even stipulated 16 protective orders require good cause showing
How later courts described this case
- even stipulated 16 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 Thomas C. Hurrell, State Bar No. 119876
E-Mail: thurrell@hurrellcantrall.com
2 Nzhdeh Aghazaryan, State Bar No. 316492
E-Mail: naghazaryan@hurrellcantrall.com
3 Niloo Savis, State Bar No. 186809
E-Mail: nsavis@hurrellcantrall.com
4 HURRELL CANTRALL LLP
800 West 6th Street, Suite 700
5 Los Angeles, CA 90017-2710
Telephone: (213) 426-2000
6 Facsimile: (213) 426-2020
7 Attorneys for Defendant, COUNTY OF LOS ANGELES
8 Eugenia Bagdassarian, Esq. (SBN 334898)
Eugenia@TrialLit.com
9 TRIAL LIT ATTORNEYS, APC
600 W. Broadway, Suite 235
10 Glendale, CA 91204
E-Service: service@TrialLit.com
11 Tel: (818) 584-3500
Fax: (877) 565-0213
12
Attorneys for Plaintiff RONNY J. CLARK, JR.
13
14 UNITED STATES DISTRICT COURT
15 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
16
17 RONNY JAY CLARK, JR., an Case No. 2:25-cv-00931-HDV(SSCx)
Individual,
18 STIPULATED PROTECTIVE
Plaintiff, ORDER1
19
v. [Assigned to Hon. Hernan D. Vera,
20 Courtroom "5B"]
COUNTY OF LOS ANGELES; and
21 DOES 1 to 10, inclusive, [DISCOVERY MATTER]
22 Defendants.
23
24
25
26 1 This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Stephanie S. Christensen’s Procedures as of
27
24 July 2023. All deviations or amendments to the model protective order have been
red-lined in accordance with Magistrate Christensen's order.
1 1. INTRODUCTION
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 production of confidential, proprietary, or private information for which special
4 protection from public disclosure and from use for any purpose other than
5 prosecuting this litigation may be warranted. Accordingly, the parties hereby
6 stipulate to and petition the court to enter the following Stipulated Protective Order.
7 The parties acknowledge that this Order does not confer blanket protections on all
8 disclosures or responses to discovery and that the protection it affords from public
9 disclosure and use extends only to the limited information or items that are entitled
10 to confidential treatment under the applicable legal principles.
11 1.2 Good Cause Statement
12 This action involves the County of Los Angeles and members of the Los
13 Angeles Sherrif's Department. This action is likely to involve the exchange of
14 protected health information (“PHI”), Police Officer Personnel information, and
15 Open Investigations Consisting of Official Information for which special protection
16 from public disclosure and from use for any purpose other than prosecution of this
17 action is warranted. Such confidential materials and information consist of, among
18 other things, medical records containing PHI, Police Officer Personnel information
19 and Open Investigations Consisting of Official Information, other administrative
20 materials and information, as well as video recordings, audio recordings, and
21 photographs involving incidents to which law enforcement responded.
22 Accordingly, to expedite the flow of information, to facilitate the prompt
23 resolution of disputes over confidentiality of discovery materials, to adequately
24 protect information the parties are entitled to keep confidential, to ensure that the
25 parties are permitted reasonable necessary uses of such material in preparation for
26 and in the conduct of trial, to address their handling at the end of the litigation, and
27 serve the ends of justice, a protective order for such information is justified in this
1 confidential for tactical reasons and that nothing be so designated without a good
2 faith belief that it has been maintained in a confidential, non-public manner, and
3 there is good cause why it should not be part of the public record of this case.
4 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties
5 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
6 Protective Order does not entitle them to file confidential information under seal;
7 Local Rule 79-5 sets forth the procedures that must be followed and the standards
8 that will be applied when a party seeks permission from the court to file material
9 under seal.
10 There is a strong presumption that the public has a right of access to judicial
11 proceedings and records in civil cases. In connection with non-dispositive motions,
12 good cause must be shown to support a filing under seal. See Kamakana v. City and
13 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of
14 Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon
15 v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
16 protective orders require good cause showing), and a specific showing of good
17 cause or compelling reasons with proper evidentiary support and legal justification,
18 must be made with respect to Protected Material that a party seeks to file under seal.
19 The parties’ mere designation of Disclosure or Discovery Material as
20 CONFIDENTIAL does not—without the submission of competent evidence by
21 declaration, establishing that the material sought to be filed under seal qualifies as
22 confidential, privileged, or otherwise protectable—constitute good cause.
23 Further, if a party requests sealing related to a dispositive motion or trial, then
24 compelling reasons, not only good cause, for the sealing must be shown, and the
25 relief sought shall be narrowly tailored to serve the specific interest to be protected.
26 See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each
27 item or type of information, document, or thing sought to be filed or introduced
1 protection must articulate compelling reasons, supported by specific facts and legal
2 justification, for the requested sealing order. Again, competent evidence supporting
3 the application to file documents under seal must be provided by declaration.
4 Any document that is not confidential, privileged, or otherwise protectable in its
5 entirety will not be filed under seal if the confidential portions can be redacted. If
6 documents can be redacted, then a redacted version for public viewing, omitting
7 only the confidential, privileged, or otherwise protectable portions of the document,
8 shall be filed. Any application that seeks to file documents under seal in their
9 entirety should include an explanation of why redaction is not feasible.
10 2. DEFINITIONS
11 2.1 Action: this pending federal lawsuit, encaptioned Ronny Jay Clark, Jr.
12 v. County of Los Angeles, et. al. 2:25-cv-00931-HDV(SSCx).
13 2.2 Challenging Party: a Party or Non-Party that challenges the
14 designation of information or items under this Order.
15 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of
16 how it is generated, stored or maintained) or tangible things that qualify for
17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
18 the Good Cause Statement.
19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
20 their support staff).
21 2.5 Designating Party: a Party or Non-Party that designates information or
22 items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL.”
24 2.6 Disclosure or Discovery Material: all items or information, regardless
25 of the medium or manner in which it is generated, stored, or maintained (including,
26 among other things, testimony, transcripts, and tangible things), that are produced or
27 generated in disclosures or responses to discovery in this matter.
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
5 in 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
10 Action. In-House Counsel does not include Outside Counsel of Record or any other
11 outside 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-
24 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
25 demonstrations, and organizing, storing, or retrieving data in any form or medium)
26 and their employees and subcontractors.
27 2.15 Protected Material: any Disclosure or Discovery Material that is
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 designated as
16 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and
17 used or introduced as an exhibit at trial becomes public and will be presumptively
18 available to all members of the public, including the press, unless compelling
19 reasons supported by specific factual findings to proceed otherwise are made to the
20 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81
21 (distinguishing “good cause” showing for sealing documents produced in discovery
22 from “compelling reasons” standard when merits-related documents are part of court
23 record). Accordingly, for such materials, the terms of this Stipulated Protective
24 Order do not extend beyond the commencement of the trial.
25 Even after Final Disposition of this litigation, the confidentiality obligations
26 imposed by this Stipulated Protective Order shall remain in effect until a
27 Designating Party agrees otherwise in writing or a court order otherwise directs.
1 5. DESIGNATING PROTECTED MATERIAL
2
5.1 Exercise of Restraint and Care in Designating Material for Protection.
3
Each Party or Non-Party that designates information or items for protection under
4
this Order must take care to limit any such designation to specific material that
5
qualifies under the appropriate standards. The Designating Party must designate for
6
protection only those parts of material, documents, items, or oral or written
7
communications that qualify so that other portions of the material, documents,
8
items, or communications for which protection is not warranted are not swept
9
unjustifiably within the ambit of this Order.
10
Mass, indiscriminate, or routinized designations are prohibited. Designations
11
that are shown to be clearly unjustified or that have been made for an improper
12
purpose (e.g., to unnecessarily encumber the case development process or to
13
impose unnecessary expenses and burdens on other parties) may expose the
14
Designating Party to sanctions.
15
If it comes to a Designating Party’s attention that information or items that it
16
designated for protection do not qualify for protection, that Designating Party must
17
promptly notify all other Parties that it is withdrawing the inapplicable designation.
18
5.2 Manner and Timing of Designations. Except as otherwise provided in
19
this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a)
20
below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that
21
qualifies for protection under this Stipulated Protective Order must be clearly so
22
designated before the material is disclosed or produced.
23
Designation in conformity with this Stipulated Protective Order requires:
24
(a) for information in documentary form (e.g., paper or electronic
25
documents, but excluding transcripts of depositions or other pretrial or trial
26
proceedings), that the Producing Party affix at a minimum, the legend
27
“CONFIDENTIAL” to each page that contains protected material. If only a
1 portion or portions of the material on a page qualifies for protection, the Producing
2 Party also must clearly identify the protected portion(s) (e.g., by making
3 appropriate markings in the margins).
4 A Party or Non-Party that makes original documents available for inspection
5 need not designate them for protection until after the inspecting Party has indicated
6 which documents it would like copied and produced. During the inspection and
7 before the designation, all of the material made available for inspection shall be
8 deemed CONFIDENTIAL. After the inspecting Party has identified the documents
9 it wants copied and produced, the Producing Party must determine which
10 documents, or portions thereof, qualify for protection under this Stipulated
11 Protective Order. Then, before producing the specified documents, the Producing
12 Party must affix the “CONFIDENTIAL” legend to each page that contains
13 Protected Material. If only a portion or portions of the material on a page qualifies
14 for protection, the Producing Party also must clearly identify the protected
15 portion(s) (e.g., by making appropriate markings in the margins).
16 (b) for testimony given in depositions that the Designating Party identify
17 the Disclosure or Discovery Material on the record, before the close of the
18 deposition all protected testimony.
19 (c) for information produced in some form other than documentary and
20 for any other tangible items, that the Producing Party affix in a prominent place on
21 the exterior of the container or containers in which the information is stored the
22 “CONFIDENTIAL” legend. If only a portion or portions of the information
23 warrants protection, the Producing Party, to the extent practicable, shall identify the
24 protected portion(s).
25
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
26
failure to designate qualified information or items does not, standing alone, waive
27
the Designating Party’s right to secure protection under this Order for such material.
1 efforts to assure that the material is treated in accordance with the provisions of this
2 Stipulated Protective Order.
3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4
2.1 Timing of Challenges. Any Party or Non-Party may challenge a
5
designation of confidentiality at any time that is consistent with the court’s
6
Scheduling Order.
7
2.2 Meet and Confer. The Challenging Party shall initiate the dispute
8
resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge
9
Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2
10
2.3 The burden of persuasion in any such challenge proceeding shall be on
11
the Designating Party. Frivolous challenges, and those made for an improper
12
purpose (e.g., to harass or impose unnecessary expenses and burdens on other
13
parties) may expose the Challenging Party to sanctions. Unless the Designating
14
Party has waived or withdrawn the confidentiality designation, all parties shall
15
continue to afford the material in question the level of protection to which it is
16
entitled under the Producing Party’s designation until the court rules on the
17
challenge.
18
7. ACCESS TO AND USE OF PROTECTED MATERIAL
19
7.1 Basic Principles. A Receiving Party may use Protected Material that
20
is disclosed or produced by another Party or by a Non-Party in connection with this
21
Action only for prosecuting, defending, or attempting to settle this Action. Such
22
Protected Material may be disclosed only to the categories of persons and under the
23
conditions described in this Order. When the Action reaches a Final Disposition, a
24
Receiving Party must comply with the provisions of section 13 below.
25
26
27
2 Judge Christensen’s Procedures are available at https://www.cacd.uscourts.gov/honorable-
stephanie-s-christensen.
1 Protected Material must be stored and maintained by a Receiving Party at a
2 location and in a secure manner that ensures that access is limited to the persons
3 authorized under this Stipulated Protective Order.
4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
5 otherwise ordered by the court or permitted in writing by the Designating Party, a
6 Receiving Party may disclose any information or item designated
7 “CONFIDENTIAL” only:
8 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as
9 well as employees of said Outside Counsel of Record to whom it is reasonably
10 necessary to disclose the information for this Action;
11 (b) to the officers, directors, and employees (including House Counsel) of
12 the Receiving Party to whom disclosure is reasonably necessary for this Action;
13 (c) to 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 (d) to the court and its personnel;
17 (e) to court reporters and their staff;
18
(f) to professional jury or trial consultants, mock jurors, and Professional
19
Vendors to whom disclosure is reasonably necessary for this Action and who have
20
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
21
(g) to the author or recipient of a document containing the information or
22
a custodian or other person who otherwise possessed or knew the information;
23
(h) during their depositions, to witnesses, and attorneys for witnesses, in
24
the Action to whom disclosure is reasonably necessary, provided: (1) the deposing
25
party requests that the witness sign the “Acknowledgment and Agreement to Be
26
Bound” (Exhibit A); and (2) the witness will not be permitted to keep any
27
confidential information unless they sign the “Acknowledgment and Agreement to
1 ordered by the court. Pages of transcribed deposition testimony or exhibits to
2 depositions that reveal Protected Material may be separately bound by the court
3 reporter and may not be disclosed to anyone except as permitted under this
4 Stipulated Protective Order; and
5 (i) to any mediator or settlement officer, and their supporting personnel,
6 mutually agreed upon by any of the parties engaged in settlement discussions.
7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
8 PRODUCED IN OTHER LITIGATION
9
If a Party is served with a subpoena or a court order issued in other litigation
10
that compels disclosure of any information or items designated in this Action as
11
“CONFIDENTIAL,” that Party must:
12
(a) promptly notify in writing the Designating Party. Such notification
13
shall include a copy of the subpoena or court order;
14
(b) promptly notify in writing the party who caused the subpoena or order
15
to issue in the other litigation that some or all of the material covered by the
16
subpoena or order is subject to this Protective Order. Such notification shall include
17
a copy of this Stipulated Protective Order; and
18
(c) cooperate with respect to all reasonable procedures sought to be
19
pursued by the Designating Party whose Protected Material may be affected.
20
If the Designating Party timely seeks a protective order, the Party served
21
with the subpoena or court order shall not produce any information designated in
22
this action as “CONFIDENTIAL” before a determination by the court from which
23
the subpoena or order issued, unless the Party has obtained the Designating Party’s
24
permission. The Designating Party shall bear the burden and expense of seeking
25
protection in that court of its confidential material and nothing in these provisions
26
should be construed as authorizing or encouraging a Receiving Party in this Action
27
to disobey a lawful directive from another court.
1 9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3
9.1 Application. The terms of this Stipulated Protective Order are
4
applicable to information produced by a Non-Party in this Action and designated as
5
“CONFIDENTIAL.” Such information produced by Non-Parties in connection with
6
this litigation is protected by the remedies and relief provided by this Order.
7
Nothing in these provisions should be construed as prohibiting a Non-Party from
8
seeking additional protections.
9
9.2 Notification. In the event that a Party is required, by a valid discovery
10
request, to produce a Non-Party’s confidential information in its possession, and the
11
Party is subject to an agreement with the Non-Party not to produce the Non-
12
Party’s confidential information, then the Party shall:
13
(a) promptly notify in writing the Requesting Party and the Non-Party
14
that some or all of the information requested is subject to a confidentiality
15
agreement with a Non-Party;
16
(b) make the information requested available for inspection by the Non-
17
Party, if requested.
18
9.3 Conditions of Production. If the Non-Party fails to seek a protective
19
order from this court within 14 days of receiving the notice and accompanying
20
information, the Receiving Party may produce the Non-Party’s confidential
21
information responsive to the discovery request. If the Non-Party timely seeks a
22
protective order, the Receiving Party shall not produce any information in its
23
possession or control that is subject to the confidentiality agreement with the Non-
24
Party before a determination by the court. Absent a court order to the contrary, the
25
Non-Party shall bear the burden and expense of seeking protection in this court of its
26
Protected Material.
27
///
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has
3 disclosed Protected Material to any person or in any circumstance not authorized
4 under this Stipulated Protective Order, the Receiving Party must immediately (a)
5 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
6 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
7 the person or persons to whom unauthorized disclosures were made of all the terms
8 of this Order, and (d) request such person or persons to execute the
9 “Acknowledgment and 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
14
protection, the obligations of the Receiving Parties are those set forth in Rule
15
26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended
16
to modify whatever procedure may be established in an e-discovery order that
17
provides for production without prior privilege review. Pursuant to Rules 502(d)
18
and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement
19
on the effect of disclosure of a communication or information covered by the
20
attorney-client privilege or work product protection, the parties may incorporate
21
their agreement in the stipulated 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
1 addressed in this Stipulated Protective Order. Similarly, no Party waives any right
2 to object on any ground to use in evidence of any of the material covered by this
3 Stipulated Protective Order.
4 12.3 Filing Protected Material. A Party that seeks to file under seal any
5 Protected Material must comply with Local Rule 79-5. Protected Material may
6 only be filed under seal pursuant to a court order authorizing the sealing of the
7 specific Protected Material at issue. If a Party's request to file Protected Material
8 under seal is denied by the court, then the Receiving Party may file the
9 information in the public record unless otherwise instructed by the court.
10 13. FINAL DISPOSITION
11
After the Final Disposition of this Action, as defined in paragraph 4, within
12
60 days of a written request by the Designating Party, each Receiving Party must
13
return all Protected Material to the Producing Party or destroy such material. As
14
used in this subdivision, “all Protected Material” includes all copies, abstracts,
15
compilations, summaries, and any other format reproducing or capturing any of the
16
Protected Material. Whether the Protected Material is returned or destroyed, the
17
Receiving Party must submit a written certification to the Producing Party (and, if
18
not the same person or entity, to the Designating Party) by the 60 day deadline that
19
(1) identifies (by category, where appropriate) all the Protected Material that was
20
returned or destroyed and (2) affirms that the Receiving Party has not retained any
21
copies, abstracts, compilations, summaries or any other format reproducing or
22
capturing any of the Protected Material. Notwithstanding this provision, Counsel is
23
entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
24
and hearing transcripts, legal memoranda, correspondence, deposition and trial
25
exhibits, expert reports, attorney work product, and consultant and expert work
26
product, even if such materials contain Protected Material. Any such archival
27
copies that contain or constitute Protected Material remain subject to this Protective
1 || Order as set forth in Section 4.
2\114. VIOLATION
3 Any violation of this Stipulated Protective Order may be punished by any
and all appropriate measures including, without limitation, contempt proceedings
>|! and/or monetary sanctions.
6
IIT IS SO STIPULATED, THROUGH COUNSEL FO RECORD:
8
9 | DATED: July 28, 2025 HURRELL CANTRALL LLP
10
11
12 By: /S/ Niloo Savis
43 THOMAS C. HURRELL
NZHDEH AGHAZARYAN
ES 14 NILOO SAVIS
15 Attorneys for Defendant, COUNTY OF
2h LOS ANGELES
16
7 Dated: July 31, 2025 TRIAL LIT ATTORNEYS, APC
18
By: __/s/ Eugenia Bagdassarian
19 Eugenia Bagdassarian, Esq.
Attorneys for Plaintiff,
20 RONNY JAY CLARK JR.
21
22 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
23
241 DATED: July 31, 2025
25 HON. STEPHANIE S. CHRISTENSEN
26 United States Magistrate Judge
27
28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, ________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of
6 perjury that I have read in its entirety and understand the Stipulated Protective
7 Order that was issued by the United States District Court for the Central District
8 of California on _________________in the case of Ronny Jay Clark Jr. v.
9 County of Los Angeles, et al., Case No. 2:25-cv-00931-HDV(SSCx). I agree to
10 comply with and to be bound by all the terms of this Stipulated Protective Order
11 and I understand and acknowledge that failure to so comply could expose me to
12 sanctions and punishment in the nature of contempt. I solemnly promise that I
13 will not disclose in any manner any information or item that is subject to this
14 Stipulated Protective Order to any person or entity except in strict compliance
15 with the provisions of this Order.
16 I further agree to submit to the jurisdiction of the United States District
17 Court for the Central District of California for the purpose of enforcing the terms
18 of this Stipulated Protective Order, even if such enforcement proceedings occur
19 after termination of this action. I hereby appoint ________________________
20 [print or type full name] of _________ [print or type full address and
21 telephone number] as my California agent for service of process in connection
22 with this action or any proceedings related to enforcement of this Stipulated
23 Protective Order.
24
25
26
27
1
2 Date: ___________________________
3 City and State where sworn and signed:
___________________________
4
Printed name: ___________________________
5
Signature: ___________________________
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