distinguishing “good cause” showing for sealing documents produced 6 || in discovery from “compelling reasons” standard when merits-related 7 || documents are part of court record
How later courts described this case
- distinguishing “good cause” showing for sealing documents produced 6 || in discovery from “compelling reasons” standard when merits-related 7 || documents are part of court record
Written by the judges who cited it.
The opinion
1 John P. Kristensen (SBN 224132) Harold Greenberg (SBN 40827)
Jesenia A. Martinez (SBN 316969) Joshua Tey (SBN 310453)
2 || Jacob J. Ventura (SBN 315491) LAW FIRM OF HAROLD GREENBERG
3 KRISTENSEN LLP 2263 South Harvard Boulevard
12540 Beatrice Street, Suite 200 Los Angeles, California 90018-2143
4 || Los Angeles, California 90066 Telephone: (323) 732-9536
5 Telephone: (310) 507-7924 Facsimile: (323) 732-0803
Facsimile: (310) 507-7906 Harold@ hglaw.pro
6 || john@kristensenlaw.com Joshua @ hglaw.pro
7 | Jeser ia@ kr istensenlaw.com Attorneys for Defendant Joe Diaz
Jacob @kristensenlaw.com
8
9 Jarrett Ellzey (Pro Hac Vice) Richard E. Williamson (SBN 120368)
Texas Bar No. 24040864 Robert Corey Hayden (SBN 84816)
10 || HUGHES ELLZEY, LLP EZER WILLIAMSON LAW APC
11 || 1105 Milford Street 21515 Hawthorne Blvd. Suite 1150
Houston, Texas 77066 Torrance, California 90503
12 Telephone: (713) 554-2377 Telephone: (310) 277-7747
13 Facsimile: (888) 995-3335 Facsimile: (310) 277-2576
Jarrett @ hughesellzey.com rew @ezerwilliamsonlaw.com
14 Attorneys for Plaintiffs rch @ezerwilliamsonlaw.com
15 Attorneys for Defendants Stars Planet,
16 Inc. dba Silver Reign Gentlemen’s
> Club, Stanley Yang, David Chew, and
17 Becky Sheely
18 THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA — WESTERN DIVISION
ANGELICA MORA, an individual; ) Case No.: 2:20-cv—00414 JFW (JCx)
20 || GISELLE OJEDA, an individual; CO, LECTIVE ACTION
91 | SHANNA BARTHOLOMEW, an
2 | ne NANDA BROCE) STIPULATED PROTECTIVE
’ , ORDER
23 || individual and on behalf of all )
54 others similarly situated, CHANGES MADE BY COURT
Plaintiffs,
25 )
VS. )
2 | sTARS PLANET, INC. dba )
27 || SILVER REIGN GENTLEMEN’S _ )
28 CLUB, a California Corporation; )
1 JOE DIAZ, an individual; )
STANLEY YANG, an individual; )
2 || BECKY SHEELY, an individual; )
3 DAVID CHEW, an individual; )
DOE MANAGER 3; and DOES 4- _ )
4 || 100, inclusive, )
Defendants.
6 Discovery in this action is likely to involve production of confidential,
7 proprietary, or private information for which special protection from public
8 || disclosure and from use for any purpose other than prosecuting, defending, or
9 attempting to settle this litigation may be warranted. Accordingly, the parties
10 hereby stipulate to and petition the Court to enter the following Stipulated
11 || Protective Order. The parties acknowledge that this Order does not confer
|= 12 | blanket protections on all disclosures or responses to discovery and that the
13 protection it affords from public disclosure and use extends only to the limited
14 | information or items that are entitled to confidential treatment under the
15 applicable legal principles. The parties further acknowledge that this Stipulated
16 || Protective Order does not entitle them to file confidential information under
17 || seal. Rather, when the parties seek permission from the court to file material
18 || under seal, the parties must comply with Civil Local Rule 79-5 and with any
19 pertinent orders of the assigned District Judge and Magistrate Judge. See, e.g.,
20 Standing Order (Docket No. 23), 9 (governing Proposed Protective Order
21 | and Filings Under Seal).
22 GOOD CAUSE STATEMENT
23 This action is likely to involve private information of third parties,
24 including exotic dancers and employees of Defendant adult entertainment
25 || establishment. The parties acknowledge that highly sensitive and personal
26 || details about Plaintiffs will be exchanged in this action because: (1) there is a
27 significant social stigma associated with nude and semi-nude dancing that
28 | exotic dancers, also known as “strippers” perform; (2) there are risks inherent
1 || 1n working as an exotic dancer including risk of injury by current or former
2 || customers of Defendants if an exotic dancer’s name or address is disclosed;
3 || (3) dancers will likely want to protect their rights to privacy, which are
4 || reasonable and justified.
5 This dispute will also likely involve as confidential financial records of
6 || Defendants and their employees. Such confidential and proprietary materials
7 || and information consist of, among other things, the identities, addresses, phone
8 || numbers, email addresses, of exotic dancers, confidential business or financial
9 | information including wage and hour information protected from public
a to 10 || disclosure under California’s right to privacy, information regarding
11 || confidential business practices otherwise generally unavailable to the public
2 12 || and competitors of Defendant, or which may be privileged or otherwise
13 || protected from disclosure under state or federal statutes, court rules, case
14 || decisions, or common law.
15 Accordingly, to expedite the flow of information, to facilitate the prompt
- 16 || resolution of disputes over confidentiality of discovery materials, to adequately
17 || protect information the parties are entitled to keep confidential, to ensure that
18 || the parties are permitted reasonable necessary uses of such material in
“19 preparation for and in the conduct of trial, to address their handling at the end
20 || of the litigation, and serve the ends of justice, a protective order for such
21 || information is justified in this matter. It is the intent of the parties that
22 || information will not be designated as confidential for tactical reasons and that
23 || nothing be so designated without a good faith belief that it has been maintained
24 || confidential, non-public manner, and there is good cause why it should not
25 || be part of the public record of this case.
26 DEFINITIONS
27 Action: Mora, et al. vs. Stars Planet, Inc. dba Silver Reign, etc., et al. (Case
28 || No. 2:20-cv-414-JFW (JCx).
1 Challenging Party: a Party or Non-Party that challenges the designation
2 || of information or items under this Order.
3 “CONFIDENTIAL” Information or Items: information (regardless of
4 || how it is generated, stored or maintained) or tangible things that qualify for
5 || protection under Federal Rule of Civil Procedure 26(c), and as specified above
6 || in the Good Cause Statement.
7 Counsel: Outside Counsel of Record and House Counsel (as well as
8 || their support staff).
9 Designating Party: a Party or Non-Party that designates information or
a 10 || items that it produces in disclosures or in responses to discovery as
11 | “CONFIDENTIAL.”
2 12 Disclosure or Discovery Material: all items or information, regardless of
13 || the medium or manner in which it is generated, stored, or maintained
. 14 | Gncluding, among other things, testimony, transcripts, and tangible things),
15 || that are produced or generated in disclosures or responses to discovery in this
- 16 matter.
17 Expert: a person with specialized knowledge or experience in a matter
18 || pertinent to the litigation who has been retained by a Party or its counsel to
* 19 || serve as an expert witness or as a consultant in this Action.
20 House Counsel: attorneys who are employees of a party to this Action.
21 || House Counsel does not include Outside Counsel of Record or any other
22 || outside counsel.
23 Non-Party: any natural person, partnership, corporation, association, or
24 | other legal entity not named as a Party to this action.
25 Outside Counsel of Record: attorneys who are not employees of a party
26 || to this Action but are retained to represent or advise a party to this Action and
27 || have appeared in this Action on behalf of that party or are affiliated with a law
28 || firm which has appeared on behalf of that party, and includes support staff.
1 Party: any party to this Action, including all of its officers, directors,
2 || employees, consultants, retained experts, and Outside Counsel of Record (and
3 || their support staff).
4 Producing Party: a Party or Non-Party that produces Disclosure or
5 || Discovery Material in this Action.
6 Professional Vendors: persons or entities that provide litigation support
7 || services (e.g., photocopying, videotaping, translating, preparing exhibits or
8 || demonstrations, and organizing, storing, or retrieving data in any form or
9 || medium) and their employees and subcontractors.
pm 10 Protected Material: any Disclosure or Discovery Material that is
11 | designated as “CONFIDENTIAL.”
2 12 Receiving Party: a Party that receives Disclosure or Discovery Material
13 | from a Producing Party.
SCOPE
15 The protections conferred by this Stipulation and Order cover not only
- 16 || Protected Material (as defined above), but also (1) any information copied or
17 || extracted from Protected Material; (2) all copies, excerpts, summaries, or
18 || compilations of Protected Material; and (3) any testimony, conversations, or
“19 presentations by Parties or their Counsel that might reveal Protected Material
20 || other than during a court hearing or at trial.
21 Any use of Protected Material during a court hearing or at trial shall be
22 || governed by the orders of the presiding judge. This Order does not govern the
23 || use of Protected Material during a court hearing or at trial.
IA DURATION
25 Once a case proceeds to trial, all of the information that was designated
26 || as confidential or maintained pursuant to this protective order and offered into
27 || evidence or referenced therein becomes public and will be presumptively
28 || available to all members of the public, including the press, unless compelling
1 || reasons supported by specific factual findings to proceed otherwise are made to
2 || the trial judge in advance of the trial, including the identities of Defendants’
3 || exotic dancers and other employees and Defendants’ financial information. See
4 || Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.
5 || 2006) (distinguishing “good cause” showing for sealing documents produced
6 || in discovery from “compelling reasons” standard when merits-related
7 || documents are part of court record). Accordingly, the terms of this protective
8 || order do not extend beyond the commencement of the trial to the extent noted.
9 Even after final disposition of this litigation, the confidentiality
a 10 | obligations imposed by this Order shall remain in effect until a Designating
11 || Party agrees otherwise in writing or a court order otherwise directs. Final
2 12 || disposition shall be deemed to be the later of (1) dismissal of all claims and
13 || defenses in this Action, with or without prejudice; and (2) final judgment
. 14 || herein after the completion and exhaustion of all appeals, rehearings, remands,
15 || trials, or reviews of this Action, including the time limits for filing any motions
- 16 || or applications for extension of time pursuant to applicable law.
DESIGNATING PROTECTED MATERIAL
18 Exercise of Restraint and Care in Designating Material for
* 19 | Protection. Each Party or Non-Party that designates information or items for
20 || protection under this Order must take care to limit any such designation to
21 || specific material that qualifies under the appropriate standards. The
22 || Designating Party must designate for protection only those parts of material,
23 || documents, items, or oral or written communications that qualify so that other
24 | portions of the material, documents, items, or communications for which
25 || protection is not warranted are not swept unjustifiably within the ambit of this
26 || Order.
27 Mass, indiscriminate, or routinized designations are prohibited.
28 || Designations that are shown to be clearly unjustified or that have been made
1 || for an improper purpose (e.g., to unnecessarily encumber the case development
2 || process or to impose unnecessary expenses and burdens on other parties) may
3 || expose the Designating Party to sanctions.
4 If it comes to a Designating Party’s attention that information or items
5 || that it designated for protection do not qualify for protection, that Designating
6 || Party must promptly notify all other Parties that it is withdrawing the
7 || inapplicable designation.
8 Manner and Timing of Designations. Except as otherwise provided in
9 || this Order, or as otherwise stipulated or ordered, Disclosure or Discovery
a ¢,, 10 | Material that qualifies for protection under this Order must be clearly so
11 || designated before the material is disclosed or produced.
2 12 Designation in conformity with this Order requires:
13 For information in documentary form (e.g., paper or electronic
. 14 || documents, but excluding transcripts of depositions or other pretrial or trial
15 || proceedings), that the Producing Party affix at a minimum, the legend
- 16 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page
17 || that contains protected material. If only a portion or portions of the material on
18 || a page qualifies for protection, the Producing Party also must clearly identify
* 19 || the protected portion(s) (e.g., by making appropriate markings in the margins).
20 A Party or Non-Party that makes original documents available for
21 || inspection need not designate them for protection until after the inspecting
22 || Party has indicated which documents it would like copied and produced.
23 || During the inspection and before the designation, all of the material made
24 || available for inspection shall be deemed “CONFIDENTIAL.” After the
25 || inspecting Party has identified the documents it wants copied and produced,
26 || the Producing Party must determine which documents, or portions thereof,
27 || qualify for protection under this Order. Then, before producing the specified
28 || documents, the Producing Party must affix the “CONFIDENTIAL legend” to
1 || each page that contains Protected Material. If only a portion or portions of the
2 || material on a page qualifies for protection, the Producing Party also must
3 || clearly identify the protected portion(s) (e.g., by making appropriate markings
4 || in the margins).
5 For testimony given in depositions, that the Designating Party identify
6 || the Disclosure or Discovery Material on the record, before the close of the
7 || deposition all protected testimony.
8 For information produced in some form other than documentary and for
9 || any other tangible items, that the Producing Party affix in a prominent place on
a 10 || the exterior of the container or containers in which the information is stored the
11 || legend “CONFIDENTIAL.” If only a portion or portions of the information
2 12 || warrants protection, the Producing Party, to the extent practicable, shall
13 || identify the protected portion(s).
. 14 Inadvertent Failures to Designate. If timely corrected, an inadvertent
15 || failure to designate qualified information or items does not, standing alone,
- 16 || waive the Designating Party’s right to secure protection under this Order for
17 || such material. Upon timely correction of a designation, the Receiving Party
18 || must make reasonable efforts to assure that the material is treated in
* 19 || accordance with the provisions of this Order.
20 CHALLENGING CONFIDENTIALITY DESIGNATIONS
21 Timing of Challenges. Any Party or Non-Party may challenge a
22 || designation of confidentiality at any time that is consistent with the Court’s
23 || Scheduling Order.
24 Meet and Confer. The Challenging Party shall initiate the dispute
25 || resolution process under Local Rule 37.1 et seq.
26 The burden of persuasion in any such challenge proceeding shall be on
27 || the Designating Party. Frivolous challenges, and those made for an improper
28 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other
1 || parties) may expose the Challenging Party to sanctions. Unless the Designating
2 || Party has waived or withdrawn the confidentiality designation, all parties shall
3 || continue to afford the material in question the level of protection to which it is
4 || entitled under the Producing Party’s designation until the Court rules on the
5 | challenge.
6 ACCESS TO AND USE OF PROTECTED MATERIAL
7 Basic Principles. A Receiving Party may use Protected Material that is
8 || disclosed or produced by another Party or by a Non-Party in connection with
9 | this Action only for prosecuting, defending, or attempting to settle this Action.
a 10 || Such Protected Material may be disclosed only to the categories of persons and
11 || under the conditions described in this Order. When the Action has been
2 12 || terminated, a Receiving Party must comply with the provisions of the section
13 || below denominated “FINAL DISPOSITION.”
. 14 Protected Material must be stored and maintained by a Receiving Party
15 || at a location and in a secure manner that ensures that access is limited to the
- 16 || persons authorized under this Order.
Disclosure of “CONFIDENTIAL” Information or Items. Unless
18 || otherwise ordered by the court or permitted in writing by the Designating
“19 Party, a Receiving Party may disclose any information or item designated
20 || “CONFIDENTIAL” only to:
21 The Receiving Party’s Outside Counsel of Record in this Action, as well
22 || as employees of said Outside Counsel of Record to whom it is reasonably
23 || necessary to disclose the information for this Action;
24 The officers, directors, and employees (including House Counsel) of the
25 || Receiving Party to whom disclosure is reasonably necessary for this Action;
26 Experts (as defined in this Order) of the Receiving Party to whom
27 || disclosure is reasonably necessary for this Action and who have signed the
28 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);
1 The court and its personnel;
2 Court reporters and their staff;
3 Professional jury or trial consultants, mock jurors, and Professional
4 || Vendors to whom disclosure is reasonably necessary for this Action and who
5 || have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
6 The author or recipient of a document containing the information or a
7 || custodian or other person who otherwise possessed or knew the information;
8 During their depositions, witnesses, and attorneys for witnesses, in the
9 || Action to whom disclosure is reasonably necessary provided: (1) the deposing
a ¢,, 10 | party requests that the witness sign the form attached as Exhibit A hereto; and
11 | (2) they will not be permitted to keep any confidential information unless they
2 12 || sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
13 || otherwise agreed by the Designating Party or ordered by the court. Pages of
. 14 || transcribed deposition testimony or exhibits to depositions that reveal
15 || Protected Material may be separately bound by the court reporter and may not
- 16 || be disclosed to anyone except as permitted under this Stipulated Protective
17 || Order; and any mediator or settlement officer, and their supporting personnel,
18 || mutually agreed upon by any of the parties engaged in settlement discussions.
“19 PROTECTED MATERIAL SUBPOENAED OR
20 ORDERED PRODUCED IN OTHER LITIGATION
21 If a Party is served with a subpoena or a court order issued in other
22 || litigation that compels disclosure of any information or items designated in this
23 || Action as “CONFIDENTIAL,” that Party must:
24 Promptly notify in writing the Designating Party. Such notification shall
25 || include a copy of the subpoena or court order;
26 Promptly notify in writing the party who caused the subpoena or order to
27 || issue in the other litigation that some or all of the material covered by the
28
1 || subpoena or order is subject to this Protective Order. Such notification shall
2 || include a copy of this Stipulated Protective Order; and
3 Cooperate with respect to all reasonable procedures sought to be pursued
4 || by the Designating Party whose Protected Material may be affected.
5 If the Designating Party timely seeks a protective order, the Party served
6 || with the subpoena or court order shall not produce any information designated
7 || 1n this action as “CONFIDENTIAL” before a determination by the court from
8 || which the subpoena or order issued, unless the Party has obtained the
9 || Designating Party’s permission or unless otherwise required by the law or
a 10 | court order. The Designating Party shall bear the burden and expense of
11 || seeking protection in that court of its confidential material and nothing in these
2 12 || provisions should be construed as authorizing or encouraging a Receiving
13 || Party in this Action to disobey a lawful directive from another court.
. 14 A NON-PARTY’S PROTECTED MATERIAL
15 SOUGHT TO BE PRODUCED IN THIS LITIGATION
- 16 The terms of this Order are applicable to information produced by a
|= 17 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such
18 || information produced by Non-Parties in connection with this litigation is
“19 protected by the remedies and relief provided by this Order. Nothing in these
20 || provisions should be construed as prohibiting a Non-Party from seeking
21 || additional protections.
22 In the event that a Party is required, by a valid discovery request, to
23 || produce a Non-Party’s confidential information in its possession, and the Party
24 || is subject to an agreement with the Non-Party not to produce the Non-Party’s
25 || confidential information, then the Party shall:
26 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
28 || agreement with a Non-Party;
1 Promptly provide the Non-Party with a copy of the Stipulated Protective
2 || Order in this Action, the relevant discovery request(s), and a reasonably
3 || specific description of the information requested; and
4 Make the information requested available for inspection by the Non-
5 || Party, if requested.
6 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
8 || Party may produce the Non-Party’s confidential information responsive to the
9 || discovery request. If the Non-Party timely seeks a protective order, the
a to 10 || Receiving Party shall not produce any information in its possession or control
11 | that is subject to the confidentiality agreement with the Non-Party before a
2 12 || determination by the court unless otherwise required by the law or court order.
13 || Absent a court order to the contrary, the Non-Party shall bear the burden and
. 14 || expense of seeking protection in this court of its Protected Material.
15 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
- 16 If a Receiving Party learns that, by inadvertence or otherwise, it has
17 || disclosed Protected Material to any person or in any circumstance not
18 || authorized under this Stipulated Protective Order, the Receiving Party must
“19 immediately (a) notify in writing the Designating Party of the unauthorized
20 || disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
21 || Protected Material, (c) inform the person or persons to whom unauthorized
22 || disclosures were made of all the terms of this Order, and (d) request such
23 || person or persons to execute the “Acknowledgment and Agreement to Be
24 || Bound” that is attached hereto as Exhibit A.
25 INADVERTENT PRODUCTION OF PRIVILEGED OR
26 OTHERWISE PROTECTED MATERIAL
27 When a Producing Party gives notice to Receiving Parties that certain
28 || inadvertently produced material is subject to a claim of privilege or other
1 || protection, the obligations of the Receiving Parties are those set forth in
2 || Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to
3 || modify whatever procedure may be established in an e-discovery order that
4 || provides for production without prior privilege review. Pursuant to Federal
5 || Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on
6 || the effect of disclosure of a communication or information covered by the
7 || attorney-client privilege or work product protection, the parties may
8 || incorporate their agreement in the stipulated protective order submitted to the
9 court.
10 MISCELLANEOUS
11 Right to Further Relief. Nothing in this Order abridges the right of any
2 12 || person to seek its modification by the Court in the future.
13 Right to Assert Other Objections. By stipulating to the entry of this
. 14 || Protective Order no Party waives any right it otherwise would have to object to
15 || disclosing or producing any information or item on any ground not addressed
- 16 || in this Stipulated Protective Order. Similarly, no Party waives any right to
17 || object on any ground to use in evidence of any of the material covered by this
18 || Protective Order.
“19 Filing Protected Material. A Party that seeks to file under seal any
20 || Protected Material must comply with Civil Local Rule 79-5 and with any
21 || pertinent orders of the assigned District Judge and Magistrate Judge. See, e.g.,
22 || Standing Order (Docket No. 23), § 9 (governing Proposed Protective Order
23 || and Filings Under Seal). Protected Material may only be filed under seal
24 || pursuant to a court order authorizing the sealing of the specific Protected
25 || Material at issue. If a Party's request to file Protected Material under seal is
26 || denied by the court, then the Receiving Party may file the information in the
27 || public record unless otherwise instructed by the court.
28 || ///
1 FINAL DISPOSITION
2 After the final disposition of this Action within 60 days of a written
3 || request by the Designating Party, each Receiving Party must return all
4 || Protected Material to the Producing Party or destroy such material. As used in
5 || this subdivision, “all Protected Material” includes all copies, abstracts,
6 || compilations, summaries, and any other format reproducing or capturing any
7 || of the Protected Material. Whether the Protected Material is returned or
8 || destroyed, the Receiving Party must submit a written certification to the
9 || Producing Party (and, if not the same person or entity, to the Designating
a to 10 || Party) by the 60 day deadline that (1) identifies (by category, where
11 || appropriate) all the Protected Material that was returned or destroyed and
2 12 || (2) affirms that the Receiving Party has not retained any copies, abstracts,
13 || compilations, summaries or any other format reproducing or capturing any of
. 14 || the Protected Material. Notwithstanding this provision, Counsel are entitled to
15 || retain an archival copy of all pleadings, motion papers, trial, deposition, and
- 16 || hearing transcripts, legal memoranda, correspondence, deposition and trial
17 || exhibits, expert reports, attorney work product, and consultant and expert work
18 || product, even if such materials contain Protected Material. Any such archival
“19 copies that contain or constitute Protected Material remain subject to this
20 || Protective Order as set forth in the section denominated “DURATION.”
21 Any violation of this Order may be punished by any and all appropriate
22 || measures including, without limitation, contempt proceedings and/or monetary
23 || sanctions.
24
5 Dated: June 24, 2020 KRISTENSEN LLP
26 /s/ John P. Kristensen
John P. Kristensen
08 Attorneys for Plaintiffs
1 Dated: June 24, 2020 LAW FIRM OF HAROLD GREENBERG
2 /s/ Harold Greenberg (with permission)
3 Harold Greenberg
Attorneys for Defendant Joe Diaz
4
5 || Dated: June 24, 2020 EZER WILLIAMSON LAW APC
6
7 /s/ Robert C. Hayden (with permission)
Robert C. Hayden
8 Attorneys for Defendant Silver
9 Reign, Stanley Yang, Becky Sheely
and David Chew
a 10
| =
12 LOCAL RULES-4.3.4(a)(2)() CERTIFICATION
<q
13 The undersigned attests that all other signatories listed above on whose
14 | behalf this filing is submitted concur in the filing’s content and have authorized
O
|} 15 || the filing.
wo
| 16
17 /s/ John P. Kristensen
Oo John P. Kristensen
18
“19
IT IS SO ORDERED AS MODIFIED.
20
21
7 Dated: June 24, 2020 /s/
Honorable Jacqueline Chooljian
23 United States Magistrate Judge
24
25
26
27
28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, , declare under penalty of perjury that I have read in its
5 || entirety and understand the Stipulated Protective Order that was issued by the
6 || United States District Court for the Central District of California in the case of
7 || Mora, et al. vs. Stars Planet, Inc. dba Silver Reign etc., et al, Case No.: 2:20-
8 || cv-00414-JFW (JCx). Lagree to comply with and to be bound by all the terms
9 || of this Stipulated Protective Order and I understand and acknowledge that
a to 10 || failure to so comply could expose me to sanctions and punishment in the
11 | nature of contempt. I solemnly promise that I will not disclose in any manner
2 12 || any information or item that 1s subject to this Stipulated Protective Order to
13 || any person or entity except in strict compliance with the provisions of this
14 || Order.
15 I further agree to submit to the jurisdiction of the United States District
- 16 || Court for the Central District of California for the purpose of enforcing the
|< 17 || terms of this Stipulated Protective Order, even if such enforcement
18 || proceedings occur after termination of this action.
“19 Date:
20 City and State where sworn and signed:
21 Printed name:
22 Signature:
23
24
25
26
27
28