even stipulated 23 protective orders require good cause showing
How later courts described this case
- even stipulated 23 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 EELmIaZilA: BemEcTnHu lVty.@ MeCfsNmUmLlaTwY. c(oSmB N 192455)
2 CHRISTOPHER J. WALDON (SBN 310179)
Email: cwaldon@efsmmlaw.com
3 CHRISTINA M. TROTZ (SBN 354732)
Email: ctrotz@efsmmlaw.com
4 EVANS FEARS SCHUTTERT MCNULTY MICKUS
1 Park Plaza, Suite 500
5 Irvine, CA 92614
Telephone: (949) 484-7488
6 Facsimile: (949) 966-0706
7 Attorneys for Defendant
FCA US LLC
8
9 Tionna Carvalho (SBN 299010)
tcarvalho@slpattorney.com
10
Elizabeth Larocque (SBN 219977)
11 elarocque@slpattorney.com
STRATEGIC LEGAL PRACTICES
12
1888 Century Park East, 19th Floor
13 Los Angeles, CA 90067
Tel: (310) 929-4900
14
Facsimile: (310) 943-3838
15 emailservices@slpattorney.com
16 Attorneys for Plaintiff
TOMMY T. LOR
17
UNITED STATES DISTRICT COURT
18
CENTRAL DISTRICT OF CALIFORNIA
19
20 TOMMY T. LOR, CASE NO: 2:24−cv−08216 WLH (SSCx)
21 Plaintiff, District Judge: Hon. Wesley L. Hsu
Magistrate Judge: Hon. Stephanie S.
22 vs. Christensen
23 FCA US LLC; and DOES 1 to 10, STIPULATION AND PROTECTIVE
inclusive, ORDER
24
Defendants. Superior Ct. Complaint Filed: 08/22/2024
25 Trial Date: 11/3/2025
26
27
28
1 1. INTRODUCTION
2 1.1 Purposes and Limitations. Discovery in this action is likely
3 to involve production of confidential, proprietary, or private information
4 for which special protection from public disclosure and from use for any
5 purpose other than prosecuting this litigation may be warranted.
6 Accordingly, the parties hereby stipulate to and petition the court to
7 enter the following Stipulated Protective Order. The parties
8 acknowledge that this Order does not confer blanket protections on all
9 disclosures or responses to discovery and that the protection it affords
10 from public disclosure and use extends only to the limited information or
11 items that are entitled to confidential treatment under the applicable
12 legal principles.
13 1.2 Good Cause Statement.
14 This action is likely to involve trade secrets, customer and pricing
15 lists and other valuable research, development, commercial, financial,
16 technical and/or proprietary information for which special protection
17 from public disclosure and from use for any purpose other than
18 prosecution of this action is warranted. Such confidential and
19 proprietary materials and information consist of, among other things,
20 confidential business or financial information, information regarding
21 confidential business practices, or other confidential research,
22 development, or commercial information (including information
23 implicating privacy rights of third parties), information otherwise
24 generally unavailable to the public, or which may be privileged or
25 otherwise protected from disclosure under state or federal statutes,
26 court rules, case decisions, or common law. Accordingly, to expedite the
27 flow of information, to facilitate the prompt resolution of disputes over
28 confidentiality of discovery materials, to adequately protect information
1 the parties are entitled to keep confidential, to ensure that the parties
2 are permitted reasonable necessary uses of such material in preparation
3 for and in the conduct of trial, to address their handling at the end of the
4 litigation, and serve the ends of justice, a protective order for such
5 information is justified in this matter. It is the intent of the parties that
6 information will not be designated as confidential for tactical reasons
7 and that nothing be so designated without a good faith belief that it has
8 been maintained in a confidential, non-public manner, and there is good
9 cause why it should not be part of the public record of this case.
10 1.3 Acknowledgment of Procedure for Filing Under Seal. The
11 parties further acknowledge, as set forth in Section 12.3, below, that this
12 Stipulated Protective Order does not entitle them to file confidential
13 information under seal; Local Rule 79-5 sets forth the procedures that
14 must be followed and the standards that will be applied when a party
15 seeks permission from the court to file material under seal.
16 There is a strong presumption that the public has a right of access
17 to judicial proceedings and records in civil cases. In connection with
18 non-dispositive motions, good cause must be shown to support a filing
19 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
20 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
21 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
22 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
23 protective orders require good cause showing), and a specific showing of
24 good cause or compelling reasons with proper evidentiary support and
25 legal justification, must be made with respect to Protected Material
26 that a party seeks to file under seal. The parties’ mere designation of
27 Disclosure or Discovery Material as CONFIDENTIAL does not—
28 without the submission of competent evidence by declaration,
1 establishing that the material sought to be filed under seal qualifies as
2 confidential, privileged, or otherwise protectable—constitute good
3 cause.
4 Further, if a party requests sealing related to a dispositive motion
5 or trial, then compelling reasons, not only good cause, for the sealing
6 must be shown, and the relief sought shall be narrowly tailored to serve
7 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
8 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
9 information, document, or thing sought to be filed or introduced under
10 seal in connection with a dispositive motion or trial, the party seeking
11 protection must articulate compelling reasons, supported by specific
12 facts and legal justification, for the requested sealing order. Again,
13 competent evidence supporting the application to file documents under
14 seal must be provided by declaration.
15 Any document that is not confidential, privileged, or otherwise
16 protectable in its entirety will not be filed under seal if the confidential
17 portions can be redacted. If documents can be redacted, then a
18 redacted version for public viewing, omitting only the confidential,
19 privileged, or otherwise protectable portions of the document, shall be
20 filed. Any application that seeks to file documents under seal in their
21 entirety should include an explanation of why redaction is not feasible.
22 2. DEFINITIONS
23 2.1 Action: this pending federal lawsuit].
24 2.2 Challenging Party: a Party or Non-Party that challenges the
25 designation of information or items under this Order.
26 2.3 “CONFIDENTIAL” Information or Items: information
27 (regardless of how it is generated, stored or maintained) or tangible
28 things that qualify for protection under Rule 26(c) of the Federal Rules
1 of Civil Procedure, and as specified above in the Good Cause Statement.
2 2.4 Counsel: Outside Counsel of Record and House Counsel (as
3 well as their support staff).
4 2.5 Designating Party: a Party or Non-Party that designates
5 information or items that it produces in disclosures or in responses to
6 discovery as “CONFIDENTIAL.”
7 2.6 Disclosure or Discovery Material: all items or information,
8 regardless of the medium or manner in which it is generated, stored, or
9 maintained (including, among other things, testimony, transcripts, and
10 tangible things), that are produced or generated in disclosures or
11 responses to discovery in this matter.
12 2.7 Expert: a person with specialized knowledge or experience in
13 a matter pertinent to the litigation who has been retained by a Party or
14 its counsel to serve as an expert witness or as a consultant in this
15 Action.
16 2.8 Final Disposition: the later of (1) dismissal of all claims and
17 defenses in this Action, with or without prejudice; and (2) final judgment
18 herein after the completion and exhaustion of all appeals, rehearings,
19 remands, trials, or reviews of this Action, including the time limits for
20 filing any motions or applications for extension of time pursuant to
21 applicable law.
22 2.9 In-House Counsel: attorneys who are employees of a party to
23 this Action. In-House Counsel does not include Outside Counsel of
24 Record or any other outside counsel.
25 2.10 Non-Party: any natural person, partnership, corporation,
26 association, or other legal entity not named as a Party to this action.
27 2.11 Outside Counsel of Record: attorneys who are not employees
28 of a party to this Action but are retained to represent or advise a party
1 to this Action and have appeared in this Action on behalf of that party or
2 are affiliated with a law firm which has appeared on behalf of that
3 party, and includes support staff.
4 2.12 Party: any party to this Action, including all of its officers,
5 directors, employees, consultants, retained experts, and Outside Counsel
6 of Record (and their support staffs).
7 2.13 Producing Party: a Party or Non-Party that produces
8 Disclosure or Discovery Material in this Action.
9 2.14 Professional Vendors: persons or entities that provide
10 litigation- support services (e.g., photocopying, videotaping, translating,
11 preparing exhibits or demonstrations, and organizing, storing, or
12 retrieving data in any form or medium) and their employees and
13 subcontractors.
14 2.15 Protected Material: any Disclosure or Discovery Material
15 that is designated as “CONFIDENTIAL.”
16 2.16 Receiving Party: a Party that receives Disclosure or
17 Discovery Material from a Producing Party.
18 3. SCOPE
19 The protections conferred by this Stipulation and Order cover not
20 only Protected Material (as defined above), but also (1) any information
21 copied or extracted from Protected Material; (2) all copies, excerpts,
22 summaries, or compilations of Protected Material; and (3) any
23 testimony, conversations, or presentations by Parties or their Counsel
24 that might reveal Protected Material.
25 Any use of Protected Material at trial shall be governed by the
26 orders of the trial judge. This Stipulated Protective Order does not
27 govern the use of Protected Material at trial.
28 / / /
1 4. TRIAL AND DURATION
2 The terms of this Stipulated Protective Order apply through Final
3 Disposition of the Action.
4 Once a case proceeds to trial, information that was designated as
5 CONFIDENTIAL or maintained pursuant to this Stipulated Protective
6 Order and used or introduced as an exhibit at trial becomes public and
7 will be presumptively available to all members of the public, including
8 the press, unless compelling reasons supported by specific factual
9 findings to proceed otherwise are made to the trial judge in advance of
10 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good
11 cause” showing for sealing documents produced in discovery from
12 “compelling reasons” standard when merits-related documents are part
13 of court record). Accordingly, for such materials, the terms of this
14 Stipulated Protective Order do not extend beyond the commencement of
15 the trial.
16 Even after Final Disposition of this litigation, the confidentiality
17 obligations imposed by this Stipulated Protective Order shall remain in
18 effect until a Designating Party agrees otherwise in writing or a court
19 order otherwise directs.
20 5. DESIGNATING PROTECTED MATERIAL
21 5.1 Exercise of Restraint and Care in Designating Material for
22 Protection. Each Party or Non-Party that designates information or
23 items for protection under this Order must take care to limit any such
24 designation to specific material that qualifies under the appropriate
25 standards. The Designating Party must designate for protection only
26 those parts of material, documents, items, or oral or written
27 communications that qualify so that other portions of the material,
28 documents, items, or communications for which protection is not
1 warranted are not swept unjustifiably within the ambit of this Order.
2 Mass, indiscriminate, or routinized designations are prohibited.
3 Designations that are shown to be clearly unjustified or that have been
4 made for an improper purpose (e.g., to unnecessarily encumber the case
5 development process or to impose unnecessary expenses and burdens
6 on other parties) may expose the Designating Party to sanctions.
7 If it comes to a Designating Party’s attention that information or
8 items that it designated for protection do not qualify for protection, that
9 Designating Party must promptly notify all other Parties that it is
10 withdrawing the inapplicable designation.
11 5.2 Manner and Timing of Designations. Except as otherwise
12 provided in this Stipulated Protective Order (see, e.g., second paragraph
13 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
14 or Discovery Material that qualifies for protection under this Stipulated
15 Protective Order must be clearly so designated before the material is
16 disclosed or produced.
17 Designation in conformity with this Stipulated Protective Order
18 requires:
19 (a) for information in documentary form (e.g., paper or
20 electronic documents, but excluding transcripts of depositions or other
21 pretrial or trial proceedings), that the Producing Party affix at a
22 minimum, the legend “CONFIDENTIAL” to each page that contains
23 protected material. If only a portion or portions of the material on a
24 page qualifies for protection, the Producing Party also must clearly
25 identify the protected portion(s) (e.g., by making appropriate markings
26 in the margins).
27 A Party or Non-Party that makes original documents available for
28 inspection need not designate them for protection until after the
1 inspecting Party has indicated which documents it would like copied
2 and produced. During the inspection and before the designation, all of
3 the material made available for inspection shall be deemed
4 CONFIDENTIAL. After the inspecting Party has identified the
5 documents it wants copied and produced, the Producing Party must
6 determine which documents, or portions thereof, qualify for protection
7 under this Stipulated Protective Order. Then, before producing the
8 specified documents, the Producing Party must affix the
9 “CONFIDENTIAL” legend to each page that contains Protected
10 Material. If only a portion or portions of the material on a page
11 qualifies for protection, the Producing Party also must clearly identify
12 the protected portion(s) (e.g., by making appropriate markings in the
13 margins).
14 (b) for testimony given in depositions that the Designating
15 Party identify the Disclosure or Discovery Material on the record, before
16 the close of the deposition all protected testimony.
17 (c) for information produced in some form other than
18 documentary and for any other tangible items, that the Producing Party
19 affix in a prominent place on the exterior of the container or containers
20 in which the information is stored the “CONFIDENTIAL” legend. If
21 only a portion or portions of the information warrants protection, the
22 Producing Party, to the extent practicable, shall identify the protected
23 portion(s).
24 5.3 Inadvertent Failures to Designate. If timely corrected, an
25 inadvertent failure to designate qualified information or items does not,
26 standing alone, waive the Designating Party’s right to secure protection
27 under this Order for such material. Upon timely correction of a
28 designation, the Receiving Party must make reasonable efforts to assure
1 that the material is treated in accordance with the provisions of this
2 Stipulated Protective Order.
3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4 6.1 Timing of Challenges. Any Party or Non-Party may
5 challenge a designation of confidentiality at any time that is consistent
6 with the court’s Scheduling Order.
7 6.2 Meet and Confer. The Challenging Party shall initiate the
8 dispute resolution process under Local Rule 37.1 et seq. and with
9 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-
10 Discovery Motion Conference.”1
11 6.3 The burden of persuasion in any such challenge proceeding
12 shall be on the Designating Party. Frivolous challenges, and those
13 made for an improper purpose (e.g., to harass or impose unnecessary
14 expenses and burdens on other parties) may expose the Challenging
15 Party to sanctions. Unless the Designating Party has waived or
16 withdrawn the confidentiality designation, all parties shall continue to
17 afford the material in question the level of protection to which it is
18 entitled under the Producing Party’s designation until the court rules
19 on the challenge.
20 7. ACCESS TO AND USE OF PROTECTED MATERIAL
21 7.1 Basic Principles. A Receiving Party may use Protected
22 Material that is disclosed or produced by another Party or by a Non-
23 Party in connection with this Action only for prosecuting, defending, or
24 attempting to settle this Action. Such Protected Material may be
25 disclosed only to the categories of persons and under the conditions
26 described in this Order. When the Action reaches a Final Disposition, a
27
1 Judge Christensen’s Procedures are available at
28 https://www.cacd.uscourts.gov/honorable-stephanie-s-christensen.
1 Receiving Party must comply with the provisions of section 13 below.
2 Protected Material must be stored and maintained by a Receiving
3 Party at a location and in a secure manner that ensures that access is
4 limited to the persons authorized under this Stipulated Protective
5 Order.
6 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
7 Unless otherwise ordered by the court or permitted in writing by the
8 Designating Party, a Receiving Party may disclose any information or
9 item designated “CONFIDENTIAL” only:
10 (a) to the Receiving Party’s Outside Counsel of Record in this
11 Action, as well as employees of said Outside Counsel of Record to whom
12 it is reasonably necessary to disclose the information for this Action;
13 (b) to the officers, directors, and employees (including House
14 Counsel) of the Receiving Party to whom disclosure is reasonably
15 necessary for this Action;
16 (c) to Experts (as defined in this Order) of the Receiving Party
17 to whom disclosure is reasonably necessary for this Action and who
18 have signed the “Acknowledgment and Agreement to Be Bound”
19 (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
23 Professional Vendors to whom disclosure is reasonably necessary for
24 this Action and who have signed the “Acknowledgment and Agreement
25 to Be Bound” (Exhibit A);
26 (g) to the author or recipient of a document containing the
27 information or a custodian or other person who otherwise possessed or
28 knew the information;
1 (h) during their depositions, to witnesses, and attorneys for
2 witnesses, in the Action to whom disclosure is reasonably necessary,
3 provided: (1) the deposing party requests that the witness sign the
4 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
5 witness will not be permitted to keep any confidential information
6 unless they sign the “Acknowledgment and Agreement to Be Bound”
7 (Exhibit A), unless otherwise agreed by the Designating Party or
8 ordered by the court. Pages of transcribed deposition testimony or
9 exhibits to depositions that reveal Protected Material may be
10 separately bound by the court reporter and may not be disclosed to
11 anyone except as permitted under this Stipulated Protective Order; and
12 (i) to any mediator or settlement officer, and their supporting
13 personnel, mutually agreed upon by any of the parties engaged in
14 settlement discussions.
15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
16 PRODUCED IN OTHER LITIGATION
17 If a Party is served with a subpoena or a court order issued in
18 other litigation that compels disclosure of any information or items
19 designated in this Action as “CONFIDENTIAL,” that Party must:
20 (a) promptly notify in writing the Designating Party. Such
21 notification shall include a copy of the subpoena or court order;
22 (b) promptly notify in writing the party who caused the
23 subpoena or order to issue in the other litigation that some or all of the
24 material covered by the subpoena or order is subject to this Protective
25 Order. Such notification shall include a copy of this Stipulated
26 Protective Order; and
27 (c) cooperate with respect to all reasonable procedures sought to
28 be pursued by the Designating Party whose Protected Material may be
1 affected.
2 If the Designating Party timely seeks a protective order, the
3 Party served with the subpoena or court order shall not produce any
4 information designated in this action as “CONFIDENTIAL” before a
5 determination by the court from which the subpoena or order issued,
6 unless the Party has obtained the Designating Party’s permission. The
7 Designating Party shall bear the burden and expense of seeking
8 protection in that court of its confidential material and nothing in these
9 provisions should be construed as authorizing or encouraging a
10 Receiving Party in this Action to disobey a lawful directive from
11 another court.
12 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
13 BE PRODUCED IN THIS LITIGATION
14 9.1 Application. The terms of this Stipulated Protective
15 Order are applicable to information produced by a Non-Party in
16 this Action and designated as “CONFIDENTIAL.” Such
17 information produced by Non-Parties in connection with this
18 litigation is protected by the remedies and relief provided by this
19 Order. Nothing in these provisions should be construed as
20 prohibiting a Non-Party from seeking additional protections.
21 9.2 Notification. In the event that a Party is required, by a
22 valid discovery request, to produce a Non-Party’s confidential
23 information in its possession, and the Party is subject to an
24 agreement with the Non-Party not to produce the Non-Party’s
25 confidential information, then the Party shall:
26 (a) promptly notify in writing the Requesting Party
27 and the Non-Party that some or all of the information
28 requested is subject to a confidentiality agreement with a
1 Non-Party;
2 (b) make the information requested available for
3 inspection by the Non-Party, if requested.
4 9.3 Conditions of Production. If the Non-Party fails to seek
5 a protective order from this court within 14 days of receiving the
6 notice and accompanying information, the Receiving Party may
7 produce the Non-Party’s confidential information responsive to the
8 discovery request. If the Non-Party timely seeks a protective
9 order, the Receiving Party shall not produce any information in its
10 possession or control that is subject to the confidentiality
11 agreement with the Non-Party before a determination by the court.
12 Absent a court order to the contrary, the Non-Party shall bear the
13 burden and expense of seeking protection in this court of its
14 Protected Material.
15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
16 MATERIAL
17 If a Receiving Party learns that, by inadvertence or otherwise, it
18 has disclosed Protected Material to any person or in any circumstance
19 not authorized under this Stipulated Protective Order, the Receiving
20 Party must immediately (a) notify in writing the Designating Party of
21 the unauthorized disclosures, (b) use its best efforts to retrieve all
22 unauthorized copies of the Protected Material, (c) inform the person or
23 persons to whom unauthorized disclosures were made of all the terms
24 of this Order, and (d) request such person or persons to execute the
25 “Acknowledgment and Agreement to Be Bound” (Exhibit A)
26 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
27 OTHERWISE PROTECTED MATERIAL
28 When a Producing Party gives notice to Receiving Parties that
1 certain inadvertently produced material is subject to a claim of
2 privilege or other protection, the obligations of the Receiving Parties
3 are those set forth in Rule 26(b)(5)(B) of the Federal Rules of Civil
4 Procedure. This provision is not intended to modify whatever
5 procedure may be established in an e-discovery order that provides for
6 production without prior privilege review. Pursuant to Rules 502(d)
7 and (e) of the Federal Rules of Evidence, insofar as the parties reach an
8 agreement on the effect of disclosure of a communication or information
9 covered by the attorney-client privilege or work product protection, the
10 parties may incorporate their agreement in the stipulated protective
11 order submitted to the court.
12 12. MISCELLANEOUS
13 12.1 Right to Further Relief. Nothing in this Stipulated
14 Protective Order abridges the right of any person to seek its
15 modification by the court in the future.
16 12.2 Right to Assert Other Objections. By stipulating to the
17 entry of this Stipulated Protective Order no Party waives any right it
18 otherwise would have to object to disclosing or producing any
19 information or item on any ground not addressed in this Stipulated
20 Protective Order. Similarly, no Party waives any right to object on any
21 ground to use in evidence of any of the material covered by this
22 Stipulated Protective Order.
23 12.3 Filing Protected Material. A Party that seeks to file under
24 seal any Protected Material must comply with Local Rule 79-5.
25 Protected Material may only be filed under seal pursuant to a court
26 order authorizing the sealing of the specific Protected Material at issue.
27 If a Party's request to file Protected Material under seal is denied by
28 the court, then the Receiving Party may file the information in the
1 public record unless otherwise instructed by the court.
2 13. FINAL DISPOSITION
3 After the Final Disposition of this Action, as defined in paragraph
4 4, within 60 days of a written request by the Designating Party, each
5 Receiving Party must return all Protected Material to the Producing
6 Party or destroy such material. As used in this subdivision, “all
7 Protected Material” includes all copies, abstracts, compilations,
8 summaries, and any other format reproducing or capturing any of the
9 Protected Material. Whether the Protected Material is returned or
10 destroyed, the Receiving Party must submit a written certification to
11 the Producing Party (and, if not the same person or entity, to the
12 Designating Party) by the 60 day deadline that (1) identifies (by
13 category, where appropriate) all the Protected Material that was
14 returned or destroyed and (2) affirms that the Receiving Party has not
15 retained any copies, abstracts, compilations, summaries or any other
16 format reproducing or capturing any of the Protected Material.
17 Notwithstanding this provision, Counsel is entitled to retain an
18 archival copy of all pleadings, motion papers, trial, deposition, and
19 hearing transcripts, legal memoranda, correspondence, deposition and
20 trial exhibits, expert reports, attorney work product, and consultant
21 and expert work product, even if such materials contain Protected
22 Material. Any such archival copies that contain or constitute Protected
23 Material remain subject to this Protective Order as set forth in Section
24 4.
25
26
27
28
1) 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished
3 by any and all appropriate measures including, without limitation,
4 contempt proceedings and/or monetary sanctions.
5
6
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8
9 DATED: June 2, 2025 __/s/ Elizabeth Larocque
Elizabeth Larocque
10 Tionna Carvalho
1] Attorney(s) for Plaintiff(s)
12
1, | DATED: June 2, 2025 CO hldle—
Christopher J. Waldon
15 Attorney for Defendant
16
17
18
19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
20
>, | DATED: June 2, 2025
2 STEPHANIE S. CHRISTENSEN
33 United States Magistrate Judge
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-17-
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
6 Stipulated Protective Order that was issued by the United States
7 District Court for the Central District of California on [date] in the
8 case of __________ [insert formal name of the case and the
9 number and initials assigned to it by the court]. I agree to
10 comply with and to be bound by all the terms of this Stipulated
11 Protective Order and I understand and acknowledge that failure to so
12 comply could expose me to sanctions and punishment in the nature of
13 contempt. I solemnly promise that I will not disclose in any manner
14 any information or item that is subject to this Stipulated Protective
15 Order to any person or entity except in strict compliance with the
16 provisions of this Order.
17 I further agree to submit to the jurisdiction of the United States
18 District Court for the Central District of California for the purpose of
19 enforcing the terms of this Stipulated Protective Order, even if such
20 enforcement proceedings occur after termination of this action. I
21 hereby appoint ________________________ [print or type full name]
22 of _________ [print or type full address and telephone number]
23 as my California agent for service of process in connection with this
24 action or any proceedings related to enforcement of this Stipulated
25 Protective Order.
26
27
28
1
2 Date: ___________________________
3 City and State where sworn and
4 signed: ___________________________
5 Printed name: ___________________________
6 Signature: ___________________________
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| CERTIFICATE OF SERVICE
2 I am employed in the County of Orange, State of California. I am over the
age of 18 and nota party to the within action; my business address is | Park Plaza,
3 | Suite 500, Irvine, CA 92614.
4 On June 2, 2025, I served, in the manner indicated below, the foregoing
5 document described as:
6 STIPULATION AND PROTECTIVE ORDER
7 | on the interested parties in this action as follows:
8 BY ELECTRONIC TRANSMISSION: Pursuant to controlling General
Orders and LBR, the foregoing document will be served by the court via
? NEF and hyperlink to the document. On June 2, 2025, I checked the
CM/ECF docket for this proceeding and determined that the following
10 person(s) are on the Electronic Mail Notice List to receive NE
transmission at the email address(es) stated below.
12 || Tionna Carvalho (SBN 299010) Attorneys for Plaintiff
tcarvalho@slpattorney.com TOMMY T. LOR
13 || Elizabeth Larocque (SBN 219977)
14 || clarocque@slpattorney.com
STRATEGIC LEGAL PRACTICES
15 || 1888 Century Park East, 19th Floor
16 || Los Angeles, CA 90067
Tel: (310) 929-4900
17 || Facsimile: (310) 943-3838
1g ||_emailservices@slpattorney.com
19 | Ed (F EDERAL) I declare that I am employed in the office of a member of
the bar of this court at whose direction the service was made.
20
I declare under penalty of petjury under the laws of the State of California
21 | that the above is true and correct. Executed on June 2, 2025 at Irvine, California.
22
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24
25
26
27 Jacquelerfe Zambrano
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