even stipulated 18 protective orders require good cause showing
How later courts described this case
- even stipulated 18 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 JOHN W. HOWARD (SBN 80200) MOLLY M. LENS (Cal. Bar
SCOTT J. STREET (SBN 258962) #283867)
2 JW Howard/ Attorneys, Ltd. O’Melveny & Myers LLP
600 West Broadway, Suite 1400 1999 Avenue of the Stars, 8th Floor
3 San Diego, CA 92101 Los Angeles, California 90067-6035
Tel: 619-234-2842; Fax 619-234-1716 Tel: (310) 553-6700
4 Johnh@jwhowardattorneys.com Fax: (310) 246-6779
Sstreet@jwhowardattorneys.com mlens@omm.com
5
NICHOLAS R. BARRY (pro hac vice) NATASHA W. TELEANU (pro hac
6 IAN PRIOR (pro hac vice) vice)
America First Legal Foundation O’MELVENY & MYERS LLP
7 611 Pennsylvania Ave, SE #231 1301 Avenue of the Americas, 17th
Washington, DC 20003 Floor
8 Telephone: (615) 431-9303 New York, New York 10019
nicholas.barry@aflegal.org Telephone: +1 212 326 2000
9 ianprior@aflegal.org Facsimile: +1 212 326 2061
nteleanu@omm.com
10 Counsel for Plaintiff
Attorneys for Defendants
11
12
UNITED STATES DISTRICT COURT
13
CENTRAL DISTRICT OF CALIFORNIA
14
15 JEFF VAUGHN
Case No.: 2:24-cv-05570-HDV-RAO
16 Plaintiff,
17 v. DISCOVERY MATTER:
18 CBS BROADCASTING, INC., a STIPULATED PROTECTIVE
Delaware Corporation, and ORDER1
19 PARAMOUNT GLOBAL, a
Delaware Corporation, Wendy
20 McMahon, an individual,
21 Defendants.
22
23
24
25
26
27
1 This Stipulated Protective Order is substantially based on the model protective
1 1. INTRODUCTION
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 production of confidential, proprietary, or private information for which special
4 protection from public disclosure and from use for any purpose other than
5 prosecuting this litigation may be warranted. Accordingly, the parties hereby
6 stipulate to and petition the court to enter the following Stipulated Protective Order.
7 The parties acknowledge that this Order does not confer blanket protections on all
8 disclosures or responses to discovery and that the protection it affords from public
9 disclosure and use extends only to the limited information or items that are entitled
10 to confidential treatment under the applicable legal principles.
11 1.2 Good Cause Statement.
12 This action is likely to involve trade secrets and other valuable commercial,
13 financial, technical and/or proprietary information, including, for example, non-
14 public information about the production of KCBS-TV/KCAL-TV nightly news as
15 well personnel-related information for third-parties, for which special protection
16 from public disclosure and from use for any purpose other than prosecution of this
17 action is warranted. Such confidential and proprietary materials and information
18 consist of, among other things, confidential business or financial information,
19 information regarding confidential business practices, commercial information
20 (including information implicating privacy rights of third parties), information
21 otherwise generally unavailable to the public, or which may be privileged or
22 otherwise protected from disclosure under state or federal statutes, court rules, case
23 decisions, or common law. Accordingly, to expedite the flow of information, to
24 facilitate the prompt resolution of disputes over confidentiality of discovery
25 materials, to adequately protect information the parties are entitled to keep
26 confidential, to ensure that the parties are permitted reasonable necessary uses of
27 such material in preparation for and in the conduct of trial, to address their handling
1 information is justified in this matter. It is the intent of the parties that information
2 will not be designated as confidential for tactical reasons and that nothing be so
3 designated without a good faith belief that it has been maintained in a confidential,
4 non-public manner, and there is good cause why it should not be part of the public
5 record of this case.
6 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties
7 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
8 Protective Order does not entitle them to file confidential information under seal;
9 Local Civil Rule 79-5 sets forth the procedures that must be followed and the
10 standards that will be applied when a party seeks permission from the court to file
11 material under seal.
12 There is a strong presumption that the public has a right of access to judicial
13 proceedings and records in civil cases. In connection with non-dispositive motions,
14 good cause must be shown to support a filing under seal. See Kamakana v. City
15 and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of
16 Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-
17 Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
18 protective orders require good cause showing), and a specific showing of good
19 cause or compelling reasons with proper evidentiary support and legal justification,
20 must be made with respect to Protected Material that a party seeks to file under
21 seal. The parties’ mere designation of Disclosure or Discovery Material as
22 CONFIDENTIAL does not—without the submission of competent evidence by
23 declaration, establishing that the material sought to be filed under seal qualifies as
24 confidential, privileged, or otherwise protectable—constitute good cause.
25 Further, if a party requests sealing related to a dispositive motion or trial,
26 then compelling reasons, not only good cause, for the sealing must be shown, and
27 the relief sought shall be narrowly tailored to serve the specific interest to be
1 2010). For each item or type of information, document, or thing sought to be filed
2 or introduced under seal in connection with a dispositive motion or trial, the party
3 seeking protection must articulate compelling reasons, supported by specific facts
4 and legal justification, for the requested sealing order. Again, competent evidence
5 supporting the application to file documents under seal must be provided by
6 declaration.
7 Any document that is not confidential, privileged, or otherwise protectable in
8 its entirety will not be filed under seal if the confidential portions can be redacted.
9 If documents can be redacted, then a redacted version for public viewing, omitting
10 only the confidential, privileged, or otherwise protectable portions of the document,
11 shall be filed. Any application that seeks to file documents under seal in their
12 entirety should include an explanation of why redaction is not feasible.
13
14 2. DEFINITIONS
15 2.1 Action: Jeff Vaughn v. CBS Broadcasting et al., No. 2:24-cv-05570-
16 HDV-RAO.
17 2.2 Challenging Party: a Party or Non-Party that challenges the designation
18 of information or items under this Order.
19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
20 how it is generated, stored or maintained) or tangible things that qualify for
21 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified
22 above in the Good Cause Statement.
23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
24 their support staff).
25 2.5 Designating Party: a Party or Non-Party that designates information or
26 items that it produces in disclosures or in responses to discovery as
27 “CONFIDENTIAL.”
1 of the medium or manner in which it is generated, stored, or maintained (including,
2 among other things, testimony, transcripts, and tangible things), that are produced or
3 generated in disclosures or responses to discovery in this matter.
4 2.7 Expert: a person with specialized knowledge or experience in a matter
5 pertinent to the litigation who has been retained by a Party or its counsel to serve as
6 an expert witness or as a consultant in this Action.
7 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses
8 in this Action, with or without prejudice; and (2) final judgment herein after the
9 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
10 this Action, including the time limits for filing any motions or applications for
11 extension of time pursuant to applicable law.
12 2.9 In-House Counsel: attorneys who are employees of a party to this
13 Action. In-House Counsel does not include Outside Counsel of Record or any other
14 outside counsel.
15 2.10 Non-Party: any natural person, partnership, corporation, association, or
16 other legal entity not named as a Party to this action.
17 2.11 Outside Counsel of Record: attorneys who are not employees of a party
18 to this Action but are retained to represent or advise a party to this Action and have
19 appeared in this Action on behalf of that party or are affiliated with a law firm which
20 has appeared on behalf of that party, and includes support staff.
21 2.12 Party: any party to this Action, including all of its officers, directors,
22 employees, consultants, retained experts, and Outside Counsel of Record (and their
23 support staffs).
24 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
25 Discovery Material in this Action.
26 2.14 Professional Vendors: persons or entities that provide litigation-
27 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
1 and their employees and subcontractors.
2 2.15 Protected Material: any Disclosure or Discovery Material that is
3 designated as “CONFIDENTIAL.”
4 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
5 from a Producing Party.
6
7 3. SCOPE
8 The protections conferred by this Stipulation and Order cover not only
9 Protected Material (as defined above), but also (1) any information copied or
10 extracted from Protected Material; (2) all copies, excerpts, summaries, or
11 compilations of Protected Material; and (3) any testimony, conversations, or
12 presentations by Parties or their Counsel that might reveal Protected Material.
13 For the avoidance of doubt, the designation of any documents or information
14 as “confidential” under this Stipulation and Order does not cover the following
15 information: (a) any information that is independently in the public domain at the
16 time of disclosure to a Receiving Party or becomes part of the public domain after
17 its disclosure to a Receiving Party as a result of publication not involving a
18 violation of this Order and (b) any information independently known to the
19 Receiving Party prior to the disclosure or obtained by the Receiving Party after the
20 disclosure from a source who obtained the information lawfully and under no
21 obligation of confidentiality to the Designating Party. For the avoidance of doubt,
22 however, any documents designated as “confidential” pursuant to this Stipulation
23 and Order must be treated as such, unless and until the designation is withdrawn
24 and/or the Court rules otherwise or the document is otherwise independently in the
25 possession of the author or intended recipient(s) of a document (including persons
26 who are “CC’d” or “BCC’d”) prior to the designation of the document as
27 “confidential.”
1 trial judge. This Stipulated Protective Order does not govern the use of Protected
2 Material at trial.
3
4 4. TRIAL AND DURATION
5 The terms of this Stipulated Protective Order apply through Final Disposition
6 of the Action.
7 Once a case proceeds to trial, information that was designated as
8 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and
9 used or introduced as an exhibit at trial becomes public and will be presumptively
10 available to all members of the public, including the press, unless compelling
11 reasons supported by specific factual findings to proceed otherwise are made to the
12 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81
13 (distinguishing “good cause” showing for sealing documents produced in discovery
14 from “compelling reasons” standard when merits-related documents are part of
15 court record). Accordingly, for such materials, the terms of this Stipulated
16 Protective Order do not extend beyond the commencement of the trial.
17 Even after Final Disposition of this litigation, the confidentiality obligations
18 imposed by this Stipulated Protective Order shall remain in effect until a
19 Designating Party agrees otherwise in writing or a court order otherwise directs.
20 Final disposition shall be deemed to be the later of (1) dismissal of all claims and
21 defenses in this Action, with or without prejudice; and (2) final judgment herein
22 after the completion and exhaustion of all appeals, rehearings, remands, trials, or
23 reviews of this Action, including the time limits for filing any motions or
24 applications for extension of time pursuant to applicable law.
25
26 5. DESIGNATING PROTECTED MATERIAL
27 5.1 Exercise of Restraint and Care in Designating Material for Protection.
1 this Order must take care to limit any such designation to specific material that
2 qualifies under the appropriate standards.
3 Mass, indiscriminate, or routinized designations are prohibited. Designations
4 that are shown to be clearly unjustified or that have been made for an improper
5 purpose (e.g., to unnecessarily encumber the case development process or to
6 impose unnecessary expenses and burdens on other parties) may expose the
7 Designating Party to sanctions.
8 If it comes to a Designating Party’s attention that information or items that it
9 designated for protection do not qualify for protection, that Designating Party must
10 promptly notify all other Parties that it is withdrawing the inapplicable designation.
11 5.2 Manner and Timing of Designations. Except as otherwise provided in
12 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a)
13 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that
14 qualifies for protection under this Stipulated Protective Order must be clearly so
15 designated before the material is disclosed or produced.
16 Designation in conformity with this Stipulated Protective Order requires:
17 (a) for information in documentary form (e.g., paper or electronic
18 documents, but excluding transcripts of depositions or other pretrial or trial
19 proceedings), that the Producing Party affix at a minimum, the legend
20 “CONFIDENTIAL” to each page that contains protected material.
21 A Party or Non-Party that makes original documents available for inspection
22 need not designate them for protection until after the inspecting Party has indicated
23 which documents it would like copied and produced. During the inspection and
24 before the designation, all of the material made available for inspection shall be
25 deemed CONFIDENTIAL. After the inspecting Party has identified the documents
26 it wants copied and produced, the Producing Party must determine which
27 documents qualify for protection under this Stipulated Protective Order. Then,
1 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a
2 portion or portions of the material on a page qualifies for protection, the Producing
3 Party also must clearly identify the protected portion(s) (e.g., by making
4 appropriate markings in the margins).
5 (b) for testimony given in depositions, the Designating Party may
6 provisionally designate the entirety of deposition testimony as “CONFIDENTIAL,”
7 with the obligation to identify more specific portions of the testimony as to which
8 protection is sought within 30 days following receipt of the deposition transcript (or
9 within the time otherwise agreed by the Parties).
10 (c) for information produced in some form other than documentary and
11 for any other tangible items, that the Producing Party affix in a prominent place on
12 the exterior of the container or containers in which the information is stored the
13 “CONFIDENTIAL” legend. If only a portion or portions of the information
14 warrants protection, the Producing Party, to the extent practicable, shall identify the
15 protected portion(s).
16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
17 failure to designate qualified information or items does not, standing alone, waive
18 the Designating Party’s right to secure protection under this Order for such material.
19 Upon timely correction of a designation, the Receiving Party must make reasonable
20 efforts to assure that the material is treated in accordance with the provisions of this
21 Stipulated Protective Order.
22
23 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
24 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
25 designation of confidentiality at any time that is consistent with the court’s
26 Scheduling Order. Unless a prompt challenge to a Designating Party’s
27 confidentiality designation is necessary to avoid foreseeable, substantial unfairness,
1 a Party does not waive its right to challenge a confidentiality designation by
2 electing not to mount a challenge promptly after the original designation is
3 disclosed.
4 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
5 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge
6 Oliver’s Law and Motion Procedures titled “Informal Discovery Dispute
7 Resolution.”2
8 6.3 The burden of persuasion in any such challenge proceeding shall be on
9 the Designating Party. Frivolous challenges, and those made for an improper
10 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
11 parties) may expose the Challenging Party to sanctions. Unless the Designating
12 Party has waived or withdrawn the confidentiality designation (including by failing
13 to file the stipulation required by Local Rule 37-2.1), all parties shall continue to
14 afford the material in question the level of protection to which it is entitled under
15 the Producing Party’s designation until the court rules on the challenge.
16
17 7. ACCESS TO AND USE OF PROTECTED MATERIAL
18 7.1 Basic Principles. A Receiving Party may use Protected Material that
19 is disclosed or produced by another Party or by a Non-Party in connection with this
20 Action only for prosecuting, defending, or attempting to settle this Action. Such
21 Protected Material may be disclosed only to the categories of persons and under the
22 conditions described in this Order. When the Action reaches a Final Disposition, a
23 Receiving Party must comply with the provisions of section 13 below.
24 Protected Material must be stored and maintained by a Receiving Party at a
25 location and in a secure manner that ensures that access is limited to the persons
26
27
2 Judge Christensen’s Procedures are available at
1 authorized under this Stipulated Protective Order.
2 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
3 otherwise ordered by the court or permitted in writing by the Designating Party, a
4 Receiving Party may disclose any information or item designated
5 “CONFIDENTIAL” only:
6 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as
7 well as employees of said Outside Counsel of Record to whom it is reasonably
8 necessary to disclose the information for this Action
9 (b) to the officers, directors, and employees (including House Counsel) of
10 the Receiving Party to whom disclosure is reasonably necessary for this Action;
11 (c) to Experts (as defined in this Order) of the Receiving Party to whom
12 disclosure is reasonably necessary for this Action and who have signed the
13 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14 (d) to the court and its personnel;
15 (e) to court reporters and their staff;
16 (f) to professional jury or trial consultants, mock jurors, and Professional
17 Vendors to whom disclosure is reasonably necessary for this Action and who have
18 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
19 (g) to the author or recipient of a document containing the information or
20 a custodian or other person who otherwise possessed or knew the information;
21 (h) any deposition or non-trial hearing witness in the Action (including,
22 for the avoidance of doubt, in preparation for such testimony) who previously did
23 not have access to the Confidential Materials (including any counsel for such
24 individuals); provided, provided: (1) the witness signs the “Acknowledgment and
25 Agreement to Be Bound” (Exhibit A); and (2) the witness will not be permitted to
26 keep any confidential information unless they sign the “Acknowledgment and
27 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
1 (i) to any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions.
3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
4 PRODUCED IN OTHER LITIGATION
5 If a Party is served with a subpoena or a court order issued in other litigation
6 that compels disclosure of any information or items designated in this Action as
7 “CONFIDENTIAL,” that Party must:
8 (a) promptly notify in writing the Designating Party. Such notification
9 shall include a copy of the subpoena or court order;
10 (b) promptly notify in writing the party who caused the subpoena or order
11 to issue in the other litigation that some or all of the material covered by the
12 subpoena or order is subject to this Protective Order. Such notification shall include
13 a copy of this Stipulated Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to be
15 pursued by the Designating Party whose Protected Material may be affected.
16 If the Designating Party timely seeks a protective order, the Party served
17 with the subpoena or court order shall not produce any information designated in
18 this action as “CONFIDENTIAL” before a determination by the court from which
19 the subpoena or order issued, unless the Party has obtained the Designating Party’s
20 permission. The Designating Party shall bear the burden and expense of seeking
21 protection in that court of its confidential material and nothing in these provisions
22 should be construed as authorizing or encouraging a Receiving Party in this Action
23 to disobey a lawful directive from another court.
24
25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
26 PRODUCED IN THIS LITIGATION
27 9.1 Application. The terms of this Stipulated Protective Order are
1 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with
2 this litigation is protected by the remedies and relief provided by this Order.
3 Nothing in these provisions should be construed as prohibiting a Non-Party from
4 seeking additional protections.
5 9.2 Notification. In the event that a Party is required, by a valid discovery
6 request, to produce a Non-Party’s confidential information in its possession, and the
7 Party is subject to an agreement with the Non-Party not to produce the Non-
8 Party’s confidential information, then the Party shall:
9 (a) promptly notify in writing the Requesting Party and the Non-Party
10 that some or all of the information requested is subject to a confidentiality
11 agreement with a Non-Party;
12 (b) make the information requested available for inspection by the Non-
13 Party, if requested.
14 9.3 Conditions of Production. If the Non-Party fails to seek a protective
15 order from this court within 14 days of receiving the notice and accompanying
16 information, the Receiving Party may produce the Non-Party’s confidential
17 information responsive to the discovery request. If the Non-Party timely seeks a
18 protective order, the Receiving Party shall not produce any information in its
19 possession or control that is subject to the confidentiality agreement with the Non-
20 Party before a determination by the court. Absent a court order to the contrary, with
21 the court having discretion to shift costs, the Non-Party shall bear the burden and
22 expense of seeking protection in this court of its Protected Material.
23
24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
26 Protected Material to any person or in any circumstance not authorized under this
27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
1 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
2 person or persons to whom unauthorized disclosures were made of all the terms of
3 this Order, and (d) request such person or persons to execute the “Acknowledgment
4 and Agreement to Be Bound” (Exhibit A).
5
6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
7 PROTECTED MATERIAL
8 When a Producing Party gives notice to Receiving Parties that certain
9 inadvertently produced material is subject to a claim of privilege or other
10 protection, the obligations of the Receiving Parties are those set forth in Rule
11 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended
12 to modify whatever procedure may be established in an e-discovery order that
13 provides for production without prior privilege review. Pursuant to Federal Rule of
14 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of
15 disclosure of a communication or information covered by the attorney-client
16 privilege or work product protection, the parties may incorporate their agreement in
17 the stipulated protective order submitted to the court.
18
19 12. MISCELLANEOUS
20 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
21 abridges the right of any person to seek its modification by the court in the future.
22 12.2 Right to Assert Other Objections. By stipulating to the entry of this
23 Stipulated Protective Order no Party waives any right it otherwise would have to
24 object to disclosing or producing any information or item on any ground not
25 addressed in this Stipulated Protective Order. Similarly, no Party waives any right
26 to object on any ground to use in evidence of any of the material covered by this
27 Stipulated Protective Order. And nothing in these provisions should be construed
1 12.3 Filing Protected Material. A Party that seeks to file under seal any
2 Protected Material must comply with Local Rule 79-5. Protected Material may
3 only be filed under seal pursuant to a court order authorizing the sealing of the
4 specific Protected Material at issue. If a Party's request to file Protected Material
5 under seal is denied by the court, then the Receiving Party may file the information
6 in the public record unless otherwise instructed by the court.
7
8 13. FINAL DISPOSITION
9 After the Final Disposition of this Action, as defined in paragraph 4, within
10 60 days of a written request by the Designating Party, each Receiving Party must
11 return all Protected Material to the Producing Party or destroy such material. As
12 used in this subdivision, “all Protected Material” includes all copies, abstracts,
13 compilations, summaries, and any other format reproducing or capturing any of the
14 Protected Material. Whether the Protected Material is returned or destroyed, the
15 Receiving Party must submit a written certification to the Producing Party (and, if
16 not the same person or entity, to the Designating Party) by the 60 day deadline that
17 (1) identifies (by category, where appropriate) all the Protected Material that was
18 returned or destroyed and (2) affirms that the Receiving Party has not retained any
19 copies, abstracts, compilations, summaries or any other format reproducing or
20 capturing any of the Protected Material. Notwithstanding this provision, Counsel is
21 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
22 and hearing transcripts, legal memoranda, correspondence, deposition and trial
23 exhibits, expert reports, attorney work product, and consultant and expert work
24 product, even if such materials contain Protected Material. Any such archival
25 copies that contain or constitute Protected Material remain subject to this Protective
26 Order as set forth in Section 4.
27
1 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished by any
3 and all appropriate measures including, without limitation, contempt proceedings
4 and/or monetary sanctions.
5
6
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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8
DATED: April 14, 2025 /s/ Michelle Volk
9
Attorney(s) for Plaintiff(s)
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12 DATED: April 14, 2025 /s/ Molly M. Lens
13 Attorney(s) for Defendant(s)
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1 ATTESTATION OF FILING
2 Pursuant to Local Rule 5-4.3.4 regarding signatures, I, Molly M. Lens, hereby
3 attest that concurrence in the filing has been obtained from counsel with conformed
4 signatures above.
5 /s/ Molly M. Lens
Molly M. Lens
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
10
11 DATED:_A_p_r_i_l _1_4_, _2_0_2_5_ ________/_s_/_______________________
HON. ROZELLA A. OLIVER
12 UNITED STATES MAGISTRATE JUDGE
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, ________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of
5 perjury that I have read in its entirety and understand the Stipulated Protective
6 Order that was issued by the United States District Court for the Central District
7 of California on ___________[date] in the case of Brian Beneker v. CBS Studios
8 et al., Case No. 2:24-cv-01659-JFW. I agree to comply with and to be bound by all
9 the terms of this Stipulated Protective Order and I understand and acknowledge
10 that failure to so comply could expose me to sanctions and punishment in the
11 nature of contempt. I solemnly promise that I will not disclose in any manner any
12 information or item that is subject to this Stipulated Protective Order to any person
13 or entity except in strict compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District
15 Court for the Central District of California for the purpose of enforcing the terms of
16 this Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint ________________________ [print
18 or type full name] of _________ [print or type full address and telephone
19 number] as my California agent for service of process in connection with this
20 action or any proceedings related to enforcement of this Stipulated Protective
21 Order.
22
23 Date: ___________________________
24 City and State where sworn and
25 signed: ___________________________
26 Printed name: ___________________________
27 Signature: ___________________________