even stipulated protective orders 21 require good cause showing
How later courts described this case
- even stipulated protective orders 21 require good cause showing
Written by the judges who cited it.
The opinion
1 STEPHANIE FORMAN, ESQ.; STATE BAR NO.: 195757
ERIC J. PALMER, ESQ.; STATE BAR NO.: 231207
2
THARPE & HOWELL, LLP
3 15250 Ventura Blvd., Ninth Floor
Sherman Oaks, California 91403
4 (818) 205-9955; (818) 205-9944 fax
E-Mail: sforman@tharpe-howell.com
5 E-Mail: epalmer@tharpe-howell.com
6 Attorneys for Defendant,
WALMART INC.
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 ANDREA LINDER, Case No. 2:25-cv-05591
[Los Angeles County Superior Court Case
12 Plaintiff, No. 25LBCV01056]
13 v. [Assigned to District Judge Maame Ewusi-
Mensah Frimpong and Magistrate Judge
14 WALMART, INC. and DOES 1 to 50, Stephanie S. Christensen]
inclusive,
15
Defendants. [DISCOVERY MATTER]
16 STIPULATED PROTECTIVE ORDER1
17
18 Complaint Filed: March 28, 2025
Trial Date: September 14, 2026
19
1. INTRODUCTION
20
1.1 Purposes and Limitations. Discovery in this action is likely to involve
21
production of confidential, proprietary, or private information for which special
22
protection from public disclosure and from use for any purpose other than prosecuting
23
this litigation may be warranted. Accordingly, the parties hereby stipulate to and
24
petition the court to enter the following Stipulated Protective Order. The parties
25
acknowledge that this Order does not confer blanket protections on all disclosures or
26
27 1 This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Stephanie S. Christensen’s Procedures as of
28
1 responses to discovery and that the protection it affords from public disclosure
2 and use extends only to the limited information or items that are entitled to
3 confidential treatment under the applicable legal principles.
4 1.2 GOOD CAUSE STATEMENT
5 Federal Rules of Civil Procedure, Rule 26(c)(1) states in pertinent part, that the
6 Court, upon a showing of good cause may “issue an order to protect a party from
7 annoyance, embarrassment, oppression, or undue burden or expense.” Fed.R.Civ.P.
8 26(c)(1). In the instant matter, Defendant Walmart Inc.’s Confidential Documents
9 contain proprietary and confidential trade secret information relating to Defendant’s
10 business practices, policies and procedures, its safety protocol, and its video
11 surveillance system. Defendant Walmart Inc., (“Defendant” or “Walmart”) derives
12 independent economic value from maintaining the confidentiality of the policies and
13 procedures set forth in these Confidential Documents.
14 Defendant is a leading national retailer with its first store opening in 1962. The
15 retail industry is very competitive. As a result of years of investing time and money
16 in research and investigation, Defendant developed the policies contained in the
17 Confidential Documents for the purposes of maintaining the security of its facilities,
18 providing quality customer service, and ensuring the safety of its employees,
19 customers, and other invitees. These policies and procedures, as memorialized in the
20 Confidential Documents, were created and generated by Walmart for Walmart, and
21 are used for the purposes of maintaining safety at its stores and creating efficient and
22 organized work environments for its employees. As a result, Defendant is able to
23 minimize the waste of any resources, which is a key factor in generating profitability
24 for its business.
25 Defendant derives economic value from maintaining the secrecy of its Confidential
26 Documents. If disclosed to the public, the trade secret information contained in
27 Defendant’s Confidential Documents would reveal Defendant’s internal operations
28 and could potentially be used by competitors as a means to compete for its customers,
1 interfere with its business plans and thereby gain unfair business advantages. If
2 Defendant’s safety protocol were revealed to the general public, it would hinder
3 Defendant’s ability to effectively resolve and minimize liability claims, and its goal of
4 protecting its customers and employees from theft and other crimes. Unrestricted or
5 unprotected disclosure of such information would result in prejudice or harm to
6 Defendant by revealing Walmart’s competitive confidential information, which has
7 been developed at the expense of Walmart and which represents valuable tangible and
8 intangible assets. Accordingly, the parties respectfully submit that there is good cause
9 for the entry of this Protective Order.
10 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties further
11 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order
12 does not entitle them to file confidential information under seal; Local Rule 79-5 sets
13 forth the procedures that must be followed and the standards that will be applied when
14 a party seeks permission from the court to file material under seal.
15 There is a strong presumption that the public has a right of access to judicial
16 proceedings and records in civil cases. In connection with non-dispositive motions,
17 good cause must be shown to support a filing under seal. See Kamakana v. City and
18 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd
19 v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
20 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
21 require good cause showing), and a specific showing of good cause or compelling
22 reasons with proper evidentiary support and legal justification, must be made with
23 respect to Protected Material that a party seeks to file under seal. The parties’ mere
24 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
25 without the submission of competent evidence by declaration, establishing that the
26 material sought to be filed under seal qualifies as confidential, privileged, or otherwise
27 protectable—constitute good cause.
28 Further, if a party requests sealing related to a dispositive motion or trial, then
1 compelling reasons, not only good cause, for the sealing must be shown, and the relief
2 sought shall be narrowly tailored to serve the specific interest to be protected. See
3 Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each item
4 or type of information, document, or thing sought to be filed or introduced under seal
5 in connection with a dispositive motion or trial, the party seeking protection must
6 articulate compelling reasons, supported by specific facts and legal justification, for
7 the requested sealing order. Again, competent evidence supporting the application to
8 file documents under seal must be provided by declaration.
9 Any document that is not confidential, privileged, or otherwise protectable in its
10 entirety will not be filed under seal if the confidential portions can be redacted. If
11 documents can be redacted, then a redacted version for public viewing, omitting only
12 the confidential, privileged, or otherwise protectable portions of the document, shall
13 be filed. Any application that seeks to file documents under seal in their entirety should
14 include an explanation of why redaction is not feasible.
15 2. DEFINITIONS
16 2.1 Action: Andrea Linder v. Walmart, Inc., and Does 1-50, inclusive. Case
17 No. 2:35-CV-05591.
18 2.2 Challenging Party: a Party or Non-Party that challenges the designation
19 of information or items under this Order.
20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
21 how it is generated, stored, or maintained) or tangible things that qualify for protection
22 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
23 Statement.
24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
25 support staff).
26 2.5 Designating Party: a Party or Non-Party that designates information or
27 items that it produces in disclosures or in responses to discovery as
28 “CONFIDENTIAL.”
1 2.6 Disclosure or Discovery Material: all items or information, regardless of
2 the medium or manner in which it is generated, stored, or maintained (including,
3 among other things, testimony, transcripts, and tangible things), that are produced or
4 generated in disclosures or responses to discovery in this matter.
5 2.7 Expert: a person with specialized knowledge or experience in a matter
6 pertinent to the litigation who has been retained by a Party or its counsel to serve as
7 an expert witness or as a consultant in this Action.
8 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in
9 this Action, with or without prejudice; and (2) final judgment herein after the
10 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
11 this Action, including the time limits for filing any motions or applications for
12 extension of time pursuant to applicable law.
13 2.9 In-House Counsel: attorneys who are employees of a party to this Action.
14 House Counsel does not include Outside Counsel of Record or any other outside
15 counsel.
16 2.10 Non-Party: any natural person, partnership, corporation, association, or
17 other legal entity not named as a Party to this action.
18 2.11 Outside Counsel of Record: attorneys who are not employees of a party
19 to this Action but are retained to represent or advise a party to this Action and have
20 appeared in this Action on behalf of that party or are affiliated with a law firm which
21 has appeared on behalf of that party, including support staff.
22 2.12 Party: any party to this Action, including all of its officers, directors,
23 employees, consultants, retained experts, and Outside Counsel of Record (and their
24 support staffs).
25 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
26 Discovery Material in this Action.
27 2.14 Professional Vendors: persons or entities that provide litigation support
28 services (e.g., photocopying, videotaping, translating, preparing exhibits or
1 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
2 their employees and subcontractors.
3 2.15 Protected Material: any Disclosure or Discovery Material that is
4 designated as “CONFIDENTIAL.”
5 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
6 from a Producing Party.
7 3. SCOPE
8 The protections conferred by this Stipulation and Order cover not only Protected
9 Material (as defined above), but also (1) any information copied or extracted from
10 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
11 Material; and (3) any testimony, conversations, or presentations by Parties or their
12 Counsel that might reveal Protected Material.
13 Any use of Protected Material at trial shall be governed by the orders of the trial
14 judge. This Stipulated Protective Order does not govern the use of Protected Material
15 at trial.
16 4. TRIAL AND DURATION
17 The terms of this Stipulated Protective Order apply through Final Disposition of
18 the Action.
19 Once a case proceeds to trial, information that was designated as CONFIDENTIAL
20 or maintained pursuant to this Stipulated Protective Order and used or introduced as
21 an exhibit at trial becomes public and will be presumptively available to all members
22 of the public, including the press, unless compelling reasons supported by specific
23 factual findings to proceed otherwise are made to the trial judge in advance of the trial.
24 See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing for sealing
25 documents produced in discovery from “compelling reasons” standard when merits-
26 related documents are part of court record). Accordingly, for such materials, the terms
27 of this Stipulated Protective Order do not extend beyond the commencement of the
28 trial.
1 Even after Final Disposition of this litigation, the confidentiality obligations
2 imposed by this Stipulated Protective Order shall remain in effect until a Designating
3 Party agrees otherwise in writing or a court order otherwise directs.
4 5. DESIGNATING PROTECTED MATERIAL
5 5.1 Exercise of Restraint and Care in Designating Material for Protection.
6 Each Party or Non-Party that designates information or items for protection under this
7 Order must take care to limit any such designation to specific material that qualifies
8 under the appropriate standards. The Designating Party must designate for protection
9 only those parts of material, documents, items, or oral or written communications that
10 qualify so that other portions of the material, documents, items, or communications
11 for which protection is not warranted are not swept unjustifiably within the ambit of
12 this Order.
13 Mass, indiscriminate, or routinized designations are prohibited. Designations that
14 are shown to be clearly unjustified or that have been made for an improper purpose
15 (e.g., to unnecessarily encumber the case development process or to impose
16 unnecessary expenses and burdens on other parties) may expose the Designating Party
17 to sanctions.
18 If it comes to a Designating Party’s attention that information or items that it
19 designated for protection do not qualify for protection, that Designating Party must
20 promptly notify all other Parties that it is withdrawing the inapplicable designation.
21 5.2 Manner and Timing of Designations. Except as otherwise provided in
22 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
23 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
24 under this Order must be clearly so designated before the material is disclosed or
25 produced.
26 Designation in conformity with this Order requires:
27 (a) for information in documentary form (e.g., paper or electronic
28 documents, but excluding transcripts of depositions or other pretrial or trial
1 proceedings), that the Producing Party affix at a minimum, the legend
2 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
3 contains protected material. If only a portion or portions of the material on a page
4 qualifies for protection, the Producing Party also must clearly identify the protected
5 portion(s) (e.g., by making appropriate markings in the margins).
6 A Party or Non-Party that makes original documents available for
7 inspection need not designate them for protection until after the inspecting Party has
8 indicated which documents it would like copied and produced. During the inspection
9 and before the designation, all of the material made available for inspection shall be
10 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
11 it wants copied and produced, the Producing Party must determine which documents,
12 or portions thereof, qualify for protection under this Order. Then, before producing
13 the specified documents, the Producing Party must affix the “CONFIDENTIAL
14 legend” to each page that contains Protected Material. If only a portion or portions of
15 the material on a page qualifies for protection, the Producing Party also must clearly
16 identify the protected portion(s) (e.g., by making appropriate markings in the margins).
17 (b) for testimony given in depositions that the Designating Party identify
18 the Disclosure or Discovery Material on the record, before the close of the deposition
19 all protected testimony.
20 (c) for information produced in some form other than documentary and for
21 any other tangible items, that the Producing Party affix in a prominent place on the
22 exterior of the container or containers in which the information is stored the legend
23 “CONFIDENTIAL.” If only a portion or portions of the information warrants
24 protection, the Producing Party, to the extent practicable, shall identify the protected
25 portion(s).
26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
27 failure to designate qualified information or items does not, standing alone, waive the
28 Designating Party’s right to secure protection under this Order for such material. Upon
1 timely correction of a designation, the Receiving Party must make reasonable efforts
2 to assure that the material is treated in accordance with the provisions of this Stipulated
3 Protective Order.
4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
5 a. Timing of Challenges. Any Party or Non-Party may challenge a
6 designation of confidentiality at any time that is consistent with the court’s Scheduling
7 Order.
8 b. Meet and Confer. The Challenging Party shall initiate the dispute
9 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge
10 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”
11 c. The burden of persuasion in any such challenge proceeding shall be on
12 the Designating Party. Frivolous challenges, and those made for an improper purpose
13 (e.g., to harass or impose unnecessary expenses and burdens on other parties), may
14 expose the Challenging Party to sanctions. Unless the Designating Party has waived
15 or withdrawn the confidentiality designation, all parties shall continue to afford the
16 material in question the level of protection to which it is entitled under the
17 Producing Party’s designation until the Court rules on the challenge.
18 7. ACCESS TO AND USE OF PROTECTED MATERIAL
19 a. 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 has been terminated, a
24 Receiving Party must comply with the provisions of Section 13 below (FINAL
25 DISPOSITION).
26 Protected Material must be stored and maintained by a Receiving Party at a
27 location and in a secure manner that ensures that access is limited to the persons
28 authorized under this Order.
1 b. Disclosure of “CONFIDENTIAL” Information or Items. Unless
2 otherwise ordered by the Court or permitted in writing by the Designating Party, a
3 Receiving Party may disclose any information or item designated “CONFIDENTIAL”
4 only to:
5 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as
6 well as employees of said Outside Counsel of Record to whom it is reasonably
7 necessary to disclose the information for this Action;
8 (b) to the officers, directors, and employees (including House Counsel) of
9 the Receiving Party to whom disclosure is reasonably necessary for this Action;
10 (c) to Experts (as defined in this Order) of the Receiving Party to whom
11 disclosure is reasonably necessary for this Action and who have signed the
12 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13 (d) to the court and its personnel;
14 (e) to court reporters and their staff;
15 (f) to professional jury or trial consultants, mock jurors, and Professional
16 Vendors to whom disclosure is reasonably necessary for this Action and who have
17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
18 (g) to the author or recipient of a document containing the information or
19 a custodian or other person who otherwise possessed or knew the information;
20 (h) during their depositions, to witnesses, and attorneys for witnesses, in
21 the Action to whom disclosure is reasonably necessary, provided: (1) the deposing
22 party requests that the witness sign the “Acknowledgment and Agreement to Be
23 Bound” (Exhibit A); and (2) the witness will not be permitted to keep any confidential
24 information unless they sign the “Acknowledgment and Agreement to Be Bound”
25 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court.
26 Pages of transcribed deposition testimony or exhibits to depositions that reveal
27 Protected Material may be separately bound by the court reporter and may not be
28 disclosed to anyone except as permitted under this Stipulated Protective Order; and
1 (i) to any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions.
3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
4 PRODUCED IN OTHER LITIGATION
5 If a Party is served with a subpoena or a court order issued in other litigation
6 that compels disclosure of any information or items designated in this Action as
7 “CONFIDENTIAL,” that Party must:
8 (a) promptly notify in writing the Designating Party. Such notification
9 shall include a copy of the subpoena or court order;
10 (b) promptly notify in writing the party who caused the subpoena or order
11 to issue in the other litigation that some or all of the material covered by the subpoena
12 or order is subject to this Protective Order. Such notification shall include a copy of
13 this Stipulated Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to be pursued
15 by the Designating Party whose Protected Material may be affected.
16 If the Designating Party timely seeks a protective order, the Party served with
17 the subpoena or court order shall not produce any information designated in this action
18 as “CONFIDENTIAL” before a determination by the court from which the subpoena
19 or order issued, unless the Party has obtained the Designating Party’s permission. The
20 Designating Party shall bear the burden and expense of seeking protection in that court
21 of its confidential material and nothing in these provisions should be construed as
22 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
23 directive from another court.
24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
25 PRODUCED IN THIS LITIGATION
26 9.1 Application. The terms of this Stipulated Protective Order are
27 applicable to information produced by a Non-Party in this Action and designated as
28 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with
1 this litigation is protected by the remedies and relief provided by this Order. Nothing
2 in these provisions should be construed as prohibiting a Non-Party from seeking
3 additional protections.
4 9.2 Notification. In the event that a Party is required, by a valid discovery
5 request, to produce a Non-Party’s confidential information in its possession, and the
6 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s
7 confidential information, then the Party shall:
8 (a) promptly notify in writing the Requesting Party and the Non-Party that
9 some or all of the information requested is subject to a confidentiality agreement
10 with a Non-Party;
11 (b) make the information requested available for inspection by the Non-
12 Party, if requested.
13 9.3 Conditions of Production. If the Non-Party fails to seek a protective
14 order from this court within 14 days of receiving the notice and accompanying
15 information, the Receiving Party may produce the Non-Party’s confidential
16 information responsive to the discovery request. If the Non-Party timely seeks a
17 protective order, the Receiving Party shall not produce any information in its
18 possession or control that is subject to the confidentiality agreement with the Non-
19 Party before a determination by the court. Absent a court order to the contrary, the
20 Non-Party shall bear the burden and expense of seeking protection in this court of its
21 Protected Material.
22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
24 Protected Material to any person or in any circumstance not authorized under this
25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
26 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
27 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
28 persons to whom unauthorized disclosures were made of all the terms of this Order,
1 and (d) request such person or persons to execute the “Acknowledgment and
2 Agreement to Be Bound” (Exhibit A).
3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
4 PROTECTED MATERIAL
5 When a Producing Party gives notice to Receiving Parties that certain
6 inadvertently produced material is subject to a claim of privilege or other protection,
7 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the
8 Federal Rules of Civil Procedure. This provision is not intended to modify whatever
9 procedure may be established in an e-discovery order that provides for production
10 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules
11 of Evidence, insofar as the parties reach an agreement on the effect of disclosure of a
12 communication or information covered by the attorney-client privilege or work
13 product protection, the parties may incorporate their agreement in the stipulated
14 protective order submitted to the court.
15 12. MISCELLANEOUS
16 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
17 abridges the right of any person to seek its modification by the court in the future.
18 12.2 Right to Assert Other Objections. By stipulating to the entry of this
19 Stipulated Protective Order no Party waives any right it otherwise would have to object
20 to disclosing or producing any information or item on any ground not addressed in this
21 Stipulated Protective Order. Similarly, no Party waives any right to object on any
22 ground to use in evidence of any of the material covered by this Stipulated Protective
23 Order.
24 12.3 Filing Protected Material. A Party that seeks to file under seal any
25 Protected Material must comply with Local Rule 79-5. Protected Material may only
26 be filed under seal pursuant to a court order authorizing the sealing of the specific
27 Protected Material at issue. If a Party's request to file Protected Material under seal is
28 denied by the court, then the Receiving Party may file the information in the public
1 record unless otherwise instructed by the court.
2 13. FINAL DISPOSITION
3 After the Final Disposition of this Action, as defined in paragraph 4, within 60
4 days of a written request by the Designating Party, each Receiving Party must return
5 all Protected Material to the Producing Party or destroy such material. As used in this
6 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
7 summaries, and any other format reproducing or capturing any of the Protected
8 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
9 must submit a written certification to the Producing Party (and, if not the same person
10 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
11 category, where appropriate) all the Protected Material that was returned or destroyed
12 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
13 compilations, summaries or any other format reproducing or capturing any of the
14 Protected Material. Notwithstanding this provision, Counsel is entitled to retain an
15 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
16 legal memoranda, correspondence, deposition and trial exhibits, expert reports,
17 attorney work product, and consultant and expert work product, even if such materials
18 contain Protected Material. Any such archival copies that contain or constitute
19 Protected Material remain subject to this Protective Order as set forth in Section 4.
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
| 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished by any and
3|| all appropriate measures including, without limitation, contempt proceedings and/or
monetary sanctions.
5
6
7\| IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
8 EISENBERG LAW GROUP
9
Dated: September 25, 2025
10 By: ___/s/ Vick V_Petrosian
JASON G. EISENBERG
gq il VICK V. PETROSIAN
a Attorneys for Plaintiff,
ANDREA LINDER
zo THARPE & HOWELL, LLP
15
Dated: September 25, 2025 By: /s/ Eric J. Palmer
16 STEPHANIE FORMAN
Se 17 ERIC J. PALMER
Attorneys for Defendant,
18 WALMART INC.
Eric J. Palmer, the filer of this document, attests that all other signatories listed above, and on
whose behalf this filing is submitted, concur in the filing’s content and have authorized the
20 filing, pursuant to L.R. 5-4.3.4(a)(2)(i).
21
92 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
23
24|| DATED: September 25, 2025 Z
Hon. Stephanie S. Christensen
25 United States Magistrate Judge
26
27
28
Ve]
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
5
under penalty of perjury that I have read in its entirety and understand the
6
Stipulated Protective Order that was issued by the United States District Court for
7
the Central District of California on [date] in the case of Andrea Linder v
8
Walmart, Inc. and Does1-50 inclusive. Case No:2:25-cv-05591. I agree to comply
9
with and to be bound by all the terms of this Stipulated Protective Order and I
10
understand and acknowledge that failure to so comply could expose me to
11
sanctions and punishment in the nature of contempt. I solemnly promise that I
12
will not disclose in any manner any information or item that is subject to this
13
Stipulated Protective Order to any person or entity except in strict compliance
14
with the provisions of this Order.
15
I further agree to submit to the jurisdiction of the United States District
16
Court for the Central District of California for the purpose of enforcing the terms
17
of this Stipulated Protective Order, even if such enforcement proceedings occur
18
after termination of this action. I hereby appoint ___________________________
19
[print or type full name] of ________________________________ [print or
20
type full address and telephone number] as
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1 my California agent for service of process in connection with this action or any
2 proceedings related to enforcement of this Stipulated Protective Order.
3
4 Date: ___________________________
5 City and State where sworn and
6 signed: ___________________________
7 Printed name: ___________________________
8 Signature: ___________________________
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