# Todd v. Dilda

> District Court, E.D. California · August 24, 2023

URL: https://www.frixlaw.com/law-library/cases/10055152

## Case

- **Court:** District Court, E.D. California
- **Decided:** August 24, 2023
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

ALESHIRE & WYNDER, LLP
1 MARTIN KOCZANOWICZ, State Bar No. 128290
mkoczanowicz@awattorneys.com
2 GLEN E. TUCKER, State Bar No. 54709
gtucker@awattorneys.com
3 JOHN FOX, State Bar No. 171426
JFox@awattorneys.com
4 JOSHUA IMERI-GARCIA, State Bar No. 346901
jimerigarcia@awattorneys.com
5 3701 Wilshire Blvd., Suite 725
Los Angeles, California 90010
6 Telephone: (310) 527-6660
Facsimile: (949) 223-1180
7
Attorneys for Defendants, OFFICER
8 NICHOLAUS D. DILDA and CITY OF
RIDGECREST
9

10 LAW OFFICE OF JOSEPH D. BUSSONE
JOSEPH D. BUSSONE, State Bar No. 108168
11 jdb@bussonelaw.com
4208 Cactus Street, Suite B
12 Lake Isabella, California 93240
Telephone: (760) 531-3191
13 Facsimile: (760) 531-3192

14 Attorney for Plaintiff, STEVE J. TODD

15 UNITED STATES DISTRICT COURT
16 EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION
17
18 STEVE J. TODD, Case No. 1:23-cv-00913-ADA-CBD

19 Plaintiff, Assigned to:
Hon. Ana de Alba, Ctrm. 1
20 v.
[PROPOSED] STIPULATED
21 NICHOLAUS D. DILDA; CITY OF PROTECTIVE ORDER
RIDGECREST; and DOES 1 - 10,
22
Defendants.
23

24
25 / / /
26
/ / /
27
1 IT IS HEREBY STIPULATED, by and between Plaintiff STEVEN A.
2 TODD (“Plaintiff”), on the one hand, and Defendants CITY OF RIDGECREST
3 AND NICHOLAS DILDA( (“Defendants”), on the other hand, by and through their
4 respective counsel of record, that the following Stipulated Protective Order (the
5 “Protective Order”) may be entered by the Court:
6 1. A. PURPOSES AND LIMITATIONS
7 Discovery in this action is likely to involve production of confidential,
8 proprietary or private information for which special protection from public
9 disclosure and from use for any purpose other than prosecuting this litigation may
10 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
11 enter the following Stipulated Protective Order. The parties acknowledge that this
12 Order does not confer blanket protections on all disclosures or responses to
13 discovery and that the protection it affords from public disclosure and use extends
14 only to the limited information or items that are entitled to confidential treatment
15 under the applicable legal principles.
16 B. GOOD CAUSE STATEMENT
17 This action is likely to involve materials and information that were acquired
18 in confidence by public employees in the course of their duties and have not been
19 officially disclosed or made open or available to the public. Such confidential
20 materials and information consist of, among other things: (1) confidential police
21 personnel files and accompanying materials maintained by the City of Ridgecrest
22 Police Department; (2) law enforcement investigative reports and records which
23 may contain personal contact information of third party witnesses; (3) information
24 otherwise generally unavailable to the public, or which may be privileged or
25 otherwise protected from disclosure under state or federal statues, court rules, case
26 decisions, or common law. Defendants contend that individual officers have an
27 interest in protecting their own privacy rights to information in their personnel files
1 Accordingly, to expedite the flow of information, to facilitate the prompt
2 resolution of disputes over confidentiality of discovery materials, to adequately
3 protect information the parties are entitled to keep confidential, to ensure that the
4 parties are permitted reasonably necessary uses of such material in preparation for
5 and in the conduct of trial, to address their handling at the end of the litigation, and
6 serve the ends of justice, a protective order for such information is justified in this
7 matter. It is the intent of the parties that information will not be designated as
8 confidential for tactical reasons and that nothing be so designated without a good
9 faith belief that it has been maintained in a confidential, non-public manner, and
10 there is good cause why it should not be part of the public record of this case.
11 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
12 The parties further acknowledge, as set forth in Section 12.3, below, that this
13 Stipulated Protective Order does not entitle them to file confidential information
14 under seal; Local Civil Rule 141et seq. sets forth the procedures that must be
15 followed and the standards that will be applied when a party seeks permission from
16 the court to file material under seal.
17 There is a strong presumption that the public has a right of access to judicial
18 proceedings and records in civil cases. In connection with non-dispositive motions,
19 good cause must be shown to support a filing under seal. See Kamakana v. City and
20 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
21 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
22 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
23 require good cause showing), and a specific showing of good cause or compelling
24 reasons with proper evidentiary support and legal justification, must be made with
25 respect to Protected Material that a party seeks to file under seal. The parties’ mere
26 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
27 without the submission of competent evidence by declaration, establishing that the
1 otherwise protectable—constitute good cause.
2 Further, if a party requests sealing related to a dispositive motion or trial, then
3 compelling reasons, not only good cause, for the sealing must be shown, and the
4 relief sought shall be narrowly tailored to serve the specific interest to be protected.
5 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
6 each item or type of information, document, or thing sought to be filed or introduced
7 under seal in connection with a dispositive motion or trial, the party seeking
8 protection must articulate compelling reasons, supported by specific facts and legal
9 justification, for the requested sealing order. Again, competent evidence supporting
10 the application to file documents under seal must be provided by declaration.
11 Any document that is not confidential, privileged, or otherwise protectable in
12 its entirety will not be filed under seal if the confidential portions can be redacted.
13 If documents can be redacted, then a redacted version for public viewing, omitting
14 only the confidential, privileged, or otherwise protectable portions of the document,
15 shall be filed. Any application that seeks to file documents under seal in their
16 entirety should include an explanation of why redaction is not feasible.
17 2. DEFINITIONS
18 2.1 Action: this pending federal lawsuit.
19 2.2 Challenging Party: a Party or Non-Party that challenges the
20 designation of information or items under this Order.
21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
22 how it is generated, stored or maintained) or tangible things that qualify for
23 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
24 the Good Cause Statement.
25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
26 their support staff).
27 2.5 Designating Party: a Party or Non-Party that designates information or
1 “CONFIDENTIAL.”
2 2.6 Disclosure or Discovery Material: all items or information, regardless
3 of the medium or manner in which it is generated, stored, or maintained (including,
4 among other things, testimony, transcripts, and tangible things), that are produced or
5 generated in disclosures or responses to discovery in this matter.
6 2.7 Expert: a person with specialized knowledge or experience in a matter
7 pertinent to the litigation who has been retained by a Party or its counsel to serve as
8 an expert witness or as a consultant in this Action.
9 2.8 House Counsel: attorneys who are employees of a party to this Action.
10 House Counsel does not include Outside Counsel of Record or any other outside
11 counsel.
12 2.9 Non-Party: any natural person, partnership, corporation, association or
13 other legal entity not named as a Party to this action.
14 2.10 Outside Counsel of Record: attorneys who are not employees of a
15 party to this Action but are retained to represent or advise a party to this Action and
16 have appeared in this Action on behalf of that party or are affiliated with a law firm
17 that has appeared on behalf of that party, and includes support staff.
18 2.11 Party: any party to this Action, including all of its officers, directors,
19 employees, consultants, retained experts, and Outside Counsel of Record (and their
20 support staffs).
21 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
22 Discovery Material in this Action.
23 2.13 Professional Vendors: persons or entities that provide litigation
24 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
25 demonstrations, and organizing, storing, or retrieving data in any form or medium)
26 and their employees and subcontractors.
27 2.14 Protected Material: any Disclosure or Discovery Material that is
1 2.15 Receiving Party: a Party that receives Disclosure or Discovery
2 Material from a Producing Party.
3. SCOPE
3
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
Any use of Protected Material at trial shall be governed by the orders of the
9
trial judge. This Order does not govern the use of Protected Material at trial.
10
4. DURATION
11
FINAL DISPOSITION of the action is defined as the conclusion of any
12
appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal
13
has run. Except as set forth below, the terms of this protective order apply through
14
FINAL DISPOSITION of the action. The parties may stipulate that the they will be
15
contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
16
but will have to file a separate action for enforcement of the agreement once all
17
proceedings in this case are complete.
18
Once a case proceeds to trial, information that was designated as
19
CONFIDENTIAL or maintained pursuant to this protective order used or introduced
20
as an exhibit at trial becomes public and will be presumptively available to all
21
members of the public, including the press, unless compelling reasons supported by
22
specific factual findings to proceed otherwise are made to the trial judge in advance
23
of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
24
showing for sealing documents produced in discovery from “compelling reasons”
25
standard when merits-related documents are part of court record). Accordingly, for
26
such materials, the terms of this protective order do not extend beyond the
27
1 5. DESIGNATING PROTECTED MATERIAL
2 5.1 Exercise of Restraint and Care in Designating Material for Protection.
3 Each Party or Non-Party that designates information or items for protection under
4 this Order must take care to limit any such designation to specific material that
5 qualifies under the appropriate standards. The Designating Party must designate for
6 protection only those parts of material, documents, items or oral or written
7 communications that qualify so that other portions of the material, documents, items
8 or communications for which protection is not warranted are not swept unjustifiably
9 within the ambit of this Order.
10 Mass, indiscriminate or routinized designations are prohibited. Designations
11 that are shown to be clearly unjustified or that have been made for an improper
12 purpose (e.g., to unnecessarily encumber the case development process or to impose
13 unnecessary expenses and burdens on other parties) may expose the Designating
14 Party to sanctions.
15 If it comes to a Designating Party’s attention that information or items that it
16 designated for protection do not qualify for protection, that Designating Party must
17 promptly notify all other Parties that it is withdrawing the inapplicable designation.
18 5.2 Manner and Timing of Designations. Except as otherwise provided in
19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
21 under this Order must be clearly so designated before the material is disclosed or
22 produced.
23 Designation in conformity with this Order requires:
24 (a) for information in documentary form (e.g., paper or electronic
25 documents, but excluding transcripts of depositions or other pretrial or trial
26 proceedings), that the Producing Party affix at a minimum, the legend
27 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
1 protection, the Producing Party also must clearly identify the protected portion(s)
2 (e.g., by making appropriate markings in the margins).
3 A Party or Non-Party that makes original documents available for inspection
4 need not designate them for protection until after the inspecting Party has indicated
5 which documents it would like copied and produced. During the inspection and
6 before the designation, all of the material made available for inspection shall be
7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
8 documents it wants copied and produced, the Producing Party must determine which
9 documents, or portions thereof, qualify for protection under this Order. Then,
10 before producing the specified documents, the Producing Party must affix the
11 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
12 portion of the material on a page qualifies for protection, the Producing Party also
13 must clearly identify the protected portion(s) (e.g., by making appropriate markings
14 in the margins).
15 (b) for testimony given in depositions that the Designating Party identifies
16 the Disclosure or Discovery Material on the record, before the close of the
17 deposition all protected testimony.
18 (c) for information produced in some form other than documentary and
19 for any other tangible items, that the Producing Party affix in a prominent place on
20 the exterior of the container or containers in which the information is stored the
21 legend “CONFIDENTIAL.” If only a portion or portions of the information
22 warrants protection, the Producing Party, to the extent practicable, shall identify the
23 protected portion(s).
24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
25 failure to designate qualified information or items does not, standing alone, waive the
26 Designating Party’s right to secure protection under this Order for such material. Upon
27 timely correction of a designation, the Receiving Party must make reasonable efforts to
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 251 et seq.
7 6.3 The burden of persuasion in any such challenge proceeding shall be on
8 the Designating Party. Frivolous challenges, and those made for an improper
9 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
10 parties) may expose the Challenging Party to sanctions. Unless the Designating
11 Party has waived or withdrawn the confidentiality designation, all parties shall
12 continue to afford the material in question the level of protection to which it is
13 entitled under the Producing Party’s designation until the Court rules on the
14 challenge.
15 7. ACCESS TO AND USE OF PROTECTED MATERIAL
16 7.1 Basic Principles. A Receiving Party may use Protected Material that is
17 disclosed or produced by another Party or by a Non-Party in connection with this
18 Action only for prosecuting, defending or attempting to settle this Action. Such
19 Protected Material may be disclosed only to the categories of persons and under the
20 conditions described in this Order. When the Action has been terminated, a
21 Receiving Party must comply with the provisions of section 13 below (FINAL
22 DISPOSITION).
23 Protected Material must be stored and maintained by a Receiving Party at a
24 location and in a secure manner that ensures that access is limited to the persons
25 authorized under this Order.
26 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
27 otherwise ordered by the court or permitted in writing by the Designating Party, a
1 “CONFIDENTIAL” only to:
2 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
3 well as employees of said Outside Counsel of Record to whom it is reasonably
4 necessary to disclose the information for this Action;
5 (b) the officers, directors, and employees (including House Counsel) of
6 the Receiving Party to whom disclosure is reasonably necessary for this Action;
7 (c) Experts (as defined in this Order) of the Receiving Party to whom
8 disclosure is reasonably necessary for this Action and who have signed the
9 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
10 (d) the court and its personnel;
11 (e) court reporters and their staff;
12 (f) professional jury or trial consultants, mock jurors, and Professional
13 Vendors to whom disclosure is reasonably necessary for this Action and who have
14 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
15 (g) the author or recipient of a document containing the information or a
16 custodian or other person who otherwise possessed or knew the information;
17 (h) during their depositions, witnesses, and attorneys for witnesses, in the
18 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
19 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
20 will not be permitted to keep any confidential information unless they sign the
21 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
22 agreed by the Designating Party or ordered by the court. Pages of transcribed
23 deposition testimony or exhibits to depositions that reveal Protected Material may
24 be separately bound by the court reporter and may not be disclosed to anyone except
25 as permitted under this Stipulated Protective Order; and
26 (i) any mediator or settlement officer, and their supporting personnel,
27 mutually agreed upon by any of the parties engaged in settlement discussions.
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,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification
7 shall include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order
9 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 a copy of this Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be
13 pursued by the Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with
15 the subpoena or court order shall not produce any information designated in this
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
21 to disobey a lawful directive from another court.
22 9. 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
1 (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-Party
6 that some or all of the information requested is subject to a confidentiality
7 agreement 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
12 Non-Party, if requested.
13 (c) If the Non-Party fails to seek a protective order from this court within
14 14 days of receiving the notice and accompanying information, the Receiving Party
15 may produce the Non-Party’s confidential information responsive to the discovery
16 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
17 not 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
20 expense of seeking protection in this court of its Protected Material.
21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
23 Protected Material to any person or in any circumstance not authorized under this
24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
25 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
26 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
27 persons to whom unauthorized disclosures were made of all the terms of this Order,
1 Agreement to Be Bound” that is attached hereto as Exhibit A.
2 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
3 PROTECTED MATERIAL
4 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
8 procedure may be established in an e-discovery order that provides for production
9 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
10 (e), insofar as the parties reach an agreement on the effect of disclosure of a
11 communication or information covered by the attorney-client privilege or work
12 product protection, the parties may incorporate their agreement in the stipulated
13 protective order submitted to the court.
14 12. MISCELLANEOUS
15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
16 person to seek its modification by the Court in the future.
17 12.2 Right to Assert Other Objections. By stipulating to the entry of this
18 Protective Order, no Party waives any right it otherwise would have to object to
19 disclosing or producing any information or item on any ground not addressed in this
20 Stipulated Protective Order. Similarly, no Party waives any right to object on any
21 ground to use in evidence of any of the material covered by this Protective Order.
22 12.3 Filing Protected Material. A Party that seeks to file under seal any
23 Protected Material must comply with Local Civil Rule 141. Protected Material may
24 only be filed under seal pursuant to a court order authorizing the sealing of the
25 specific Protected Material at issue. If a Party’s request to file Protected Material
26 under seal is denied by the court, then the Receiving Party may file the information
27 in the public record unless otherwise instructed by the court.
1 13. FINAL DISPOSITION
2 After the final disposition of this Action, as defined in paragraph 4, within 60
3 days of a written request by the Designating Party, each Receiving Party must return
4 all Protected Material to the Producing Party or destroy such material. As used in
5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
6 summaries, and any other format reproducing or capturing any of the Protected
7 Material. Whether the Protected Material is returned or destroyed, the Receiving
8 Party must submit a written certification to the Producing Party (and, if not the same
9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
10 (by category, where appropriate) all the Protected Material that was returned or
11 destroyed and (2) affirms that the Receiving Party has not retained any copies,
12 abstracts, compilations, summaries or any other format reproducing or capturing any
13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
16 reports, attorney work product, and consultant and expert work product, even if such
17 materials contain Protected Material. Any such archival copies that contain or
18 constitute Protected Material remain subject to this Protective Order as set forth in
19 Section 4 (DURATION).
20 14. VIOLATION
21 Any violation of this Order may be punished by appropriate measures including,
22 without limitation, contempt proceedings and/or monetary sanctions.
23 / / /
24 / / /
25 / / /
26
27
1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3 DATED: August 23, 2023 ALESHIRE & WYNDER, LLP
MARTIN KOCZANOWICZ
4 GLEN E. TUCKER
5 JOHN FOX
JOSHUA IMERI-GARCIA
6
7
8 By: /s/: John Fox
9 JOHN FOX
Attorneys for Defendants, OFFICER
10 NICHOLAUS D. DILDA and CITY OF
RIDGECREST
12
13. || DATED: 2023 LAW OFFICE OF JOSEPH D. BUSSONE
4 JOSEPH D. BUSSONE

15
16 By: /s/
17 JOSEPH D. BUSSONE
ig Attorneys for Plaintiff, STEVEN J. TODD

19 || tT Is SO ORDERED.
Dated: _ August 24, 2023 | V Vv D
21 UNITED STATES MAGISTRATE JUDGE
22
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01251 0111/011456 2 -145-

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, ________________________ of _______________________________________,
5 declare under penalty of perjury that I have read in its entirety and understand the
6 Stipulated Protective Order that was issued by the United States District Court for
7 the Eastern District of California on ______________ in the case of Steve J. Todd v.
8 Nicholaus D. Dilda; City of Ridgecrest; Case No. 1:23-cv-00913-ADA-CBD. I
9 agree to comply with and to be bound by all the terms of this Stipulated Protective
10 Order and I understand and acknowledge that failure to so comply could expose me
11 to sanctions and punishment in the nature of contempt. I solemnly promise that I
12 will not disclose in any manner any information or item that is subject to this
13 Stipulated Protective Order to any person or entity except in strict compliance with
14 the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for the
16 Eastern District of California for enforcing the terms of this Stipulated Protective
17 Order, even if such enforcement proceedings occur after termination of this action.
18 I hereby appoint ______________________________________________________
19 as my California agent for service of process in connection with this action or any
20 proceedings related to enforcement of this Stipulated Protective Order.
21 Date: _______________________
22 City and State where sworn and signed:
23 Printed name:
24
25 Signature: ___________________________________
26
27
PROOF OF SERVICE
Steven J. Todd v Nicholaus D. Dilda, et al
2 U.S.D.C. Eastern District; Case No. 1:23-cv-00913-ADA-CBD
3 || STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
4 At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Los Angeles, State of California. My business address is 3701
5 Wilshire Blvd., Suite 725, Los Angeles, CA 90010.
6 On August 23, 2023, I served true copies of the following document(s) described as
[PROPOSED] STIPULATED PROTECTIVE ORDER on the interested parties in this action
7 as follows:
8 || J oseph D. Bussone, Beg. Attorney for Plaintiff
LAW OFFICE OF JOSEPH D. BUSSONE STEV J. TODD
9 || 4208 Cactus Street, Suite B
Lake Isabella, CA 93240
10 || Phone: (760) 531-3191
Fax: (760) 531-3192
11 |) Email: jdb@bussonelaw.com
Mobile: (630) 965-8858
BY CM/ECF NOTICE OF ELECTRONIC FILING: [electronically filed the
13 document(s) with the Clerk of the Court by using the CM/ECEF system. Participants in the case
who are registered CM/ECF users will be served by the CM/ECE system. Participants in the case
14 |) who are not registered CM/ECF users will be served by mail or by other means permitted by the
court rules.
15
I declare under penalty of perjury under the laws of the United States of America that the
16 || foregoing is true and correct and that I am employed in the office of a member of the bar of this
7 Court at whose direction the service was made.

18 Executed on August 23, 2023, at Los Angeles, California.

19 sli ws .
20 ons E. Madrid
21
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112451 0111/011A56 2 -|-

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10055152. Public record. Not legal advice.