Opinion

J.W. v. Jarad Higgins

Court
District Court, C.D. California
Filed
Oct 21, 2020
Cited by
0 cases
Authority
More cited than 17.9%

distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record

How later courts described this case

  • distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record
  • even stipulated protective orders require 21 good cause showing

Written by the judges who cited it.

The opinion

1 Robert S. Meloni (Pro Hac Vice)

MELONI &MCCAFFREY, A Professional Corporation

2 3 Columbus Circle, 15th Floor

New York, New York 10019

3 P: (212) 520-6089

F: (917) 210-3758

4 E-Mail: rmeloni@m2lawgroup.com

E-Mail: tmccaffrey@m2lawgroup.com

5 Attorneys for Defendants Grade A Productions, LLC erroneously sued as Grade A

Productions, Interscope Records, a division of UMG Recordings, Inc. erroneouly

6 sued as Interscope Records and UMG Recordings, Inc., Nick Mira

7 Max J. Sprecher, Esq. (SBN: 169285)

LAW OFFICES OF MAX J. SPRECHER

8 5850 Canoga Avenue, 4th Floor

Woodland Hills, CA 91367

9 T: 818.996.2255

F: 818.996.4204

10 E-Mail: max@sprecherlaw.com

Attorneys for Defendants Grade A Productions, LLC erroneously sued as Grade A

11 Productions, Interscope Records, a division of UMG Recordings, Inc. erroneouly

sued as Interscope Records and UMG Recordings, Inc., Nick Mira and Estate of

12 Jarad Higgins

UNITED STATES DISTRICT COURT

13

CENTRAL DISTRICT OF CALIFORNIA

14

WESTERN DIVISION

15

J.W., A MINOR BY AND THROUGH Case No. 2:19cv06007 SB (AFMx)

16 HIS GUARDIAN AD LITEM THOMAS Filed: July 12, 2019

F. WILLISCH,

17

Plaintiff,

18 STIPULATED PROTECTIVE

vs. ORDER1

19

JARAD HIGGINS, professionally

20 known as JUICE WRLD; NICK

MIRA; GRADE A PRODUCTIONS;

21 INTERSCOPE RECORDS;

UNIVERSAL MUSIC GROUP

22 RECORDINGS, INC., AKA UMG

RECORDINGS INC.

23

Defendant.

24

25 1. A. PURPOSES AND LIMITATIONS

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

27

28 1. This Stipulated Protective Order is based substantially on the model protective order provided

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

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

3 Accordingly, the parties hereby stipulate to and petition the Court to enter the

4 following Stipulated Protective Order. The parties acknowledge that this Order does

5 not confer blanket protections on all disclosures or responses to discovery and that

6 the protection it affords from public disclosure and use extends only to the limited

7 information or items that are entitled to confidential treatment under the applicable

8 legal principles.

9 B. GOOD CAUSE STATEMENT

10 This action is likely to involve commercial, financial, technical and/or

11 proprietary information for which special protection from public disclosure and from

12 use for any purpose other than prosecution of this action is warranted. For example,

13 the agreements between and/or among the defendant artist, the defendant producer

14 and/or one or more of the defendant companies contain proprietary contractual

15 information as to the terms and conditions of the services rendered and the value of

16 the consideration provided in exchange therefore. It also contains the financial terms

17 of those agreements, the disclosure of which could impact the professional standing

18 of the artists and impact future agreements between the companies and other artists.

19 Such confidential and proprietary materials and information consist of, among other

20 things, confidential business or financial information, information regarding

21 confidential business practices, or other confidential commercial information

22 (including information implicating privacy rights of third parties), information

23 otherwise generally unavailable to the public, or which may be privileged or

24 otherwise protected from disclosure under state or federal statutes, court rules, case

25 decisions, or common law. Accordingly, to expedite the flow of information, to

26 facilitate the prompt resolution of disputes over confidentiality of discovery

27 materials, to adequately protect information the parties are entitled to keep

28 confidential, to ensure that the parties are permitted reasonable necessary uses of

1 such material in preparation for and in the conduct of trial, to address their handling

2 at the end of the litigation, and serve the ends of justice, a protective order for such

3 information is justified in this matter. It is the intent of the parties that information

4 will not be designated as confidential for tactical reasons and that nothing be so

5 designated without a good faith belief that it has been maintained in a confidential,

6 non-public manner, and there is good cause why it should not be part of the public

7 record of this case.

8 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

9 SEAL

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

11 Stipulated Protective Order does not entitle them to file confidential information

12 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and

13 the standards that will be applied when a party seeks permission from the court to file

14 material under seal.

15 There is a strong presumption that the public has a right of access to judicial

16 proceedings and records in civil cases. In connection with non-dispositive motions,

17 good cause must be shown to support a filing under seal. See Kamakana v. City and

18 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

19 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,

20 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require

21 good cause showing), and a specific showing of good cause or compelling reasons

22 with proper evidentiary support and legal justification, must be made with respect to

23 Protected Material that a party seeks to file under seal. The parties’ mere designation

24 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the

25 submission of competent evidence by declaration, establishing that the material

26 sought to be filed under seal qualifies as confidential, privileged, or otherwise

27 protectable—constitute good cause.

28

1 Further, if a party requests sealing related to a dispositive motion or trial, then

2 compelling reasons, not only good cause, for the sealing must be shown, and the

3 relief sought shall be narrowly tailored to serve the specific interest to be protected.

4 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For

5 each item or type of information, document, or thing sought to be filed or introduced

6 under seal in connection with a dispositive motion or trial, the party seeking

7 protection must articulate compelling reasons, supported by specific facts and legal

8 justification, for the requested sealing order. Again, competent evidence supporting

9 the application to file documents under seal must be provided by declaration.

10 Any document that is not confidential, privileged, or otherwise protectable in

11 its entirety will not be filed under seal if the confidential portions can be redacted. If

12 documents can be redacted, then a redacted version for public viewing, omitting only

13 the confidential, privileged, or otherwise protectable portions of the document, shall

14 be filed. Any application that seeks to file documents under seal in their entirety

15 should include an explanation of why redaction is not feasible.

16 2. DEFINITIONS

17 2.1 Action: this pending federal lawsuit.

18 2.2 Challenging Party: a Party or Non-Party that challenges the designation

19 of information or items under this Order.

20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

22 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the

23 Good Cause Statement.

24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

25 their support staff).

26 2.5 Designating Party: a Party or Non-Party that designates information or

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

28 “CONFIDENTIAL.”

1 2.6 Disclosure or Discovery Material: all items or information, regardless of

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

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

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

5 2.7 Expert: a person with specialized knowledge or experience in a matter

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

7 an expert witness or as a consultant in this Action.

8 2.8 House Counsel: attorneys who are employees of a party to this Action.

9 House Counsel does not include Outside Counsel of Record or any other outside

10 counsel.

11 2.9 Non-Party: any natural person, partnership, corporation, association or

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

13 2.10 Outside Counsel of Record: attorneys who are not employees of a party

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

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

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

17 2.11 Party: any party to this Action, including all of its officers, directors,

18 employees, consultants, retained experts, and Outside Counsel of Record (and their

19 support staffs).

20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

21 Discovery Material in this Action.

22 2.13 Professional Vendors: persons or entities that provide litigation support

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

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

25 and their employees and subcontractors.

26 2.14 Protected Material: any Disclosure or Discovery Material that is

27 designated as “CONFIDENTIAL.”

28

1 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

2 from a Producing Party.

3 3. SCOPE

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

5 Protected Material (as defined above), but also (1) any information copied or

6 extracted from Protected Material; (2) all copies, excerpts, summaries, or

7 compilations of Protected Material; and (3) any testimony, conversations, or

8 presentations by Parties or their Counsel that might reveal Protected Material.

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

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

11 4. DURATION

12 Once a case proceeds to trial, information that was designated as

13 CONFIDENTIAL or maintained pursuant to this protective order used or introduced

14 as an exhibit at trial becomes public and will be presumptively available to all

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

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

17 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

18 showing for sealing documents produced in discovery from “compelling reasons”

19 standard when merits-related documents are part of court record). Accordingly, the

20 terms of this protective order do not extend beyond the commencement of the trial.

21 5. DESIGNATING PROTECTED MATERIAL

22 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

25 qualifies under the appropriate standards. The Designating Party must designate for

26 protection only those parts of material, documents, items or oral or written

27 communications that qualify so that other portions of the material, documents, items

28

1 or communications for which protection is not warranted are not swept unjustifiably

2 within the ambit of this Order.

3 Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

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

7 Party to sanctions.

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

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

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

11 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

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

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

15 produced.

16 Designation in conformity with this Order requires:

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

18 documents, but excluding transcripts of depositions or other pretrial or trial

19 proceedings), that the Producing Party affix at a minimum, the legend

20 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

21 contains protected material. If only a portion of the material on a page qualifies for

22 protection, the Producing Party also must clearly identify the protected portion(s)

23 (e.g., by making appropriate markings in the margins).

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

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

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

27 before the designation, all of the material made available for inspection shall be

28 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

1 it wants copied and produced, the Producing Party must determine which documents,

2 or portions thereof, qualify for protection under this Order. Then, before producing

3 the specified documents, the Producing Party must affix the “CONFIDENTIAL

4 legend” to each page that contains Protected Material. If only a portion of the

5 material on a page qualifies for protection, the Producing Party also must clearly

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

7 margins).

8 (b) for testimony given in depositions that the Designating Party

9 identifies the Disclosure or Discovery Material on the record, before the close of the

10 deposition all protected testimony.

11 (c) for information produced in some form other than documentary

12 and for any other tangible items, that the Producing Party affix in a prominent place

13 on the exterior of the container or containers in which the information is stored the

14 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants

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

16 portion(s).

17 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

20 Upon timely correction of a designation, the Receiving Party must make reasonable

21 efforts to assure that the material is treated in accordance with the provisions of this

22 Order.

23 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

24 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

26 Scheduling Order.

27 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

28 resolution process under Local Rule 37-1 et seq.

1 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

2 joint stipulation pursuant to Local Rule 37-2.

3 6.4 The burden of persuasion in any such challenge proceeding shall be on

4 the Designating Party. Frivolous challenges, and those made for an improper purpose

5 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may

6 expose the Challenging Party to sanctions. Unless the Designating Party has waived

7 or withdrawn the confidentiality designation, all parties shall continue to afford the

8 material in question the level of protection to which it is entitled under the Producing

9 Party’s designation until the Court rules on the challenge.

10 7. ACCESS TO AND USE OF PROTECTED MATERIAL

11 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

14 Protected Material may be disclosed only to the categories of persons and under the

15 conditions described in this Order. When the Action has been terminated, a

16 Receiving Party must comply with the provisions of section 13 below (FINAL

17 DISPOSITION).

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

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

20 authorized under this Order.

21 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

23 Receiving Party may disclose any information or item designated

24 “CONFIDENTIAL” only to:

25 (a) the Receiving Party’s Outside Counsel of Record in this Action, as

26 well as employees of said Outside Counsel of Record to whom it is reasonably

27 necessary to disclose the information for this Action;

28

1 (b) the officers, directors, and employees (including House Counsel) of

2 the Receiving Party to whom disclosure is reasonably necessary for this Action;

3 (c) Experts (as defined in this Order) of the Receiving Party to whom

4 disclosure is reasonably necessary for this Action and who have signed the

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

6 (d) the court and its personnel;

7 (e) court reporters and their staff;

8 (f) professional jury or trial consultants, mock jurors, and Professional

9 Vendors to whom disclosure is reasonably necessary for this Action and who have

10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

11 (g) the author or recipient of a document containing the information or a

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

13 (h) during their depositions, witnesses, and attorneys for witnesses, in

14 the Action to whom disclosure is reasonably necessary provided: (1) the deposing

15 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2)

16 they will not be permitted to keep any confidential information unless they sign the

17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

18 agreed by the Designating Party or ordered by the court. Pages of transcribed

19 deposition testimony or exhibits to depositions that reveal Protected Material may be

20 separately bound by the court reporter and may not be disclosed to anyone except as

21 permitted under this Stipulated Protective Order; and

22 (i) any mediator or settlement officer, and their supporting personnel,

23 mutually agreed upon by any of the parties engaged in settlement discussions.

24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

25 OTHER LITIGATION

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

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

28 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating

1 Party. Such notification shall include a copy of the subpoena or court order; (b)

2 promptly notify in writing the party who caused the subpoena or order to issue in the

3 other litigation that some or all of the material covered by the subpoena or order is

4 subject to this Protective Order. Such notification shall include a copy of this

5 Stipulated Protective Order; and (c) cooperate with respect to all reasonable

6 procedures sought to be pursued by the Designating Party whose Protected Material

7 may be affected.

8 If the Designating Party timely seeks a protective order, the Party served with

9 the subpoena or court order shall not produce any information designated in this

10 action as “CONFIDENTIAL” before a determination by the court from which the

11 subpoena or order issued, unless the Party has obtained the Designating Party’s

12 permission. The Designating Party shall bear the burden and expense of seeking

13 protection in that court of its confidential material and nothing in these provisions

14 should be construed as authorizing or encouraging a Receiving Party in this Action to

15 disobey a lawful directive from another court.

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

17 PRODUCED IN THIS LITIGATION

18 (a) The terms of this Order are applicable to information produced by a

19 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

20 produced by Non-Parties in connection with this litigation is protected by the

21 remedies and relief provided by this Order. Nothing in these provisions should be

22 construed as prohibiting a Non-Party from seeking additional protections.

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

24 produce a Non-Party’s confidential information in its possession, and the Party is

25 subject to an agreement with the Non-Party not to produce the Non-Party’s

26 confidential information, then the Party shall:

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

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

1 with a Non-Party;

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

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

4 specific description of the information requested; and

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

6 Party, if requested.

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

8 within 14 days of receiving the notice and accompanying information, the Receiving

9 Party may produce the Non-Party’s confidential information responsive to the

10 discovery request. If the Non-Party timely seeks a protective order, the Receiving

11 Party shall not produce any information in its possession or control that is subject to

12 the confidentiality agreement with the Non-Party before a determination by the court.

13 Absent a court order to the contrary, the Non-Party shall bear the burden and expense

14 of seeking protection in this court of its Protected Material.

15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

19 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

20 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

21 persons to whom unauthorized disclosures were made of all the terms of this Order,

22 and (d) request such person or persons to execute the “Acknowledgment and

23 Agreement to Be Bound” that is attached hereto as Exhibit A.

24 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

25 PROTECTED MATERIAL

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

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

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

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

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

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

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

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

6 parties may incorporate their agreement in the stipulated protective order submitted

7 to the court.

8 12. MISCELLANEOUS

9 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

11 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

16 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

19 specific Protected Material at issue. If a Party’s request to file Protected Material

20 under seal is denied by the court, then the Receiving Party may file the information

21 in the public record unless otherwise instructed by the court.

22 13. FINAL DISPOSITION

23 After the final disposition of this Action, as defined in paragraph 4,

24 within 60 days of a written request by the Designating Party, each Receiving Party

25 must return all Protected Material to the Producing Party or destroy such material. As

26 used in this subdivision, “all Protected Material” includes all copies, abstracts,

27 compilations, summaries, and any other format reproducing or capturing any of the

28 Protected Material. Whether the Protected Material is returned or destroyed, the

1 Receiving Party must submit a written certification to the Producing Party (and, if

2 not the same person or entity, to the Designating Party) by the 60 day deadline that

3 (1) identifies (by category, where appropriate) all the Protected Material that was

4 returned or destroyed and (2) affirms that the Receiving Party has not retained any

5 copies, abstracts, compilations, summaries or any other format reproducing or

6 capturing any of the Protected Material. Notwithstanding this provision, Counsel are

7 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,

8 and hearing transcripts, legal memoranda, correspondence, deposition and trial

9 exhibits, expert reports, attorney work product, and consultant and expert work

10 product, even if such materials contain Protected Material. Any such archival copies

11 that contain or constitute Protected Material remain subject to this Protective Order

12 as set forth in Section 4 (DURATION).

13 14. VIOLATION

14 Any violation of this Order may be punished by appropriate measures

15 including, without limitation, contempt proceedings and/or monetary sanctions.

16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

17 GUTMAN LAW MELONI & McCAFFREY

A Professional Corporation

18

By: /s/John Juenger

19 John Juenger, SBN 22520 By: /s/Robert S. Meloni

Alan S. Gutman, SBN 128514 Robert S. Meloni (Pro Hac Vice)

20

Attorneys for Plaintiff J.W., a minor by Attorneys for Defendants Grade A

21 and through his Guardian Ad Litem Productions, LLC erroneously sued as

Thomas F. Willisch Grade A Productions, Interscope

22

Records, a division of UMG

23 Recordings, Inc. erroneously sued as

Interscope Records and UMG

24

Recordings, Inc., and Nick Mira

25

26

27

28

1 LAW OFFICES OF MAX J.

5 SPRECHER?

3 By: /s/Max J. Sprecher

4 Robert S. Meloni (Pro Hac Vice)

Attorneys for Defendants Grade A

5 Productions, LLC erroneously sued as

6 Grade A Productions, Interscope

Records, a division of UMG

7 Recordings, Inc. erroneously sued as

g Interscope Records and UMG

Recordings, Inc., Nick Mira, and

9 Estate of Jarad Higgins

10

1]

12 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

13

14 DATED: 10/21/2020 q .

15 kK

16 Oe

HON. ALEXANDER F. MacKINNON

17 United States Magistrate Judge

18

19

20

21

22

23

24

25

26

27

28 |2 Pursuant to Local Rule 5-4.3.4(a)(2)(), the filer of this document hereby attests that all

signatories concur in the filing of this document.

15 Case No. 2:19cv0Q6007

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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