Opinion

Ronny Jay Clark Jr. v. County of Los Angeles

Court
District Court, C.D. California
Filed
Jul 31, 2025
Cited by
0 cases
Authority
More cited than 38.5%

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

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1

2 Date: ___________________________

3 City and State where sworn and signed:

___________________________

4

Printed name: ___________________________

5

Signature: ___________________________

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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