Opinion

Douglas Galanter v. Access Finance, Inc.

Court
District Court, C.D. California
Filed
Mar 19, 2025
Cited by
0 cases
Authority
More cited than 34.5%

even stipulated 11 protective orders require good cause showing

How later courts described this case

  • even stipulated 11 protective orders require good cause showing

Written by the judges who cited it.

The opinion

1

UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

3

4

Douglas Galanter, Case No. 2:23-cv-09466-ODW-

5

v. SSC

6

7 Los Angeles Auto Wholesalers & STIPULATED PROTECTIVE

ORDER1

8 Recovery Services, Inc.

9

10

11

1. INTRODUCTION

12

13 1.1 Purposes and Limitations. Discovery in this action is likely to

14 involve production of confidential, proprietary, or private information for

15 which special protection from public disclosure and from use for any

16 purpose other than prosecuting this litigation may be warranted.

17 Accordingly, the parties hereby stipulate to and petition the court to

18 enter the following Stipulated Protective Order. The parties

19 acknowledge that this Order does not confer blanket protections on all

20 disclosures or responses to discovery and that the protection it affords

21 from public disclosure and use extends only to the limited information or

22

items that are entitled to confidential treatment under the applicable

23

legal principles.

24

1.2 Good Cause Statement.

25

26

27

1 This Stipulated Protective Order is substantially based on the model

protective order provided under Magistrate Judge Stephanie S.

1 This action is likely to involve customer and pricing lists and other

2 valuable research, development, commercial, financial, technical and/or

3 proprietary information for which special protection from public

4 disclosure and from use for any purpose other than prosecution of this

5 action is warranted. Such confidential and proprietary materials and

6 information consist of, among other things, confidential business or

7 financial information, information regarding confidential business

8

practices, or other confidential research, development, or commercial

9

information (including information implicating privacy rights of third

10

parties), information otherwise generally unavailable to the public, or

11

which may be privileged or otherwise protected from disclosure under

12

state or federal statutes, court rules, case decisions, or common law.

13

Accordingly, to expedite the flow of information, to facilitate the prompt

14

resolution of disputes over confidentiality of discovery materials, to

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adequately protect information the parties are entitled to keep

16

confidential, to ensure that the parties are permitted reasonable

17

necessary uses of such material in preparation for and in the conduct of

18

trial, to address their handling at the end of the litigation, and serve the

19

ends of justice, a protective order for such information is justified in this

20

matter. It is the intent of the parties that information will not be

21

22 designated as confidential for tactical reasons and that nothing be so

23 designated without a good faith belief that it has been maintained in a

24 confidential, non-public manner, and there is good cause why it should

25 not be part of the public record of this case.

26 1.3 Acknowledgment of Procedure for Filing Under Seal. The

27 parties further acknowledge, as set forth in Section 12.3, below, that this

1 information under seal; Local Rule 79-5 sets forth the procedures that

2 must be followed and the standards that will be applied when a party

3 seeks permission from the court to file material under seal.

4 There is a strong presumption that the public has a right of access

5 to judicial proceedings and records in civil cases. In connection with

6 non-dispositive motions, good cause must be shown to support a filing

7 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d

8

1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors

9

Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony

10

Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

11

protective orders require good cause showing), and a specific showing of

12

good cause or compelling reasons with proper evidentiary support and

13

legal justification, must be made with respect to Protected Material that

14

a party seeks to file under seal. The parties’ mere designation of

15

Disclosure or Discovery Material as CONFIDENTIAL does not—

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without the submission of competent evidence by declaration,

17

establishing that the material sought to be filed under seal qualifies as

18

confidential, privileged, or otherwise protectable—constitute good cause.

19

Further, if a party requests sealing related to a dispositive motion

20

or trial, then compelling reasons, not only good cause, for the sealing

21

22 must be shown, and the relief sought shall be narrowly tailored to serve

23 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,

24 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of

25 information, document, or thing sought to be filed or introduced under

26 seal in connection with a dispositive motion or trial, the party seeking

27 protection must articulate compelling reasons, supported by specific

1 competent evidence supporting the application to file documents under

2 seal must be provided by declaration.

3 Any document that is not confidential, privileged, or otherwise

4 protectable in its entirety will not be filed under seal if the confidential

5 portions can be redacted. If documents can be redacted, then a redacted

6 version for public viewing, omitting only the confidential, privileged, or

7 otherwise protectable portions of the document, shall be filed. Any

8

application that seeks to file documents under seal in their entirety

9

should include an explanation of why redaction is not feasible.

10

11

2. DEFINITIONS

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2.1 Action: this pending federal lawsuit.

13

2.2 Challenging Party: a Party or Non-Party that challenges the

14

designation of information or items under this Order.

15

2.3 “CONFIDENTIAL” Information or Items: information

16

(regardless of how it is generated, stored or maintained) or tangible

17

18 things that qualify for protection under Rule 26(c) of the Federal Rules of

19 Civil Procedure, and as specified above in the Good Cause Statement.

20 2.4 Counsel: Outside Counsel of Record and House Counsel (as

21 well as their support staff).

22 2.5 Designating Party: a Party or Non-Party that designates

23 information or items that it produces in disclosures or in responses to

24 discovery as “CONFIDENTIAL.”

25 2.6 Disclosure or Discovery Material: all items or information,

26 regardless of the medium or manner in which it is generated, stored, or

27

maintained (including, among other things, testimony, transcripts, and

1 tangible things), that are produced or generated in disclosures or

2 responses to discovery in this matter.

3 2.7 Expert: a person with specialized knowledge or experience in

4 a matter pertinent to the litigation who has been retained by a Party or

5 its counsel to serve as an expert witness or as a consultant in this Action.

6 2.8 Final Disposition: the later of (1) dismissal of all claims and

7 defenses in this Action, with or without prejudice; and (2) final judgment

8

herein after the completion and exhaustion of all appeals, rehearings,

9

remands, trials, or reviews of this Action, including the time limits for

10

filing any motions or applications for extension of time pursuant to

11

applicable law.

12

2.9 In-House Counsel: attorneys who are employees of a party to

13

this Action. In-House Counsel does not include Outside Counsel of

14

Record or any other outside counsel.

15

2.10 Non-Party: any natural person, partnership, corporation,

16

association, or other legal entity not named as a Party to this action.

17

2.11 Outside Counsel of Record: attorneys who are not employees

18

of a party to this Action but are retained to represent or advise a party to

19

this Action and have appeared in this Action on behalf of that party or

20

are affiliated with a law firm which has appeared on behalf of that party,

21

22 and includes support staff.

23 2.12 Party: any party to this Action, including all of its officers,

24 directors, employees, consultants, retained experts, and Outside Counsel

25 of Record (and their support staffs).

26 2.13 Producing Party: a Party or Non-Party that produces

27 Disclosure or Discovery Material in this Action.

1 litigation- support services (e.g., photocopying, videotaping, translating,

2 preparing exhibits or demonstrations, and organizing, storing, or

3 retrieving data in any form or medium) and their employees and

4 subcontractors.

5 2.15 Protected Material: any Disclosure or Discovery Material that

6 is designated as “CONFIDENTIAL.”

7 2.16 Receiving Party: a Party that receives Disclosure or Discovery

8

Material from a Producing Party.

9

10

3. SCOPE

11

The protections conferred by this Stipulation and Order cover not

12

only Protected Material (as defined above), but also (1) any information

13

copied or extracted from Protected Material; (2) all copies, excerpts,

14

summaries, or compilations of Protected Material; and (3) any

15

testimony, conversations, or presentations by Parties or their Counsel

16

that might reveal Protected Material.

17

18 Any use of Protected Material at trial shall be governed by the

19 orders of the trial judge. This Stipulated Protective Order does not

20 govern the use of Protected Material at trial.

21

22 4. TRIAL AND DURATION

23

The terms of this Stipulated Protective Order apply through Final

24

Disposition of the Action.

25

Once a case proceeds to trial, information that was designated as

26

CONFIDENTIAL or maintained pursuant to this Stipulated Protective

27

1 will be presumptively available to all members of the public, including

2 the press, unless compelling reasons supported by specific factual

3 findings to proceed otherwise are made to the trial judge in advance of

4 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good

5 cause” showing for sealing documents produced in discovery from

6 “compelling reasons” standard when merits-related documents are part

7 of court record). Accordingly, for such materials, the terms of this

8

Stipulated Protective Order do not extend beyond the commencement of

9

the trial.

10

Even after Final Disposition of this litigation, the confidentiality

11

obligations imposed by this Stipulated Protective Order shall remain in

12

effect until a Designating Party agrees otherwise in writing or a court

13

order otherwise directs.

14

15

5. DESIGNATING PROTECTED MATERIAL

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5.1 Exercise of Restraint and Care in Designating Material for

17

18 Protection. Each Party or Non-Party that designates information or

19 items for protection under this Order must take care to limit any such

20 designation to specific material that qualifies under the appropriate

21 standards. The Designating Party must designate for protection only

22 those parts of material, documents, items, or oral or written

23 communications that qualify so that other portions of the material,

24 documents, items, or communications for which protection is not

25 warranted are not swept unjustifiably within the ambit of this Order.

26 Mass, indiscriminate, or routinized designations are prohibited.

27

Designations that are shown to be clearly unjustified or that have been

1 made for an improper purpose (e.g., to unnecessarily encumber the case

2 development process or to impose unnecessary expenses and burdens on

3 other parties) may expose the Designating Party to sanctions.

4 If it comes to a Designating Party’s attention that information or

5 items that it designated for protection do not qualify for protection, that

6 Designating Party must promptly notify all other Parties that it is

7 withdrawing the inapplicable designation.

8

5.2 Manner and Timing of Designations. Except as otherwise

9

provided in this Stipulated Protective Order (see, e.g., second paragraph

10

of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure

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or Discovery Material that qualifies for protection under this Stipulated

12

Protective Order must be clearly so designated before the material is

13

disclosed or produced.

14

Designation in conformity with this Stipulated Protective Order

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requires:

16

17 (a) for information in documentary form (e.g., paper or electronic

18 documents, but excluding transcripts of depositions or other pretrial or

19 trial proceedings), that the Producing Party affix at a minimum, the

20 legend “CONFIDENTIAL” to each page that contains protected

21 material. If only a portion or portions of the material on a page

22 qualifies for protection, the Producing Party also must clearly identify

23 the protected portion(s) (e.g., by making appropriate markings in the

24 margins).

25 A Party or Non-Party that makes original documents available for

26

inspection need not designate them for protection until after the

27

inspecting Party has indicated which documents it would like copied

1 and produced. During the inspection and before the designation, all of

2 the material made available for inspection shall be deemed

3 CONFIDENTIAL. After the inspecting Party has identified the

4 documents it wants copied and produced, the Producing Party must

5 determine which documents, or portions thereof, qualify for protection

6 under this Stipulated Protective Order. Then, before producing the

7 specified documents, the Producing Party must affix the

8

“CONFIDENTIAL” legend to each page that contains Protected

9

Material. If only a portion or portions of the material on a page

10

qualifies for protection, the Producing Party also must clearly identify

11

the protected portion(s) (e.g., by making appropriate markings in the

12

margins).

13

(b) for testimony given in depositions that the Designating Party

14

identify the Disclosure or Discovery Material on the record, before the

15

close of the deposition all protected testimony.

16

(c) for information produced in some form other than

17

documentary and for any other tangible items, that the Producing Party

18

affix in a prominent place on the exterior of the container or containers

19

in which the information is stored the “CONFIDENTIAL” legend. If only

20

a portion or portions of the information warrants protection, the

21

22 Producing Party, to the extent practicable, shall identify the protected

23 portion(s).

24 5.3 Inadvertent Failures to Designate. If timely corrected, an

25 inadvertent failure to designate qualified information or items does not,

26 standing alone, waive the Designating Party’s right to secure protection

27

under this Order for such material. Upon timely correction of a

1 designation, the Receiving Party must make reasonable efforts to assure

2 that the material is treated in accordance with the provisions of this

3 Stipulated Protective Order.

4

5 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

6

6.1 Timing of Challenges. Any Party or Non-Party may

7

challenge a designation of confidentiality at any time that is consistent

8

with the court’s Scheduling Order.

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6.2 Meet and Confer. The Challenging Party shall initiate the

10

dispute resolution process under Local Rule 37.1 et seq. and with

11

Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-

12

Discovery Motion Conference.”2

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6.3 The burden of persuasion in any such challenge proceeding

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shall be on the Designating Party. Frivolous challenges, and those

15

made for an improper purpose (e.g., to harass or impose unnecessary

16

expenses and burdens on other parties) may expose the Challenging

17

18 Party to sanctions. Unless the Designating Party has waived or

19 withdrawn the confidentiality designation, all parties shall continue to

20 afford the material in question the level of protection to which it is

21 entitled under the Producing Party’s designation until the court rules on

22 the challenge.

23

24 7. ACCESS TO AND USE OF PROTECTED MATERIAL

25

7.1 Basic Principles. A Receiving Party may use Protected

26

27

2 Judge Christensen’s Procedures are available at

1 Material that is disclosed or produced by another Party or by a Non-

2 Party in connection with this Action only for prosecuting, defending, or

3 attempting to settle this Action. Such Protected Material may be

4 disclosed only to the categories of persons and under the conditions

5 described in this Order. When the Action reaches a Final Disposition, a

6 Receiving Party must comply with the provisions of section 13 below.

7 Protected Material must be stored and maintained by a Receiving

8

Party at a location and in a secure manner that ensures that access is

9

limited to the persons authorized under this Stipulated Protective

10

Order.

11

7.2 Disclosure of “CONFIDENTIAL” Information or Items.

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Unless otherwise ordered by the court or permitted in writing by the

13

Designating Party, a Receiving Party may disclose any information or

14

item designated “CONFIDENTIAL” only:

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(a) to the Receiving Party’s Outside Counsel of Record in this

16

Action, as well as employees of said Outside Counsel of Record to whom

17

it is reasonably necessary to disclose the information for this Action;

18

(b) to the officers, directors, and employees (including House

19

Counsel) of the Receiving Party to whom disclosure is reasonably

20

necessary for this Action;

21

22 (c) to Experts (as defined in this Order) of the Receiving Party to

23 whom disclosure is reasonably necessary for this Action and who have

24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

25 (d) to the court and its personnel;

26 (e) to court reporters and their staff;

27 (f) to professional jury or trial consultants, mock jurors, and

1 this Action and who have signed the “Acknowledgment and Agreement

2 to Be Bound” (Exhibit A);

3 (g) to the author or recipient of a document containing the

4 information or a custodian or other person who otherwise possessed or

5 knew the information;

6 (h) during their depositions, to witnesses, and attorneys for

7 witnesses, in the Action to whom disclosure is reasonably necessary,

8

provided: (1) the deposing party requests that the witness sign the

9

“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the

10

witness will not be permitted to keep any confidential information

11

unless they sign the “Acknowledgment and Agreement to Be Bound”

12

(Exhibit A), unless otherwise agreed by the Designating Party or

13

ordered by the court. Pages of transcribed deposition testimony or

14

exhibits to depositions that reveal Protected Material may be separately

15

bound by the court reporter and may not be disclosed to anyone except

16

as permitted under this Stipulated Protective Order; and

17

(i) to any mediator or settlement officer, and their supporting

18

personnel, mutually agreed upon by any of the parties engaged in

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settlement discussions.

20

21

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

22

PRODUCED IN OTHER LITIGATION

23

24 If a Party is served with a subpoena or a court order issued in

25 other litigation that compels disclosure of any information or items

26 designated in this Action as “CONFIDENTIAL,” that Party must:

27

(a) promptly notify in writing the Designating Party. Such

1 notification shall include a copy of the subpoena or court order;

2 (b) promptly notify in writing the party who caused the

3 subpoena or order to issue in the other litigation that some or all of the

4 material covered by the subpoena or order is subject to this Protective

5 Order. Such notification shall include a copy of this Stipulated

6 Protective Order; and

7 (c) cooperate with respect to all reasonable procedures sought to

8

be pursued by the Designating Party whose Protected Material may be

9

affected.

10

If the Designating Party timely seeks a protective order, the

11

Party served with the subpoena or court order shall not produce any

12

information designated in this action as “CONFIDENTIAL” before a

13

determination by the court from which the subpoena or order issued,

14

unless the Party has obtained the Designating Party’s permission. The

15

Designating Party shall bear the burden and expense of seeking

16

protection in that court of its confidential material and nothing in these

17

provisions should be construed as authorizing or encouraging a

18

Receiving Party in this Action to disobey a lawful directive from another

19

court.

20

21

22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

23 PRODUCED IN THIS LITIGATION

24 9.1 Application. The terms of this Stipulated Protective Order

25 are applicable to information produced by a Non-Party in this Action and

26 designated as “CONFIDENTIAL.” Such information produced by Non-

27 Parties in connection with this litigation is protected by the remedies

1 construed as prohibiting a Non-Party from seeking additional

2 protections.

3 9.2 Notification. In the event that a Party is required, by a valid

4 discovery request, to produce a Non-Party’s confidential information in

5 its possession, and the Party is subject to an agreement with the Non-

6 Party not to produce the Non-Party’s confidential information, then the

7 Party shall:

8

(a) promptly notify in writing the Requesting Party and the

9

Non-Party that some or all of the information requested is subject to a

10

confidentiality agreement with a Non-Party;

11

(b) make the information requested available for inspection by

12

the Non-Party, if requested.

13

9.3 Conditions of Production. If the Non-Party fails to seek a

14

protective order from this court within 14 days of receiving the notice

15

and accompanying information, the Receiving Party may produce the

16

Non-Party’s confidential information responsive to the discovery request.

17

If the Non-Party timely seeks a protective order, the Receiving Party

18

shall not produce any information in its possession or control that is

19

subject to the confidentiality agreement with the Non-Party before a

20

determination by the court. Absent a court order to the contrary, the

21

22 Non-Party shall bear the burden and expense of seeking protection in

23 this court of its Protected Material.

24

25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED

26 MATERIAL

27

If a Receiving Party learns that, by inadvertence or otherwise, it

1 has disclosed Protected Material to any person or in any circumstance

2 not authorized under this Stipulated Protective Order, the Receiving

3 Party must immediately (a) notify in writing the Designating Party of

4 the unauthorized disclosures, (b) use its best efforts to retrieve all

5 unauthorized copies of the Protected Material, (c) inform the person or

6 persons to whom unauthorized disclosures were made of all the terms of

7 this Order, and (d) request such person or persons to execute the

8

“Acknowledgment and Agreement to Be Bound” (Exhibit A).

9

10

11. INADVERTENT PRODUCTION OF PRIVILEGED OR

11

OTHERWISE PROTECTED MATERIAL

12

When a Producing Party gives notice to Receiving Parties that

13

14 certain inadvertently produced material is subject to a claim of privilege

15 or other protection, the obligations of the Receiving Parties are those set

16 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This

17 provision is not intended to modify whatever procedure may be

18 established in an e-discovery order that provides for production without

19 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal

20 Rules of Evidence, insofar as the parties reach an agreement on the

21 effect of disclosure of a communication or information covered by the

22 attorney-client privilege or work product protection, the parties may

23

incorporate their agreement in the stipulated protective order

24

submitted to the court.

25

26

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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

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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 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

7

|| DATED: March 19, 2025 /s/

Attorney(s) for Plaintiff(s)

10 ALEXANDER TRUEBLOOD

1]

DATED: March 19, 2025

13 Attorney(s) for Defendant

LANCE D. ORLOFF

ALEXIS A. ARTEAGA

15

16

17 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

Z—

19 DATED: March 19, 2025

20 STEPHANIE S. CHRISTENSEN

21 United States Magistrate Judge

22

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28

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

7

District Court for the Central District of California on [date] in the

8

case of __________ [insert formal name of the case and the

9

number and initials assigned to it by the court]. I agree to

10

comply with and to be bound by all the terms of this Stipulated

11

Protective Order and I understand and acknowledge that failure to so

12

comply could expose me to sanctions and punishment in the nature of

13

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]

23

of _________ [print or type full address and telephone number] as

24

25

26

27

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.

4

5 Date: ___________________________

6 City and State where sworn and

7 signed: ___________________________

8

Printed name: ___________________________

9

Signature: ___________________________

10

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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