothing in these provisions should be construed as
23
authorizing or encouraging a Receiving Party in this Action to disobey a lawful
24
directive from another court.
25
///
26
///
27
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
1 PRODUCED IN THIS LITIGATION
2 (a) The terms of this Order are applicable to information produced by a
3 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
4 produced by Non-Parties in connection with this litigation is protected by the
remedies and relief provided by this Order. Nothing in these provisions should be
5
construed as prohibiting a Non-Party from seeking additional protections.
6
(b) In the event that a Party is required, by a valid discovery request, to
7
produce a Non-Party’s confidential information in its possession, and the Party is
8
subject to an agreement with the Non-Party not to produce the Non-Party’s
9
confidential information, then the Party shall:
10
(1) promptly notify in writing the Requesting Party and the Non-Party that
11
some or all of the information requested is subject to a confidentiality agreement with
12
a Non-Party;
13
(2) promptly provide the Non-Party with a copy of the Stipulated Protective
14
Order in this Action, the relevant discovery request(s), and a reasonably specific
15 description of the information requested; and
16 (3) make the information requested available for inspection by the Non-
17 Party, if requested.
18 (c) If the Non-Party fails to seek a protective order from this court within 14
19 days of receiving the notice and accompanying information, the Receiving Party may
20 produce the Non-Party’s confidential information responsive to the discovery request.
21 If the Non-Party timely seeks a protective order, the Receiving Party shall not
22 produce any information in its possession or control that is subject to the
confidentiality agreement with the Non-Party before a determination by the court.
23
Absent a court order to the contrary, the Non-Party shall bear the burden
24
and expense of seeking protection in this court of its Protected Material.
25
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
26
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
27
Protected Material to any person or in any circumstance not authorized under this
1 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
2 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
3 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
4 persons to whom unauthorized disclosures were made of all the terms of this Order,
and (d) request such person or persons to execute the “Acknowledgment and
5
Agreement to Be Bound” that is attached hereto as Exhibit A.
6
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
7
PROTECTED MATERIAL
8
Pursuant to Fed. R. Civ. P. 26(b)(5)(B) and Fed. R. Evid. 502, the inadvertent
9
production of privileged documents and data pursuant to this Order shall not result in
10
the waiver of any applicable privileges as to those documents and data. Also, the
11
inadvertent production of privileged documents or data under this Order shall not
12
result in the waiver of any applicable privileges as to those documents and data in any
13
other Federal or State proceeding. Any privileged material inadvertently disclosed
14
shall be and remain the property of the Producing Party.
15 (a) If a Producing Party determines that it has produced a document or data
16 to which it wishes to assert a claim of privilege, it shall notify the Receiving Party
17 promptly of its claim. As part of the notification, the Producing Party shall identify,
18 by Bates number(s) if possible, the document(s) or data as to which the Disclosing is
19 asserting a claim of privilege.
20 (b) A Receiving Party shall notify the Producing Party upon identification
21 of any document(s) or data that reasonably appears to be potentially privileged. Such
22 notification shall not waive the party's ability to challenge any assertion of privilege
made by the Producing Party as to the identified document(s) or data. As part of the
23
notification, the Receiving Party shall identify, by Bates Number(s) if possible, the
24
document(s) or data at issue. The Receiving Party shall segregate the specified
25
document(s) or data, as well as any copies thereof, from any other materials, and the
26
Receiving Party shall not use the information in the potentially privileged
27
document(s) or data, except as provided by Fed. R. Civ. P. 26(b)(5)(B), for a period
1 of 14 days after the date on which the Receiving Party notifies the Producing Party.
2 Within that 14-day period, or any other period of time agreed to by the parties, the
3 Producing Party shall determine whether it will assert a claim of privilege as to the
4 identified document(s) or data, and it shall notify the Receiving Party counsel of its
determination.
5
(c) Upon receiving notice of a claim of privilege by the Producing Party
6
regarding a produced document or data, the Receiving Party shall segregate, in
7
accordance with Fed. R. Civ. P. 26(b)(5)(B), the specified document or data, as well
8
as any copies thereof, and shall not use the information in the specified document or
9
data, except as provided by Fed. R. Civ. P. 26(b)(5)(B), until after the claim is
10
resolved. If a court upholds — or if the Receiving Party does not challenge — the
11
Producing Party's claim of privilege as to a produced document or data, the Receiving
12
Party shall return or dispose of the specified document or data, as well as any hard or
13
electronic copies thereof. Within five business days of taking such measures, the
14
Receiving Party shall certify that it has complied with the requirements of this
15 paragraph
16 This provision is not intended to modify whatever procedure may be
17 established in an e-discovery order that provides for production without prior
18 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
19 parties reach an agreement on the effect of disclosure of a communication or
20 information covered by the attorney-client privilege or work product protection, the
21 parties may incorporate their agreement in the stipulated protective order submitted
22 to the court provided the Court so allows.
12. MISCELLANEOUS
23
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
24
person to seek its modification by the Court in the future.
25
12.2 Right to Assert Other Objections. By stipulating to the entry of this
26
Protective Order no Party waives any right it otherwise would have to object to
27
disclosing or producing any information or item on any ground not addressed in this
1 Stipulated Protective Order. Similarly, no Party waives any right to object on any
2 ground to use in evidence of any of the material covered by this Protective Order.
3 12.3 Filing Protected Material. A Party that seeks to file under seal any
4 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
only be filed under seal pursuant to a court order authorizing the sealing of the specific
5
Protected Material at issue. If a Party's request to file Protected Material under seal
6
is denied by the court, then the Receiving Party may file the information in the public
7
record unless otherwise instructed by the court.
8
13. FINAL DISPOSITION
9
After the final disposition of this Action, as defined in paragraph 4, the
10
Designating Party will provide notice via written request to the Receiving Party to
11
return all Protected Material to the Producing Party or destroy such material. Within
12
60 days of the written request by the Designating Party, each Receiving Party must
13
return all Protected Material to the Producing Party or destroy such material. As used
14
in this subdivision, “all Protected Material” includes all copies, abstracts,
15 compilations, summaries, and any other format reproducing or capturing any of the
16 Protected Material. Whether the Protected Material is returned or destroyed, the
17 Receiving Party must submit a written certification to the Producing Party (and, if not
18 the same person or entity, to the Designating Party) by the 60 day deadline that (1)
19 identifies (by category, where appropriate) all the Protected Material that was
20 returned or destroyed and (2) affirms that the Receiving Party has not retained
21 any copies, abstracts, compilations, summaries or any other format reproducing or
22 capturing any of the Protected Material. Notwithstanding this provision, Counsel are
entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
23
and hearing transcripts, legal memoranda, correspondence, deposition and trial
24
exhibits, expert reports, attorney work product, and consultant and expert work
25
product, even if such materials contain Protected Material. Any such archival copies
26
that contain or constitute Protected Material remain subject to this Protective Order
27
as set forth in Section 4 (DURATION).
1 14. VIOLATION
2 Any violation of this Order may be punished by any and all appropriate
3 measures including, without limitation, contempt proceedings and/or monetary
4 sanctions.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5
6
DATED: May 8, 2020 MCMURRAY HENRIKS, LLP
7
8
By: /s/ Michael Bral
9
Michael Bral, Esq.
10 Randy McMurray, Esq.
Yana Henricks., Esq.
11 Attorneys for Plaintiff, IGNACIO
ESCALANTE
12
13
DATED: May 8, 2020 IVIE, MCNEILL, & WYATT
14
15
By: /s/ Jack F. Altura
16
Rickey Ivie, Esq.
17 Jack Altura, Esq.
Attorneys for Defendant, COUNTY OF
18 LOS ANGELES
19
20
ATTESTATION OF FILING ATTORNEY
21
I attest that all signatories listed above, and on whose behalf this filing is
22
submitted, concur in the filing’s content and have authorized the filing of this
23
document.
24
Dated: May 8, 2020
25
26 /s/ Jack F. Altura
JACK F. ALTURA
27
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
for Foenbte-
2 || DATED: May 20, 2020 By:
3 HON. JEAN P. ROSENBLUTH
United States Magistrate Judge
4
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15
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 that
5 I have read in its entirety and understand the Stipulated Protective Order that was
6 issued by the United States District Court for the Central District of California on
7 [________________] in the case of Ignacio Escalante v. County of Los Angeles, et
8 al., Case No. 2:19-CV-08695-JFW-JPR. I agree to comply with and to be bound by
9 all the terms of this Stipulated Protective Order and I understand and acknowledge
10 that failure to so comply could expose me to sanctions and punishment in the nature
11 of contempt. I solemnly promise that I will not disclose in any manner any information
12 or item that is subject to this Stipulated Protective Order to any person or entity except
13 in strict compliance with the provisions of this Order. I further agree to submit to the
14 jurisdiction of the United States District Court for the Central District of California
15 for enforcing the terms of this Stipulated Protective Order, even if such enforcement
16 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 Date: ______________________________________
23
24 City and State where sworn and signed: _________________________________
25 Printed name: _______________________________
26 Signature: __________________________________
27