even stipulated 17 protective orders require good cause showing
How later courts described this case
- even stipulated 17 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1
UNITED STATES DISTRICT COURT
2
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
3
4
SEAN SINGLETARY, an Case No. 2:22-cv-01606-WLH-SSCx
5
individual,
6
STIPULATED PROTECTIVE
7 Plaintiff,
ORDER1
8
v.
9
CITY OF SANTA MONICA, a
10
public entity, CHIEF CYNTHIA
11 RENAUD, in her individual and
official capacity, CITY OF LOS
12
ANGELES, a public entity,
13 CHIEF MICHEL MOORE, in his
14 individual and official capacity,
COUNTY OF SANTA BARBARA,
15
a public entity, SHERIFF BILL
16 BROWN, in his individual and
official capacity, CHIEF DEPUTY
17
ROBERT PLASTINO, in his
18 individual and official capacity,
and DOES 1-50 inclusive,
19
20 Defendants.
21
22
23
24
25
26
27
1 This Stipulated Protective Order is substantially based on the model
protective order provided under Magistrate Judge Stephanie S.
1 1. INTRODUCTION
2 1.1 Purposes and Limitations. Discovery in this action is likely to
3 involve production of confidential, proprietary, or private information for
4 which special protection from public disclosure and from use for any
5 purpose other than prosecuting this litigation may be warranted.
6 Accordingly, the parties hereby stipulate to and petition the court to
7 enter the following Stipulated Protective Order. The parties
8
acknowledge that this Order does not confer blanket protections on all
9
disclosures or responses to discovery and that the protection it affords
10
from public disclosure and use extends only to the limited information or
11
items that are entitled to confidential treatment under the applicable
12
legal principles.
13
1.2 Good Cause Statement.
14
This action involves Plaintiff Sean Singletary (“Plaintiff”), the City of
15
Santa Monica, Chief Cynthia Renaud, the City of Los Angeles, Chief Michel
16
Moore, the County of Santa Barbara, Sheriff Bill Brown, and Chief Deputy
17
Robert Plastino (collectively “Defendants”). Plaintiff will likely seek
18
materials and information that Defendant entities maintain as confidential,
19
such as personnel records, including internal investigations and materials,
20
video recordings, audio recordings, and other administrative materials and
21
information which Defendants believe need special protection from public
22
disclosure and from use for any purpose other than prosecuting this
23
litigation.
24
Defendants assert that the confidentiality of the materials and
25
information that Plaintiff will likely seek is recognized by California and
26
federal law, as evidenced inter alia by California Penal Code section 832.7
27
and Kerr v. United States Dist. Ct. for N.D. Cal., 511 F.2d 192, 198 (9th Cir.
1 1975), aff'd, 426 U.S. 394 (1976). Defendants have not publicly released the
2 materials and information referenced above. These materials and
3 information are of the type that have been used to initiate disciplinary action
4 against police officers and have been used as evidence in disciplinary
5 proceedings where the officers’ conduct was considered to be contrary to
6 department policy.
7 Defendants contend that absent a protective order delineating the
responsibilities of nondisclosure on the part of the parties hereto, there is a
8
specific risk of unnecessary and undue disclosure by one or more of the
9
many attorneys, secretaries, law clerks, paralegals and expert witnesses
10
involved in this case, as well as the corollary risk of embarrassment,
11
harassment as well as professional, physical and legal harm on the part of
12
the officers referenced in the materials and information.
13
Defendants also contend that the unfettered disclosure of the materials
14
and information, absent a protective order, would allow the media to share
15
this information with potential jurors in the area, impacting the rights of the
16
Defendants herein to receive a fair trial.
17
Accordingly, to expedite the flow of information, to facilitate the
18
prompt resolution of disputes over confidentiality of discovery materials,
19
20 to adequately protect information the parties are entitled to keep
21 confidential, to ensure that the parties are permitted reasonable
22 necessary uses of such material in preparation for and in the conduct of a
23 trial, to address their handling at the end of the litigation, and serve the
24 ends of justice, a protective order for such information is justified in this
25 matter. It is the intent of the parties that information will not be
26 designated as confidential for tactical reasons and that nothing be so
27 designated without a good faith belief that it has been maintained in a
1 confidential, non-public manner, and there is good cause why it should
2 not be part of the public record of this case.
3
4 1.3 Acknowledgment of Procedure for Filing Under Seal. The
5 parties further acknowledge, as set forth in Section 12.3, below, that this
6 Stipulated Protective Order does not entitle them to file confidential
7 information under seal; Local Rule 79-5 sets forth the procedures that
8
must be followed and the standards that will be applied when a party
9
seeks permission from the court to file material under seal.
10
There is a strong presumption that the public has a right of access
11
to judicial proceedings and records in civil cases. In connection with
12
non-dispositive motions, good cause must be shown to support a filing
13
under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
14
1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
15
Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
16
Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
17
protective orders require good cause showing), and a specific showing of
18
good cause or compelling reasons with proper evidentiary support and
19
legal justification, must be made with respect to Protected Material that
20
a party seeks to file under seal. The parties’ mere designation of
21
22 Disclosure or Discovery Material as CONFIDENTIAL does not—
23 without the submission of competent evidence by declaration,
24 establishing that the material sought to be filed under seal qualifies as
25 confidential, privileged, or otherwise protectable—constitute good cause.
26 Further, if a party requests sealing related to a dispositive motion
27 or trial, then compelling reasons, not only good cause, for the sealing
1 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
2 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
3 information, document, or thing sought to be filed or introduced under
4 seal in connection with a dispositive motion or trial, the party seeking
5 protection must articulate compelling reasons, supported by specific
6 facts and legal justification, for the requested sealing order. Again,
7 competent evidence supporting the application to file documents under
8
seal must be provided by declaration.
9
Any document that is not confidential, privileged, or otherwise
10
protectable in its entirety will not be filed under seal if the confidential
11
portions can be redacted. If documents can be redacted, then a redacted
12
version for public viewing, omitting only the confidential, privileged, or
13
otherwise protectable portions of the document, shall be filed. Any
14
application that seeks to file documents under seal in their entirety
15
should include an explanation of why redaction is not feasible.
16
17
2. DEFINITIONS
18
19 2.1 Action: This pending federal lawsuit.
20 2.2 Challenging Party: a Party or Non-Party that challenges the
21 designation of information or items under this Order.
22 2.3 “CONFIDENTIAL” Information or Items: information
23 (regardless of how it is generated, stored or maintained) or tangible
24 things that qualify for protection under Rule 26(c) of the Federal Rules of
25 Civil Procedure, and as specified above in the Good Cause Statement.
26 This also includes (1) any information copied or extracted from the
27
Confidential information; (2) copies, excerpts, summaries or compilations
1 of Confidential information; and (3) any testimony, conversations, or
2 presentations that might reveal Confidential information.
3 2.4 Counsel: Outside Counsel of Record and House Counsel (as
4 well as their support staff).
5 2.5 Designating Party: a Party or Non-Party that designates
6 information or items that it produces in disclosures or in responses to
7 discovery as “CONFIDENTIAL.”
8
2.6 Disclosure or Discovery Material: all items or information,
9
regardless of the medium or manner in which it is generated, stored, or
10
maintained (including, among other things, testimony, transcripts, and
11
tangible things), that are produced or generated in disclosures or
12
responses to discovery in this matter.
13
2.7 Expert: a person with specialized knowledge or experience in
14
a matter pertinent to the litigation who has been retained by a Party or
15
its counsel to serve as an expert witness or as a consultant in this Action.
16
2.8 Final Disposition: the later of (1) dismissal of all claims and
17
defenses in this Action, with or without prejudice; and (2) final judgment
18
herein after the completion and exhaustion of all appeals, rehearings,
19
remands, trials, or reviews of this Action, including the time limits for
20
filing any motions or applications for extension of time pursuant to
21
22 applicable law.
23 2.9 In-House Counsel: attorneys who are employees of a party to
24 this Action. In-House Counsel does not include Outside Counsel of
25 Record or any other outside counsel.
26 2.10 Non-Party: any natural person, partnership, corporation,
27 association, or other legal entity not named as a Party to this action.
1 of a party to this Action but are retained to represent or advise a party to
2 this Action and have appeared in this Action on behalf of that party or
3 are affiliated with a law firm which has appeared on behalf of that party,
4 and includes support staff.
5 2.12 Party: any party to this Action, including all of its officers,
6 directors, employees, consultants, retained experts, and Outside Counsel
7 of Record (and their support staffs).
8
2.13 Producing Party: a Party or Non-Party that produces
9
Disclosure or Discovery Material in this Action.
10
2.14 Professional Vendors: persons or entities that provide
11
litigation- support services (e.g., photocopying, videotaping, translating,
12
preparing exhibits or demonstrations, and organizing, storing, or
13
retrieving data in any form or medium) and their employees and
14
subcontractors.
15
2.15 Protected Material: any Disclosure or Discovery Material that
16
is designated as “CONFIDENTIAL.”
17
2.16 Receiving Party: a Party that receives Disclosure or Discovery
18
Material from a Producing Party.
19
20
3. SCOPE
21
22 The protections conferred by this Stipulation and Order cover not
23 only Protected Material (as defined above), but also (1) any information
24 copied or extracted from Protected Material; (2) all copies, excerpts,
25 summaries, or compilations of Protected Material; and (3) any
26 testimony, conversations, or presentations by Parties or their Counsel
27
that might reveal Protected Material.
1 Any use of Protected Material at trial shall be governed by the
2 orders of the trial judge. This Stipulated Protective Order does not
3 govern the use of Protected Material at trial.
4
5 4. TRIAL AND DURATION
6 Even after Final Disposition of this litigation, the confidentiality
7 obligations imposed by this Stipulated Protective Order shall remain in
8
effect until a Designating Party agrees otherwise in writing or a court
9
order otherwise directs. Final disposition shall be deemed to be the
10
later of (1) dismissal of all claims and defenses in this Action, with or
11
without prejudice; and (2) final judgment herein after the completion
12
and exhaustion of all appeals, rehearings, remands, trials, or reviews of
13
this Action, including the time limits for filing any motions or
14
applications for extension of time pursuant to applicable law.
15
16
5. DESIGNATING PROTECTED MATERIAL
17
18 5.1 Exercise of Restraint and Care in Designating Material for
19 Protection. Each Party or Non-Party that designates information or
20 items for protection under this Order must take care to limit any such
21 designation to specific material that qualifies under the appropriate
22 standards. The Designating Party must designate for protection only
23 those parts of material, documents, items, or oral or written
24 communications that qualify so that other portions of the material,
25 documents, items, or communications for which protection is not
26 warranted are not swept unjustifiably within the ambit of this Order.
27
Mass, indiscriminate, or routinized designations are prohibited.
1 Designations that are shown to be clearly unjustified or that have been
2 made for an improper purpose (e.g., to unnecessarily encumber the case
3 development process or to impose unnecessary expenses and burdens on
4 other parties) may expose the Designating Party to sanctions.
5 If it comes to a Designating Party’s attention that information or
6 items that it designated for protection do not qualify for protection, that
7 Designating Party must promptly notify all other Parties that it is
8
withdrawing the inapplicable designation.
9
5.2 Manner and Timing of Designations. Except as otherwise
10
provided in this Stipulated Protective Order (see, e.g., second paragraph
11
of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
12
or Discovery Material that qualifies for protection under this Stipulated
13
Protective Order must be clearly so designated before the material is
14
disclosed or produced.
15
Designation in conformity with this Stipulated Protective Order
16
requires:
17
18 (a) for information in documentary form (e.g., paper or electronic
19 documents, but excluding transcripts of depositions or other pretrial or
20 trial proceedings), that the Producing Party affix at a minimum, the
21 legend “CONFIDENTIAL” to each page that contains protected
22 material. If only a portion or portions of the material on a page
23 qualifies for protection, the Producing Party also must clearly identify
24 the protected portion(s) (e.g., by making appropriate markings in the
25 margins).
26
A Party or Non-Party that makes original documents available for
27
inspection need not designate them for protection until after the
1 inspecting Party has indicated which documents it would like copied
2 and produced. During the inspection and before the designation, all of
3 the material made available for inspection shall be deemed
4 CONFIDENTIAL. After the inspecting Party has identified the
5 documents it wants copied and produced, the Producing Party must
6 determine which documents, or portions thereof, qualify for protection
7 under this Stipulated Protective Order. Then, before producing the
8
specified documents, the Producing Party must affix the
9
“CONFIDENTIAL” legend to each page that contains Protected
10
Material. If only a portion or portions of the material on a page
11
qualifies for protection, the Producing Party also must clearly identify
12
the protected portion(s) (e.g., by making appropriate markings in the
13
margins).
14
(b) for testimony given in depositions that the Designating Party
15
identify the Disclosure or Discovery Material on the record, before the
16
close of the deposition all protected testimony.
17
(c) for information produced in some form other than
18
documentary and for any other tangible items, that the Producing Party
19
affix in a prominent place on the exterior of the container or containers
20
in which the information is stored the “CONFIDENTIAL” legend. If only
21
22 a portion or portions of the information warrants protection, the
23 Producing Party, to the extent practicable, shall identify the protected
24 portion(s).
25 5.3 Inadvertent Failures to Designate. If timely corrected, an
26 inadvertent failure to designate qualified information or items does not,
27
standing alone, waive the Designating Party’s right to secure protection
1 under this Order for such material. Upon timely correction of a
2 designation, the Receiving Party must make reasonable efforts to assure
3 that the material is treated in accordance with the provisions of this
4 Stipulated Protective Order.
5
6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
7
6.1 Timing of Challenges. Any Party or Non-Party may
8
challenge a designation of confidentiality at any time that is consistent
9
with the court’s Scheduling Order.
10
6.2 Meet and Confer. The Challenging Party shall initiate the
11
dispute resolution process under Local Rule 37.1 et seq. and with
12
Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-
13
Discovery Motion Conference.”2
14
6.3 The burden of persuasion in any such challenge proceeding
15
shall be on the Designating Party. Frivolous challenges, and those
16
made for an improper purpose (e.g., to harass or impose unnecessary
17
18 expenses and burdens on other parties) may expose the Challenging
19 Party to sanctions. Unless the Designating Party has waived or
20 withdrawn the confidentiality designation, all parties shall continue to
21 afford the material in question the level of protection to which it is
22 entitled under the Producing Party’s designation until the court rules on
23 the challenge.
24
25 7. ACCESS TO AND USE OF PROTECTED MATERIAL
26
27
2 Judge Christensen’s Procedures are available at
1 7.1 Basic Principles. A Receiving Party may use Protected
2 Material that is disclosed or produced by another Party or by a Non-
3 Party in connection with this Action only for prosecuting, defending, or
4 attempting to settle this Action. Such Protected Material may be
5 disclosed only to the categories of persons and under the conditions
6 described in this Order. When the Action reaches a Final Disposition, a
7 Receiving Party must comply with the provisions of section 13 below.
8
Protected Material must be stored and maintained by a Receiving
9
Party at a location and in a secure manner that ensures that access is
10
limited to the persons authorized under this Stipulated Protective
11
Order.
12
7.2 Disclosure of “CONFIDENTIAL” Information or Items.
13
Unless otherwise ordered by the court or permitted in writing by the
14
Designating Party, a Receiving Party may disclose any information or
15
item designated “CONFIDENTIAL” only:
16
(a) to the Receiving Party’s Outside Counsel of Record in this
17
Action, as well as employees of said Outside Counsel of Record to whom
18
it is reasonably necessary to disclose the information for this Action;
19
(b) to the officers, directors, and employees (including House
20
Counsel) of the Receiving Party to whom disclosure is reasonably
21
22 necessary for this Action;
23 (c) to Experts (as defined in this Order) of the Receiving Party to
24 whom disclosure is reasonably necessary for this Action and who have
25 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
26 (d) to the court and its personnel;
27 (e) to court reporters and their staff;
1 Professional Vendors to whom disclosure is reasonably necessary for
2 this Action and who have signed the “Acknowledgment and Agreement
3 to Be Bound” (Exhibit A);
4 (g) to the author or recipient of a document containing the
5 information or a custodian or other person who otherwise possessed or
6 knew the information;
7 (h) during their depositions, to witnesses, and attorneys for
8
witnesses, in the Action to whom disclosure is reasonably necessary,
9
provided: (1) the deposing party requests that the witness sign the
10
“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
11
witness will not be permitted to keep any confidential information
12
unless they sign the “Acknowledgment and Agreement to Be Bound”
13
(Exhibit A), unless otherwise agreed by the Designating Party or
14
ordered by the court. Pages of transcribed deposition testimony or
15
exhibits to depositions that reveal Protected Material may be separately
16
bound by the court reporter and may not be disclosed to anyone except
17
as permitted under this Stipulated Protective Order; and
18
(i) to any mediator or settlement officer, and their supporting
19
personnel, mutually agreed upon by any of the parties engaged in
20
settlement discussions.
21
22
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
23
PRODUCED IN OTHER LITIGATION
24
25 If a Party is served with a subpoena or a court order issued in
26 other litigation that compels disclosure of any information or items
27 designated in this Action as “CONFIDENTIAL,” that Party must:
1 (a) promptly notify in writing the Designating Party. Such
2 notification shall include a copy of the subpoena or court order;
3 (b) promptly notify in writing the party who caused the
4 subpoena or order to issue in the other litigation that some or all of the
5 material covered by the subpoena or order is subject to this Protective
6 Order. Such notification shall include a copy of this Stipulated
7 Protective Order; and
8
(c) cooperate with respect to all reasonable procedures sought to
9
be pursued by the Designating Party whose Protected Material may be
10
affected.
11
If the Designating Party timely seeks a protective order, the
12
Party served with the subpoena or court order shall not produce any
13
information designated in this action as “CONFIDENTIAL” before a
14
determination by the court from which the subpoena or order issued,
15
unless the Party has obtained the Designating Party’s permission. The
16
Designating Party shall bear the burden and expense of seeking
17
protection in that court of its confidential material and nothing in these
18
provisions should be construed as authorizing or encouraging a
19
Receiving Party in this Action to disobey a lawful directive from another
20
court.
21
22
23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
24 PRODUCED IN THIS LITIGATION
25 9.1 Application. The terms of this Stipulated Protective Order
26 are applicable to information produced by a Non-Party in this Action and
27 designated as “CONFIDENTIAL.” Such information produced by Non-
1 and relief provided by this Order. Nothing in these provisions should be
2 construed as prohibiting a Non-Party from seeking additional
3 protections.
4 9.2 Notification. In the event that a Party is required, by a valid
5 discovery request, to produce a Non-Party’s confidential information in
6 its possession, and the Party is subject to an agreement with the Non-
7 Party not to produce the Non-Party’s confidential information, then the
8
Party shall:
9
(a) promptly notify in writing the Requesting Party and the
10
Non-Party that some or all of the information requested is subject to a
11
confidentiality agreement with a Non-Party;
12
(b) make the information requested available for inspection by
13
the Non-Party, if requested.
14
9.3 Conditions of Production. If the Non-Party fails to seek a
15
protective order from this court within 14 days of receiving the notice
16
and accompanying information, the Receiving Party may produce the
17
Non-Party’s confidential information responsive to the discovery request.
18
If the Non-Party timely seeks a protective order, the Receiving Party
19
shall not produce any information in its possession or control that is
20
subject to the confidentiality agreement with the Non-Party before a
21
22 determination by the court. Absent a court order to the contrary, the
23 Non-Party shall bear the burden and expense of seeking protection in
24 this court of its Protected Material.
25
26 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
27 MATERIAL
1 If a Receiving Party learns that, by inadvertence or otherwise, it
2 has disclosed Protected Material to any person or in any circumstance
3 not authorized under this Stipulated Protective Order, the Receiving
4 Party must immediately (a) notify in writing the Designating Party of
5 the unauthorized disclosures, (b) use its best efforts to retrieve all
6 unauthorized copies of the Protected Material, (c) inform the person or
7 persons to whom unauthorized disclosures were made of all the terms of
8
this Order, and (d) request such person or persons to execute the
9
“Acknowledgment and Agreement to Be Bound” (Exhibit A).
10
11
11. INADVERTENT PRODUCTION OF PRIVILEGED OR
12
OTHERWISE PROTECTED MATERIAL
13
14 When a Producing Party gives notice to Receiving Parties that
15 certain inadvertently produced material is subject to a claim of privilege
16 or other protection, the obligations of the Receiving Parties are those set
17 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
18 provision is not intended to modify whatever procedure may be
19 established in an e-discovery order that provides for production without
20 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
21 Rules of Evidence, insofar as the parties reach an agreement on the
22 effect of disclosure of a communication or information covered by the
23
attorney-client privilege or work product protection, the parties may
24
incorporate their agreement in the stipulated protective order
25
submitted to the court.
26
27
1 12. MISCELLANEOUS
2 12.1 Right to Further Relief. Nothing in this Stipulated
3 Protective Order abridges the right of any person to seek its
4
modification by the court in the future.
5
12.2 Right to Assert Other Objections. By stipulating to the entry
6
of this Stipulated Protective Order no Party waives any right it
7
otherwise would have to object to disclosing or producing any
8
information or item on any ground not addressed in this Stipulated
9
Protective Order. Similarly, no Party waives any right to object on any
10
ground to use in evidence of any of the material covered by this
11
Stipulated Protective Order.
12
12.3 Filing Protected Material. A Party that seeks to file under
13
seal any Protected Material must comply with Local Rule 79-5.
14
Protected Material may only be filed under seal pursuant to a court
15
order authorizing the sealing of the specific Protected Material at issue.
16
If a Party's request to file Protected Material under seal is denied by the
17
18 court, then the Receiving Party may file the information in the public
19 record unless otherwise instructed by the court.
20
21 13. FINAL DISPOSITION
22 After the Final Disposition of this Action, as defined in paragraph
23
4, within 60 days of a written request by the Designating Party, each
24
Receiving Party must return all Protected Material to the Producing
25
Party or destroy such material. As used in this subdivision, “all
26
Protected Material” includes all copies, abstracts, compilations,
27
summaries, and any other format reproducing or capturing any of the
1 Protected Material. Whether the Protected Material is returned or
2 destroyed, the Receiving Party must submit a written certification to
3 the Producing Party (and, if not the same person or entity, to the
4 Designating Party) by the 60 day deadline that (1) identifies (by
5 category, where appropriate) all the Protected Material that was
6 returned or destroyed and (2) affirms that the Receiving Party has not
7 retained any copies, abstracts, compilations, summaries or any other
8
format reproducing or capturing any of the Protected Material.
9
Notwithstanding this provision, Counsel is entitled to retain an archival
10
copy of all pleadings, motion papers, trial, deposition, and hearing
11
transcripts, legal memoranda, correspondence, deposition and trial
12
exhibits, expert reports, attorney work product, and consultant and
13
expert work product, even if such materials contain Protected Material.
14
Any such archival copies that contain or constitute Protected Material
15
remain subject to this Protective Order as set forth in Section 4.
16
///
17
18
19
20
21
22
23
24
25
26
27
1 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished
3 by any and all appropriate measures including, without limitation,
4 contempt proceedings and/or monetary sanctions.
5
6 IT IS SO STIPULATED THROUGH COUNSEL OF RECORD.
7
8 Dated: December 18, 2024 SIAS LAW, INC.
9
10
11 By: /s/ Jason O. Sias
Jason O. Sias
12
Attorneys for Plaintiff
13 SEAN SINGLETARY
14
Dated: December 18, 2024 DOUGLAS / HICKS LAW, APC
15
16
17
By: /s/ Jamon R. Hicks
18
Jamon R. Hicks
19 Attorneys for Plaintiff
SEAN SINGLETARY
20
21
22
23
24
25
26
27
1 Dated: December 18, 2024 MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
2
3
4 By: /s/ Kayleigh A. Andersen
5 Eugene P. Ramirez
Kayleigh A. Andersen
6
Attorneys for Defendants
7 CITY OF SANTA MONICA and
CHIEF CYNTHIA RENAUD
8
9
Dated: December 18, 2024 BURKE, WILLIAMS & SORENSEN, LLP
10
11
12 By: /s/ Lisa W. Lee
13 Lisa W. Lee
Attorneys for Defendants
14 CITY OF LOS ANGELES and CHIEF
15 MICHEL MOORE
16
Dated: December 18, 2024 COUNTY OF SANTA BARBARA
17
18
19
By: /s/ - Mary Pat Barry
20 Rachel Van Mullem
Mary Pat Barry
21
Attorneys for Defendants
22 COUNTY OF SANTA BARBARA,
SHERIFF BILL BROWN, and CHIEF
23
DEPUTY ROBERT PLASTINO
24
25
26
27
1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2 Za
3 DATED: December 19, 2024
4 STEPHANIE 8S. CHRISTENSEN
5 United States Magistrate Judge
6
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1]
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1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3
I, ________________________ [print or type full name], of
4
_________________ [print or type full address], declare under
5
penalty of perjury that I have read in its entirety and understand the
6
Stipulated Protective Order that was issued by the United States
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District Court for the Central District of California on [date] in the
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case of __________ [insert formal name of the case and the
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number and initials assigned to it by the court]. I agree to
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comply with and to be bound by all the terms of this Stipulated
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Protective Order and I understand and acknowledge that failure to so
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comply could expose me to sanctions and punishment in the nature of
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14 contempt. I solemnly promise that I will not disclose in any manner
15 any information or item that is subject to this Stipulated Protective
16 Order to any person or entity except in strict compliance with the
17 provisions of this Order.
18 I further agree to submit to the jurisdiction of the United States
19 District Court for the Central District of California for the purpose of
20 enforcing the terms of this Stipulated Protective Order, even if such
21 enforcement proceedings occur after termination of this action. I
22 hereby appoint ________________________ [print or type full name]
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of _________ [print or type full address and telephone number] as
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1 my California agent for service of process in connection with this action
2 or any proceedings related to enforcement of this Stipulated Protective
3 Order.
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5 Date: ___________________________
6 City and State where sworn and
7 signed: ___________________________
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Printed name: ___________________________
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Signature: ___________________________
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