The opinion
1 | ANDREW BAUM - State Bar No. 190397
abaum @ elaserweil.com
2 | MICHAEL L. SMITH - State Bar No. 298917
msmith@ glaserweil-com
3 | GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
4 | 10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
5 | Telephone: (310) 553-3000
Facsimile: (310) 556-2920
Attorneys for Defendants
7 | County of Los Angeles, Los Angeles County Probation Department;
Deputy Probation Officer Ernest Walker; Deputy Probation Officer
8 || David Glasby: Deputy Probation Officer Jeffrey Eckler; and Deputy
Probation Officer/Deputy Services Officer Erin Walton
0 UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
1
| DOMINQUE ANDERSON; LELA CASE NO.: 2:21-cv-05966-MCS-JEM
‘oO DENNIS; DEBRRA CARR; EIONA
13 | FORD. aka ETONA BULLARD; Hon. Mark C. Scarsi
Ss FALLON RICHIE; CRYSTAL CHAVIS;
oO 14 | and SHAYPREA MOORE JEFFERSON,
n aka SHAYPREA MOORE, STIPULATED PROTECTIVE
15 Plaintiff ORDER
aintuT,
UO 16
V. TRIAL DATE: — January 24, 2023
17
COUNTY OF LOS ANGELES, LOS
18 | ANGELES COUNTY PROBATION
DEPARTMENT; LOS ANGELES
19 | COUNTY CHIEF PROBATION
OFFICER ROBERT TAYLOR;
20 | CRITTENTON SERVICES FOR
CHILDREN AND FAMILIES GROUP
21 | HOME; DEPUTY PROBATION
OFFICER ERNEST WALKER;
22 | DEPUTY PROBATION OFFICER
JEFFREY ECKLER; DEPUTY
23 | PROBATION OFFICER DAVID
GLASBY; DEPUTY PROBATION
24 | OFFICER/DEPUTY SERVICES
OFFICER SERRINA HART; DEPUTY
25 | PROBATION OFFICER/DEPUTY
SERVICES OFFICER ERIN WALTON;
26 | DEPUTY PROBATION
OFFICER/DEPUTY SERVICES
27 | OFFICER FNU NEWBELL; DEPUTY
PROBATION OFFICER FNU GOOD;
28 | DEPUTY PROBATION OFFICER FNU
1 | TUCKER; JOHN EVANS; OFFICER
FNU ISKANDER; OFFICER FNU
2 aR TINEZ: and DOES I through 100,
Defendants.
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Bos
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1 PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 | proprietary, or private information for which special protection from public disclosut
4 land from use for any purpose other than prosecuting this litigation may be warranted
5 | Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 | following Stipulated Protective Order. The parties acknowledge that this Order does
7 |not confer blanket protections on all disclosures or responses to discovery and that th
8 || protection it affords from public disclosure and use extends only to the limited
9 |information or items that are entitled to confidential treatment under the applicable
10 | legal principles. The parties further acknowledge, as set forth in Section XII(C),
11 | below, that this Stipulated Protective Order does not entitle them to file confidential
12 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
13 | followed and the standards that will be applied when a party seeks permission from
14 | the Court to file material under seal.
© 15 A. GOOD CAUSE STATEMENT
U 16 This action involves a lawsuit by former detainees and probationers who were
17 |juveniles at the time they were detained and/or on probation, and is therefore likely t
18 {involve issues and discovery regarding sensitive juvenile records for which special
19 | protection from public disclosure and from use for any purpose other than prosecutio
20 □□ this action is warranted. Additionally, this action involves claims against several
21 individual probation officers and will likely seek confidential personnel records for
22 |these employees. Such confidential and proprietary materials and information consis
23 of, among other things, medical records, psychological treatment records, criminal
24 records, including records that include sensitive third-party information, and
25 |/personnel records. Accordingly, to expedite the flow of information, to facilitate the
26 prompt resolution of disputes over confidentiality of discovery materials, to
27 adequately protect information the parties are entitled to keep confidential, to ensure
28 |that the parties are permitted reasonable necessary uses of such material in
1 | preparation for and in the conduct of trial, to address their handling at the end of the
2 |litigation, and serve the ends of justice, a protective order for such information is
3 ||justified in this matter. It is the intent of the parties that information will not be
4 |designated as confidential for tactical reasons and that nothing be so designated
5 || without a good faith belief that it has been maintained in a confidential, non-public
6 ||manner, and there is good cause why it should not be part of the public record of this
7 ||case.
8 B. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
9 SEAL
10 The parties further acknowledge, as set forth in Section 12.C, below, that this
11 | Stipulated Protective Order does not entitle them to file confidential information
Junder seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
13 standards that will be applied when a party seeks permission from the court to file
14 | material under seal.
6 15 There is a strong presumption that the public has a right of access to judicial
U 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, Inc
20 1187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require gooc
21 cause showing), and a specific showing of good cause or compelling reasons with
22 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 lof 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 Further, if a party requests sealing related to a dispositive motion or trial, then
1 |compelling reasons, not only good cause, for the sealing must be shown, and the reli
2 |sought shall be narrowly tailored to serve the specific interest to be protected. See
3 || Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each
4 litem or type of information, document, or thing sought to be filed or introduced unde
5 seal in connection with a dispositive motion or trial, the party seeking protection mus
6 |articulate compelling reasons, supported by specific facts and legal justification, for
7 |the requested sealing order. Again, competent evidence supporting the application to
8 ||file documents under seal must be provided by declaration.
9 Any document that is not confidential, privileged, or otherwise protectable in
10 its entirety will not be filed under seal if the confidential portions can be redacted. If
11 | documents can be redacted, then a redacted version for public viewing, omitting only
|the confidential, privileged, or otherwise protectable portions of the document, shall
13 |be filed. Any application that seeks to file documents under seal in their entirety
14 | should include an explanation of why redaction is not feasible.
© 15 {IL DEFINITIONS
UO 16 A. Action: The pending action, Dominique Anderson v. County of Los
17 | Angeles, et al. (Central District of California Case No. 2:21-cv-05966-MCS-JEM).
18 B. Challenging Party: A Party or Non-Party that challenges the designatio:
19 {of information or items under this Order.
20 C. “CONFIDENTIAL” Information or Items: Information (regardless of
21 | how it is generated, stored or maintained) or tangible things that qualify for protectio
22 Junder Federal Rule of Civil Procedure 26(c), and as specified above in the Good
23 | Cause Statement.
24 D. Counsel: Outside Counsel of Record, House Counsel (as well as their
25 support staff).
26 E. 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 F. Disclosure or Discovery Material: All items or information, regardless
2 |of 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 G. 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 H. House Counsel: Attorneys who are employees of a party to this Action.
9 |For Defendants, this includes Los Angeles County Counsel. House Counsel does no
10 include Outside Counsel of Record or any other outside counsel.
11 I. Non-Party: Any natural person, partnership, corporation, association, 01
Jother legal entity not named as a Party to this action.
13 J. Outside Counsel of Record: Attorneys who are not employees of a part
14 |'to this Action but are retained to represent or advise a party to this Action and have
6 15 | appeared in this Action on behalf of that party or are affiliated with a law firm which
UO 16 |has appeared on behalf of that party, and includes support staff.
17 K. 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 L. Producing Party: A Party or Non-Party that produces Disclosure or
21 | Discovery Material in this Action.
22 M. 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 □□□ their employees and subcontractors.
26 N. — Protected Material: Any Disclosure or Discovery Material that is
27 | designated as “CONFIDENTIAL.”
28 O. Receiving Party: A Party that receives Disclosure or Discovery Materia
1 from a Producing Party.
2/1. SCOPE
3 A. — The protections conferred by this Stipulation and Order cover not only
4 |Protected Material (as defined above), but also (1) any information copied or
5 extracted from Protected Material; (2) all copies, excerpts, summaries, or
6 compilations of Protected Material; and (3) any testimony, conversations, or
7 || presentations by Parties or their Counsel that might reveal Protected Material.
8 B. — Any use of Protected Material at trial shall be governed by the
9 lorders of the trial judge. This Order does not govern the use of Protected Material at
10 |{trial.
11 |IV. DURATION
2 Even after final disposition of this litigation, the confidentiality obligations
13 imposed by this Order shall remain in effect until a Designating Party agrees
14 | otherwise in writing or a court order otherwise directs. Final disposition shall be
6 15 |deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
UO 16 |or without prejudice; and (2) final judgment herein after the completion and
17 | exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
18 including the time limits for filing any motions or applications for extension of time
19 | pursuant to applicable law.
VV. DESIGNATING PROTECTED MATERIAL
21 A. Exercise of Restraint and Care in Designating Material for Protection
22 1. Each Party or Non-Party that designates information or items for
23 □ protection under this Order must take care to limit any such designation to specific
24 {material that qualifies under the appropriate standards. The Designating Party must
25 designate for protection only those parts of material, documents, items, or oral or
26 | written communications that qualify so that other portions of the material, document:
27 items, or communications for which protection is not warranted are not swept
28 Junjustifiably within the ambit of this Order.
l 2. Mass, indiscriminate, or routinized designations are prohibited.
2 |Designations that are shown to be clearly unjustified or that have been made for an
3 || improper purpose (e.g., to unnecessarily encumber the case development process or t
4 impose unnecessary expenses and burdens on other parties) may expose the
5 | Designating Party to sanctions.
6 3. If it comes to a Designating Party’s attention that information or
7 |items that it designated for protection do not qualify for protection, that Designating
8 |Party must promptly notify all other Parties that it is withdrawing the inapplicable
9 | designation.
10 B. Manner and Timing of Designations
11 1. Except as otherwise provided in this Order (see, e.g., Section
| V.B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or Discovery
13 | Material that qualifies for protection under this Order must be clearly so designated
14 | before the material is disclosed or produced.
6 15 2. Designation in conformity with this Order requires the following:
U 16 a. For information in documentary form (e.g., paper or
17 |electronic documents, but excluding transcripts of depositions or other pretrial or tria
18 | proceedings), that the Producing Party affix at a minimum, the legend
19 |“CONFIDENTIAL?” (hereinafter “CONFIDENTIAL legend”), to each page that
20 |contains protected material. If only a portion or portions of the material on a page
21 | qualifies for protection, the Producing Party also must clearly identify the protected
22 |portion(s) (e.g., by making appropriate markings in the margins).
23 b. A Party or Non-Party that makes original documents
24 available for inspection need not designate them for protection until after the
25 inspecting Party has indicated which documents it would like copied and produced.
26 | During the inspection and before the designation, all of the material made available
27 for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
28 identified the documents it wants copied and produced, the Producing Party must
1 | determine which documents, or portions thereof, qualify for protection under this
2 |Order. Then, before producing the specified documents, the Producing Party must
3 affix the “CONFIDENTIAL legend” to each page that contains Protected Material. ]
4 lonly a portion or portions of the material on a page qualifies for protection, the
5 |Producing Party also must clearly identify the protected portion(s) (e.g., by making
6 | appropriate markings in the margins).
7 C. For testimony given in depositions, that the Designating
8 |Party identify the Disclosure or Discovery Material on the record, before the close of
9 ||the deposition all protected testimony.
10 d. For information produced in form other than document and
11 □ □□□ any other tangible items, that the Producing Party affix in a prominent place on tk
|exterior of the container or containers in which the information is stored the legend
13 “CONFIDENTIAL.” If only a portion or portions of the information warrants
14 | protection, the Producing Party, to the extent practicable, shall identify the protected
6 15 | portion(s).
U 16 C. Inadvertent Failure to Designate
17 1. If timely corrected, an inadvertent failure to designate qualified
18 {information or items does not, standing alone, waive the Designating Party’s right to
19 |secure protection under this Order for such material. Upon timely correction of a
20 designation, the Receiving Party must make reasonable efforts to assure that the
21 |material is treated in accordance with the provisions of this Order.
22 |VI. CHALLENGING CONFIDENTIALITY DESIGNATIONS
23 A. — Timing of Challenges
24 1. Any party or Non-Party may challenge a designation of
25 {confidentiality at any time that is consistent with the Court’s Scheduling Order.
26 B. Meet and Confer
27 1. The Challenging Party shall initiate the dispute resolution process
28 |under Local Rule 37.1 et seq.
l C. — Any challenge submitted to the Court shall be via a joint stipulation
2 pursuant to Local Rule 37-2.
3 D. The burden of persuasion in any such challenge proceeding shall be on
4 |the Designating Party. Frivolous challenges, and those made for an improper purpos
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 jor 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 | VII. ACCESS TO AND USE OF PROTECTED MATERIAL
11 A. — Basic Principles
2 1. A Receiving Party may use Protected Material that is disclosed o1
13 | produced by another Party or by a Non-Party in connection with this Action only for
14 | prosecuting, defending, or attempting to settle this Action. Such Protected Material
6 15 |may be disclosed only to the categories of persons and under the conditions describe:
U 16 in this Order. When the Action has been terminated, a Receiving Party must comply
17 | with the provisions of Section XIII below (FINAL DISPOSITION).
18 2. Protected Material must be stored and maintained by a Receiving
19 |Party at a location and in a secure manner that ensures that access is limited to the
20 | persons authorized under this Order.
21 B. Disclosure of “CONFIDENTIAL” Information or Items
22 1. Unless otherwise ordered by the Court or permitted in writing by
23 the Designating Party, a Receiving Party may disclose any information or item
24 designated “CONFIDENTIAL” only to:
25 a. The Receiving Party’s Outside Counsel of Record in this
26 | Action, as well as employees of said Outside Counsel of Record to whom it is
27 |reasonably necessary to disclose the information for this Action;
28 b. | The officers, directors, and employees (including House
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1 |Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this
2 | Action;
3 c. Experts (as defined in this Order) of the Receiving Party to
4 |whom 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
9 |Professional Vendors to whom disclosure is reasonably necessary or this Action and
10 | who have signed the “Acknowledgment and Agreement to be Bound” attached as
11 | Exhibit A hereto;
2 g. The author or recipient of a document containing the
13 |information or a custodian or other person who otherwise possessed or knew the
14 information;
© 15 h. During their depositions, witnesses, and attorneys for
U 16 | witnesses, in the Action to whom disclosure is reasonably necessary provided: (1) the
17 |deposing party requests that the witness sign the “Acknowledgment and Agreement 1
18 |Be Bound;” and (ii) they will not be permitted to keep any confidential information
19 | unless they sign the “Acknowledgment and Agreement to Be Bound,” unless
20 otherwise agreed by the Designating Party or ordered by the Court. Pages of
21 |transcribed deposition testimony or exhibits to depositions that reveal Protected
22 | Material may be separately bound by the court reporter and may not be disclosed to
23 anyone except as permitted under this Stipulated Protective Order; and
24 i. Any mediator or settlement officer, and their supporting
25 |personnel, mutually agreed upon by any of the parties engaged in settlement
26 || discussions.
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1 | VOI. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCE
2 IN OTHER LITIGATION
3 A. — Ifa Party is served with a subpoena or a court order issued in other
4 litigation that compels disclosure of any information or items designated in this
5 | Action as “CONFIDENTIAL,” that Party must:
6 1. Promptly notify in writing the Designating Party. Such
7 |notification shall include a copy of the subpoena or court order;
8 2. Promptly notify in writing the party who caused the subpoena or
9 lorder to issue in the other litigation that some or all of the material covered by the
10 subpoena or order is subject to this Protective Order. Such notification shall include
11 copy of this Stipulated Protective Order; and
2 3. Cooperate with respect to all reasonable procedures sought to be
13 | pursued by the Designating Party whose Protected Material may be affected.
14 B. If the Designating Party timely seeks a protective order, the Party servec
6 15 | with the subpoena or court order shall not produce any information designated in this
U 16 action as “CONFIDENTIAL” before a determination by the Court from which the
17 |subpoena or order issued, unless the Party has obtained the Designating Party’s
18 |permission. The Designating Party shall bear the burden and expense of seeking
19 | protection in that court of its confidential material and nothing in these provisions
20 should be construed as authorizing or encouraging a Receiving Party in this Action tc
21 |disobey a lawful directive from another court.
22 □ □□□ A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
23 PRODUCED IN THIS LITIGATION
24 A. — The terms of this Order are applicable to information produced by a
25 |Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
26 | produced by Non-Parties in connection with this litigation is protected by the
27 |remedies and relief provided by this Order. Nothing in these provisions should be
28 |construed as prohibiting a Non-Party from seeking additional protections.
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l B. — In the event that a Party is required, by a valid discovery request, to
2 □ produce a Non-Party’s confidential information in its possession, and the Party is
3 ||subject to an agreement with the Non-Party not to produce the Non-Party’s
4 |confidential information, then the Party shall:
5 1. Promptly notify in writing the Requesting Party and the Non-Part
6 that some or all of the information requested is subject to a confidentiality agreement
7 | with a Non-Party;
8 2. Promptly provide the Non-Party with a copy of the Stipulated
9 |Protective Order in this Action, the relevant discovery request(s), and a reasonably
10 ||specific description of the information requested; and
11 3. Make the information requested available for inspection by the
| Non-Party, if requested.
13 C. — Ifthe Non-Party fails to seek a protective order from this court within 1-
14 days of receiving the notice and accompanying information, the Receiving Party may
6 15 | produce the Non-Party’s confidential information responsive to the discovery reques
U 16 If the Non-Party timely seeks a protective order, the Receiving Party shall not
17 | produce any information in its possession or control that is subject to the
18 {confidentiality agreement with the Non-Party before a determination by the court.
19 | Absent a court order to the contrary, the Non-Party shall bear the burden and expens«
20 |of seeking protection in this court of its Protected Material.
21 |X. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22 A. — Ifa Receiving Party learns that, by inadvertence or otherwise, it has
23 |disclosed Protected Material to any person or in any circumstance not authorized
24 |under this Stipulated Protective Order, the Receiving Party must immediately (1)
25 |notify in writing the Designating Party of the unauthorized disclosures, (2) use its be:
26 efforts to retrieve all unauthorized copies of the Protected Material, (3) inform the
27 person or persons to whom unauthorized disclosures were made of all the terms of
28 this Order, and (4) request such person or persons to execute the “Acknowledgment
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1 |and Agreement to be Bound” that is attached hereto as Exhibit A.
2 |XI. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
3 PROTECTED MATERIAL
4 A. | When a Producing Party gives notice to Receiving Parties that certain
5 inadvertently produced material is subject to a claim of privilege or other protection,
6 ||the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
7 |Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
8 ||may be established in an e-discovery order that provides for production without prio
9 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
10 | parties reach an agreement on the effect of disclosure of a communication or
11 |information covered by the attorney-client privilege or work product protection, the
12 |parties may incorporate their agreement in the Stipulated Protective Order submitted
13 the Court.
5 14 MISCELLANEOUS
6 15 A. Right to Further Relief
U 16 1. Nothing in this Order abridges the right of any person to
17 | seek its modification by the Court in the future.
18 B. Right to Assert Other Objections
19 1. By stipulating to the entry of this Protective Order, no Party
20 | waives any right it otherwise would have to object to disclosing or producing any
21 |information or item on any ground not addressed in this Stipulated Protective Order.
22 |Similarly, no Party waives any right to object on any ground to use in evidence of an
23 {of the material covered by this Protective Order.
24 C. Filing Protected Material
25 1. A Party that seeks to file any Protected Material must comply wit
26 |Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a
27 |court order authorizing the sealing of the specific Protected Material at issue. Ifa
28 || Party's request to file Protected Material under seal is denied by the Court, then the
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1 Receiving Party may file the information in the public record unless otherwise
2 |instructed by the Court.
3 | FINAL DISPOSITION
4 A. After the final disposition of this Action, as defined in Section V, within
5 |s1xty (60) days of a written request by the Designating Party, each Receiving Party
6 ||must return all Protected Material to the Producing Party or destroy such material. A
7 used in this subdivision, “all Protected Material” includes all copies, abstracts,
8 |;compilations, summaries, and any other format reproducing or capturing any of the
9 |Protected Material. Whether the Protected Material is returned or destroyed, the
10 | Receiving Party must submit a written certification to the Producing Party (and, if no
11 ||the same person or entity, to the Designating Party) by the 60 day deadline that (1)
|identifies (by category, where appropriate) all the Protected Material that was
13 | returned or destroyed and (2) affirms that the Receiving Party has not retained any
14 | copies, abstracts, compilations, summaries or any other format reproducing or
6 15 capturing any of the Protected Material. Notwithstanding this provision, Counsel are
UO 16 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
17 | and hearing transcripts, legal memoranda, correspondence, deposition and trial
18 |exhibits, expert reports, attorney work product, and consultant and expert work
19 | product, even if such materials contain Protected Material. Any such archival copies
20 that contain or constitute Protected Material remain subject to this Protective Order a
21 |set forth in Section TV (DURATION).
22 B. — Any violation of this Order may be punished by any and all appropriate
23 |measures including, without limitation, contempt proceedings and/or monetary
24 sanctions.
25 IT IS SO STIPULATED
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DATED: November 23, 2021 LAW OFFICES OF JUSTIN H. KING
3
By:_/s/ Justin H. King
4 JUSTIN H. KING
Attorneys for Plaintiffs
5 Dominique Anderson, Lela Dennis, Debr:
Carr, Eiona Ford, aka Eiona Bullard, Fall
6 Richie, Crystal Chavis, and Shayprea
Moore Jefferson, aka Shayprea Moore
8
. GLASER WEIL FINK HOWARD
5 DATED: November 23, 2021 AVCHEN & SHAPIRO Lip
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11 By:_/s/ Andrew Baum
ANDREW BAUM
12 MICHAEL L. SMITH
Attorneys for Defendants
OV 13 County of Los Angeles, Los Angeles
= County Probation Department; eputy
14 Probation Officer Ernest Walker; Deputy
Probation Officer David Glasby; Deputy
co 15 Probation Officer Jeffrey Eckler; an
rh Deputy Probation Officer/Deputy Service
UO 16 Officer Erin Walton
17 | DATED: November 23, 2021 LYNBERG & WATKINS
18 By:_/s/ Michael J. Larin
19 MICHAEL J. LARIN
PHILLIP M. HAYES
50 Attorneys for Defendant __
Crittenton Services for Children and
Families Group Home
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| DATED: November 23, 2021 HUPRICH | VEGA, ATTORNEYS AT LAW
24 By:_/s/ Joseph Huprich
35 JOSEPH HUPRICH
Attorneys for Defendant
26 John Evans
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' [FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
3 |IDated: 11/24/2021
; [HONORABLE JOHN E. MCDERMOTT
, United States Magistrate Judge
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I EXHIBIT A
> ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, , of , declare unde
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penalty of perjury that I have read in its entirety and understand the Stipulated
6 | Protective Order that was issued by the United States District Court for the Central
7 {District of California on in the case Dominique Anderson v. County o
Los Angeles, et al. (Case No. 2:21-cv-05966-MCS-JEM). I agree to comply with anc
19 | to be bound by all the terms of this Stipulated Protective Order and I understand and
acknowledge that failure to so comply could expose me to sanctions and punishment
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in the nature of contempt. I solemnly promise that I will not disclose in any manner
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14 any information or item that is subject to this Stipulated Protective Order to any
VY)
1S person or entity except in strict compliance with the provisions of this Order.
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4 I agree to submit to the jurisdiction of the United States District Court for the
ig |Central District of California for the purpose of enforcing the terms of this Stipulated
'? Protective Order, even if such enforcement proceedings occur after termination of thi
20
action. I hereby appoint of é
22 California agent for service of process in connection with this action or any
proceedings related to enforcement of this Stipulated Protective Order.
24
Date:
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26 ||City and State where sworn and signed:
27 |:
Printed Name: Signature:
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