even stipulated protective 15 orders require good cause showing
How later courts described this case
- even stipulated protective 15 orders require good cause showing
Written by the judges who cited it.
The opinion
1 William D. Hendricks CA Bar 221071
whendricks@wdhlegal.com
2 LAW OFFICES OF WILLIAM D. HENDRICKS
20350 Ventura Blvd., Suite 100
3 Woodland Hills, CA 91364
Telephone: 818-961-9000
4 Facsimile: 888-636-2420
5 Attorneys for Plaintiff TARONDRA NELSON
6
James T. Conley CA Bar No. 224174
7 james.conley@ogletree.com
Caitlyn B. Emery CA Bar No. 332987
8 caitlyn.emery@ogletree.com
OGLETREE, DEAKINS, NASH,
9 SMOAK & STEWART, P.C.
4660 La Jolla Village Drive, Suite 900
10 San Diego, CA 92122
Telephone: 858-652-3100
11 Facsimile: 858-652-3101
12 Attorneys for Defendant
WAL-MART ASSOCIATES, INC.
13
UNITED STATES DISTRICT COURT
14
CENTRAL DISTRICT OF CALIFORNIA
15
16
TARONDRA NELSON, an individual, Case No. 2:24-cv-06344-JLS-SSC
17
Plaintiff, STIPULATED PROTECTIVE
18
ORDER; 1
v.
19
Complaint Filed: July 5, 2022
WAL-MART ASSOCIATES, INC., a
20 Delaware Corporation, TRAVIS Removal Date: July 26, 2024
JOHNSON, an individual, NANH
21 NGUYEN, an individual, and DOES 1
through 50, inclusive,
22
Defendants.
23
24
25
26
27 1 This Stipulated Protective Order is substantially based on the model protective order
provided under Magistrate Judge Stephanie S. Christensen’s Procedures as of July 24,
28
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 prosecuting
5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and
6 petition the court to enter the following Stipulated Protective Order. The parties
7 acknowledge that this Order does not confer blanket protections on all disclosures or
8 responses to discovery and that the protection it affords from public disclosure and use
9 extends only to the limited information or items that are entitled to confidential
10 treatment under the applicable legal principles.
11 1.2 Good Cause Statement. This action is likely to involve trade secrets,
12 customer and pricing lists and other valuable research, development, commercial,
13 financial, technical and/or proprietary information for which special protection from
14 public disclosure and from use for any purpose other than prosecution of this action is
15 warranted. Such confidential and proprietary materials and information consist of,
16 among other things, confidential business or financial information, information
17 regarding confidential business practices, or other confidential research, development,
18 or commercial information (including information implicating privacy rights of third
19 parties), information otherwise generally unavailable to the public, or which may be
20 privileged or otherwise protected from disclosure under state or federal statutes, court
21 rules, case decisions, or common law. Accordingly, to expedite the flow of
22 information, to facilitate the prompt resolution of disputes over confidentiality of
23 discovery materials, to adequately protect information the parties are entitled to keep
24 confidential, to ensure that the parties are permitted reasonable necessary uses of such
25 material in preparation for and in the conduct of trial, to address their handling at the
26 end of the litigation, and serve the ends of justice, a protective order for such
27 information is justified in this matter. It is the intent of the parties that information
28 will not be designated as confidential for tactical reasons and that nothing be so
1 designated without a good faith belief that it has been maintained in a confidential,
2 non-public manner, and there is good cause why it should not be part of the public
3 record of this case.
4 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties further
5 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order
6 does not entitle them to file confidential information under seal; Local Rule 79-5 sets
7 forth the procedures that must be followed and the standards that will be applied when
8 a party seeks permission from the court to file material under seal.
9 There is a strong presumption that the public has a right of access to judicial
10 proceedings and records in civil cases. In connection with non-dispositive motions,
11 good cause must be shown to support a filing under seal. See Kamakana v. City and
12 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd
13 v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v.
14 Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective
15 orders require good cause showing), and a specific showing of good cause or
16 compelling reasons with proper evidentiary support and legal justification, must be
17 made with respect to Protected Material that a party seeks to file under seal. The
18 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL
19 does not—without the submission of competent evidence by declaration, establishing
20 that the material sought to be filed under seal qualifies as confidential, privileged, or
21 otherwise protectable—constitute good cause.
22 Further, if a party requests sealing related to a dispositive motion or trial, then
23 compelling reasons, not only good cause, for the sealing must be shown, and the relief
24 sought shall be narrowly tailored to serve the specific interest to be protected. See
25 Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each item
26 or type of information, document, or thing sought to be filed or introduced under seal
27 in connection with a dispositive motion or trial, the party seeking protection must
28 articulate compelling reasons, supported by specific facts and legal justification, for
1 the requested sealing order. Again, competent evidence supporting the application to
2 file documents under seal must be provided by declaration.
3 Any document that is not confidential, privileged, or otherwise protectable in
4 its entirety will not be filed under seal if the confidential portions can be redacted. If
5 documents can be redacted, then a redacted version for public viewing, omitting only
6 the confidential, privileged, or otherwise protectable portions of the document, shall
7 be filed. Any application that seeks to file documents under seal in their entirety
8 should include an explanation of why redaction is not feasible.
9 2. DEFINITIONS
10 2.1 Action: Tarondra Nelson v. Wal-Mart Associates, Inc., a Delaware
11 Corporation, et al.
12 2.2 Challenging Party: a Party or Non-Party that challenges the designation
13 of information or items under this Order.
14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
15 how it is generated, stored or maintained) or tangible things that qualify for protection
16 under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in
17 the Good Cause Statement.
18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
19 support staff).
20 2.5 Designating Party: a Party or Non-Party that designates information or
21 items that it produces in disclosures or in responses to discovery as
22 “CONFIDENTIAL.”
23 2.6 Disclosure or Discovery Material: all items or information, regardless of
24 the medium or manner in which it is generated, stored, or maintained (including,
25 among other things, testimony, transcripts, and tangible things), that are produced or
26 generated in disclosures or responses to discovery in this matter.
27 / / /
28 / / /
1 2.7 Expert: a person with specialized knowledge or experience in a matter
2 pertinent to the litigation who has been retained by a Party or its counsel to serve as
3 an expert witness or as a consultant in this Action.
4 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in
5 this Action, with or without prejudice; and (2) final judgment herein after the
6 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
7 this Action, including the time limits for filing any motions or applications for
8 extension of time pursuant to applicable law.
9 2.9 In-House Counsel: attorneys who are employees of a party to this Action.
10 In-House Counsel does not include Outside Counsel of Record or any other outside
11 counsel.
12 2.10 Non-Party: any natural person, partnership, corporation, association, or
13 other legal entity not named as a Party to this action.
14 2.11 Outside Counsel of Record: attorneys who are not employees of a party
15 to this Action but are retained to represent or advise a party to this Action and have
16 appeared in this Action on behalf of that party or are affiliated with a law firm which
17 has appeared on behalf of that party, and includes support staff.
18 2.12 Party: any party to this Action, including all of its officers, directors,
19 employees, consultants, retained experts, and Outside Counsel of Record (and their
20 support staffs).
21 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
22 Discovery Material in this Action.
23 2.14 Professional Vendors: persons or entities that provide litigation- support
24 services (e.g., photocopying, videotaping, translating, preparing exhibits or
25 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
26 their employees and subcontractors.
27 2.15 Protected Material: any Disclosure or Discovery Material that is
28 designated as “CONFIDENTIAL.”
1 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
2 from a Producing Party.
3 3. SCOPE
4 The protections conferred by this Stipulation and Order cover not only
5 Protected Material (as defined above), but also (1) any information copied or
6 extracted from Protected Material; (2) all copies, excerpts, summaries, or
7 compilations of Protected Material; and (3) any testimony, conversations, or
8 presentations by Parties or their Counsel that might reveal Protected Material.
9 Any use of Protected Material at trial shall be governed by the orders of the
10 trial judge. This Stipulated Protective Order does not govern the use of Protected
11 Material at trial.
12 4. TRIAL AND DURATION
13 The terms of this Stipulated Protective Order apply through Final Disposition
14 of the Action.
15 ONCE A CASE PROCEEDS TO TRIAL, INFORMATION THAT WAS
16 DESIGNATED AS CONFIDENTIAL OR MAINTAINED PURSUANT TO
17 THIS STIPULATED PROTECTIVE ORDER AND USED OR INTRODUCED
18 AS AN EXHIBIT AT TRIAL BECOMES PUBLIC AND WILL BE
19 PRESUMPTIVELY AVAILABLE TO ALL MEMBERS OF THE PUBLIC,
20 INCLUDING THE PRESS, UNLESS COMPELLING REASONS
21 SUPPORTED BY SPECIFIC FACTUAL FINDINGS TO PROCEED
22 OTHERWISE ARE MADE TO THE TRIAL JUDGE IN ADVANCE OF THE
23 TRIAL. SEE KAMAKANA, 447 F.3D AT 1180–81 (DISTINGUISHING “GOOD
24 CAUSE” SHOWING FOR SEALING DOCUMENTS PRODUCED IN
25 DISCOVERY FROM “COMPELLING REASONS” STANDARD WHEN
26 MERITS-RELATED DOCUMENTS ARE PART OF COURT RECORD).
27 ACCORDINGLY, FOR SUCH MATERIALS, THE TERMS OF THIS
28 / / /
1 STIPULATED PROTECTIVE ORDER DO NOT EXTEND BEYOND THE
2 COMMENCEMENT OF THE TRIAL.
3 Even after Final Disposition of this litigation, the confidentiality obligations
4 imposed by this Stipulated Protective Order shall remain in effect until a Designating
5 Party agrees otherwise in writing or a court order otherwise directs.
6 5. DESIGNATING PROTECTED MATERIAL
7 5.1 Exercise of Restraint and Care in Designating Material for Protection.
8 Each Party or Non-Party that designates information or items for protection under this
9 Order must take care to limit any such designation to specific material that qualifies
10 under the appropriate standards. The Designating Party must designate for protection
11 only those parts of material, documents, items, or oral or written communications that
12 qualify so that other portions of the material, documents, items, or communications
13 for which protection is not warranted are not swept unjustifiably within the ambit of
14 this Order.
15 Mass, indiscriminate, or routinized designations are prohibited. Designations
16 that are shown to be clearly unjustified or that have been made for an improper
17 purpose (e.g., to unnecessarily encumber the case development process or to impose
18 unnecessary expenses and burdens on other parties) may expose the Designating
19 Party to sanctions.
20 If it comes to a Designating Party’s attention that information or items that it
21 designated for protection do not qualify for protection, that Designating Party must
22 promptly notify all other Parties that it is withdrawing the inapplicable designation.
23 5.2 Manner and Timing of Designations. Except as otherwise provided in
24 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below),
25 or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies
26 for protection under this Stipulated Protective Order must be clearly so designated
27 before the material is disclosed or produced.
28 / / /
1 Designation in conformity with this Stipulated Protective Order requires:
2 (a) for information in documentary form (e.g., paper or electronic
3 documents, but excluding transcripts of depositions or other pretrial or trial
4 proceedings), that the Producing Party affix at a minimum, the legend
5 “CONFIDENTIAL” to each page that contains protected material. If only a portion
6 or portions of the material on a page qualifies for protection, the Producing Party also
7 must clearly identify the protected portion(s) (e.g., by making appropriate markings
8 in the margins).
9 A Party or Non-Party that makes original documents available for inspection
10 need not designate them for protection until after the inspecting Party has indicated
11 which documents it would like copied and produced. During the inspection and
12 before the designation, all of the material made available for inspection shall be
13 deemed CONFIDENTIAL. After the inspecting Party has identified the documents
14 it wants copied and produced, the Producing Party must determine which documents,
15 or portions thereof, qualify for protection under this Stipulated Protective Order.
16 Then, before producing the specified documents, the Producing Party must affix the
17 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a
18 portion or portions of the material on a page qualifies for protection, the Producing
19 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
20 markings in the margins).
21 (b) for testimony given in depositions that the Designating Party identify the
22 Disclosure or Discovery Material on the record, before the close of the deposition all
23 protected testimony.
24 (c) for information produced in some form other than documentary and for
25 any other tangible items, that the Producing Party affix in a prominent place on the
26 exterior of the container or containers in which the information is stored the
27 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants
28 / / /
1 protection, the Producing Party, to the extent practicable, shall identify the protected
2 portion(s).
3 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
4 failure to designate qualified information or items does not, standing alone, waive the
5 Designating Party’s right to secure protection under this Order for such material. Upon
6 timely correction of a designation, the Receiving Party must make reasonable efforts
7 to assure that the material is treated in accordance with the provisions of this Stipulated
8 Protective Order.
9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
11 designation of confidentiality at any time that is consistent with the court’s
12 Scheduling Order.
13 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
14 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge
15 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2
16 6.3 The burden of persuasion in any such challenge proceeding shall be on
17 the Designating Party. Frivolous challenges, and those made for an improper purpose
18 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
19 expose the Challenging Party to sanctions. Unless the Designating Party has waived
20 or withdrawn the confidentiality designation, all parties shall continue to afford the
21 material in question the level of protection to which it is entitled under the Producing
22 Party’s designation until the court rules on the challenge.
23 7. ACCESS TO AND USE OF PROTECTED MATERIAL
24 7.1 Basic Principles. A Receiving Party may use Protected Material that is
25 disclosed or produced by another Party or by a Non-Party in connection with this
26
27
2 Judge Christensen’s Procedures are available at
28
1 Action only for prosecuting, defending, or attempting to settle this Action. Such
2 Protected Material may be disclosed only to the categories of persons and under the
3 conditions described in this Order. When the Action reaches a Final Disposition, a
4 Receiving Party must comply with the provisions of section 13 below.
5 Protected Material must be stored and maintained by a Receiving Party at a
6 location and in a secure manner that ensures that access is limited to the persons
7 authorized under this Stipulated Protective Order.
8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
9 otherwise ordered by the court or permitted in writing by the Designating Party, a
10 Receiving Party may disclose any information or item designated
11 “CONFIDENTIAL” only:
12 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as
13 well as employees of said Outside Counsel of Record to whom it is reasonably
14 necessary to disclose the information for this Action;
15 (b) to the officers, directors, and employees (including House Counsel) of
16 the Receiving Party to whom disclosure is reasonably necessary for this Action;
17 (c) to Experts (as defined in this Order) of the Receiving Party to whom
18 disclosure is reasonably necessary for this Action and who have signed the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20 (d) to the court and its personnel;
21 (e) to court reporters and their staff;
22 (f) to professional jury or trial consultants, mock jurors, and Professional
23 Vendors to whom disclosure is reasonably necessary for this Action and who have
24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (g) to the author or recipient of a document containing the information or a
26 custodian or other person who otherwise possessed or knew the information;
27 (h) during their depositions, to witnesses, and attorneys for witnesses, in the
28 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party
1 requests that the witness sign the “Acknowledgment and Agreement to Be Bound”
2 (Exhibit A); and (2) the witness will not be permitted to keep any confidential
3 information unless they sign the “Acknowledgment and Agreement to Be Bound”
4 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court.
5 Pages of transcribed deposition testimony or exhibits to depositions that reveal
6 Protected Material may be separately bound by the court reporter and may not be
7 disclosed to anyone except as permitted under this Stipulated Protective Order; and
8 (i) to any mediator or settlement officer, and their supporting personnel,
9 mutually agreed upon by any of the parties engaged in settlement discussions.
10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
11 PRODUCED IN OTHER LITIGATION
12 If a Party is served with a subpoena or a court order issued in other litigation
13 that compels disclosure of any information or items designated in this Action as
14 “CONFIDENTIAL,” that Party must:
15 (a) promptly notify in writing the Designating Party. Such notification shall
16 include a copy of the subpoena or court order;
17 (b) promptly notify in writing the party who caused the subpoena or order
18 to issue in the other litigation that some or all of the material covered by the subpoena
19 or order is subject to this Protective Order. Such notification shall include a copy of
20 this Stipulated Protective Order; and
21 (c) cooperate with respect to all reasonable procedures sought to be pursued
22 by the Designating Party whose Protected Material may be affected.
23 If the Designating Party timely seeks a protective order, the Party served
24 with the subpoena or court order shall not produce any information designated in this
25 action as “CONFIDENTIAL” before a determination by the court from which the
26 subpoena or order issued, unless the Party has obtained the Designating Party’s
27 permission. The Designating Party shall bear the burden and expense of seeking
28 protection in that court of its confidential material and nothing in these provisions
1 should be construed as authorizing or encouraging a Receiving Party in this Action
2 to disobey a lawful directive from another court.
3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 9.1 Application. The terms of this Stipulated Protective Order are applicable
6 to information produced by a Non-Party in this Action and designated as
7 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with
8 this litigation is protected by the remedies and relief provided by this Order. Nothing
9 in these provisions should be construed as prohibiting a Non-Party from seeking
10 additional protections.
11 9.2 Notification. In the event that a Party is required, by a valid discovery
12 request, to produce a Non-Party’s confidential information in its possession, and the
13 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s
14 confidential information, then the Party shall:
15 (a) promptly notify in writing the Requesting Party and the Non-Party that
16 some or all of the information requested is subject to a confidentiality agreement with
17 a Non-Party;
18 (b) make the information requested available for inspection by the Non-
19 Party, if requested.
20 9.3 Conditions of Production. If the Non-Party fails to seek a protective order
21 from this court within 14 days of receiving the notice and accompanying information,
22 the Receiving Party may produce the Non-Party’s confidential information responsive
23 to the discovery request. If the Non-Party timely seeks a protective order, the
24 Receiving Party shall not produce any information in its possession or control that is
25 subject to the confidentiality agreement with the Non-Party before a determination by
26 the court. Absent a court order to the contrary, the Non-Party shall bear the burden
27 and expense of seeking protection in this court of its Protected Material.
28 / / /
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
3 Protected Material to any person or in any circumstance not authorized under this
4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
7 persons to whom unauthorized disclosures were made of all the terms of this Order,
8 and (d) request such person or persons to execute the “Acknowledgment and
9 Agreement to Be Bound” (Exhibit A).
10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
11 PROTECTED MATERIAL
12 When a Producing Party gives notice to Receiving Parties that certain
13 inadvertently produced material is subject to a claim of privilege or other protection,
14 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the
15 Federal Rules of Civil Procedure. This provision is not intended to modify whatever
16 procedure may be established in an e-discovery order that provides for production
17 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules
18 of Evidence, insofar as the parties reach an agreement on the effect of disclosure of a
19 communication or information covered by the attorney-client privilege or work
20 product protection, the parties may incorporate their agreement in the stipulated
21 protective order submitted to the court.
22 12. MISCELLANEOUS
23 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
24 abridges the right of any person to seek its modification by the court in the future.
25 12.2 Right to Assert Other Objections. By stipulating to the entry of this
26 Stipulated Protective Order no Party waives any right it otherwise would have to
27 object to disclosing or producing any information or item on any ground not
28 addressed in this Stipulated Protective Order. Similarly, no Party waives any right to
1 object on any ground to use in evidence of any of the material covered by this
2 Stipulated Protective Order.
3 12.3 Filing Protected Material. A Party that seeks to file under seal any
4 Protected Material must comply with Local Rule 79-5. Protected Material may only
5 be filed under seal pursuant to a court order authorizing the sealing of the specific
6 Protected Material at issue. If a Party's request to file Protected Material under seal
7 is denied by the court, then the Receiving Party may file the information in the public
8 record unless otherwise instructed by the court.
9 13. FINAL DISPOSITION
10 After the Final Disposition of this Action, as defined in paragraph 4, within 60
11 days of a written request by the Designating Party, each Receiving Party must return
12 all Protected Material to the Producing Party or destroy such material. As used in
13 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
14 summaries, and any other format reproducing or capturing any of the Protected
15 Material. Whether the Protected Material is returned or destroyed, the Receiving
16 Party must submit a written certification to the Producing Party (and, if not the same
17 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
18 (by category, where appropriate) all the Protected Material that was returned or
19 destroyed and (2) affirms that the Receiving Party has not retained any copies,
20 abstracts, compilations, summaries or any other format reproducing or capturing any
21 of the Protected Material. Notwithstanding this provision, Counsel is entitled to retain
22 an archival copy of all pleadings, motion papers, trial, deposition, and hearing
23 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
24 reports, attorney work product, and consultant and expert work product, even if such
25 materials contain Protected Material. Any such archival copies that contain or
26 constitute Protected Material remain subject to this Protective Order as set forth in
27 Section 4.
28 / / /
1 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished by any and
3 all appropriate measures including, without limitation, contempt proceedings and/or
4 monetary sanctions.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5
6
7 DATED: April 23, 2025 LAW OFFICES OF WILLIAM D.
HENDRICKS
8
9
10 By: /s/ William D. Hendricks
William D. Hendricks
11
Attorney for Plaintiff TARONDRA
NELSON
12
13
DATED: April 23, 2025 OGLETREE, DEAKINS, NASH, SMOAK &
14 STEWART, P.C.
15
16
By: /s/ James T. Conley
17
James T. Conley
18 Caitlyn B. Emery
ATTORNEYS FOR DEFENDANT
19 WAL-MART ASSOCIATES, INC.
20
ATTESTATION – L.R. 5-4.3.4
21
I attest that all other signatories listed on this signature page, and on whose
22
behalf the filing is submitted, concur in the filing’s content and have authorized the
23
filing.
24
25
Date: April 23, 2025 By: /s/ James T. Conley
26 James T. Conley
27
28
1 ||FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
3|| DATED: April 24, 2025 AA
STEPHANIE S. CHRISTENSEN
United States Magistrate Judge
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14 eT. DOA oe ALIAA eer
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
5 penalty of perjury that I have read in its entirety and understand the Stipulated
6 Protective Order that was issued by the United States District Court for the Central
7 District of California on [date] in the case of __________ [insert formal name
8 of the case and the number and initials assigned to it by the court]. I agree to
9 comply with and to be bound by all the terms of this Stipulated Protective Order and
10 I understand and acknowledge that failure to so comply could expose me to
11 sanctions and punishment in the nature of contempt. I solemnly promise that I will
12 not disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the
14 provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint ________________________ [print or
19 type full name] of _________ [print or type full address and telephone number]
20 as my California agent for service of process in connection with this action or any
21 proceedings related to enforcement of this Stipulated Protective Order.
22 Date:
___________________________
23 City and State where sworn and
24 signed:
___________________________
25
26 Printed name:
___________________________
27 Signature: ___________________________
28