The opinion
1 Mmeegghhaann@ Ct.h Memuruprhpehye y(lSaBwNye 2rs5.9c4o8m7 )
Matthew D. Murphey (SBN 194111)
2 matt@themurpheylawyers.com
Dennis J. Canty (SBN 207978)
3 dennis@themurpheylawyers.com
MURPHEY & MURPHEY, A.P.C.
4 120 Vantis Drive Suite 300
Aliso Viejo, California 92656
5 Telephone: (949) 464-4540
Facsimile: (562)375-6674
6
Attorneys for Plaintiff,
7 William Joiner
8 JONATHAN L. SEGAL (SBN264238)
jonathansegal@dwt.com
9 SAM LACHMAN (SBN 331969)
samlachman@dwt.com
10 DAVIS WRIGHT TREMAINE LLP
350 South Grand Ave., 27th Floor
11 Los Angeles, California 90071-2566
Telephone: (213) 633-6800
12 ABIGAIL EVERDELL (Pro hac vice)
abigaileverdell@dwt.com
13 DAVIS WRIGHT TREMAINE LLP
1251 Avenue of the Americas, 21st Fl.
14 New York, NY 10020
Telephone: (212) 489-8230
15
Attorneys for Defendants
16 ANDREW CALLAGHAN, CHANNEL 5
LLC, EVAN GILBERT-KATZ, AND
17 NICOLAS MOSHER
18
19 UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
20
21 WILLIAM JOINER., an Individual, ) CASE NO.: 8:24-cv-01160-CBM-KS
)
22 ) STIPULATED PROTECTIVE ORDER
Plaintiff, )
23 ) Assigned to Judge:
v. ) Hon. Consuelo B. Marshall
24 )
) Discovery Matters, Magistrate Judge:
25 CHANNEL 5, LLC, et al, ) Hon. Karen L. Stevenson
)
26 )
Defendants. )
27 )
)
28
1 Plaintiff William Joiner (“Plaintiff” or “Mr. Joiner”) and Defendants Andrew
2 Callaghan, Channel 5 LLC, Evan Gilbert-Katz, and Nicolas Mosher (“Defendants”)
3 (together with Plaintiff, the “Parties”) hereby stipulate to the Court’s Preferred Form
4 Protective Order as follows:
5
1. GENERAL
6
1.1 Purposes and Limitations. Discovery in this action is likely to involve production
7
of confidential, proprietary, or private information for which special protection from public
8
disclosure and from use for any purpose other than prosecuting this litigation may be
9
warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the
10
following Stipulated Protective Order. The parties acknowledge that this Order does not
11
confer blanket protections on all disclosures or responses to discovery and that the protection
12
it affords from public disclosure and use extends only to the limited information or items that
13
are entitled to confidential treatment under the applicable legal principles. The parties further
14
acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does
15
not entitle them to file confidential information. Civil Local Rule 79-5 sets forth the
16 procedures that must be followed and the standards that will be applied when a party seeks
17 permission from the court to file material under seal.
18 1.2 Good Cause Statement.
19 This action is likely to involve unpublished newsgathering information, trade secrets,
20 customer and pricing lists and other valuable research, development, commercial, financial,
21 technical and/or proprietary information for which special protection from public disclosure
22 and from use for any purpose other than prosecution of this action is warranted. Such
23 confidential and proprietary materials and information consist of, among other things,
unpublished newsgathering information, confidential business or financial information,
24
information regarding confidential business practices, or other confidential research,
25
development, or commercial information (including information implicating privacy rights
26
of third parties), information otherwise generally unavailable to the public, or which may be
27
privileged or otherwise protected from disclosure under state or federal statutes, court rules,
28
1 case decisions, or common law. Accordingly, to expedite the flow of information, to facilitate
2 the prompt resolution of disputes over confidentiality of discovery materials, to adequately
3 protect information the parties are entitled to keep confidential, to ensure that the parties are
4 permitted reasonable necessary uses of such material in preparation for and in the conduct of
trial, to address their handling at the end of the litigation, and serve the ends of justice, a
5
protective order for such information is justified in this matter. It is the intent of the parties
6
that information will not be designated as confidential for tactical reasons and that nothing
7
be so designated without a good faith belief that it has been maintained in a confidential,
8
non-public manner, and there is good cause why it should not be part of the public record of
9
this case.
10
11
2. DEFINITIONS
12
2.1 Action: Joiner v. Channel 5, LLC, et al, 8:24-cv-01160-CBM-KS.
13
2.2 “ATTORNEYS-EYES ONLY” Information or Items: extremely sensitive
14
“CONFIDENTIAL” Information or Items, the disclosure of which to another Party or Non-
15
Party would create a substantial risk of serious harm that could not be avoided by less
16 restrictive means.
17 2.3 Challenging Party: a Party or Non-Party that challenges the designation of
18 information or items under this Order.
19 2.4 “CONFIDENTIAL” Information or Items: information (regardless of how it is
20 generated, stored or maintained) or tangible things that qualify for protection under Federal
21 Rule of Civil Procedure 26(c), and as specified above in the Good Cause Statement.
22 2.5 Counsel: Outside Counsel of Record (as well as their support staff).
23 2.6 Designating Party: a Party or Non-Party that designates information or items that
it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
24
2.7 Disclosure or Discovery Material: all items or information, regardless of the
25
medium or manner in which it is generated, stored, or maintained (including, among other
26
things, testimony, transcripts, and tangible things), that are produced or generated in
27
disclosures or responses to discovery in this matter.
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1 2.8 Expert: a person with specialized knowledge or experience in a matter pertinent
2 to the litigation who has been retained by a Party or its counsel to serve as an expert witness
3 or as a consultant in this Action.
4 2.9 House Counsel: attorneys who are employees of a party to this Action. House
Counsel does not include Outside Counsel of Record or any other outside counsel.
5
2.10 Non-Party: any natural person, partnership, corporation, association, or other
6
legal entity not named as a Party to this action.
7
2.11 Outside Counsel of Record: attorneys who are not employees of a party to this
8
Action but are retained to represent or advise a party to this Action and have appeared in this
9
Action on behalf of that party or are affiliated with a law firm that has appeared on behalf of
10
that party, including support staff.
11
2.12 Party: any party to this Action, including all of its officers, directors, employees,
12
consultants, retained experts, and Outside Counsel of Record (and their support staffs).
13
2.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
14
Material in this Action.
15
2.14 Professional Vendors: persons or entities that provide litigation support services
16 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
17 organizing, storing, or retrieving data in any form or medium) and their employees and
18 subcontractors.
19 2.15 Protected Material: any Disclosure or Discovery Material that is designated as
20 “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.”
21 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material from a
22 Producing Party.
23
3. SCOPE
24
The protections conferred by this Stipulation and Order cover not only Protected
25
Material (as defined above), but also (1) any information copied or extracted from Protected
26
Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3)
27
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1 any testimony, conversations, or presentations by Parties or their Counsel that might reveal
2 Protected Material.
3 Any use of Protected Material at trial shall be governed by the orders of the trial judge.
4 This Order does not govern the use of Protected Material at trial.
5
4. DURATION
6
Once a case proceeds to trial, all of the court-filed information to be introduced that
7
was previously designated as confidential or maintained pursuant to this protective order
8
becomes public and will be presumptively available to all members of the public, including
9
the press, unless compelling reasons supported by specific factual findings to proceed
10
otherwise are made to the trial judge in advance of the trial. See Kamakana v. City and Cty.
11
of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing
12
for sealing documents produced in discovery from “compelling reasons” standard when
13
merits-related documents are part of court record). Accordingly, the terms of this protective
14
order do not extend beyond the commencement of the trial.
15
16 5. DESIGNATING PROTECTED MATERIAL
17 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party
18 or Non-Party that designates information or items for protection under this Order must take
19 care to limit any such designation to specific material that qualifies under the appropriate
20 standards. The Designating Party must designate for protection only those parts of material,
21 documents, items, or oral or written communications that qualify so that other portions of
22 the material, documents, items, or communications for which protection is not warranted are
23 not swept unjustifiably within the ambit of this Order.
Mass, indiscriminate, or routinized designations are prohibited. Designations that are
24
shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
25
unnecessarily encumber the case development process or to impose unnecessary expenses
26
and burdens on other parties) may expose the Designating Party to sanctions.
27
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1 If it comes to a Designating Party’s attention that information or items that it
2 designated for protection do not qualify for protection, that Designating Party must promptly
3 notify all other Parties that it is withdrawing the inapplicable designation.
4 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order
(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
5
Disclosure or Discovery Material that qualifies for protection under this Order must be
6
clearly so designated before the material is disclosed or produced.
7
Designation in conformity with this Order requires:
8
(a) for information in documentary form (e.g., paper or electronic documents, but
9
excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing
10
Party affix, at a minimum, the legend “CONFIDENTIAL” or “ATTORNEYS’ EYES
11
ONLY” (hereinafter “CONFIDENTIAL legend” or “AEO legend”), to each page that
12
contains protected material. If only a portion or portions of the material on a page qualifies
13
for protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
14
by making appropriate markings in the margins).
15
A Party or Non-Party that makes original documents available for inspection need not
16 designate them for protection until after the inspecting Party has indicated which documents
17 it would like copied and produced. During the inspection and before the designation, all of
18 the material made available for inspection shall be deemed “CONFIDENTIAL.” After the
19 inspecting Party has identified the documents it wants copied and produced, the Producing
20 Party must determine which documents, or portions thereof, qualify for protection under this
21 Order. Then, before producing the specified documents, the Producing Party must affix the
22 “CONFIDENTIAL legend” or “AEO legend” to each page that contains Protected Material.
23 If only a portion or portions of the material on a page qualifies for protection, the Producing
Party also must clearly identify the protected portion(s) (e.g., by making appropriate
24
markings in the margins).
25
(b) for testimony given in depositions that the Designating Party identify the
26
Disclosure or Discovery Material on the record, before the close of the deposition.
27
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1 (c) for information produced in some form other than documentary and for any other
2 tangible items, that the Producing Party affix in a prominent place on the exterior of the
3 container or containers in which the information is stored the as “CONFIDENTIAL” or
4 “ATTORNEYS EYES ONLY” (as the case may be). If only a portion or portions of the
information warrants protection, the Producing Party, to the extent practicable, shall identify
5
the protected portion(s).
6
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
7
designate qualified information or items does not, standing alone, waive the Designating
8
Party’s right to secure protection under this Order for such material. Upon timely correction
9
of a designation, the Receiving Party must make reasonable efforts to assure that the material
10
is treated in accordance with the provisions of this Order.
11
12
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
13
6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
14
confidentiality at any time that is consistent with the Court’s Scheduling Order.
15
6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
16 process under Local Rule 37-1, et seq. Any discovery motion must strictly comply with the
17 procedures set forth in Local Rules 37-1, 37-2, and 37-3.
18 6.3 Burden. The burden of persuasion in any such challenge proceeding shall be on
19 the Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
20 to harass or impose unnecessary expenses and burdens on other parties) may expose the
21 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the
22 confidentiality designation, all parties shall continue to afford the material in question the
23 level of protection to which it is entitled under the Producing Party’s designation until the
Court rules on the challenge.
24
25
7. ACCESS TO AND USE OF PROTECTED MATERIAL
26
7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed
27
or produced by another Party or by a Non-Party in connection with this Action only for
28
1 prosecuting, defending, or attempting to settle this Action. Such Protected Material may be
2 disclosed only to the categories of persons and under the conditions described in this Order.
3 When the Action has been terminated, a Receiving Party must comply with the provisions
4 of section 13 below (FINAL DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a location
5
and in a secure manner that ensures that access is limited to the persons authorized under this
6
Order.
7
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
8
ordered by the Court or permitted in writing by the Designating Party, a Receiving Party may
9
disclose any information or item designated “CONFIDENTIAL” only to:
10
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
11
employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose
12
the information for this Action;
13
(b) the officers, directors, and employees (including House Counsel) of the Receiving
14
Party to whom disclosure is reasonably necessary for this Action;
15
(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
16 reasonably necessary for this Action and who have signed the “Acknowledgment and
17 Agreement to Be Bound” (Exhibit A);
18 (d) the Court and its personnel;
19 (e) court reporters and their staff;
20 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to
21 whom disclosure is reasonably necessary for this Action and who have signed the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
23 (g) the author or recipient of a document containing the information or a custodian or
other person who otherwise possessed or knew the information;
24
(h) during their depositions, witnesses, and attorneys for witnesses, in the Action to
25
whom disclosure is reasonably necessary provided: (1) the deposing party requests that the
26
witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted to keep
27
any confidential information unless they sign the “Acknowledgment and Agreement to Be
28
1 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the
2 Court. Pages of transcribed deposition testimony or exhibits to depositions that reveal
3 Protected Material may be separately bound by the court reporter and may not be disclosed
4 to anyone except as permitted under this Stipulated Protective Order; and
(i) any mediator or settlement officer, and their supporting personnel, mutually agreed
5
upon by any of the parties engaged in settlement discussions.
6
7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
7
Information or Items. Unless otherwise ordered by the Court or permitted in writing by the
8
Designating Party, a Receiving Party may disclose any information or item designated
9
“HIGHLY CONFIDENTIAL” only to:
10
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well
11
as employees of said Outside Counsel of Record to whom it is reasonably necessary to
12
disclose the information for this Action;
13
(b) Experts (as defined in this Order) of the Receiving Party to whom
14
disclosure is reasonably necessary for this Action and who have signed the
15
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
16 (c) the Court and its personnel;
17 (d) private court reporters and their staff to whom disclosure is reasonably
18 necessary for this Action and who have signed the “Acknowledgment and Agreement to Be
19 Bound” (Exhibit A);
20 (e) professional jury or trial consultants, mock jurors, and Professional
21 Vendors to whom disclosure is reasonably necessary for this Action and who have signed the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
23 (f) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information; and
24
(g) any mediator or settlement officer, and their supporting personnel,
25
mutually agreed upon by any of the parties engaged in settlement discussions.
26
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1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
2 OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation that
4 compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL,” or “ATTORNEYS’ EYES ONLY” (as the case may be), that Party
5
must:
6
(a) promptly notify in writing the Designating Party. Such notification shall include a
7
copy of the subpoena or court order;
8
(b) promptly notify in writing the party who caused the subpoena or order to issue in
9
the other litigation that some or all of the material covered by the subpoena or order is subject
10
to this Protective Order. Such notification shall include a copy of this Stipulated Protective
11
Order; and
12
(c) cooperate with respect to all reasonable procedures sought to be pursued by the
13
Designating Party whose Protected Material may be affected.
14
If the Designating Party timely seeks a protective order, the Party served with the
15
subpoena or court order shall not produce any information designated in this action as
16 “CONFIDENTIAL” or “ATTORNEYS EYES ONLY” before a determination by the court
17 from which the subpoena or order issued, unless the Party has obtained the Designating
18 Party’s permission. The Designating Party shall bear the burden and expense of seeking
19 protection in that court of its confidential material and nothing in these provisions should be
20 construed as authorizing or encouraging a Receiving Party in this Action to disobey a lawful
21 directive from another court.
22
23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN
THIS LITIGATION
24
(a) The terms of this Order are applicable to information produced by a Non-Party in
25
this Action and designated as “CONFIDENTIAL” or “ATTORNEYS EYES ONLY.” Such
26
information produced by Non-Parties in connection with this litigation is protected by the
27
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1 remedies and relief provided by this Order. Nothing in these provisions should be construed
2 as prohibiting a Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to produce a
4 Non-Party’s confidential information in its possession, and the Party is subject to an
agreement with the Non-Party not to produce the Non-Party’s confidential information, then
5
the Party shall:
6
(1) promptly notify in writing the Requesting Party and the Non-Party that some or
7
all of the information requested is subject to a confidentiality agreement with a Non-Party;
8
(2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in
9
this Action, the relevant discovery request(s), and a reasonably specific description of the
10
information requested; and
11
(3) make the information requested available for inspection by the Non-Party, if
12
requested.
13
(c) If the Non-Party fails to seek a protective order from this Court within 14 days of
14
receiving the notice and accompanying information, the Receiving Party may produce the
15
Non-Party’s confidential information responsive to the discovery request. If the Non-Party
16 timely seeks a protective order, the Receiving Party shall not produce any information in its
17 possession or control that is subject to the confidentiality agreement with the Non-Party
18 before a determination by the Court. Absent a court order to the contrary, the Non-Party shall
19 bear the burden and expense of seeking protection in this Court of its Protected Material.
20
21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
23 Protected Material to any person or in any circumstance not authorized under this Stipulated
Protective Order, the Receiving Party must immediately (a) notify in writing the Designating
24
Party of the unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized
25
copies of the Protected Material, (c) inform the person or persons to whom unauthorized
26
disclosures were made of all the terms of this Order, and (d) request such person or persons
27
28
1 to execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto as
2 Exhibit A.
3
4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL
5
When a Producing Party gives notice to Receiving Parties that certain inadvertently
6
produced material is subject to a claim of privilege or other protection, the obligations of the
7
Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
8
provision is not intended to modify whatever procedure may be established in an e-discovery
9
order that provides for production without prior privilege review. Pursuant to Federal Rule
10
of Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of
11
disclosure of a communication or information covered by the attorney-client privilege or
12
work product protection, the parties may incorporate their agreement in the stipulated
13
protective order submitted to the Court.
14
15 12. MISCELLANEOUS
16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to
17 seek its modification by the Court in the future.
18 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
19 Order, no Party waives any right it otherwise would have to object to disclosing or producing
20 any information or item on any ground not addressed in this Stipulated Protective Order.
21 Similarly, no Party waives any right to object on any ground to use in evidence of any of the
22 material covered by this Protective Order.
23 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
Material must comply with Civil Local Rule 79-5. Protected Material may only be filed under
24
seal pursuant to a court order authorizing the sealing of the specific Protected Material at
25
issue; good cause must be shown in the request to file under seal. If a Party’s request to file
26
Protected Material under seal is denied by the Court, then the Receiving Party may file the
27
information in the public record unless otherwise instructed by the Court.
28
1 13. FINAL DISPOSITION
2 After the final disposition of this Action, within 60 days of a written request by the
3 Designating Party, each Receiving Party must return all Protected Material to the Producing
4 Party or destroy such material. As used in this subdivision, “all Protected Material” includes
all copies, abstracts, compilations, summaries, and any other format reproducing or capturing
5
any of the Protected Material. Whether the Protected Material is returned or destroyed, the
6
Receiving Party must submit a written certification to the Producing Party (and, if not the
7
same person or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
8
category, where appropriate) all the Protected Material that was returned or destroyed, and
9
(2) affirms that the Receiving Party has not retained any copies, abstracts, compilations,
10
summaries or any other format reproducing or capturing any of the Protected Material.
11
Notwithstanding this provision, counsel are entitled to retain an archival copy of all
12
pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
13
correspondence, deposition and trial exhibits, expert reports, attorney work product, and
14
consultant and expert work product, even if such materials contain Protected Material. Any
15
such archival copies that contain or constitute Protected Material remain subject to this
16 Protective Order as set forth in Section 4 (DURATION).
17
18 14. VIOLATION OF ORDER
19 Any violation of this Order may be punished by any and all appropriate measures
20 including, without limitation, contempt proceedings and/or monetary sanctions.
21
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1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD,
2
3 || Dated: July 11, 2025 /s/ Meghan C. Murphey
Meghan C. Murphey
4 Matthew D. Murphey
5 Attorneys for Plaintiff William Joiner
Dated: July 11, 2025 /s/ Abigail Everdell
6
Abigail Everdell
7 Attorneys for Defendants Channel 5,
g LLC, Andrew Callaghan, Evan
Gilbert Katz, and Nicolas Mosher
9
10
1] ATTESTATION RE ELECTRONIC SIGNATURES
12 The filer of this document attest that all other Signatories to this document, on whose
13 || behalf this filing is submitted, concur as to the content and have authorized their signature
14 || and filing of the document.
15
Dated: July 14, 2025 By: /s/Meghan C. Murphey
16 Meghan C. Murphey
17
18 IT IS SO ORDERED.
19
29 || DATED: July 16, 2025 q fA Hoseusnr
Honorable Karen L. Stevenson
21 Chief U.S. Magistrate Judge
22
23
24
25
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14
STIPULATED PROTECTIVE ORDER
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I, _______________________________________________ [print full name], of
3
__________________________________________________ [print full address], declare
4
under penalty of perjury that I have read in its entirety and understand the Stipulated
5
Protective Order that was issued by the United States District Court for the Central District
6
of California on __________[date] in the case of Joiner v. Channel 5, LLC, et al,, 8:24-CV-
7
01160-CBM-KS. I agree to comply with and to be bound by all the terms of this Stipulated
8
Protective Order and I understand and acknowledge that failure to so comply could expose
9
me to sanctions and punishment in the nature of contempt.
10
I solemnly promise that I will not disclose in any manner any information or item that
11
is subject to this Stipulated Protective Order to any person or entity except in strict
12
compliance with the provisions of this Order.
13
I further agree to submit to the jurisdiction of the United States District Court for the
14
Central District of California for the purpose of enforcing the terms of this Stipulated
15
Protective Order, even if such enforcement proceedings occur after termination of this action.
16
17
Date: ______________________________________
18
19
City and State Where Sworn and Signed: _________________________________
20
21
Printed Name: _______________________________
22
23
Signature: __________________________________
24
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