distinguishing “good cause” 27 showing for sealing documents produced in discovery from “compelling reasons” 28 1 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 27 showing for sealing documents produced in discovery from “compelling reasons” 28 1 standard when merits-related documents are part of court record
Written by the judges who cited it.
The opinion
1 Milord A. Keshishian, SBN 197835
milord@milordlaw.com
2 Shirley Matcha, SBN 354003
shirley@milordlaw.com
3 MILORD LAW GROUP, P.C.
333 South Hope Street, Suite 4025
4 Los Angeles, California 90071
Tel: (310) 226-7878
5 Fax: (310) 226-7879
6 Attorneys for Defendant
United Best Sheet Metal, Inc. NOTE: CHANGES MADE BY THE COURT
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 HUNTER KERHART, an individual; Case No.: 2:24−cv−08989-FMO-(ASx)
12 Assigned to the Honorable Alka Sagar
Plaintiff,
13
JOINT MOTION FOR STIPULATED
14 vs.
PROTECTIVE ORDER
15 EXCEPT AS MODIFIED BY THE
UNITED BEST SHEET METAL, INC., a
COURT
16 California Corporation; and DOES 1-10.
17
Defendants.
18
19
20
21
22
23
24
25
26
27
28
1 1. A. PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,
2
proprietary, or private information for which special protection from public
3
disclosure and from use for any purpose other than prosecuting this litigation may
4
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
5
6 grant the following Joint Motion for Stipulated Protective Order (“Stipulated
7 Protective Order”). The parties acknowledge that this Order does not confer
8 blanket protections on all disclosures or responses to discovery and that the
9 protection it affords from public disclosure and use extends only to the limited
10 information or items that are entitled to confidential treatment under the applicable
11 legal principles. The parties further acknowledge, as set forth in Section 12.3,
12 below, that this Stipulated Protective Order does not entitle them to file confidential
13 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
14
followed and the standards that will be applied when a party seeks permission from
15
the court to file material under seal.
16
17
B. GOOD CAUSE STATEMENT
18
This action is likely to involve trade secrets, customer and pricing lists, and
19
other valuable research, development, commercial, financial, and/or proprietary
20
information for which special protection from public disclosure and from use for
21
any purpose other than prosecution of this action is warranted. Such confidential and
22
proprietary materials and information consist of, among other things, confidential
23
business or financial information, information regarding confidential business
24
practices, or other confidential research, development, or commercial information
25
(including information implicating privacy rights of third parties), information
26
otherwise generally unavailable to the public, or which may be privileged or
27
otherwise protected from disclosure under state or federal statutes, court rules, case
28
1 decisions, or common law. Accordingly, to expedite the flow of information, to
2 facilitate the prompt resolution of disputes over confidentiality of discovery
3 materials, to adequately protect information the parties are entitled to keep
4 confidential, to ensure that the parties are permitted reasonable necessary uses of
5 such material in preparation for and in the conduct of trial, to address their handling
6 at the end of the litigation, and serve the ends of justice, a protective order for such
7 information is justified in this matter. It is the intent of the parties that information
8 will not be designated as confidential or attorneys eyes’ only for tactical reasons
9 and that nothing be so designated without a good faith belief that it has been
10 maintained in a confidential, non-public manner, and there is good cause why it
11 should not be part of the public record of this case, or in the case of the most
12 competitively sensitive material, why it should be produced solely on an attorneys’
13 eyes only basis.
14
15
16 2. DEFINITIONS
2.1 Action: Hunter Kerhart v. United Best Sheet Metal, Inc. et al.
17
No. 2:24−cv−08989−FMO−(ASx)
18
2.2 Challenging Party: A Party or Non-Party that challenges the designation of
19
information or items under this Order.
20
2.3 “CONFIDENTIAL” Information or Items: Information (regardless of how it
21
is generated, stored or maintained) or tangible things that qualify for
22
protection under Federal Rule of Civil Procedure 26(c), and as specified
23
above in the Good Cause Statement.
24
2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information
25
or Items: Extremely sensitive “Confidential Information or Items,” disclosure
26
of which to another Party or Non-Party would create a substantial risk of
27
serious harm that could not be avoided by less restrictive means.
28
2.5 Support Staff: any contractor or employee of Counsel’s firm.
1 2.6 Counsel: Outside Counsel of Record (as well as their Support Staff).
2 2.-5- 7 Designating Party: A Party or Non-Party that designates information or items
3 that it produces in disclosures or in responses to discovery as
4 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
5 EYES ONLY.”
6 2.-6- 8 Disclosure or Discovery Material: All items or information, regardless of the
7 medium or manner in which it is generated, stored, or maintained (including,
8 among other things, testimony, transcripts, and tangible things), that are
9 produced or generated in disclosures or responses to discovery in this matter.
10 2.-7- 9 Expert: A person with specialized knowledge or experience in a matter
11 pertinent to the litigation who has been retained by a Party or its counsel to
12 serve as an expert witness or as a consultant in this Action.
13 2.-8- 10 House Counsel: attorneys who are employees of a party to this Action.
14 House Counsel does not include Outside Counsel of Record or any other
15 outside counsel.
16 2.-9- 11 Non-Party: any natural person, partnership, corporation, association, or other
17 legal entity not named as a Party to this action.
18 2.1-0- 2Outside Counsel of Record: Attorneys who are not employees of a party to
19 this Action but are retained to represent or advise a party to this Action and
20 have appeared in this Action on behalf of that party or are affiliated with a
21 law firm which has appeared on behalf of that party, and includes Support
22 Staff.
23 2.1-1- 3Party: any party to this Action, including all of its officers, directors,
24 employees, consultants, retained experts, and Outside Counsel of Record
25 (and their Support Staff).
26 2.1-2- 4Producing Party: a Party or Non-Party that produces Disclosure or Discovery
27 Material in this Action.
28 2.1-3- 5Professional Vendors: Persons or entities that provide litigation support
1 services (e.g., photocopying, videotaping, translating, preparing exhibits or
2 demonstrations, and organizing, storing, or retrieving data in any form or
3 medium) and their employees and subcontractors.
4 2.1-4- 6 Protected Material: Any Disclosure or Discovery Material that is designated
5 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
6 EYES ONLY.”
7 2.1-5- 7 Receiving Party: a Party that receives Disclosure or Discovery Material from
8 a Producing Party.
9
10 3. SCOPE
11 The protections conferred by this Stipulation and Order cover not only
12 Protected Material (as defined above), but also (1) any information copied or
13 extracted from Protected Material; (2) all copies, excerpts, summaries, or
14 compilations of Protected Material; and (3) any testimony, conversations, or
15 presentations by Parties, Non-Parties, or their Counsel that might reveal Protected
16 Material.
17 Any use of Protected Material at trial will be governed by the orders of the
18 trial judge. This Order does not govern the use of Protected Material at trial.
19
20 4. DURATION
21 Once a case proceeds to trial, all of the information that was designated as
22 confidential or maintained pursuant to this protective order becomes public and will
23 be presumptively available to all members of the public, including the press, unless
24 compelling reasons supported by specific factual findings to proceed otherwise are
25 made to the trial judge in advance of the trial. See Kamakana v. City and County of
26 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
27 showing for sealing documents produced in discovery from “compelling reasons”
28
1 standard when merits-related documents are part of court record). Accordingly, the
2 terms of this protective order do not extend beyond the commencement of the trial.
3
4
5 5. DESIGNATING PROTECTED MATERIAL
6 5.1 Exercise of Restraint and Care in Designating Material for Protection.
7 Each Party or Non-Party that designates information or items for protection under
8 this Order must take care to limit any such designation to specific material that
9 qualifies under the appropriate standards. The Designating Party must designate for
10 protection only those parts of material, documents, items, or oral or written
11 communications that qualify so that other portions of the material, documents,
12 items, or communications for which protection is not warranted are not swept
13 unjustifiably within the ambit of this Order.
14 Mass, indiscriminate, or routinized designations are prohibited. Designations
15 that are shown to be clearly unjustified or that have been made for an improper
16 purpose (e.g., to unnecessarily encumber the case development process or to impose
17 unnecessary expenses and burdens on other parties) may expose the Designating
18 Party to sanctions.
19 If it comes to a Designating Party’s attention that information or items that it
20 designated for protection do not qualify for protection, that Designating Party must
21 promptly notify all other Parties that it is withdrawing the inapplicable designation.
22 5.2 Manner and Timing of Designations. Except as otherwise provided in
23 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
24 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
25 under this Order must be clearly so designated before the material is disclosed or
26 produced.
27 Designation in conformity with this Order requires:
28
1 (a) for information in documentary form (e.g., paper or electronic documents,
2 but excluding transcripts of depositions or other pretrial or trial proceedings), that
3 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
4 “CONFIDENTIAL legend”), or “HIGHLY CONFIDENTIAL – ATTORNEYS’
5 EYES ONLY” (“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
6 legend”) to each page that contains protected material. If only a portion or portions
7 of the material on a page qualifies for protection, the Producing Party also must
8 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
9 margins).
10 A Party or Non-Party that makes original documents available for
11 inspection need not designate them for protection until after the inspecting Party has
12 indicated which documents it would like copied and produced. During the
13 inspection and before the designation, all of the material made available for
14 inspection will be deemed “CONFIDENTIAL.” After the inspecting Party has
15 identified the documents it wants copied and produced, the Producing Party must
16 determine which documents, or portions thereof, qualify for protection under this
17 Order. Then, before producing the specified documents, the Producing Party must
18 affix the “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL –
19 ATTORNEYS’ EYES ONLY legend” to each page that contains Protected Material.
20 If only a portion or portions of the material on a page qualifies for protection, the
21 Producing Party also must clearly identify the protected portion(s) (e.g., by making
22 appropriate markings in the margins).
23 (b) for testimony given in depositions that the Designating Party identify the
24 Disclosure or Discovery Material on the record, before the close of the deposition
25 all protected testimony.
26 (c) for information produced in some form other than documentary and for
27 any other tangible items, that the Producing Party affix in a prominent place on the
28 exterior of the container or containers in which the information is stored, or for
electronic files in the file name or accompanying correspondence, the legend
1 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
2 ONLY.” If only a portion or portions of the information warrants protection, the
3 Producing Party, to the extent practicable, will identify the protected portion(s).
4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
5 designate qualified information or items does not, standing alone, waive the
6 Designating Party’s right to secure protection under this Order for such material.
7 Upon timely correction of a designation, the Receiving Party must make reasonable
8 efforts to assure that the material is treated in accordance with the provisions of this
9 Order.
10
11 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
12 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
13 designation of confidentiality at any time that is consistent with the Court’s
14 Scheduling Order.
15 6.2 Meet and Confer. The Challenging Party will initiate the dispute
16 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1
17 et seq.
18 6.3 The burden of persuasion in any such challenge proceeding will be on
19 the Designating Party. Frivolous challenges, and those made for an improper
20 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
21 parties) may expose the Challenging Party to sanctions. Unless the Designating
22 Party has waived or withdrawn the confidentiality designation, all parties will
23 continue to afford the material in question the level of protection to which it is
24 entitled under the Producing Party’s designation until the Court rules on the
25 challenge.
26
27 7. ACCESS TO AND USE OF PROTECTED MATERIAL
28 7.1 Basic Principles. A Receiving Party may use Protected Material that is
1 disclosed or produced by another Party or by a Non-Party in connection with this
2 Action only for prosecuting, defending, or attempting to settle this Action. Such
3 Protected Material may be disclosed only to the categories of persons and under the
4 conditions described in this Order. When the Action has been terminated, a
5 Receiving Party must comply with the provisions of section 13 below (FINAL
6 DISPOSITION).
7 Protected Material must be stored and maintained by a Receiving Party at a
8 location and in a secure manner that ensures that access is limited to the persons
9 authorized under this Order.
10 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
11 otherwise ordered by the court or permitted in writing by the Designating Party, a
12 Receiving Party may disclose any information or item designated
13 “CONFIDENTIAL” only to:
14 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
15 as employees of said Outside Counsel of Record to whom it is reasonably necessary
16 to disclose the information for this Action;
17 (b) the officers, directors, and employees (including House Counsel) of the
18 Receiving Party to whom disclosure is reasonably necessary for this Action;
19 (c) Experts (as defined in this Order) of the Receiving Party to whom
20 disclosure is reasonably necessary for this Action and who have signed the
21 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22 (d) the Court and its personnel;
23 (e) court reporters and their staff;
24 (f) professional jury or trial consultants, mock jurors, and Professional
25 Vendors to whom disclosure is reasonably necessary for this Action and who have
26 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (g) the author or recipient of a document containing the information or a
28 custodian or other person who otherwise possessed or knew the information;
1 (h) during their depositions, witnesses, and attorneys for witnesses, in the
2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
3 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
4 will not be permitted to keep any confidential information unless they sign the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
6 agreed by the Designating Party or ordered by the court. Pages of transcribed
7 deposition testimony or exhibits to depositions that reveal Protected Material may
8 be separately bound by the court reporter and may not be disclosed to anyone except
9 as permitted under this Stipulated Protective Order; and
10 (i) any mediator or settlement officer, and their supporting personnel,
11 mutually agreed upon by any of the parties engaged in settlement discussions.
12 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
13 Information or Items. Unless otherwise ordered by the court or permitted in writing
14 by the Designating Party, a Receiving Party may disclose any information or item
15 designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only to:
16 (a) the Receiving Party’s Outside Counsel of Record, and employees of
17 the Outside Counsel of Record to whom it is reasonably necessary to disclose the
18 information for this Action;
19 (b) Experts (as defined in this Order) of the Receiving Party to whom
20 disclosure is reasonably necessary for this Action and who have signed the
21 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22 (c) the Court and its personnel;
23 (d) court reporters and their staff;
24 (e) professional jury or trial consultants and Professional Vendors to
25 whom disclosure is reasonably necessary for this Action and who have signed the
26 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (f) the author or recipient of a document containing the information or a
28 custodian or other person who otherwise possessed or knew the information;
1 (g) the Designating party’s own employees, officers, directors, and/or
2 Rule 30(b)(6) representative(s);
3 (h) during their depositions, witnesses, and attorneys for witnesses, in the
4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
5 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
6 will not be permitted to keep any confidential information unless they sign the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
8 agreed by the Designating Party or ordered by the court. Pages of transcribed
9 deposition testimony or exhibits to depositions that reveal Protected Material may
10 be separately bound by the court reporter and may not be disclosed to anyone except
11 as permitted under this Stipulated Protective Order; and
12 (i) any mediator or settlement officer, and their supporting personnel,
13 mutually agreed upon by the parties engaged in settlement discussions.
14
15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
16 OTHER LITIGATION
17 If a Party is served with a subpoena or a court order issued in other litigation
18 that compels disclosure of any information or items designated in this Action as
19 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
20 ONLY,” that Party must:
21 (a) promptly notify in writing the Designating Party. Such notification
22 shall include a copy of the subpoena or court order;
23 (b) promptly notify in writing the party who caused the subpoena or order
24 to issue in the other litigation that some or all of the material covered by the
25 subpoena or order is subject to this Protective Order. Such notification will include a
26 copy of this Stipulated Protective Order; and
27 (c) cooperate with respect to all reasonable procedures sought to be
28 pursued by the Designating Party whose Protected Material may be affected.
1 If the Designating Party timely seeks a protective order, the Party served
2 with the subpoena or court order will not produce any information designated in
3 this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
4 ATTORNEYS’ EYES ONLY” before a determination by the court from which the
5 subpoena or order issued, unless the Party has obtained the Designating Party’s
6 permission. The Designating Party will bear the burden and expense of seeking
7 protection in that court of its confidential material and nothing in these provisions
8 should be construed as authorizing or encouraging a Receiving Party in this Action
9 to disobey a lawful directive from another court.
10 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
11 PRODUCED IN THIS LITIGATION
12 (a) The terms of this Order are applicable to information produced by a Non-
13 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
14 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by
15 Non-Parties in connection with this litigation is protected by the remedies and relief
16 provided by this Order. Nothing in these provisions should be construed as
17 prohibiting a Non-Party from seeking additional protections.
18 (b) In the event that a Party is required, by a valid discovery request, to
19 produce a Non-Party’s confidential information in its possession, and the Party is
20 subject to an agreement with the Non-Party not to produce the Non-Party’s
21 confidential information, then the Party will:
22 (1) promptly notify in writing the Requesting Party and the Non-Party that
23 some or all of the information requested is subject to a confidentiality agreement
24 with a Non-Party;
25 (2) promptly provide the Non-Party with a copy of the Stipulated
26 Protective Order in this Action, the relevant discovery request(s), and a reasonably
27 specific description of the information requested; and
28 (3) make the information requested available for inspection by the Non-
1 Party, if requested.
2 (c) If the Non-Party fails to seek a protective order from this court within 14 days
3 of receiving the notice and accompanying information, the Receiving Party may
4 produce the Non-Party’s confidential information responsive to the discovery
5 request. If the Non-Party timely seeks a protective order, the Receiving Party will
6 not produce any information in its possession or control that is subject to the
7 confidentiality agreement with the Non-Party before a determination by the court.
8 Absent a court order to the contrary, the Non-Party will bear the burden and expense
9 of seeking protection in this court of its Protected Material.
10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
12 Protected Material to any person or in any circumstance not authorized under this
13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
16 persons to whom unauthorized disclosures were made of all the terms of this Order,
17 and (d) request such person or persons to execute the “Acknowledgment and
18 Agreement to Be Bound” that is attached hereto as Exhibit A.
19
20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
21 PROTECTED MATERIAL
22 When a Producing Party gives notice to Receiving Parties that certain
23 inadvertently produced material is subject to a claim of privilege or other protection,
24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
26 may be established in an e-discovery order that provides for production without
27 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
28 as the parties reach an agreement on the effect of disclosure of a communication or
1 information covered by the attorney-client privilege or work product protection, the
2 parties may incorporate their agreement in the stipulated protective order submitted
3 to the court.
4
5 12. MISCELLANEOUS
6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
7 person to seek its modification by the Court in the future.
8 12.2 Right to Assert Other Objections. By stipulating to the entry of this
9 Protective Order no Party waives any right it otherwise would have to object to
10 disclosing or producing any information or item on any ground not addressed in this
11 Stipulated Protective Order. Similarly, no Party waives any right to object on any
12 ground to use in evidence of any of the material covered by this Protective Order.
13 12.3 Filing Protected Material. A Party that seeks to file under seal any
14 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
15 only be filed under seal pursuant to a court order authorizing the sealing of the
16 specific Protected Material at issue. If a Party's request to file Protected Material
17 under seal is denied by the court, then the Receiving Party may file the information
18 in the public record unless otherwise instructed by the court.
19 13. FINAL DISPOSITION
20 Final disposition will be deemed to be the later of (1) dismissal of all claims and defenses in this
Action, with or without prejudice; and (2) final judgment herein after the completion and exhaustion of
21
all appeals, rehearings, remands, trials, or reviews of this Action, including the time limits for filing any
22
motions or applications for extension of time pursuant to applicable law. After the final disposition of
23
this Action, as defined in paragraph 4, within 60 days of a written request by the Designating Party, each
24
Receiving Party must return all Protected Material to the Producing Party or destroy such material. As
25
used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, summaries,
26 and any other format reproducing or capturing any of the Protected Material. Whether the Protected
27 Material is returned or destroyed, the Receiving Party must submit a written certification to the
28 Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline
that (1) identifies (by category, where appropriate) all the Protected Material that was returned or
1 destroyed and (2) affirms that the Receiving Party has not retained any copies,
2 abstracts, compilations, summaries or any other format reproducing or capturing any
3 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
4 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
5 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
6 reports, attorney work product, and consultant and expert work product, even if such
7 materials contain Protected Material. Any such archival copies that contain or
8 constitute Protected Material remain subject to this Protective Order as set forth in
9 Section 4 (DURATION).
10
11 14. Any violation of this Order may be punished by any and all appropriate
12 measures including, without limitation, contempt proceedings and/or monetary
13 sanctions.
14
15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
16
17
Dated: May 20, 2025 Respectfully submitted,
18
MILORD LAW GROUP, P.C.
19
/s/ Milord A. Keshishian
20 Milord A. Keshishian
Attorneys for Defendant
21
UNITED BEST SHEET METAL,
22 INC.
23
24
Dated: May 20, 2025 DONIGER / BURROUGHS
25
/s/Stephen Doniger
26 Stephen M. Doniger
Attorneys for Plaintiff
27
HUNTER KERHART
28
1 FOR GOOD CAUSE SHOWN, THE JOINT MOTION FOR STIPULATED
2 PROTECTIVE ORDER IS GRANTED AND IT IS SO ORDERED.
3
4
DATED: _M__a_y_ 2_1_,_ 2_0_2_5__ _________/_s/_ S__ag_a_r_____________________
5 HON. ALKA SAGAR
6 United States Magistrate Judge
7
8 Attestation Pursuant to L.R. 5-4.3.4(a)(2)(i)
9 I hereby attest that all other signatories listed, and on whose behalf the filing
10 is submitted, concur in the filing’s content and have authorized the filing.
11
12 Dated: May 20, 2025 /s/ Milord A. Keshishian
13 Milord A. Keshishian
14
15
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28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [full name], of _________________
5 [full address], declare under penalty of perjury that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States
7 District Court for the Central District of California on ________________, 2025, in
8 the case of Hunter Kerhart. v. United Best Sheet Metal. Inc. et al. No.
9 2:24−cv−08989−FMO−(ASx). I agree to comply with and to be bound by all the
10 terms of this Stipulated Protective Order and I understand and acknowledge that
11 failure to so comply could expose me to sanctions and punishment in the nature of
12 contempt. I solemnly promise that I will not disclose in any manner any information
13 or item that is subject to this Stipulated Protective Order to any person or entity
14 except in strict compliance with the 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 __________________________ [full
19 name] of _______________________________________ [full address and
20 telephone number] as my California agent for service of process in connection with
21 this action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23 Date: _____________________________________________________________
24 City and State where signed: __________________________________________
25 Printed name: ______________________________________________________
26 Signature: _________________________________________________________
27
28