Opinion

Pedro Cervantes v. County of San Bernardino

Court
District Court, C.D. California
Filed
Apr 3, 2025
Cited by
0 cases
Authority
More cited than 34.7%

even stipulated protective orders require good cause showing

How later courts described this case

  • even stipulated protective orders require good cause showing

Written by the judges who cited it.

The opinion

1 FUJIT LAW GROUP LLP

JOHN M. FUJI, SBN 172718

2| MAHAHDI CORZANO, SBN 254905

2 Park Plaza, Suite 450

3|| Irvine, California 92614

Phone: (2 392-5501

4] Fax: (949) 392-5501

Email: JFujii@FujiiLawGroup.com

5|| Email: MCorzano@FujiiLawGroup.com

Attorneys for Defendants

COUNTY OF SAN BERNARDINO,

7| DEPUTY M. WONG, DEPUTY M.

ALVARADO, and SERGEANT GOINES

8

9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA

11

12

PEDRO CERVANTES, CASE NO.: 2:24-cv-09692-CAS-RAO

13

Plaintiff, Judge: Christina A. Snyder

14 Magistrate Judge: Rozella A. Oliver

V.

15

COUNTY OF SAN BERNARDINO, STIPULATED PROTECTIVE ORDER

16| DEPUTY M. WONG, DEPUTY M.

ALVERADO, SERGEANT GOINES,

17| AND DOE DEPUTIES 1-10,

18

Defendants.

19

20

21

22

23

24

25

26

27

28

A. PURPOSES AND LIMITATIONS

2 Defendants COUNTY OF SAN BERNARDINO, DEPUTY MEL WONG,

3] DEPUTY MICHELLE ALVARADO, and SERGEANT RUSSEL GOINES

4||(“Defendants”) contend that discovery in this action (the “Action’”) is likely to involve

production of confidential, proprietary or private information for which special protection

6| from public disclosure and from use for any purpose other than prosecuting this litigation

7|\may be warranted. Accordingly, Defendants and Plaintiff PEDRO CERVANTES

8} (“Plaintiff”), with Plaintiff and Defendants collectively referred to herein as the “Parties”

individually as the “Party,” hereby stipulate to and petition the Court to enter the

10] following Stipulated Protective Order. The Parties acknowledge that this Order does not

11|;confer blanket protections on all disclosures or responses to discovery and that the

protection it affords from public disclosure and use extends only to the limited

information or items that are entitled to confidential treatment under the applicable legal

14} principles.

15 B. GOOD CAUSE STATEMENT

16 This Action involves records of detention and investigations performed by the San

17|| Bernardino County Sheriff's Department and its personnel, agents, and employees, and/or

other third parties contracted with the County. Defendants assert that the underlying

19|incident, and evidence thereof, may involve the identity of personnel, third-party

witnesses, and others, that is private or confidential in nature. Further, Defendants

21|anticipate that Plaintiff will seek confidential documents in this matter which may

22\include, but are not limited to, personnel records of law enforcement officers,

23|/employment records, and confidential information from the San Bernardino County

24|Sheriff's Department (including potential information implicating privacy of third

25||parties) not generally available to the public, or which may be privileged or otherwise

protected from disclosure under state or federal statutes, court rules, case decisions, or

27|common law. Should this information (photos, videos, personnel records, private

28||information of witnesses, etc.) be disclosed without the protection of this Protective

_ 1 of 13 _

1||Order, and open access to the information be allowed, the privacy and safety of those

involved in this Action, and other law enforcement matters, could be placed at risk.

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

4|| of disputes over confidentiality of discovery materials, adequately protect information the

5| Parties are entitled to keep confidential, ensure the Parties are permitted reasonable and

6|| necessary uses of such material in preparation for trial and address their handling at the

7| end of the litigation, and serve the ends of justice, a protective order for such information

justified in this matter. It is the intent of the Parties that information will not be

9| designated as “confidential” for tactical reasons and that nothing be so designated without

good faith belief that it has been maintained in a confidential, non-public manner, and

11||there is good cause why it should not be part of the public record in this Action.

12 C. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER SEAL

13 The Parties further acknowledge, as set forth in Section 12.3, below, that this

Stipulated Protective Order does not entitle them to file confidential information under

15|seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the

standards that will be applied when a party seeks permission from the court to file material

under seal.

18 There is a strong presumption that the public has a right of access to judicial

19|| proceedings and records in civil cases. In connection with non-dispositive motions, good

cause must be shown to support a filing under seal. See Kamakana v. City and County o

21|| Honolulu, 447 F.3d 1172, 1176 (9th Cir_2006); Phillips v. Gen. Motors Corp., 307 F.3d

1206, 1210-11 (9th Cir_2002); Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576,

23||577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and

specific showing of good cause or compelling reasons with proper evidentiary support

25] and legal justification, must be made with respect to Protected Material that a party seeks

file under seal. The Parties’ mere designation of Disclosure or Discovery Material as

27 CONFIDENTIAL does not—without the submission of competent evidence by

28

_9 of 13 _

1||\declaration, establishing that the material sought to be filed under seal qualifies as

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

3 Further, if a Party requests sealing related to a dispositive motion or trial, then

compelling reasons, not only good cause, for the sealing must be shown, and the relief

sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos

6||v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type

information, document, or thing sought to be filed or introduced under seal in

connection with a dispositive motion or trial, the party seeking protection must articulate

9| compelling reasons, supported by specific facts and legal justification, for the requested

10|)sealing order. Again, competent evidence supporting the application to file documents

11\/under seal must be provided by declaration.

12 Any document that is not confidential, privileged, or otherwise protectable in its

13]/entirety will not be filed under seal if the confidential portions can be redacted. If

14] documents can be redacted, then a redacted version for public viewing, omitting only the

15} confidential, privileged, or otherwise protectable portions of the document shall be filed.

16] Any application that seeks to file documents under seal in their entirety should include an

17] explanation of why redaction is not feasible.

DEFINITIONS

19 2.1 Action. This pending federal lawsuit entitled PEDRO CERVANTES v.

20] COUNTY OF SAN BERNARDINO, et al. case number 5:24-cv-09692-CAS-RAO.

21 2.2 Challenging Party. A Party or Non-Party that challenges the designation of

information or items under this Protective Order,

23 2.3 “CONFIDENTIAL” Information or Items. Information (regardless of how

it was or is generated, stored, or maintained) or tangible things that qualify for protection

under Fed. R. Civ. P. 26(c), and as specified above in the Good Cause Statement above.

26 2.4 Counsel. Outside Counsel of Record and House Counsel, as these terms are

27| defined below (as well as their support staff).

28 2.5 Designating Party. A Party or Non-Party that designates information or

23 of 13 _

1||items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

2 2.6 Disclosure or Discovery Material. All items or information, regardless of

medium or manner in which they are generated, stored, or maintained (including,

4\among other things, testimony, transcripts, and tangible things) that are produced or

generated in disclosures or responses to discovery in this matter.

6 2.7 Expert. A person with specialized knowledge or experience in a matter

7| pertinent to the litigation who has been retained by a Party or its counsel to serve as an

expert witness or as a consultant in this Action.

9 2.8 House Counsel. Attorneys who are employees of a Party to this Action.

House Counsel does not include Outside Counsel of Record or any other outside counsel.

11 2.9 Non-Party. Any natural person, partnership, corporation, association, or

12} other legal entity not named as a Party to this Action.

13 2.10 Qutside Counsel of Record. Attorneys who are not employees of a Party to

14] this Action but are retained to represent or advise a Party to this Action and have appeared

this Action on behalf of that Party or are affiliated with a law firm which has appeared

behalf of that Party, and include support staff.

17 2.11 Party. Any Party to this Action, including all of its officers, directors,

18|/employees, consultants, retained experts, and Outside Counsel of Record (and their

support staff).

20 2.12 Producing Party. A Party or Non-Party that produces Disclosure or

Discovery Material in this Action.

22 2.13 Professional Vendors. Persons or entities that produce litigation support

23||services (e.g., photocopying, videotaping, translating, preparing exhibits or

24| demonstrations, and organizing, storing, or retrieving data in any form or medium) and

25||their employees and subcontractors.

26 2.14 Protected Material. Any Disclosure or Discovery Material that is designated

“CONFIDENTIAL.”

28 2.15 Receiving Party. A Party that receives Disclosure or Discovery Material

_Aof13_

1|| from a Producing Party.

SCOPE

3 The protections conferred by this Protective Order cover not only Protected

4||Material (as defined above), but also (1) any information copied or extracted from

Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

6| Material; and (3) any testimony, conversations, or presentations by Parties or their

7| Counsel that might reveal Protected Material.

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

9|judge. This Protective Order does not govern the use of Protected Material at trial.

4. DURATION

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

maintained pursuant to this protective order used or introduced as an exhibit at trial

13||becomes public and will be presumptively available to all members of the public,

14|including the press, unless compelling reasons supported by specific factual findings to

15|| proceed otherwise are made to the trial judge in advance of the trial. See Kamakana, 447

F.3d at 1180-81 (distinguishing “good cause” showing for sealing documents produced

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

of court record). Accordingly, the terms of this protective order do not extend beyond the

commencement of the trial.

DESIGNATING PROTECTED MATERIAL

21 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each

22||Party or Non-Party that designates information or items for protection under this

23|| Protective Order must take care to limit any such designation to specific material that

24| qualifies under the appropriate standards. The Designating Party must designate for

25||protection only those parts of material, documents, items, or oral or written

26| communications that qualify so that other portions of the material, documents, items, or

27| communications for which protection is not warranted are not swept unjustifiably within

ambit of this Protective Order.

_ 5 of 13 _

1 Mass, indiscriminate, or routinized designations are prohibited. Designations that

2||are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

3||to unnecessarily encumber the case development process or to impose unnecessary

expenses and burdens on other parties) may expose the Designating Party to sanctions.

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

6| designated for protection do not qualify for protection, that Designating Party must

7| promptly notify all other Parties that it is withdrawing the inapplicable designation.

8 5.2 Manner and Timing of Designations. Except as otherwise provided in this

Protective Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

10] stipulated or ordered, Disclosure or Discovery Material that qualifies for protection under

11||this Protective Order must be clearly so designated before the material is disclosed or

produced.

13 Designation in conformity with this Protective Order requires:

14 (a) | for information in documentary form (e.g., paper or electronic documents,

excluding transcripts of depositions or other pretrial or trial proceedings), that the

Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

17|“CONFIDENTIAL legend”), to each page that contains protected material. If only a

portion or portions of the material on a page qualifies for protection, the Producing Party

must clearly identify the protected portion(s) (e.g., by making appropriate markings

the margins).

21 A Party or Non-Party that makes original documents available for inspection need

designate them for protection until after the inspecting Party has indicated which

23||documents it would like copied and produced. During the inspection and before the

24|designation, all of the material made available for inspection shall be deemed

25|“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

26|| copied and produced, the Producing Party must determine which documents, or portions

27||thereof, qualify for protection under this Protective Order. Then, before producing the

28|| specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to

_ 6 of 13 _

1||each page that contains Protected Material. If only a portion or portions of the material

a page qualifies for protection, the Producing Party must clearly identify the protected

3} portion(s) (e.g., by making appropriate markings in the margins).

4 (b) for testimony given in depositions, that the Designating Party identify before

5||the close of the deposition, all protected testimony or deposition exhibits that contain

CONFIDENTIAL Information or Items. The court reporter shall then affix the

“CONFIDENTIAL” legend to each page of the transcript or deposition exhibit that

8||contains Protected Material and may separately bound such designated transcript pages

deposition exhibits.

10 (c) for information produced in some form other than documentary, and for any

11] other tangible items, that the Producing Party affix in a prominent place on the exterior

the container or containers in which the information is stored the legend

“CONFIDENTIAL.” If only a portion or portions of the information warrants protection,

14| the Producing Party, to the extent practicable, shall identify the protected portion(s).

15 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

designate qualified information or items does not, standing alone, waive the

17| Designating Party’s right to secure protection under this Protective Order for such

material. Upon timely correction of a designation, the Receiving Party must make

19||reasonable efforts to assure that the material is treated in accordance with the provisions

20] of this Protective Order.

21/6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation

23] of confidentiality at any time that is consistent with the Court’s orders.

24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution

25|| process under Local Rule 37.1 et seq.

26 6.3 Burden. The burden of persuasion in any such challenge proceeding shall

on the Designating Party. Frivolous challenges, and those made for an improper

purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties),

□ of 13 _

1 may expose the Challenging Party to sanctions. Unless the Designating Party has waived

withdrawn the CONFIDENTIAL designation, all Parties shall continue to afford the

material in question the level of protection to which it is entitled under the Producing

4| Party’s designation until the Court rules on the challenge.

ACCESS TO AND USE OF PROTECTED MATERIAL

6 7.1. Basic Principles. A Receiving Party may use Protected Material that is

7| disclosed or produced by another Party or by a Non-Party in connection with this Action

8ionly for prosecuting, defending, or attempting to settle this Action. Such Protected

9| Material may be disclosed only to the categories of persons and under the conditions

10] described in this Protective Order. When the Action has been terminated, a Receiving

11] Party must comply with the provisions of Section 13 below (FINAL DISPOSITION).

12 Protected Material must be stored and maintained by a Receiving Party at a location

in a secure manner that ensures that access is limited only to the persons authorized

14] under this Protective Order.

15 72 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

ordered by the Court or permitted in writing by the Designating Party, a Receiving Party

17||may disclose any information or item designated “CONFIDENTIAL” only to:

18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

employees of the Outside Counsel of Record to whom it is reasonably necessary to

20] disclose the information for this Action.

21 (b) the officers, directors, and employees (including House Counsel) of the

Receiving Party to whom disclosure is reasonably necessary for this Action;

23 (c) Experts (as defined in this Protective Order) of the Receiving Party to whom

24|disclosure is reasonably necessary for this Action and who have signed the

25||“Acknowledgment and Agreement to Be Bound” (Exhibit A);

26 (d) the Court and its personnel;

27 (e) court reporters and their staff;

28 (f) professional jury or trial consultants, mock jurors, and Professional Vendors

_ 2 of 13 _

whom disclosure is reasonably necessary for this Action and who have signed the

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

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

4] custodian or other person who otherwise possessed or knew the information;

5 (h) during their depositions, witnesses and attorneys for witnesses, in the Action

to whom disclosure is reasonably necessary provided: (1) the deposing party requests that

witness and attorneys for the witness sign the “Acknowledgment and Agreement to

Be Bound” form (Exhibit A); and (2) they will not be permitted to keep any confidential

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

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

11] Pages of transcribed deposition testimony or exhibits to depositions that reveal Protected

12||Material may be separately bound by the court reporter and shall not be disclosed to

13||anyone except as permitted under this Protective Order; and

14 (i) any mediator or settlement officer, and their supporting personnel, mutually

15||agreed upon by any of the Parties engaged in settlement discussions.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

17 OTHER LITIGATION

18 If a Party is served with a subpoena or a court order issued in other litigation that

19|compels disclosure of any information or items designated in this Action as

“CONFIDENTIAL,” that Party must:

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

22||include a copy of the subpoena or court order;

23 (b) promptly notify in writing the party who caused the subpoena or order to

24|/issue in the other litigation that some or all of the material covered by the subpoena or

25] order is subject to this Protective Order. Such notification shall include a copy of this

26|| Protective Order; and

27 (c) cooperate with respect to all reasonable procedures sought to be pursued by

28| the Designating Party whose Protected Material may be affected.

_Oof 13 _

1 If the Designating Party timely seeks a protective order, the Party served with the

2||subpoena or court order shall not produce any information designated in this Action as

3|“CONFIDENTIAL” before a determination by the court from which the subpoena or

order issued, unless the Party has obtained the Designating Party’s written permission.

Designating Party shall bear the burden and expense of seeking protection in that

court of tts CONFIDENTIAL Information or Items, and nothing in these provisions

7|should be construed as authorizing or encouraging a Receiving Party in this Action to

disobey a lawful directive from another court.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED

10 IN THIS LITIGATION

11 (a) The terms of this Order are applicable to information produced by a Non-

Party in this Action and designated as “CONFIDENTIAL.” Such information produced

Non-Parties in connection with this litigation is protected by the remedies and relief

14| provided by this Order. Nothing in these provisions should be construed as prohibiting a

Non-Party from seeking additional protections.

16 (b) Inthe event that a Party is required, by a valid discovery request, to produce

Non-Party’s confidential information in its possession, and the Party is subject to an

18||agreement with the Non-Party not to produce the Non-Party’s confidential information,

then the Party shall:

20 (1) promptly notify in writing the Requesting Party and the Non-Party that

21||some or all of the information requested is subject to a confidentiality agreement with a

22|| Non-Party;

23 (2) promptly provide the Non-Party with a copy of the Stipulated

Protective Order in this Action, the relevant discovery request(s), and a reasonably

specific description of the information requested; and

26 (3) make the information requested available for inspection by the Non-

27|| Party, if requested.

28 (c) Ifthe Non-Party fails to seek a protective order from this court within 14

_1N0f 13 _

1| days of receiving the notice and accompanying information, the Receiving Party may

2|| produce the Non-Party’s confidential information responsive to the discovery request. If

3|| the Non-Party timely seeks a protective order, the Receiving Party shall not produce any

4||information in its possession or control that is subject to the confidentiality agreement

with the Non-Party before a determination by the court. Absent a court order to the

contrary, the Non-Party shall bear the burden and expense of seeking protection in this

7| court of its Protected Material.

8/10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

10] Protected Material to any person or in any circumstances not authorized under this

11|/Protective Order, the Receiving Party must immediately (a) notify in writing the

Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all

13|unauthorized copies of the Protected Material, (c) inform the person or persons to whom

14]/unauthorized disclosures were made of all the terms of this Protective Order, and (d)

15||request such person or persons to execute the “Acknowledgment and Agreement to Be

16] Bound” that is attached hereto as Exhibit A.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

18 PROTECTED MATERIAL

19 When a Producing Party gives notice to the Receiving Parties that certain

inadvertently produced material is subject to a claim of privilege or other protections, the

21] obligations of the Receiving Parties are those set forth in Fed. R. Civ. P. 26(b)(S)(B). This

22||provision is not intended to modify whatever procedure may be established in an e-

23|| discovery order that provides for production without prior privilege review. Pursuant to

Federal Rule of Evidence 502(d) and (e), insofar as the Parties reach an agreement on the

25\effect of disclosure of a communication or information covered by the attorney-client

26| privilege or work product protection, the Parties may incorporate their agreement in this

27|| Protective Order or another stipulated protective order.

28

_11 of 13 _

MISCELLANEOUS

2 12.1 Right to Further Relief. Nothing in this Protective Order abridges the right

any person to seek its modification by the Court in the future.

4 12.2 Right to Assert Other Objections. By stipulating to the entry of this

5| Protective Order, no Party waives any right it otherwise would have to object to disclosing

producing any information or item on any ground not addressed in this Protective

7| Order. Similarly, no Party waives any right to object on any ground to the use in evidence

8||of any of the material covered by this Protective Order.

9 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected

10] Material must comply with Civil Local Rule 79-5. Protected Material may only be filed

11//under seal pursuant to a court order authorizing the sealing of the specific Protected

12||Material at issue. If a Party’s request to file Protected Material under seal is denied by

13||the Court, then the Receiving Party may file the information in the public record unless

otherwise instructed by the Court.

FINAL DISPOSITION

16 After the final deposition of this Action, as defined in Section 4 above, each

Receiving Party must return all Protected Material to the Producing Party or destroy such

material within 30 days. As used in this subdivision, “all Protected Material” includes all

19|| copies, abstracts, compilations, summaries, and any other format reproducing or capturing

20| any of the Protected Material. Whether the Protected Material is returned or destroyed,

Receiving Party must submit a written certification to the Producing Party (and, if not

same person or entity, to the Designating Party) by the 60 day deadline that (1)

23||identifies (by category, where appropriate) all the Protected Material that was returned or

24| destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts,

25||compilations, summaries, or any other format reproducing or capturing any of the

26|| Protected Material. Notwithstanding this provision, Counsel are entitled to retain archival

27||copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal

28|| memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work

_ 19 0f 13 _

1|| product, and consultant and expert work product, even if such materials contain Protected

2||Material. Any such archival copies that contain or constitute Protected Material remain

3|| subject to this Protective Order as set forth in Section 4 (DURATION).

VIOLATION

5 Any violation of this Order may be punished by any and all appropriate

measures including, without limitation, contempt proceedings and/or monetary sanctions.

7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

8 Pursuant to Local Rule 5-4.3.4, by my signature below I, Mahadhi Corzano, attest

that all other signatories concur in this filing’s content and have authorized this filing.

10

11]}Dated: March 25, 2025 FUJIT LAW GROUP LLP

12

13 By: __/s/Mahadhi Corzano

JOHN M. FUJII

14 MAHADHI CORZANO

Attorneys for Defendants

15 County of San Bernardino, Mel Wong,

6 Michelle Alvarado, and Russel Goines

17|| Dated: March 25, 2025 KIRAKOSIA LAW, APC

18

19 By: __/s/Gregory L. Kirakosian

GREGORY L. KIRAKOSIAN

20 Attorney for Plaintiff

Pedro Cervantes

22 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

4/3/202

Dated: .

25 Raped OQ, OC.

26|| HON. ROZELLA A. OLIVER

United States Magistrate Judge

28

_ 12 0f 13 _

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

, [print or type full

name], declare under penalty of perjury that I have read in its entirety and understand

6||the Protective Order that was issued by the United States District Court for the Central

7|| District of California on date [date] in the Action of PEDRO

CERVANTES v. COUNTY OF SAN BERNARDINO, et al. case number 5:24-cvy-

9|09692-CAS-RAO. I agree to comply with and to be bound by all the terms of this

Protective Order, and I understand and acknowledge that failure to so comply could

11}expose me to sanctions and punishment in the nature of contempt. I solemnly promise

I will not disclose in any manner any information or item that is subject to this

Protective Order to any person or entity except in strict compliance with the provisions

14] of this Protective Order. I further agree to submit to the jurisdiction of the United States

District Court for the Central District of California for the purpose of enforcing the terms

16] of this Protective Order, even if such enforcement proceedings occur after termination of

Action.

18 I hereby appoint as my California

19| agent for service of process in connection with this Action or any proceedings related to

20| enforcement of this Protective Order.

21

22|| Date:

23|| City and State where sworn and signed:

Printed name:

25 Signature:

26

27

28

_BEXPIRIT A _

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.

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.