even stipulated 19 || protective orders require good cause showing
How later courts described this case
- even stipulated 19 || protective orders require good cause showing
Written by the judges who cited it.
The opinion
! | JUSTIN W. CLARK, State Bar No. 235477
iglark(@ilbaclaw.com
2 | SHAWYANE EMADL, State Bar No. 352292
semadi @ibaclaw.com
3 || LAWRENCE BEACH ALLEN & CHOI, PC
150 South Los Robles Avenue, Suite 660
4 || Pasadena, California 91101
5 Telephone No. (818) 545-1925
Attorneys for Defendants
6 || County of Los Angeles and
4 Deputy Larry Parks
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 | JEFFREY PAUL, Case No. 2:25-cv-00008-WLH-E
12 Plaintiff, Honorable Wesley L. Hsu
13 Vs.
STIPULATED PROTECTIVE
14 || LOS ANGELES COUNTY, ORDER
DEPUTY LARRY PARKS, AND
15 | DOE DEPUTIES 1-10,
16 Defendants.
7 Complaint Filed: January 2, 2025
18
19 | 1, A. PURPOSES AND LIMITATIONS.
20 Discovery in this action is likely to involve production of confidential,
21 || proprietary, or private information for which special protection from public
22 | disclosure and from use for any purpose other than prosecuting this litigation may
23 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court
24 || to enter the following Stipulated Protective Order. The parties acknowledge that
25 || this Order does not confer blanket protections on all disclosures or responses to
26 || discovery and that the protection it affords from public disclosure and use extends
27 || only to the limited information or items that are entitled to confidential treatment
28 || under the applicable legal principles.
1 B. GOOD CAUSE STATEMENT.
2 This lawsuit arises from an alleged unlawful seizure and use of force
3 || incident which occurred in a City of Duarte Public Safety Office (the, “Office’’)
4 || on June 28, 2024. Plaintiff Jeffrey Paul (“Plaintiff”) alleges that Los Angeles
5 || County Sheriff's Department (““LASD”) Deputy Larry Parks illegally seized the
6 || Plaintiff and used excessive force in his efforts to detain him (hereinafter, “the
7 || Incident”). Discovery in this case will likely involve the production of
8 || information and documents related to the justification for any alleged seizure of
9 || Plaintiff, the use of force (if any), the manner in which it was conducted, as well
10 || as any other documents which may be subject to various privileges that would bar
11 || them from public disclosure or filing.
12 This action is likely to involve production of information for which special
13 || protection from public disclosure and from use for any purpose other than
14 || prosecution of this action is warranted and appropriate. Such confidential and
15 || proprietary materials and information may consist of, among other things, CCTV
16 || footage from the location where the Incident took place depicting Plaintiff,
17 || reports and documents related to the Incident, and other information implicating
18 || privacy rights of the parties and/or third parties (such as, without limitation,
19 || medical records or other documents subject to privilege) that is otherwise
20 || generally unavailable to the public, or which may be privileged or otherwise
21 || protected from disclosure under state or federal statutes, court rules, case
22 || decisions, or common law. Accordingly, to expedite the flow of information, to
23 || facilitate the prompt resolution of disputes over confidentiality of discovery
24 || materials, to adequately protect information the parties are entitled to keep
25 || confidential, to ensure that the parties are permitted reasonable necessary uses of
26 || such material in preparation for and in the conduct of trial, to address their
27 || handling at the end of the litigation, and serve the ends of justice, a protective
28 || order for such information is justified in this matter. It 1s the intent of the parties
1 || that information will not be designated as confidential for tactical reasons and that
2 || nothing be so designated without a good faith belief that it has been maintained in
3 || a confidential, non-public manner, and there is good cause why it should not be
4 || part of the public record of this case.
5
6 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
7 SEAL.
8 The parties further acknowledge, as set forth in Section 12.3, below, that
9 || this Stipulated Protective Order does not entitle them to file confidential
10 || information under seal; Local Civil Rule 79-5 sets forth the procedures that must
11 || be followed and the standards that will be applied when a party seeks permission
12 || from the court to file material under seal.
13 There is a strong presumption that the public has a right to access judicial
14 || proceedings and records in civil cases. In connection with non-dispositive
15 || motions, good cause must be shown to support a filing under seal. See Kamakana
16 || v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v.
17 || Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v.
18 || Sony Electrician., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
19 || protective orders require good cause showing), and a specific showing of good
20 || cause or compelling reasons with proper evidentiary support and legal
21 || justification must be made with respect to Protected Material that a party seeks to
22 || file under seal. The parties’ mere designation of Disclosure or Discovery
23 || Material as CONFIDENTIAL does not—without the submission of competent
24 || evidence by declaration, establishing that the material sought to be filed under
25 || seal qualifies as confidential, privileged, or otherwise protectable—constitute
26 || good cause.
27 Further, if a party requests sealing related to a dispositive motion or trial,
28 || then compelling reasons, not only good cause, for the sealing must be shown, and
1 || the relief sought shall be narrowly tailored to serve the specific interest to be
2 || protected. See Pintos v. Pacific Creditors Ass ’n, 605 F.3d 665, 677-79 (9th Cir.
3 || 2010). For each item or type of information, document, or thing sought to be
4 || filed or introduced under seal in connection with a dispositive motion or trial, the
5 || party seeking protection must articulate compelling reasons, supported by specific
6 || facts and legal justification, for the requested sealing order. Again, competent
7 || evidence supporting the application to file documents under seal must be
8 || provided by declaration.
9 Any document that is not confidential, privileged, or otherwise protectable
10 || in its entirety will not be filed under seal if the confidential portions can be
11 || redacted. If documents can be redacted, then a redacted version for public
12 || viewing, omitting only the confidential, privileged, or otherwise protectable
13 || portions of the document, shall be filed. Any application that seeks to file
14 || documents under seal in their entirety should include an explanation of why
15 || redaction is not feasible.
16
17 || 2. DEFINITIONS.
18 22.1 Action: Jeffrey Paul v. Los Angeles County, et al.
19 (Case No. 2:25-cv-0008-WLH-E).
20 22.2 Challenging Party: a Party or Non-Party that challenges
21 || the designation of information or items under this Order.
22 22.3. “CONFIDENTIAL” Information or Items: information (regardless of
23 || how it is generated, stored or maintained) or tangible things that qualify for
24 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in
25 || the Good Cause Statement.
26 2.4 Counsel: Outside Counsel of Record (including, where necessary,
27 || their support staff).
28 | //
1 2.5 Designating Party: a Party or Non-Party that designates information
2 || or items thatit produces in disclosures or in responses to discovery as
3 || “CONFIDENTIAL.”
4 2.6 Disclosure or Discovery Material: all items or information,
5 || regardless of the medium or manner in which it is generated, stored, or
6 || maintained (including, among other things, testimony, transcripts, and tangible
7 || things), that are produced or generated in disclosures or responses to discovery in
8 || this matter,
9 2.7 Expert: a person with specialized knowledge or experience in a
10 || matter pertinent to the litigation who has been retained by a Party or its counsel to
11 || serve as an expert witness or as a consultant in this Action.
12 2.8 In-House Counsel: attorneys who are employees of a party to this
13 || Action. House Counsel does not include Outside Counsel of Record or any other
14 || outside counsel.
15 2.9 Non-Party: any natural person, partnership, corporation, association,
16 || of other legal entity not named as a Party to this action.
17 2.10 Outside Counsel of Record: attorneys who are not employees of a
18 || party to this Action but are retained to represent or advise a party to this Action
19 || and have appeared in this Action on behalf of that party or are affiliated with a
20 || law firm which has appeared on behalf of that party, and includes support staff.
21 2.11 Party: any party to this Action, including all of its officers, directors,
22 || employees, consultants, retained experts, and Outside Counsel of Record (and
23 || their support staffs).
24 2.12 Producing Party: a Party or Non-Party that produces Discovery
25 || Material in this Action.
26 2.13 Professional Vendors: persons or entities that provide litigation
27 || support services (e.g., photocopying, videotaping, translating, preparing exhibits
28
1 || or demonstrations, and organizing, storing, or retrieving data in any form or
2 || medium) and their employees and subcontractors.
3 2.14 Protected Material: any Disclosure or Discovery Material that is
4 || designated as “CONFIDENTIAL.”
5 2.15 Receiving Party: a Party that receives Disclosure or Discovery
6 || Material from a Producing Party.
7
8 13. SCOPE
9 The protections conferred by this Stipulation and Order cover not only
10 || Protected Material (as defined above), but also (1) any information copied or
11 || extracted from Protected Material; (2) all copies, excerpts, summaries, or
12 || compilations of Protected Material; and (3) any testimony, conversations, or
13 || presentations by Parties or their Counsel that might reveal Protected Material.
14 Any use of Protected Material at trial shall be governed by the orders of the
15 || trial judge. This Order does not govern the use of Protected Material at trial.
16
17 || 4. DURATION
18 FINAL DISPOSITION of the action is defined as the conclusion of any
19 || appellate proceedings, or, if no appeal is taken, when the time for filing of an
20 || appeal has run. Except as set forth below, the terms of this protective order apply
21 || through FINAL DISPOSITION of the action. The parties may stipulate that they
22 || will be contractually bound by the terms of this agreement beyond FINAL
23 || CONFIDENTIAL or maintained pursuant to this protective order used or
24 || appellate proceedings, or, if no appeal is taken, when the time for filing of an
25 || appeal has run. Except as set forth below, the terms of this protective order apply
26 || through FINAL DISPOSITION of the action. The parties may stipulate that they
27 || will be contractually bound by the terms of this agreement beyond FINAL
28
1 | DISPOSITION, but will have to file a separate action for enforcement of the
2 || agreement once all proceedings in this case are complete.
3 Once a case proceeds to trial, information that was designated as
4 | CONFIDENTIAL or maintained pursuant to this protective order used or
5 || introduced as an exhibit at trial becomes public and will be presumptively
6 || available to all members of the public, including the press, unless compelling
7 || reasons supported by specific factual findings to proceed otherwise are made to
8 || the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
9 || (distinguishing “good cause “showing for sealing documents produced in
10 || discovery from “compelling reasons “standard when merits-related documents are
11 || part of court record). Accordingly, for such materials, the terms of this protective
12 || order do not extend beyond the commencement of the trial.
13
14 | 5. DESIGNATING PROTECTED MATERIAL
15 5.1 Exercise of Restraint and Care in Designating Material for Protection.
16 || ach Party or Non-Party that designates information or items for protection under
17 || this Order must take care to limit any such designation to specific material that
18 || qualifies under the appropriate standards. The Designating Party must designate
19 || for protection only those parts of material, documents, items, or oral or written
20 || communications that qualify so that other portions of the material, documents,
21 || items, or communications for which protection 1s not warranted are not swept
22 || unjustifiably within the ambit of this Order.
23 Mass, indiscriminate, or routine designations are prohibited. Designations
24 || that are shown to be clearly unjustified or that have been made for an improper
25 || purpose (e.g., to unnecessarily encumber the case development process or to
26 || impose unnecessary expenses and burdens on other parties) may expose the
27 || Designating Party to sanctions.
28 | //
1 If it comes to a Designating Party’s attention that information or items that
2 || it designated for protection do not qualify for protection, that Designating Party
3 || must promptly notify all other Parties that it is withdrawing the inapplicable
4 || designation.
5 5.2. Manner and Timing of Designations. Except as otherwise provided
6 || in his Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
7 || stipulated or ordered, Disclosure or Discovery Material that qualifies for
8 || protection under this Order must be clearly so designated before the material is
9 || disclosed or produced.
10 Designation in conformity with this Order requires:
11 (a) for information in documentary form (e.g., paper or electronic
12 || documents, but excluding transcripts of depositions or other pretrial or trial
13 || proceedings), that the Producing Party affix at a minimum, the legend
14 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
15 || contains protected material. If only a portion or portions of the material on a page
16 || qualifies for protection, the Producing Party also must clearly identify the
17 || protected portion(s) (e.g., by making appropriate markings in the margins). The
18 || CONFIDENTIAL legend shall not obscure the contents of any page to which it is
19 || affixed, impede the ability to readily read the page’s contents, or appear over any
20 || words contained in the document.
21 A Party or Non-Party that makes original documents available for
22 || inspection need not designate them for protection until after the inspecting Party
23 || has indicated which documents it would like copied and produced. During the
24 || inspection and before the designation, all of the material made available for
25 || inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
26 || identified the documents it wants copied and produced, the Producing Party must
27 || determine which documents, or portions thereof, qualify for protection under this
28 || Order. Then, before producing the specified documents, the Producing Party
1 || must affix the “CONFIDENTIAL legend” to each page that contains Protected
2 || Material. If only a portion or portions of the material on a page qualifies for
3 || protection, the Producing Party also must clearly identify the protected portion(s)
4 || (e.g., by making appropriate markings in the margins).
5 (b) for testimony given in depositions that the Designating Party identify
6 || the Disclosure or Discovery Material on the record, before the close of the
7 || deposition all protected testimony.
8 (c) for information produced in some form other than documentary and for
9 || any other tangible items, that the Producing Party affix in a prominent place on
10 || the exterior of the container or containers in which the information is stored the
11 || legend “CONFIDENTIAL.” If only a portion or portions of the information
12 || warrants protection, the Producing Party, to the extent practicable, shall identify
13 || the protected portion(s).
14 5. Inadvertent Failures to Designate. If timely corrected, an inadvertent
15 || failure to designate qualified information or items does not, standing alone, waive
16 || the Designating Party’s right to secure protection under this Order for such
17 || material. Upon timely correction of a designation, the Receiving Party must
18 || make reasonable efforts to assure that the material is treated in accordance with
19 || the provisions of this Order.
20
21 | 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
23 || designation of confidentiality at any time that is consistent with the Court’s
24 6.2. Meet and Confer. The Challenging Party shall initiate the dispute
25 || resolution process under Local Rule 37.1 et seq.
26 6.3. The burden of persuasion in any such challenge proceeding shall be
27 || on the Designating Party. Frivolous challenges, and those made for an improper
28 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other
1 || parties) may expose the Challenging Party to sanctions. Unless the Designating
2 || Party has waived or withdrawn the confidentiality designation, all parties shall
3 || continue to afford the material in question the level of protection to which it is
4 || entitled under the Producing Party’s designation until the Court rules on the
5 || challenge.
6
7 7. ACCESS TO AND USE OF PROTECTED MATERIAL
8 7.1 Basic Principles. A Receiving Party may use Protected Material that
9 || is disclosed or produced by another Party or by a Non-Party in connection with
10 || this Action only for prosecuting, defending, or attempting to settle this, Action.
11 || Such Protected Material may be disclosed only to the categories of persons and
12 || under the conditions described in this Order. When the Action has been
13 || terminated, a Recetving Party must comply with the provisions of section 13
14 || below (FINAL DISPOSITION).
15 Protected Material must be stored and maintained by a Receiving Party at a
16 || location and in a secure manner that ensures that access is limited to the people
17 || authorized under this Order.
18 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless
19 || otherwise ordered by the court or permitted in writing by the Designating Party, a
20 || Receiving Party may disclose any information or item designated
21 || “CONFIDENTIAL” only to:
22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
23 || as employees of said Outside Counsel of Record to whom it is reasonably
24 || necessary to disclose the information for this Action;
25 (b) the officers, directors, and employees (including House Counsel) of the
26 || Receiving Party to whom disclosure is reasonably necessary for this Action;
27 //
28 | //
1 (c) Experts (as defined in this Order) of the Receiving Party to whom
2 || disclosure is reasonably necessary for this Action and who have signed the
3 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (d) the court and its personnel;
5 (e) court reporters and their staff;
6 (f) professional jury or trial consultants, mock jurors, and Professional
7 || Vendors to whom disclosure is reasonably necessary for this Action and who
8 || have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (g) the author or recipient of a document containing the information or a
10 || custodian or other person who otherwise possessed or knew the information;
11 (h) during their depositions, witnesses, and attorneys for witnesses, in the
12 || Action to whom disclosure is reasonably necessary provided:
13 (1) the deposing party requests that the witness sign the form attached as
14 || Exhibit 1 hereto; and (2) they will not be permitted to keep any confidential
15 || information unless they sign the “Acknowledgment and Agreement to Be Bound”
16 || (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the
17 || court. Pages of transcribed deposition testimony or exhibits to depositions that
18 || reveal Protected Material may be separately bound by the court reporter and may
19 || not be disclosed to anyone except as permitted under this Stipulated Protective
20 || Order; and
21 (1) any mediator or settlement officer, and their supporting personnel,
22 || mutually agreed upon by any of the parties engaged in settlement discussions.
23
24 | 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
25 IN OTHER LITIGATION.
26 Ifa Party is served with a subpoena or a court order issued in other
27 || litigation that compels disclosure of any information or items designated in this
28 || Action as “CONFIDENTIAL,” that Party must:
1 (a) promptly notify in writing the Designating Party. Such notification
2 || shall include a copy of the subpoena or court order;
3 (b) promptly notify in writing the party who caused the subpoena or order
4 || to issue in the other litigation that some or all of the material covered by the
5 || subpoena or order is subject to this Protective Order. Such notification shall
6 || include a copy of this Stipulated Protective Order; and
7 (c) cooperate with respect to all reasonable procedures sought to be
8 || pursued by the Designating Party whose Protected Material may be affected.
9 If the Designating Party timely seeks a protective order, the Party served
10 || with the subpoena or court order shall not produce any information designated in
11 || this action as “CONFIDENTIAL” before a determination by the court from which
12 || the subpoena or order issued, unless the Party has obtained the Designating
13 || Party’s permission. The Designating Party shall bear the burden and expense of
14 || seeking protection in that court of its confidential material and nothing in these
15 || provisions should be construed as authorizing or encouraging a Receiving Party
16 || in this Action to disobey a lawful directive from another court.
17
18 || 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
19 PRODUCED IN THIS LITIGATION.
20 (a) The terms of this Order are applicable to information produced by a
21 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such
22 || information produced by Non-Parties in connection with this litigation is
23 || protected by the remedies and relief provided by this Order. Nothing in these
24 || provisions should be construed as prohibiting a Non-Party from seeking
25 || additional protections.
26 (b) In the event that a Party is required, by a valid discovery request, to
27 || produce a Non-Party’s confidential information in its possession, and the Party 1s
28
1 || subject to an agreement with the Non-Party not to produce the Non-Party’s
2 || confidential information, then the Party shall:
3 (1) promptly notify in writing the Requesting Party and the Non-
4 Party that some or all of the information requested is subject to a
5 confidentiality agreement with a Non-Party;
6 (2) promptly provide the Non-Party with a copy of the Stipulated
7 Protective Order in this Action, the relevant discovery request(s), and a
8 reasonably specific description of the information requested; and
9 (3) make the information requested available for inspection by the
10 Non-Party, if requested.
11 (c) If the Non-Party fails to seek a protective order from this court within
12 || 14 days of receiving the notice and accompanying information, the Receiving
13 || Party may produce the Non-Party’s confidential information responsive to the
14 || discovery request. If the Non-Party timely seeks a protective order, the Receiving
15 || Party shall not produce any information in its possession or control that is subject
16 || to the confidentiality agreement with the Non-Party before a determination by the
17 || court. Absent a court order to the contrary, the Non-Party shall bear the burden
18 || and expense of seeking protection in this court of its Protected Material.
19
20 | 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL.
21 If a Receiving Party learns that, by inadvertence or otherwise, it has
22 || disclosed Protected Material to any person or in any circumstance not authorized
23 || under this Stipulated Protective Order, the Receiving Party must immediately (a)
24 || notify in writing the Designating Party of the unauthorized disclosures, (b) use its
25 || best efforts to retrieve all unauthorized copies of the Protected Material, (c)
26 || inform the person or persons to whom unauthorized disclosures were made of all
27 || the terms of this Order, and (d) request such person or persons to execute the
28
1 || “Acknowledgment and Agreement to Be Bound” that is attached hereto as
2 || Exhibit A.
3
4/11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL.
6 When a Producing Party gives notice to Receiving Parties that certain
7 || inadvertently produced material is subject to a claim of privilege or other
8 || protection, the obligations of the Receiving Parties are those set forth in Federal
9 || Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
10 || whatever procedure may be established in an e-discovery order that provides for
11 || production without prior privilege review. Pursuant to Federal Rule of Evidence
12 || 502(d) and (e), insofar as the parties reach an agreement on the effect of
13 || disclosure of a communication or information covered by the attorney-client
14 || privilege or work product protection, the parties may incorporate their agreement
15 || in the stipulated protective order submitted to the court.
16
17 ||} 12. MISCELLANEOUS.
18 12.1 Right to Further Relief. Nothing in this Order abridges the right of
19 || any person to seek its modification by the Court in the future.
20 12.2 Right to Assert Other Objections. By stipulating to the entry of this
21 || Protective Order no Party waives any right it otherwise would have to object to
22 || disclosing or producing any information or item on any ground not addressed in
23 || this Stipulated Protective Order. Similarly, no Party waives any right to object on
24 || any ground to use in evidence of any of the material covered by this Protective
25 || Order,
26 12.3 Filing Protected Material. A Party that seeks to file under seal any
27 || Protected Material must comply with Civil Local Rule 79-5. Protected Material
28 || may only be filed under seal pursuant to a court order authorizing the sealing of
1 || the specific Protected Material at issue. If a Party's request to file Protected
2 || Material under seal is denied by the court, then the Receiving Party may file the
3 || information in the public record unless otherwise instructed by the court.
4
5 |} 13. FINAL DISPOSITION.
6 After the final disposition of this Action, as defined in paragraph 4, within
7 || 60 days of a written request by the Designating Party, each Receiving Party must
8 || return all Protected Material to the Producing Party or destroy such material. As
9 || used in this subdivision, “all Protected Material” includes all copies, abstracts,
10 || compilations, summaries, and any other format reproducing or capturing any of
11 || the Protected Material. Whether the Protected Material is returned or destroyed,
12 || the Receiving Party must submit a written certification to the Producing Party
13 || (and, if not the same person or entity, to the Designating Party) by the 60 day
14 || deadline that (1) identifies (by category, where appropriate) all the Protected
15 || Material that was returned or destroyed and (2) affirms that the Receiving Party
16 || has not retained any copies, abstracts, compilations, summaries or any other
17 || format reproducing or capturing any of the Protected Material. Notwithstanding
18 || this provision, Counsel are entitled to retain an archival copy of all pleadings,
19 || motion papers, trial, deposition, and hearing transcripts, legal memoranda,
20 || correspondence, deposition and trial exhibits, expert reports, attorney work
21 || product, and consultant and expert work product, even if such materials contain
22 || Protected Material. Any such archival copies that contain or constitute Protected
23 || Material remain subject to this Protective Order as set forth in Section 4
24 | (DURATION).
25 || 14. Any violation of this Order may be punished by any and all appropriate
26 || measures including, without limitation, contempt proceedings and/or monetary
27 || sanctions.
28 | //
1 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3 || Dated: March 11, 2025 Respectfully submitted,
4 KIRAKOSIAN LAW,
5
By___/s/ Gregory L. Kirakosian
6 Gregory L. Kirakosian
7 Attorney for Plaintiff
g Jeffrey Paul
9 .
0 Dated: March 11, 2025 Respectfully submitted,
4 LAWRENCE BEACH ALLEN & CHOI, PC
12
3 By /s/_ Justin W. Clark!
14 Justin W. Clark
15 Shawyane Emadi
Attorneys for Defendants
16 County of Los Angeles and
17 Deputy Larry Parks
18
19
99 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21
22 □
ELIZ
34 DATED: March 12, 2025
Charles F. Eick
25 United States Magistrate Judge
26
27 ' Pursuant to L.R. 5-4.3.4, the filer of this stipulation attests that all other
9g || signatories listed, and on whose behalf this filing is submitted, concur in the
filing’s content and have authorized the filing.
EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
1, [print or type full name], of
[print or type full address],
6 declare under penalty of perjury that I have read in its entirety and understand the
’ Stipulated Protective Order that was issued by the United States District Court for
the Central District of California on [DATE] in the case of Jeffrey Paul v. Los
° Angeles County, et al., 2:25-cv-00008-WLH-E. I agree to comply with and to be
bound by all the terms of this Stipulated Protective Order and I understand and
acknowledge that failure to so comply could expose me to sanctions and
3 punishment in the nature of contempt. I solemnly promise that I will not disclose
14 in any manner any information or item that is subject to this Stipulated Protective
15 || Order to any person or entity except in strict compliance with the provisions of
16 || this Order.
17 I further agree to submit to the jurisdiction of the United States District
18 || Court for the Central District of California for enforcing the terms of this
19 || Stipulated Protective Order, even if such enforcement proceedings occur after
20 || termination of this action. I hereby appoint [print or type
21 || full name] of [print or type full
22 || address and telephone number] as my California agent for service of process in
23 | connection with this action or any proceedings related to enforcement of this
24 Stipulated Protective Order.
29 Date:
26 City and State where sworn and signed:
a Printed name:
8 Signature: