The opinion
1
2
3
4
5
6
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
11
12
Case No. 2:21-cv-02840-AB-AJR
13 CLEVELAND CONSTANTINE
BROWNE, ET AL., [PROPOSED] STIPULATED
14 PROTECTIVE ORDER
Plaintiffs,
15
v.
16 RODNEY SEBASTIAN CLARK, an
individual, ET AL.,
17
18 Defendants.
19
1. GENERAL
20
1.1 Purposes and Limitations. Discovery in this action is likely to involve
21
production of confidential, proprietary, or private information for which special
22
protection from public disclosure and from use for any purpose other than prosecuting
23
this litigation may be warranted. Accordingly, the parties hereby stipulate to and
24
petition the Court to enter the following Stipulated Protective Order. The parties
25
acknowledge that this Order does not confer blanket protections on all disclosures or
26
responses to discovery and that the protection it affords from public disclosure and
27
use extends only to the limited information or items that are entitled to confidential
28
1 treatment under the applicable legal principles. The parties further acknowledge, as
2 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle
3 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the
4 procedures that must be followed and the standards that will be applied when a party
5 seeks permission from the court to file material under seal.
6 1.2 Good Cause Statement.
7 This copyright infringement action has been brought by Plaintiffs against over
8 160 defendants—including many large music companies and many celebrities—and
9 discovery is likely to involve trade secrets, commercial financial, technical and/or
10 proprietary information for which special protection from public disclosure and from
11 use for any purpose other than prosecution of this action is warranted. Such sensitive
12 commercial and personal information may include, without limitation, the terms of
13 confidential recording, publishing, artist, touring, and licensing agreements between
14 Defendants and third parties, proprietary materials and information consisting of,
15 among other things, confidential business or financial information, information
16 regarding confidential business practices, or other confidential research,
17 development, or commercial information (including information implicating privacy
18 rights of Defendants and third parties), financial information, and other proprietary
19 information generally unavailable to the public. Such information may be privileged
20 or otherwise protected from disclosure under state or federal statutes, court rules, case
21 decisions, or common law, and material or information that is subject to a written
22 independent obligation of confidentiality. Accordingly, to expedite discovery, to
23 facilitate the prompt resolution of disputes over confidentiality of discovery materials,
24 to adequately protect information the parties are entitled or obligated to keep
25 confidential, to ensure that the parties are permitted reasonable necessary uses of such
26 material in preparation for and in the conduct of trial, to address their handling at the
27 end of the litigation, and to serve the ends of justice, a protective order for such
28 information is justified in this matter. It is the intent of the parties that information
1 will not be designated as confidential for tactical reasons and that nothing will be so
2 designated without a good faith belief that it has been maintained in a confidential,
3 non-public manner, and that there is good cause why it should not be part of the public
4 record of this case.
5 2. DEFINITIONS
6 2.1 Action: this action, assigned Case No. 2:21-cv-02840-AB-AJR
7 (including all actions that have been consolidated therein).
8 2.2 Challenging Party: a Party or Non-Party that challenges the designation
9 of information or items under this Order.
10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
11 how it is generated, stored or maintained) or tangible things that qualify for protection
12 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
13 Cause Statement.
14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
15 support staff).
16 2.5 Designating Party: a Party or Non-Party that designates information or
17 items that it produces in disclosures or in responses to discovery as
18 “CONFIDENTIAL.”
19 2.6 Disclosure or Discovery Material: all items or information, regardless
20 of the medium or manner in which it is generated, stored, or maintained (including,
21 among other things, testimony, transcripts, and tangible things), that are produced or
22 generated in disclosures or responses to discovery in this matter.
23 2.7 Expert: a person with specialized knowledge or experience in a matter
24 pertinent to the litigation who has been retained by a Party or its counsel to serve as
25 an expert witness or as a consultant in this Action.
26 2.8 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
27 Information or Items: information (regardless of how it is generated, stored or
28 maintained) or tangible things that qualify for protection under Federal Rule of Civil
1 Procedure 26(c), and as specified above in the Good Cause Statement, which belongs
2 to a Designating Party who has a good faith basis to believe that such information, if
3 known by the party to whom it is disclosed, would be inherently harmful to the
4 Designating Party’s business, privacy or other protected interests and, in addition,
5 would create a substantial risk of serious financial or other injury that cannot be
6 avoided by less restrictive means.
7 2.9 House Counsel: attorneys who are employees of a party to this Action.
8 House Counsel does not include Outside Counsel of Record or any other outside
9 counsel.
10 2.10 Non-Party: any natural person, partnership, corporation, association, or
11 other legal entity not named as a Party to this action.
12 2.11 Outside Counsel of Record: attorneys who are not employees of a party
13 to this Action but are retained to represent or advise a party to this Action and have
14 appeared in this Action on behalf of that party or are affiliated with a law firm that
15 has appeared on behalf of that party, including support staff.
16 2.12 Party: any party to this Action, including all of its officers, directors,
17 employees, consultants, retained experts, and Outside Counsel of Record (and their
18 support staffs).
19 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
20 Discovery Material in this Action.
21 2.14 Professional Vendors: persons or entities that provide litigation support
22 services (e.g., photocopying, videotaping, translating, preparing exhibits or
23 demonstrations, and organizing, storing, or retrieving data in any form or medium)
24 and their employees and subcontractors.
25 2.15 Protected Material: any Disclosure or Discovery Material that is
26 designated as “CONFIDENTIAL.”
27 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
28 from a Producing Party.
1
2 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 extracted
5 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
6 Protected Material; and (3) any testimony, conversations, or presentations by Parties
7 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
11 4. DURATION
12 Once a case proceeds to trial, all of the court-filed information to be introduced
13 that was previously designated as confidential or maintained pursuant to this
14 protective order becomes public and will be presumptively available to all members
15 of the public, including the press, unless compelling reasons supported by specific
16 factual findings to proceed otherwise are made to the trial judge in advance of the
17 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.
18 2006) (distinguishing “good cause” showing for sealing documents produced in
19 discovery from “compelling reasons” standard when merits-related documents are
20 part of court record). Accordingly, the terms of this protective order do not extend
21 beyond the commencement of the trial.
22
23 5. DESIGNATING PROTECTED MATERIAL
24 5.1 Exercise of Restraint and Care in Designating Material for Protection.
25 Each Party or Non-Party that designates information or items for protection under this
26 Order must take care to limit any such designation to specific material that qualifies
27 under the appropriate standards. The Designating Party must designate for protection
28 only those parts of material, documents, items, or oral or written communications that
1 qualify so that other portions of the material, documents, items, or communications
2 for which protection is not warranted are not swept unjustifiably within the ambit of
3 this Order.
4 Mass, indiscriminate, or routinized designations are prohibited. Designations
5 that are shown to be clearly unjustified or that have been made for an improper
6 purpose (e.g., to unnecessarily encumber the case development process or to impose
7 unnecessary expenses and burdens on other parties) may expose the Designating Party
8 to sanctions.
9 If it comes to a Designating Party’s attention that information or items that it
10 designated for protection do not qualify for protection, that Designating Party must
11 promptly notify all other Parties that it is withdrawing the inapplicable designation.
12 5.2 Manner and Timing of Designations. Except as otherwise provided in
13 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
14 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
15 under this Order must be clearly so designated before the material is disclosed or
16 produced.
17 Designation in conformity with this Order requires:
18 (a) for information in documentary form (e.g., paper or electronic
19 documents, but excluding transcripts of depositions or other pretrial or trial
20 proceedings), that the Producing Party affix, at a minimum, the legend
21 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), or “HIGHLY
22 CONFIDENTIAL - ATTORNEYS’ EYES ONLY” (hereinafter “HIGHLY
23 CONFIDENTIAL legend”), to each page that contains protected material. If only a
24 portion or portions of the material on a page qualifies for protection, the Producing
25 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
26 markings in the margins).
27 A Party or Non-Party that makes original documents available for inspection
28 need not designate them for protection until after the inspecting Party has indicated
1 which documents it would like copied and produced. During the inspection and
2 before the designation, all of the material made available for inspection shall be
3 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
4 it wants copied and produced, the Producing Party must determine which documents,
5 or portions thereof, qualify for protection under this Order. Then, before producing
6 the specified documents, the Producing Party must affix the “CONFIDENTIAL
7 legend” or “HIGHLY CONFIDENTIAL legend” to each page that contains Protected
8 Material. If only a portion or portions of the material on a page qualifies for
9 protection, the Producing Party also must clearly identify the protected portion(s)
10 (e.g., by making appropriate markings in the margins).
11 (b) for testimony given in depositions that the Designating Party identify
12 the Disclosure or Discovery Material on the record, before the close of the deposition.
13 (c) for information produced in some form other than documentary and
14 for any other tangible items, that the Producing Party affix in a prominent place on
15 the exterior of the container or containers in which the information is stored the legend
16 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
17 ONLY.” If only a portion or portions of the information warrants protection, the
18 Producing Party, to the extent practicable, shall identify the protected portion(s).
19 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
20 failure to designate qualified information or items does not, standing alone, waive the
21 Designating Party’s right to secure protection under this Order for such material.
22 Upon timely correction of a designation, the Receiving Party must make reasonable
23 efforts to assure that the material is treated in accordance with the provisions of this
24 Order.
25
26
27
28
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 Magistrate Judge Richlin’s Civil Procedures. Any discovery
7 motion must strictly comply with the procedures set forth in Judge Richlin’s Civil
8 Procedures.
9 6.3 Burden. The burden of persuasion in any such challenge proceeding
10 shall be on the Designating Party. Frivolous challenges, and those made for an
11 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
12 other parties) may expose the Challenging Party to sanctions. Unless the Designating
13 Party has waived or withdrawn the confidentiality designation, all parties shall
14 continue to afford the material in question the level of protection to which it is entitled
15 under the Producing Party’s designation until the Court rules on the challenge.
16
17 7. ACCESS TO AND USE OF PROTECTED MATERIAL
18 7.1 Basic Principles. A Receiving Party may use Protected Material that is
19 disclosed or produced by another Party or by a Non-Party in connection with this
20 Action only for prosecuting, defending, or attempting to settle this Action. Such
21 Protected Material may be disclosed only to the categories of persons and under the
22 conditions described in this Order. When the Action has been terminated, a Receiving
23 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
24 Protected Material must be stored and maintained by a Receiving Party at a
25 location and in a secure manner that ensures that access is limited to the persons
26 authorized under this Order.
27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
28 otherwise ordered by the Court or permitted in writing by the Designating Party, a
1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only to:
3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
4 well as employees of said Outside Counsel of Record to whom it is reasonably
5 necessary to disclose the information for this Action;
6 (b) the officers, directors, and employees (including House Counsel) of
7 the Receiving Party to whom disclosure is reasonably necessary for this Action;
8 (c) Experts (as defined in this Order) of the Receiving Party to whom
9 disclosure is reasonably necessary for this Action and who have signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
11 (d) the Court and its personnel;
12 (e) court reporters and their staff;
13 (f) professional jury or trial consultants, mock jurors, and Professional
14 Vendors to whom disclosure is reasonably necessary for this Action and who have
15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16 (g) the author or recipient of a document containing the information or
17 a custodian or other person who otherwise possessed or knew the information;
18 (h) during their depositions, witnesses, and attorneys for witnesses, in
19 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
20 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they
21 will not be permitted to keep any confidential information unless they sign the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
23 agreed by the Designating Party or ordered by the Court. Pages of transcribed
24 deposition testimony or exhibits to depositions that reveal Protected Material may be
25 separately bound by the court reporter and may not be disclosed to anyone except as
26 permitted under this Stipulated Protective Order; and
27 (i) any mediator or settlement officer, and their supporting personnel,
28 mutually agreed upon by any of the parties engaged in settlement discussions.
1 Unless otherwise ordered by the Court or permitted in writing by the
2 Designating Party, a Receiving Party may disclose any information or item designated
3 “HIGHLY CONFIDENTIAL” only to those identified in Sections 7(a), (c)-(g) and
4 (i), above, and 7(h) above to the extent counsel has a good faith belief that the witness
5 is designated to testify for the Designating Party under Rule 30(b)(6) or otherwise has
6 or would be expected to have knowledge of the contents of the document, or of its
7 subject matter, and to no one else.
8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
9 PRODUCED 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,” or “HIGHLY CONFIDENTIAL” that Party must:
13 (a) promptly notify in writing the Designating Party. Such notification shall
14 include a copy of the subpoena or court order;
15 (b) promptly notify in writing the party who caused the subpoena or order to
16 issue in the other litigation that some or all of the material covered by the subpoena
17 or order is subject to this Protective Order. Such notification shall include a copy of
18 this Stipulated Protective Order; and
19 (c) cooperate with respect to all reasonable procedures sought to be pursued
20 by the Designating Party whose Protected Material may be affected.
21 If the Designating Party timely seeks a protective order, the Party served with
22 the subpoena or court order shall not produce any information designated in this action
23 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” before a determination by
24 the court from which the subpoena or order issued, unless the Party has obtained the
25 Designating Party’s permission. The Designating Party shall bear the burden and
26 expense of seeking protection in that court of its confidential material and nothing in
27 these provisions should be construed as authorizing or encouraging a Receiving Party
28 in this Action to disobey a lawful directive from another court.
1
2 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
3 PRODUCED IN THIS LITIGATION
4 (a) The terms of this Order are applicable to information produced by a Non-
5 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
6 CONFIDENTIAL.” Such information produced by Non-Parties in connection with
7 this litigation is protected by the remedies and relief provided by this Order. Nothing
8 in these provisions should be construed as prohibiting a Non-Party from seeking
9 additional protections.
10 (b) In the event that a Party is required, by a valid discovery request, to produce
11 a Non-Party’s confidential information in its possession, and the Party is subject to an
12 agreement with the Non-Party not to produce the Non-Party’s confidential
13 information, then the Party shall:
14 (1) promptly notify in writing the Requesting Party and the Non-Party
15 that some or all of the information requested is subject to a confidentiality agreement
16 with a Non-Party;
17 (2) promptly provide the Non-Party with a copy of the Stipulated
18 Protective Order in this Action, the relevant discovery request(s), and a reasonably
19 specific description of the information requested; and
20 (3) make the information requested available for inspection by the Non-
21 Party, if requested.
22 (c) If the Non-Party fails to seek a protective order from this Court within 14
23 days of receiving the notice and accompanying information, the Receiving Party may
24 produce the Non-Party’s confidential information responsive to the discovery request.
25 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
26 any information in its possession or control that is subject to the confidentiality
27 agreement with the Non-Party before a determination by the Court. Absent a court
28
1 order to the contrary, the Non-Party shall bear the burden and expense of seeking
2 protection in this Court of its Protected Material.
3
4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
6 Protected Material to any person or in any circumstance not authorized under this
7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
8 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
9 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
10 persons to whom unauthorized disclosures were made of all the terms of this Order,
11 and (d) request such person or persons to execute the “Acknowledgment and
12 Agreement to Be Bound” that is attached hereto as Exhibit A.
13
14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
15 PROTECTED MATERIAL
16 When a Producing Party gives notice to Receiving Parties that certain
17 inadvertently produced material is subject to a claim of privilege or other protection,
18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
20 may be established in an e-discovery order that provides for production without prior
21 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
22 parties reach an agreement on the effect of disclosure of a communication or
23 information covered by the attorney-client privilege or work product protection, the
24 parties may incorporate their agreement in the stipulated protective order submitted
25 to the Court.
26
27
28
1 12. MISCELLANEOUS
2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
3 person to seek its modification by the Court in the future.
4 12.2 Right to Assert Other Objections. By stipulating to the entry of this
5 Protective Order, no Party waives any right it otherwise would have to object to
6 disclosing or producing any information or item on any ground not addressed in this
7 Stipulated Protective Order. Similarly, no Party waives any right to object on any
8 ground to use in evidence of any of the material covered by this Protective Order.
9 12.3 Filing Protected Material. A Party that seeks to file under seal any
10 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
11 only be filed under seal pursuant to a court order authorizing the sealing of the specific
12 Protected Material at issue; good cause must be shown in the request to file under
13 seal. If a Party’s request to file Protected Material under seal is denied by the Court,
14 then the Receiving Party may file the information in the public record unless
15 otherwise instructed by the Court.
16
17 13. FINAL DISPOSITION
18 After the final disposition of this Action, within 60 days of a written request by
19 the Designating Party, each Receiving Party must return all Protected Material to the
20 Producing Party or destroy such material. As used in this subdivision, “all Protected
21 Material” includes all copies, abstracts, compilations, summaries, and any other
22 format reproducing or capturing any of the Protected Material. Whether the Protected
23 Material is returned or destroyed, the Receiving Party must submit a written
24 certification to the Producing Party (and, if not the same person or entity, to the
25 Designating Party) by the 60 day deadline that (1) identifies (by category, where
26 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms
27 that the Receiving Party has not retained any copies, abstracts, compilations,
28 summaries or any other format reproducing or capturing any of the Protected Material.
1 Notwithstanding this provision, counsel are entitled to retain an archival copy of all
2 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
3 correspondence, deposition and trial exhibits, expert reports, attorney work product,
4 and consultant and expert work product, even if such materials contain Protected
5 Material. Any such archival copies that contain or constitute Protected Material
6 remain subject to this Protective Order as set forth in Section 4 (DURATION).
7 14. VIOLATION OF ORDER
8 Any violation of this Order may be punished by any and all appropriate
9 measures including, without limitation, contempt proceedings and/or monetary
10 sanctions.
11
12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
13
DATED:_12/3/2024______________________
14
_/s/__Scott Alan Burroughs________________
15
Scott Alan Burroughs, Esq.
16 Stephen M. Doniger, Esq.
Trevor W. Barrett, Esq.
17
Benjamin F. Tookey, Esq.
18 DONIGER / BURROUGHS
19
Garth A. Clarke, Esq.
20 LAW OFFICES OF GARTH CLARKE
21 Attorneys for Plaintiffs
22 DATED:_ 12/3/2024_____________________
23
_/s/ Benjamin S. Akley____________________
24 Benjamin S. Akley, Esq.
25 Shamar Toms-Anthony, Esq.
Donald S. Zakarin, Esq.
26 Frank P. Scibilia, Esq.
27 James G. Sammataro, Esq.
Sophia Sofferman, Esq.
28 Attorneys for the Pryor Cashman-Represented Defendants
1
2 Jean G. Vidal____________________________
Jean G. Vidal-Font, Esq.
3
FERRAIUOLI LLC
4 Attorney for Defendants Vladimir Felix p/k/a DJ Blass & Camilo
Echeverria p/k/a Camilo
5
6
DATED:___ 12/3/2024____________________
7
8 /s/ Mark B. Chassman_____________________
9 Mark B. Chassman, Esq.
Ana Vasquez, Esq.
10 CHASSMAN & SEELIG, LLP
11 Richard C. Wolfe, Esq.
WOLFE LAW MIAMI, P.A.
12 Attorneys for Chassman & Seelig Represented Defendants
13
14 DATED:__ 12/3/2024____________________
15
_/s/ David M. Given______________________
16 David M. Given, Esq.
17 Brian S. Conlon, Esq.
Robert Carroll III, Esq.
18 Nina C. Pouget, Esq.
19 PHILLIPS, ERLEWINE, GIVEN & CARLIN LLP
Attorneys for Defendants Empire
20 Distribution, Inc. and William Sami Etienne Grigahcine p/k/a DJ Snake
21
22
DATED:____ 12/3/2024___________________
23
/s/ Sagar P. Parikh________________________
24
Sagar P. Parikh, Esq.
25 BEVERLY HILLS LAW CORP., PC
Attorney for Defendants Cinq Music Group, LLC & Cinq Music Publishing
26
27
28
1
2 _/s/ Bradley J. Mullins_____________________
Bradley J. Mullins, Esq.
3
Mark C. Humphrey, Esq.
4 MITCHELL SILBERBERG & KNUPP
Attorneys for Defendants Aubrey Drake Graham &
5
Sound 1.0 Catalogue LP, improperly named as OVO Sound LLC
6
DATED:_____ 12/3/2024__________________
7
8 /s/ Neville L. Johnson______________________
9 Neville L. Johnson, Esq.
Douglas L. Johnson, Esq.
10 Daniel B. Lifschitz, Esq.
11 JOHNSON & JOHNSON LLP
Attorneys for Defendant Rich Music, Inc
12
13
DATED:___ 12/3/2024____________________
14
15 /s/ Michael A. Trauben____________________
Michael A. Trauben, Esq.
16 Thomas K. Richards, Esq.
17 SINGH, SINGH & TRAUBEN, LLP
Attorneys for Defendants Nelson Diaz
18 Martinez and Jose Angel Lopez Martinez
19
DATED:_____ 12/3/2024__________________
20
21 /s/ Kenneth D. Freundlich__________________
22 Kenneth D. Freundlich, Esq.
Jonah A. Grossbardt, Esq.
23
FREUNDLICH LAW
24 Attorneys for Defendants Benito Antonio Martinez Ocasio p/k/a Bad Bunny and
Rimas Music, LLC
25
26
Pursuant to Civil L.R. 5-4.3.4(a)(2)(i), the filer attests that all other signatories listed,
27
and on whose behalf this filing is submitted, concur in the filing’s content and have
28 authorized the filing.
1 Having considered the stipulation, and finding that good cause exists, the
2 Parties’ Stipulated Protective Order is GRANTED.
3
4 DATED:_1_2_/0_4_/_20_2_4_______ __________________________________
HON. A. JOEL RICHLIN
5 United States Magistrate Judge
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1 EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4
I, _____________________________ [full name], of _________________
5
[full address], declare under penalty of perjury that I have read in its entirety and
6
understand the Stipulated Protective Order that was issued by the United States
7
District Court for the Central District of California on ____________ [date] in the
8
case of ___________ [insert case name and number]. I agree to comply with and
9
to be bound by all the terms of this Stipulated Protective Order and I understand and
10
acknowledge that failure to so comply could expose me to sanctions and punishment
11
in the nature of contempt. I solemnly promise that I will not disclose in any manner
12
any information or item that is subject to this Stipulated Protective Order to any
13
person or entity except in strict compliance with the provisions of this Order.
14
I further agree to submit to the jurisdiction of the United States District Court
15
for the Central District of California for the purpose of enforcing the terms of this
16
Stipulated Protective Order, even if such enforcement proceedings occur after
17
termination of this action. I hereby appoint __________________________ [full
18
name] of _______________________________________ [full address and
19
telephone number] as my California agent for service of process in connection with
20
this action or any proceedings related to enforcement of this Stipulated Protective
21
Order.
22
Date: ______________________________________
23
City and State where signed: _________________________________
24
25
Printed name: _______________________________
26
27
Signature: __________________________________
28