# Lyle Spruill v. County of Los Angeles

> District Court, C.D. California · December 9, 2020

URL: https://www.frixlaw.com/law-library/cases/10039712

## Case

- **Court:** District Court, C.D. California
- **Decided:** December 9, 2020
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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2

3 UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION
5
LYLE SPRUILL, an individual, CASE NO. 20-cv-07909 MCS (Ex)
6
Plaintiff,
7

8 V. (PROPOSED) STIPULATED
PROTECTIVE ORDER
9 COUNTY OF LOS ANGELES, A
PUBLIC ENTITY, DEPUTY JAIME
10 GOMEZ, JR., DEPUTY MONICA Action Filed: August 31, 2020
GONZALES, DEPUTY RYAN Trial Date: None Set
11 ROTHROCK, DEPUTY SAUL
GOMEZ, DEPUTY JUAN PUENTE,
12 DEPUTY JOSHUA MUNOZ, SGT.
MICHAEL RODRIGUEZ, SGT.
13 COREY WALKER, DET. LAURA
PERALES, and DOES 1 through 15,
14 Defendants.
15
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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Subject to the Court’s approval, Plaintiff Lyle Spruill (“plaintiff”), and
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Defendants the County of Los Angeles and all individually named defendants (the
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“County” or “defendants”), by and through their attorneys of record, hereby agree
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and stipulate as follows:
20

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1. A. PURPOSES AND LIMITATIONS
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Discovery in this action is likely to involve production of confidential,
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proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the Court
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to enter the following Stipulated Protective Order. The parties acknowledge that
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this Order does not confer blanket protections on all disclosures or responses to
1 discovery and that the protection it affords from public disclosure and use extends
2 only to the limited information or items that are entitled to confidential treatment
3 under the applicable legal principles. The parties further acknowledge, as set forth
4 in Section 12.3, below, that this Stipulated Protective Order does not entitle
5 them to file confidential information under seal; Civil Local Rule 79-5 sets forth
6 the procedures that must be followed and the standards that will be applied when a
7 party seeks permission from the court to file material under seal.
8 B. GOOD CAUSE STATEMENT
9 This action involves the County of Los Angeles, and nine individual
10 deputies (“Defendants”). Plaintiff is seeking materials and information that
11 Defendant County of Los Angeles maintains as confidential, such as personnel
12 files of the police officers involved in this incident, Internal Affairs materials and
13 information, video recordings, audio recordings, and information and other
14 administrative materials and information currently in the possession of the County
15 and which Defendants believe need special protection from public disclosure and
16 from use for any purpose other than prosecuting this litigation. Plaintiff may also
17 seek official information contained in the personnel files of the police officers
18 involved in the subject incident, which the County maintains as strictly
19 confidential and which Defendants believe need special protection from public
20 disclosure and from use for any purpose other than prosecuting this litigation.
21 Defendants assert that the confidentiality of the materials and information
22 sought by Plaintiff is recognized by California and federal law, as evidenced inter
23 alia by California Penal Code section 832.7; Kerr v. United States Dist. Ct. for
24 N.D. Cal., 511 F.2d 192, 198 (9th Cir. 1975), aff’d, 426 U.S. 394 (1976). The
25 County has not publicly released the materials and information referenced above
26 except under protective order or pursuant to a court order, if at all. These materials
27 and information are of the type that can be used to initiate disciplinary action
1 used as evidence in disciplinary proceedings, where the officers’ conduct may be
2 considered to be contrary to LASD policy.
3 Defendants contend that absent a protective order delineating the
4 responsibilities of nondisclosure on the part of the parties hereto, there is a specific
5 risk of unnecessary and undue disclosure by one or more of the many attorneys,
6 secretaries, law clerks, paralegals and expert witnesses involved in this case, as
7 well as the corollary risk of embarrassment, harassment as well as professional,
8 physical and legal harm on the part of the LASD officers referenced in the
9 materials and information.
10 Defendants also contend that the unfettered disclosure of the materials and
11 information, absent a protective order, would allow the media to share this
12 information with potential jurors in the area, impacting the rights of the
13 Defendants herein to receive a fair trial.
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
23 there is good cause why it should not be part of the public record of this case.
24 2. DEFINITIONS
25 2.1 Action: this pending federal lawsuit.
26 2.2 Challenging Party: a Party or Non-Party that challenges the
27 designation 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. This also includes (1) any information copied or
5 extracted from the Confidential information; (2) all copies, excerpts, summaries or
6 compilations of Confidential information; and (3) any testimony, conversations, or
7 presentations that might reveal Confidential information.
8 2.4 “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY”
9 Information or Items: extremely sensitive “CONFIDENTIAL” Information or
10 Items, the disclosure of which to the individual Plaintiffs or any other Party or
11 Non-Party other than the Parties’ attorneys, would create a substantial risk of
12 serious harm that could not be avoided by less restrictive means.
13 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as
14 their support staff).
15 2.6 Designating Party: a Party or Non-Party that designates information
16 or items that it produces in disclosures or in responses to discovery as
17 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
18 ONLY”.
19 2.7 Disclosure or Discovery Material: all items or information, regardless
20 of the medium or manner in which it is generated, stored, or maintained
21 (including, among other things, testimony, transcripts, and tangible things), that
22 are produced or generated in disclosures or responses to discovery in this matter.
23 2.8 Expert: a person with specialized knowledge or experience in a
24 matter pertinent to the litigation who has been retained by a Party or its counsel to
25 serve as an expert witness or as a consultant in this Action.
26 2.9 House Counsel: attorneys who are employees of a party to this
27 Action. House Counsel does not include Outside Counsel of Record or any other
1 2.10 Non-Party: any natural person, partnership, corporation, association
2 or 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
4 party to this Action but are retained to represent or advise a party to this Action
5 and have appeared in this Action on behalf of that party or are affiliated with a law
6 firm which has 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 employees, consultants, retained experts, and Outside Counsel of Record (and
9 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
13 support services (e.g., photocopying, videotaping, translating, preparing exhibits
14 or demonstrations, and organizing, storing, or retrieving data in any form or
15 medium) and their employees and subcontractors.
16 2.15 Protected Material: any Disclosure or Discovery Material that is
17 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL --
18 ATTORNEYS’ EYES ONLY”.
19 2.16 Receiving Party: a Party that receives Disclosure or Discovery
20 Material from a Producing Party.
21 2.17 Plaintiffs’ Counsel: plaintiffs’ attorneys of record, and their essential
22 paralegals, law clerks, and administrative assistants.
23 3. SCOPE
24 The protections conferred by this Stipulation and Order cover not only
25 Protected Material (as defined above), but also (1) any information copied or
26 extracted from Protected Material; (2) all copies, excerpts, summaries, or
27 compilations of Protected Material; and (3) any testimony, conversations, or
1 Any use of Protected Material at trial shall be governed by the orders of the
2 trial judge. This Order does not govern the use of Protected Material at trial.
3 4. DURATION
4 Once a case proceeds to trial, information that was designated as
5 CONFIDENTIAL or maintained pursuant to this protective order used or
6 introduced as an exhibit at trial becomes public and will be presumptively
7 available to all members of the public, including the press, unless compelling
8 reasons supported by specific factual findings to proceed otherwise are made to
9 the trial judge in advance of the trial. See Kamakana v. City of Honolulu, 447 F.3d
10 1172, 1180-81 (9th Cir. 2060) (distinguishing “good cause” showing for sealing
11 documents produced in discovery from “compelling reasons” standard when
12 merits-related documents are part of court record). Accordingly, the terms of this
13 protective order do not extend beyond the commencement of the trial.
14 As for information designed as “HIGHLY CONFIDENTIAL –
15 ATTORNEYS’ EYES ONLY”, even after final disposition of this litigation, the
16 confidentiality obligations imposed by this Order shall remain in effect until a
17 Designating Party agrees otherwise in writing or a court order otherwise directs.
18 Final disposition shall be deemed to be the later of (1) dismissal of all claims and
19 defenses in this Action, with or without prejudice; and (2) final judgment herein
20 after the completion and exhaustion of all appeals, re-hearings, remands, trials, or
21 reviews of this Action, including the time limits for filing any motions or
22 applications for extension of time pursuant to applicable law.
23 5. DESIGNATING PROTECTED MATERIAL
24 5.1 Exercise of Restraint and Care in Designating Material for Protection.
25 Each Party or Non-Party that designates information or items for protection under
26 this Order must take care to limit any such designation to specific material that
27 qualifies under the appropriate standards. The Designating Party must designate
1 communications that qualify so that other portions of the material, documents,
2 items or communications for which protection is not warranted are not swept
3 unjustifiably within the ambit of this Order.
4 Mass, indiscriminate or routinized designations are prohibited.
5 Designations that are shown to be clearly unjustified or that have been made for an
6 improper purpose (e.g., to unnecessarily encumber the case development process
7 or to impose unnecessary expenses and burdens on other parties) may expose the
8 Designating Party to sanctions.
9 If it comes to a Designating Party’s attention that information or items that
10 it designated for protection do not qualify for protection, that Designating Party
11 must promptly notify all other Parties that it is withdrawing the inapplicable
12 designation.
13 5.2 Manner and Timing of Designations. Except as otherwise provided
14 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
15 stipulated or ordered, Disclosure or Discovery Material that qualifies for
16 protection under this Order must be clearly so designated before the material is
17 disclosed or produced.
18 Designation in conformity with this Order requires:
19 (a) for information in documentary form (e.g., paper or electronic
20 documents, but excluding transcripts of depositions or other pretrial or trial
21 proceedings), that the Producing Party affix at a minimum, the legend
22 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
23 ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains
24 protected material. If only a portion of the material on a page qualifies for
25 protection, the Producing Party also must clearly identify the protected portion(s)
26 (e.g., by making appropriate markings in the margins).
27 A Party or Non-Party that makes original documents available for
1 has indicated which documents it would like copied and produced. During the
2 inspection and before the designation, all of the material made available for
3 inspection shall be deemed “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
4 ATTORNEYS’ EYES ONLY.” After the inspecting Party has identified the
5 documents it wants copied and produced, the Producing Party must determine
6 which documents, or portions thereof, qualify for protection under this Order.
7 Then, before producing the specified documents, the Producing Party must affix
8 the “CONFIDENTIAL legend” to each page that contains Protected Material. If
9 only a portion of the material on a page qualifies for protection, the Producing
10 Party also must clearly identify the protected portion(s) (e.g., by making
11 appropriate markings in the margins).
12 (b) for testimony given in depositions that the Designating Party
13 identifies the Disclosure or Discovery Material on the record, before the close of
14 the deposition all protected testimony.
15 (c) for information produced in some form other than documentary
16 and for any other tangible items, that the Producing Party affix in a prominent
17 place on the exterior of the container or containers in which the information is
18 stored the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
19 ATTORNEYS’ EYES ONLY”. If only a portion or portions of the information
20 warrants protection, the Producing Party, to the extent practicable, shall identify
21 the protected portion(s).
22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
23 failure to designate qualified information or items does not, standing alone, waive
24 the Designating Party’s right to secure protection under this Order for such
25 material. Upon timely correction of a designation, the Receiving Party must make
26 reasonable efforts to assure that the material is treated in accordance with the
27 provisions of this Order.
1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
3 designation of confidentiality at any time that is consistent with the Court’s
4 Scheduling Order.
5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
6 resolution process under Local Rule 37-1 et seq.
7 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
8 joint stipulation pursuant to Local Rule 37-2.
9 6.4 The burden of persuasion in any such challenge proceeding shall be
10 on the Designating Party. Frivolous challenges, and those made for an improper
11 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
12 parties) may expose the Challenging Party to sanctions. Unless the Designating
13 Party has waived or withdrawn the confidentiality designation, all parties shall
14 continue to afford the material in question the level of protection to which it is
15 entitled under the Producing Party’s designation until the Court rules on the
16 challenge.
17 7. ACCESS TO AND USE OF PROTECTED MATERIAL
18 7.1 Basic Principles. A Receiving Party may use Protected Material that
19 is disclosed or produced by another Party or by a Non-Party in connection with
20 this Action only for prosecuting, defending or attempting to settle this Action.
21 Such Protected Material may be disclosed only to the categories of persons and
22 under the conditions described in this Order. When the Action has been
23 terminated, a Receiving Party must comply with the provisions of section 13
24 below (FINAL DISPOSITION). Protected Material must be stored and maintained
25 by a Receiving Party at a location and in a secure manner that ensures that access
26 is limited to the persons authorized under this Order.
27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only to:
3 (a) the Receiving Party’s Outside Counsel of Record in this Action,
4 as well as employees of said Outside Counsel of Record to whom it is reasonably
5 necessary to disclose the information for this Action,
6 (b) the officers, directors, and employees (including House Counsel)
7 of the Receiving Party to whom disclosure is reasonably necessary for this Action,
8 (c) Experts (as defined in this Order) of the Receiving Party to whom
9 disclosure is reasonably necessary for this Action and who have signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A),
11 (d) the court and its personnel,
12 (e) court reporters and their staff,
13 (f) professional jury or trial consultants, mock jurors, and
14 Professional Vendors to whom disclosure is reasonably necessary for this Action
15 and who have signed the “Acknowledgment and Agreement to Be Bound”
16 (Exhibit A),
17 (g) the author or recipient of a document containing the information
18 or a custodian or other person who otherwise possessed or knew the information,
19 (h) during their depositions, witnesses, and attorneys for witnesses, in
20 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
21 party requests that the witness sign the form attached as Exhibit 1 hereto; and
22 (2) they will not be permitted to keep any confidential information unless they
23 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
24 otherwise agreed by the Designating Party or ordered by the court. Pages of
25 transcribed deposition testimony or exhibits to depositions that reveal Protected
26 Material may be separately bound by the court reporter and may not be disclosed
27 to anyone except as permitted under this Stipulated Protective Order, and
1 (i) any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions.
3 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
4 ONLY” Information or Items. The Parties’ attorneys will maintain and keep safe
5 and secure any items and any information contained in such items marked
6 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. The parties’
7 attorneys will not disclose or allow any individual Plaintiffs, any other Party or
8 Non-Party access to any items and any information contained in such items
9 marked “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. Unless
10 otherwise ordered by the court or permitted in writing by the Designating Party, a
11 Receiving Party may disclose any information or item designated “HIGHLY
12 CONFIDENTIAL” only to:
13 (a) Experts (as defined in this Order) of the Receiving Party to whom
14 disclosure is reasonably necessary for this Action and who have signed the
15 “Acknowledgment and Agreement to Be Bound” (Exhibit A),
16 (b) the court and its personnel,
17 (c) private court reporters and their staff to whom disclosure is
18 reasonably necessary for this Action and who have signed the “Acknowledgment
19 and Agreement to Be Bound” (Exhibit A),
20 (d) professional jury or trial consultants, mock jurors, and
21 Professional Vendors to whom disclosure is reasonably necessary for this Action
22 and who have signed the “Acknowledgment and Agreement to Be Bound”
23 (Exhibit A),
24 (e) the author or recipient of a document containing the information
25 or a custodian or other person who otherwise possessed or knew the information,
26 and
27 (f) any mediator or settlement officer, and their supporting personnel,
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
2 IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation
4 that compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
6 ONLY” that Party must:
7 (a) promptly notify in writing the Designating Party. Such
8 notification shall include a copy of the subpoena or court order,
9 (b) promptly notify in writing the party who caused the subpoena or
10 order to issue in the other litigation that some or all of the material covered by the
11 subpoena or order is subject to this Protective Order. Such notification shall
12 include a copy of this Stipulated Protective Order, and
13 (c) cooperate with respect to all reasonable procedures sought to be
14 pursued by the Designating Party whose Protected Material may be affected. If
15 the Designating Party timely seeks a protective order, the Party served with the
16 subpoena or court order shall not produce any information designated in this
17 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
18 EYES ONLY” before a determination by the court from which the subpoena or
19 order issued, unless the Party has obtained the Designating Party’s permission.
20 The Designating Party shall bear the burden and expense of seeking protection in
21 that court of its confidential material and nothing in these provisions should be
22 construed as authorizing or encouraging a Receiving Party in this Action to
23 disobey a lawful directive from another court.
24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
25 PRODUCED IN THIS LITIGATION
26 (a) The terms of this Order are applicable to information produced by
27 a Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
1 by Non-Parties in connection with this litigation is protected by the remedies and
2 relief provided by this Order. Nothing in these provisions should be construed as
3 prohibiting a Non-Party from seeking additional protections.
4 (b) In the event that a Party is required, by a valid discovery request,
5 to produce a Non-Party’s confidential information in its possession, and the Party
6 is subject to an agreement with the Non-Party not to produce the Non-Party’s
7 confidential information, then the Party shall:
8 (1) promptly notify in writing the Requesting Party and the
9 Non-Party that some or all of the information requested is subject to a
10 confidentiality agreement with a Non-Party,
11 (2) promptly provide the Non-Party with a copy of the
12 Stipulated Protective Order in this Action, the relevant discovery request(s), and a
13 reasonably specific description of the information requested, and
14 (3) make the information requested available for inspection by
15 the Non-Party, if requested.
16 (c) If the Non-Party fails to seek a protective order from this court
17 within 14 days of receiving the notice and accompanying information, the
18 Receiving Party may produce the Non-Party’s confidential information responsive
19 to the discovery request. If the Non-Party timely seeks a protective order, the
20 Receiving Party shall not produce any information in its possession or control that
21 is subject to the confidentiality agreement with the Non-Party before a
22 determination by the court. Absent a court order to the contrary, the Non-Party
23 shall bear the burden and expense of seeking protection in this court of its
24 Protected Material.
25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
26 If a Receiving Party learns that, by inadvertence or otherwise, it has
27 disclosed Protected Material to any person or in any circumstance not authorized
1 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
2 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
3 the person or persons to whom unauthorized disclosures were made of all the
4 terms of this Order, and (d) request such person or persons to execute the
5 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
6 A.
7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
8 PROTECTED MATERIAL
9 When a Producing Party gives notice to Receiving Parties that certain
10 inadvertently produced material is subject to a claim of privilege or other
11 protection, the obligations of the Receiving Parties are those set forth in Federal
12 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
13 whatever procedure may be established in an e-discovery order that provides for
14 production without prior privilege review. Pursuant to Federal Rule of Evidence
15 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
16 of a communication or information covered by the attorney-client privilege or
17 work product protection, the parties may incorporate their agreement in the
18 stipulated protective order submitted to the court.
19 12. MISCELLANEOUS
20 12.1 Right to Further Relief. Nothing in this Order abridges the right of
21 any person to seek its modification by the Court in the future.
22 12.2 Right to Assert Other Objections. By stipulating to the entry of this
23 Protective Order, no Party waives any right it otherwise would have to object to
24 disclosing or producing any information or item on any ground not addressed in
25 this Stipulated Protective Order. Similarly, no Party waives any right to object on
26 any ground to use in evidence of any of the material covered by this Protective
27 Order.
1 12.3 Filing Protected Material. A Party that seeks to file under seal any
2 Protected Material must comply with Local Civil Rule 79-5. Protected Material
3 may only be filed under seal pursuant to a court order authorizing the sealing of
4 the specific Protected Material at issue. If a Party’s request to file Protected
5 Material under seal is denied by the court, then the Receiving Party may file the
6 information in the public record unless otherwise instructed by the court.
7 13. FINAL DISPOSITION
8 After the final disposition of this Action, as defined in paragraph 4, within
9 60 days of a written request by the Designating Party, each Receiving Party must
10 return all Protected Material to the Producing Party or destroy such material. As
11 used in this subdivision, “all Protected Material” includes all copies, abstracts,
12 compilations, summaries, and any other format reproducing or capturing any of
13 the Protected Material. Whether the Protected Material is returned or destroyed,
14 the Receiving Party must submit a written certification to the Producing Party
15 (and, if not the same person or entity, to the Designating Party) by the 60 day
16 deadline that (1) identifies (by category, where appropriate) all the Protected
17 Material that was returned or destroyed and (2) affirms that the Receiving Party
18 has not retained any copies, abstracts, compilations, summaries or any other
19 format reproducing or capturing any of the Protected Material. Notwithstanding
20 this provision, Counsel are entitled to retain an archival copy of all pleadings,
21 motion papers, trial, deposition, and hearing transcripts, legal memoranda,
22 correspondence, deposition and trial exhibits, expert reports, attorney work
23 product, and consultant and expert work product, even if such materials contain
24 Protected Material. Any such archival copies that contain or constitute Protected
25 Material remain subject to this Protective Order as set forth in Section 4
26 (DURATION).
27 //
1 14. VIOLATION
2 Any violation of this Order may be punished by appropriate measures
3 including, without limitation, contempt proceedings and/or monetary sanctions.
4
5 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
6
DATED: _1_2_/_9_/2_0_________ ____/_S_/_ C_H__A_R__L_E_S_ _F_. _E_I_C_K____________
7 HON. CHARLES F. EICK
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
4 _______________________ [print or type full address], declare under penalty of
5 perjury that I have read in its entirety and understand the Stipulated Protective
6 Order that was issued by the United States District Court for the Central District of
7 California on [date] in the case of Lyle Spruill v. County of Los Angeles, et al.,
8 Case Number 20-cv-07909 MCS (Ex).
9 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
12 promise that I will not disclose in any manner any information or item that is
13 subject to this Stipulated Protective Order to any person or entity except in strict
14 compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District
16 Court for the Central District of California for enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action.
19 I hereby appoint __________________________ [print or type full name] of
20 _______________________________________ [print or type full address and
21 telephone number] as my California agent for service of process in connection with
22 this action or any proceedings related to enforcement of this Stipulated Protective
23 Order.
24 Date: ______________________________________
25 City and State where sworn and signed: _________________________________
26 Printed name: _______________________________

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10039712. Public record. Not legal advice.