# Creative Intellects Inc. v. Patrick Haygood

> District Court, C.D. California · August 24, 2021

URL: https://www.frixlaw.com/law-library/cases/10041696

## Case

- **Court:** District Court, C.D. California
- **Decided:** August 24, 2021
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 bbailey@leaderberkon.com
STEPHANIE L. GASE (pro hac vice)
2 sgase@leaderberkon.com
DANIEL A. JOHNSON (pro hac vice)
3 djohnson@leaderberkon.com
LEADER BERKON COLAO & SILVERSTEIN LLP
4 550 South Hope Street, Suite 1850
Los Angeles, CA 90071
5 Telephone: (213) 234-1750
Facsimile: (213) 234-1747
6
Attorneys for Plaintiffs
7 Creative Intellects Inc. and Intellects Capital LLC

8
UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA

10
CREATIVE INTELLECTS INC. and Civil Action No. 2:21-cv-02670-RGK-AFM
11 INTELLECTS CAPITAL LLC,
Individually and Derivatively on
12
Behalf of Nominal Defendants
13 ATLANTIC CROSS EQUIPMENT,
LLC and A.X.E., LLC,
14

15 Plaintiffs, STIPULATED [PROPOSED]
PROTECTIVE ORDER1
16
vs.
17
PATRICK HAYGOOD, ROBERT
18
THOMPSON, TRACEY RENEE
19 MCKINNEY, RESERVATION
LAND MANAGEMENT (A
20
PROFESSIONAL CORPORATION),
21 and SABINE HOLDINGS, LLC,

22
Defendants,
23
and
24

25 ATLANTIC CROSS EQUIPMENT,
LLC, and A.X.E., LLC,
26
27
28
1 This Stipulated Protective Order is based substantially on the model protective
1 Nominal Defendants.
2
PATRICK HAYGOOD, TRACEY
3
RENEE MCKINNEY,
4 RESERVATION LAND
MANAGEMENT, ATLANTIC
5
CROSS EQUIPMENT, LLC, AND
6 A.X.E., LLC

7
Counter-Claim Plaintiffs,
8
vs.
9

10 CREATIVE INTELLECTS INC. and
INTELLECTS CAPITAL LLC, a
11
limited liability company; HATEL
12 BHAKTA, an individual person;
MITESH SOLANKI, an individual
13
person; ERIC TABARY, an
14 individual person,

15
Counter-Claim Defendants.
16
17
18 1 A. PURPOSES AND LIMITATIONS
19 Discovery in this action is likely to involve production of confidential,
20 proprietary or private information for which special protection from public
21 disclosure and from use for any purpose other than prosecuting this litigation may
22 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
23 enter the following Stipulated Protective Order. The parties acknowledge that this
24 Order does not confer blanket protections on all disclosures or responses to
25 discovery and that the protection it affords from public disclosure and use extends
26 only to the limited information or items that are entitled to confidential treatment
27 under the applicable legal principles.
28
1 B. GOOD CAUSE STATEMENT
2 This action is likely to involve personal and business financial information for
3 which special protection from public disclosure and from use for any purpose other
4 than prosecution of this action is warranted. Such confidential and proprietary
5 materials and information consist of, among other things, confidential personal or
6 business financial information, such as bank statements or other financial records,
7 and information otherwise generally unavailable to the public, or which may be
8 privileged or otherwise protected from disclosure under state or federal statutes,
9 court rules, case decisions, or common law. Accordingly, to expedite the flow of
10 information, to facilitate the prompt resolution of disputes over confidentiality of
11 discovery materials, to adequately protect information the parties are entitled to keep
12 confidential, to ensure that the parties are permitted reasonable necessary uses of
13 such material in preparation for and in the conduct of trial, to address their handling
14 at the end of the litigation, and serve the ends of justice, a protective order for such
15 information is justified in this matter. It is the intent of the parties that information
16 will not be designated as confidential for tactical reasons and that nothing be so
17 designated without a good faith belief that it has been maintained in a confidential,
18 non-public manner, and there is good cause why it should not be part of the public
19 record of this case.
20 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
21 SEAL
22 The parties further acknowledge, as set forth in Section 12.3, below, that this
23 Stipulated Protective Order does not entitle them to file confidential information
24 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
25 and the standards that will be applied when a party seeks permission from the court
26 to file material under seal.
27 There is a strong presumption that the public has a right of access to judicial
28 proceedings and records in civil cases. In connection with non-dispositive motions,
1 good cause must be shown to support a filing under seal. See Kamakana v. City and
2 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
3 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
4 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
5 good cause showing), and a specific showing of good cause or compelling reasons
6 with proper evidentiary support and legal justification, must be made with respect to
7 Protected Material that a party seeks to file under seal. The parties’ mere designation
8 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the
9 submission of competent evidence by declaration, establishing that the material
10 sought to be filed under seal qualifies as confidential, privileged, or otherwise
11 protectable—constitute good cause.
12 Further, if a party requests sealing related to a dispositive motion or trial, then
13 compelling reasons, not only good cause, for the sealing must be shown, and the
14 relief sought shall be narrowly tailored to serve the specific interest to be protected.
15 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For
16 each item or type of information, document, or thing sought to be filed or introduced
17 under seal in connection with a dispositive motion or trial, the party seeking
18 protection must articulate compelling reasons, supported by specific facts and legal
19 justification, for the requested sealing order. Again, competent evidence supporting
20 the application to file documents under seal must be provided by declaration.
21 Any document that is not confidential, privileged, or otherwise protectable in
22 its entirety will not be filed under seal if the confidential portions can be redacted.
23 If documents can be redacted, then a redacted version for public viewing, omitting
24 only the confidential, privileged, or otherwise protectable portions of the document,
25 shall be filed. Any application that seeks to file documents under seal in their
26 entirety should include an explanation of why redaction is not feasible.
27 2. DEFINITIONS
28
1 2.1 Action: Creative Intellects Inc., et al v. Patrick Haygood, et al, Case
2 No. 2:21-cv-02670-RGK-AFM.
3 2.2 Challenging Party: a Party or Non-Party that challenges the
4 designation of information or items under this Order.
5 2.3 “CONFIDENTIAL” Information or Items: information (regardless
6 of how it is generated, stored or maintained) or tangible things that qualify for
7 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
8 the Good Cause Statement.
9 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
10 their support staff).
11 2.5 Designating Party: a Party or Non-Party that designates information or
12 items that it produces in disclosures or in responses to discovery as
13 “CONFIDENTIAL.”
14 2.6 Disclosure or Discovery Material: all items or information, regardless
15 of the medium or manner in which it is generated, stored, or maintained (including,
16 among other things, testimony, transcripts, and tangible things), that are produced or
17 generated in disclosures or responses to discovery in this matter.
18 2.7 Expert: a person with specialized knowledge or experience in a matter
19 pertinent to the litigation who has been retained by a Party or its counsel to serve as
20 an expert witness or as a consultant in this Action.
21 2.8 House Counsel: attorneys who are employees of a party to this Action.
22 House Counsel does not include Outside Counsel of Record or any other outside
23 counsel.
24 2.9 Non-Party: any natural person, partnership, corporation, association or
25 other legal entity not named as a Party to this action.
26 2.10 Outside Counsel of Record: attorneys who are not employees of a party
27 to this Action but are retained to represent or advise a party to this Action and have
28
1 appeared in this Action on behalf of that party or are affiliated with a law firm that
2 has appeared on behalf of that party, and includes support staff.
3 2.11 Party: any party to this Action, including all of its officers, directors,
4 employees, consultants, retained experts, and Outside Counsel of Record (and their
5 support staffs).
6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
7 Discovery Material in this Action.
8 2.13 Professional Vendors: persons or entities that provide litigation support
9 services (e.g., photocopying, videotaping, translating, preparing exhibits or
10 demonstrations, and organizing, storing, or retrieving data in any form or medium)
11 and their employees and subcontractors.
12 2.14 Protected Material: any Disclosure or Discovery Material that is
13 designated as “CONFIDENTIAL.”
14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
15 from a Producing Party.
16 3. SCOPE
17 The protections conferred by this Stipulation and Order cover not only
18 Protected Material (as defined above), but also (1) any information copied or
19 extracted from Protected Material; (2) all copies, excerpts summaries, or
20 compilations of Protected Material; and (3) any testimony, conversations, or
21 presentations by Parties or their Counsel that might reveal Protected Material.
22 Any use of Protected Material at trial shall be governed by the orders of the
23 trial judge. This Order does not govern the use of Protected Material at trial.
24 4. DURATION
25 Once a case proceeds to trial, information that was designated as
26 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
27 as an exhibit at trial becomes public and will be presumptively available to all
28 members of the public, including the press, unless compelling reasons supported by
1 specific factual findings to proceed otherwise are made to the trial judge in advance
2 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
3 showing for sealing documents produced in discovery from “compelling reasons”
4 standard when merits-related documents are part of court record). Accordingly, the
5 terms of this protective order do not extend beyond the commencement of the trial.
6 5. DESIGNATING PROTECTED MATERIAL
7 5.1 Exercise of Restraint and Care in Designating Material for Protection.
8 Each Party or Non-Party that designates information or items for protection under
9 this Order must take care to limit any such designation to specific material that
10 qualifies under the appropriate standards. The Designating Party must designate for
11 protection only those parts of material, documents, items or oral or written
12 communications that qualify so that other portions of the material, documents, items
13 or communications for which protection is not warranted are not swept unjustifiably
14 within the ambit of this Order.
15 Mass, indiscriminate or routinized designations are prohibited. Designations
16 that are shown to be clearly unjustified or that have been made for an improper
17 purpose (e.g., to unnecessarily encumber the case development process or to impose
18 unnecessary expenses and burdens on other parties) may expose the Designating
19 Party to sanctions.
20 If it comes to a Designating Party’s attention that information or items that it
21 designated for protection do not qualify for protection, that Designating Party must
22 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.
28 Designation in conformity with this Order requires:
1 (a) for information in documentary form (e.g., paper or electronic
2 documents, but excluding transcripts of depositions or other pretrial or trial
3 proceedings), that the Producing Party affix at a minimum, the legend
4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
5 contains protected material. If only a portion of the material on a page qualifies for
6 protection, the Producing Party also must clearly identify the protected portion(s)
7 (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
11 before the designation, all of the material made available for inspection shall be
12 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
13 documents it wants copied and produced, the Producing Party must determine which
14 documents, or portions thereof, qualify for protection under this Order. Then, before
15 producing the specified documents, the Producing Party must affix the
16 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
17 portion of the material on a page qualifies for protection, the Producing Party also
18 must clearly identify the protected portion(s) (e.g., by making appropriate markings
19 in the margins).
20 (b) for testimony given in depositions that the Designating Party
21 identifies the Disclosure or Discovery Material on the record, before the close of the
22 deposition all protected testimony.
23 (c) for information produced in some form other than documentary
24 and for any other tangible items, that the Producing Party affix in a prominent place
25 on the exterior of the container or containers in which the information is stored the
26 legend “CONFIDENTIAL.” If only a portion or portions of the information
27 warrants protection, the Producing Party, to the extent practicable, shall identify the
28 protected 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
3 the 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
5 efforts to assure that the material is treated in accordance with the provisions of this
6 Order.
7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
9 designation of confidentiality at any time that is consistent with the Court’s
10 Scheduling Order.
11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
12 resolution process under Local Rule 37-1 et seq.
13 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
14 joint stipulation pursuant to Local Rule 37-2.
15 6.4 The burden of persuasion in any such challenge proceeding shall be on
16 the Designating Party. Frivolous challenges, and those made for an improper
17 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
18 parties) may expose the Challenging Party to sanctions. Unless the Designating
19 Party has waived or withdrawn the confidentiality designation, all parties shall
20 continue to afford the material in question the level of protection to which it is
21 entitled under the Producing Party’s designation until the Court rules on the
22 challenge.
23 7. ACCESS TO AND USE OF PROTECTED MATERIAL
24 7.1 Basic Principles. A Receiving Party may use Protected Material that is
25 disclosed or produced by another Party or by a Non-Party in connection with this
26 Action only for prosecuting, defending or attempting to settle this Action. Such
27 Protected Material may be disclosed only to the categories of persons and under the
28 conditions described in this Order. When the Action has been terminated, a
1 Receiving Party must comply with the provisions of section 13 below (FINAL
2 DISPOSITION).
3 Protected Material must be stored and maintained by a Receiving Party at a
4 location and in a secure manner that ensures that access is limited to the persons
5 authorized under this Order.
6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
7 otherwise ordered by the court or permitted in writing by the Designating Party, a
8 Receiving Party may disclose any information or item designated
9 “CONFIDENTIAL” only to:
10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
11 well as employees of said Outside Counsel of Record to whom it is reasonably
12 necessary to disclose the information for this Action;
13 (b) the officers, directors, and employees (including House Counsel) of
14 the Receiving Party to whom disclosure is reasonably necessary for this Action;
15 (c) Experts (as defined in this Order) of the Receiving Party to whom
16 disclosure is reasonably necessary for this Action and who have signed the
17 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
18 (d) the court and its personnel;
19 (e) court reporters and their staff;
20 (f) professional jury or trial consultants, mock jurors, and Professional
21 Vendors to whom disclosure is reasonably necessary for this Action and who have
22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) the
23 author or recipient of a document containing the information or a custodian or other
24 person who otherwise possessed or knew the information; (h) during their
25 depositions, witnesses, and attorneys for witnesses, in the Action to whom disclosure
26 is reasonably necessary provided: (1) the deposing party requests that the witness
27 sign the form attached as Exhibit 1 hereto; and (2) they will not be permitted to keep
28 any confidential information unless they sign the “Acknowledgment and Agreement
1 to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
2 ordered by the court. Pages of transcribed deposition testimony or exhibits to
3 depositions that reveal Protected Material may be separately bound by the court
4 reporter and may not be disclosed to anyone except as permitted under this Stipulated
5 Protective Order; and (i) any mediator or settlement officer, and their supporting
6 personnel, mutually agreed upon by any of the parties engaged in settlement
7 discussions.
8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
9 IN OTHER LITIGATION
10 If a Party is served with a subpoena or a court order issued in other litigation
11 that compels disclosure of any information or items designated in this Action as
12 “CONFIDENTIAL,” that Party must:
13 (a) promptly notify in writing the Designating Party. Such notification
14 shall include a copy of the subpoena or court order;
15 (b) promptly notify in writing the party who caused the subpoena or
16 order to issue in the other litigation that some or all of the material covered by the
17 subpoena or order is subject to this Protective Order. Such notification shall include
18 a copy of this Stipulated Protective Order; and
19 (c) cooperate with respect to all reasonable procedures sought to be
20 pursued by the Designating Party whose Protected Material may be affected. If the
21 Designating Party timely seeks a protective order, the Party served with the
22 subpoena or court order shall not produce any information designated in this action
23 as “CONFIDENTIAL” before a determination by the court from which the subpoena
24 or order issued, unless the Party has obtained the Designating Party’s permission.
25 The Designating Party shall bear the burden and expense of seeking protection in
26 that court of its confidential material and nothing in these provisions should be
27 construed as authorizing or encouraging a Receiving Party in this Action to disobey
28 a lawful directive from another court.
1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by a Non-
4 Party in this Action and designated as “CONFIDENTIAL.” Such information
5 produced by Non-Parties in connection with this litigation is protected by the
6 remedies and relief provided by this Order. Nothing in these provisions should be
7 construed as prohibiting a Non-Party from seeking additional protections.
8 (b) In the event that a Party is required, by a valid discovery request, to
9 produce a Non-Party’s confidential information in its possession, and the Party is
10 subject to an agreement with the Non-Party not to produce the Non-Party’s
11 confidential information, then the Party shall:
12 (1) promptly notify in writing the Requesting Party and the Non-Party
13 that some or all of the information requested is subject to a confidentiality agreement
14 with a Non-Party;
15 (2) promptly provide the Non-Party with a copy of the Stipulated
16 Protective Order in this Action, the relevant discovery request(s), and a reasonably
17 specific description of the information requested; and
18 (3) make the information requested available for inspection by the Non-
19 Party, if requested.
20 (c) If the Non-Party fails to seek a protective order from this court within 14
21 days of receiving the notice and accompanying information, the Receiving Party
22 may produce the Non-Party’s confidential information responsive to the discovery
23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
24 not produce any information in its possession or control that is subject to the
25 confidentiality agreement with the Non-Party before a determination by the court.
26 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
27 of seeking protection in this court of its Protected Material.
28 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
1 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
2 Protected Material to any person or in any circumstance not authorized under this
3 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
4 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
5 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
6 or persons to whom unauthorized disclosures were made of all the terms of this
7 Order, and (d) request such person or persons to execute the “Acknowledgment and
8 Agreement to Be Bound” that is attached hereto as Exhibit A.
9 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
10 PROTECTED MATERIAL
11 When a Producing Party gives notice to Receiving Parties that certain
12 inadvertently produced material is subject to a claim of privilege or other protection,
13 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
14 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
15 may be established in an e-discovery order that provides for production without prior
16 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as
17 the parties reach an agreement on the effect of disclosure of a communication or
18 information covered by the attorney-client privilege or work product protection, the
19 parties may incorporate their agreement in the stipulated protective order submitted
20 to the court.
21 12. MISCELLANEOUS
22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
23 person to seek its modification by the Court in the future.
24 12.2 Right to Assert Other Objections. By stipulating to the entry of this
25 Protective Order, no Party waives any right it otherwise would have to object to
26 disclosing or producing any information or item on any ground not addressed in this
27 Stipulated Protective Order. Similarly, no Party waives any right to object on any
28 ground to use in evidence of any of the material covered by this Protective 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 may
3 only be filed under seal pursuant to a court order authorizing the sealing of the
4 specific Protected Material at issue. If a Party’s request to file Protected Material
5 under seal is denied by the court, then the Receiving Party may file the information
6 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 60
9 days of a written request by the Designating Party, each Receiving Party must return
10 all Protected Material to the Producing Party or destroy such material. As used in
11 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
12 summaries, and any other format reproducing or capturing any of the Protected
13 Material. Whether the Protected Material is returned or destroyed, the Receiving
14 Party must submit a written certification to the Producing Party (and, if not the same
15 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
16 (by category, where appropriate) all the Protected Material that was returned or
17 destroyed and (2) affirms that the Receiving Party has not retained any copies,
18 abstracts, compilations, summaries or any other format reproducing or capturing any
19 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
20 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
21 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
22 reports, attorney work product, and consultant and expert work product, even if such
23 materials contain Protected Material. Any such archival copies that contain or
24 constitute Protected Material remain subject to this Protective Order as set forth in
25 Section 4 (DURATION).
26 14. VIOLATION
27 Any violation of this Order may be punished by appropriate measures
28 including, without limitation, contempt proceedings and/or monetary sanctions.
1
2 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
3
Dated: August 23, 2021 LEADER BERKON COLAO & SILVERSTEIN LLP
4
5 By: /s/ Stephanie L. Gase
Bobbie R. Bailey
6 Stephanie L. Gase (pro hac vice)
7 Daniel A. Johnson (pro hac vice)
8117 Preston Road, Suite 300
8 Dallas, Texas 75225
9 Telephone: (469) 482-5227
Facsimile: (212) 486-3099
10 Email: sgase@leaderberkon.com
11 Email: bbailey@leaderberkon.com
Email: djohnson@leaderberkon.com
12
13 Attorneys for Plaintiffs
Creative Intellects Inc. and
14 Intellects Capital LLC
15
16 Dated: August 23, 2021 THE ACADIANA LAW FIRM, LLC

17
18 By: /s/ Thomas Ainsworth Robichaux
Thomas Ainsworth Robichaux (pro hac vice)
19 1317 Milan Street
20 New Orleans, LA 70115
Telephone: (504) 605-0610
21 Facsimile: (504) 605-0620
22 Email: thomasrobichauxlaw@gmail.com

23 AND
24
Kevin J. Grochow
25
KUTAK ROCK LLP
26 5 Park Plaza, Suite 1500
Irvine, CA 92614
27
Telephone: (949) 417-0999
28 Facsimile: (949) 417-5394
Attorneys for Defendants Patrick Haygood,
2 Tracey Renee McKinney, Reservation Land
3 Management, A.X.E., LLC, and Atlantic Cross
Equipment, LLC
5
All signatories listed, and on whose behalf the filing is submitted, concur in the
6 || filing’s content and have authorized the filing.
IT IS SO ORDERED.
g || Dated: August 24, 2021 .
fo...
11
Alexander F. MacKinnon
12 United States Magistrate Judge
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14

1
EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
I, _____________________________, of _________________, declare
4
under penalty of perjury that I have read in its entirety and understand the Stipulated
5
Protective Order that was issued by the United States District Court for the Central
6
District of California on [date] in the case of Creative Intellects Inc., et al v. Patrick
7
Haygood, et al, Case No. 2:21-cv-02670-RGK-AFM. I agree to comply with and to
8
be bound by all the terms of this Stipulated Protective Order and I understand and
9
acknowledge that failure to so comply could expose me to sanctions and punishment
10
in the nature of contempt. I solemnly promise that I will not disclose in any manner
11
any information or item that is subject to this Stipulated Protective Order to any
12
person or entity except in strict compliance with the provisions of this Order. I
13
further agree to submit to the jurisdiction of the United States District Court for the
14
Central District of California for enforcing the terms of this Stipulated Protective
15
Order, even if such enforcement proceedings occur after termination of this action.
16
I hereby appoint __________________________ of
17
_______________________________________ [print or type full address and
18
telephone number] as my California agent for service of process in connection with
19
this action or any proceedings related to enforcement of this Stipulated Protective
20
Order.
21

22
Date: ______________________________________
23
City and State where sworn and signed: _________________________________
24

25
Printed name: _______________________________
26

27
Signature: __________________________________
28

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10041696. Public record. Not legal advice.