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.
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26
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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
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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
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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
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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
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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.
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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
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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),
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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
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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.
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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
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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.
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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
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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
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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
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_BEXPIRIT A _