# Opinion

> District Court, C.D. California · October 3, 2025

URL: https://www.frixlaw.com/law-library/cases/11170795

## Case

- **Full name:** Estate of Glenn McCrary, by and through his successors in interests, et al. v. Victorville Police Department, a public entity, et al.
- **Court:** District Court, C.D. California
- **Decided:** October 3, 2025
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 || Eugene P. Ramirez (State Bar No. 134865)
eugene.ramirez@manningkass.com
Yury A. Kolesnikov (State Bar No. 271173)
3 yury.kolesnikov@manningkass.com
Kayleigh Andersen (State Bar No. 306442)
4
kayleigh.andersen@manningkass.com
5||MANNING & KASS
6 ELLROD, RAMIREZ, TRESTER LLP
801 S. Figueroa St, 15th Floor
7 || Los Angeles, California 90017-3012
8 Telephone: (213) 624-6900
Facsimile: (213) 624-6999
9
10 Attorneys for Defendant Deputy CORRIN
CASSIDY

<x
< UNITED STATES DISTRICT COURT
oO CENTRAL DISTRICT OF CALIFORNIA
z 13
Zz 14 ESTATE OF GLENN MCCRARY, by | Case No.: 5:23-cv-02602 SSS (SPx)
= and through his successors in interests,
= 15 |) et al.,
STIPULATED PROTECTIVE
16 Plaintiffs, | ORDER
i V Complaint Filed: | December 20, 2023
18 Trial Date: Not Yet Set
19 || VICTORVILLE POLICE
20 DEPARTMENT, a public entity, e¢ al.,
21 Defendants.
22
°3/1. A, PURPOSES AND LIMITATIONS
24 Discovery in this action is likely to involve production of confidential,
25 || proprietary, or private information for which special protection from public disclosure
26 || and from use for any purpose other than prosecuting this litigation may be warranted.
Accordingly, the parties hereby stipulate to and petition the Court to enter the
28 following Stipulated Protective Order. The parties acknowledge that this Order does

1 ||not confer blanket protections on all disclosures or responses to discovery and that
2 ||the protection it affords from public disclosure and use extends only to the limited
3 information or items that are entitled to confidential treatment under the applicable
4 || legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
5||that this Stipulated Protective Order does not entitle them to file confidential
6 || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
7 || followed and the standards that will be applied when a party seeks permission from
8 || the court to file material under seal.
9 B. GOOD CAUSE STATEMENT
”n 10 This action is expected to involve the disclosure of highly sensitive and
2 11 || confidential information, including both (1) medical and personal records and (2) law
= 12 || enforcement personnel records and related materials. The parties agree that special
13 || protection from public disclosure—and from use for any purpose other than the
S 14 || prosecution of this case—is warranted.
15 1.1. Medical and Personal Confidential Information
16 This case may involve the production of private medical and mental health
17 || records, autopsy reports, and other sensitive documents related to the death at issue.
18||These records include, but are not limited to, HIPAA-protected health care
19 || information, as well as confidential information concerning third parties and non-
20 || parties. The parties further anticipate the disclosure of personal identifying
21 |jinformation, background investigation materials, and other documents generally
22 |) unavailable to the public or protected by law.
23 The parties agree that such materials are protected under federal and state
24 || privacy laws, including the Health Insurance Portability and Accountability Act
25 || (HIPAA), and should not be disclosed outside the litigation. The need to preserve the
26 || confidentiality of this information, particularly with respect to individuals not party
27 || to the action, supports the entry of a protective order.
28 1.2. Law Enforcement Personnel Records and Privileged Law Enforcement

1 Materials
2 Separately, Defendants contend that good cause exists for a protective order to
3 || prevent the disclosure of peace officer personnel records and associated investigative
4 || materials. These records include internal police procedures, investigative analyses,
5 ||and legal communications, the release of which could harm public safety, impair law
6 || enforcement functions, and intrude on officers’ privacy.
7 First, Defendants assert that peace officers have a reasonable expectation of
8 || privacy in their personnel records, a protection recognized under both federal law and
9 || California’s Pitchess statutes. See Sanchez v. Santa Ana Police Dept., 936 F.2d 1027,
”n 10 || 1033-34 (9th Cir. 1990); Hallon v. City of Stockton, 2012 U.S. Dist. LEXIS 14665,
2 11 || at *2—3, *12—13 (E.D. Cal. 2012); Soto v. City of Concord, 162 F.R.D. 603, 613 n.4,
12 ||616 (N.D. Cal. 1995); cf. Cal. Penal Code §§ 832.7, 832.8; Cal. Evid. Code §§ 1040-
13 || 1047. They argue that unrestricted disclosure of these materials could endanger
14 || officers, non-party witnesses, and their families or associates.
15 Second, Defendants assert that these records are protected by several federal
|| privileges, including the deliberative process privilege, the official information
privilege, the law enforcement privilege, and the attorney-client privilege (and
18 attorney work product doctrine). These privileges apply especially to materials
19 || involving internal evaluations, critical self-analysis, or legal advice, such as Internal
20 || Affairs reports, supervisory assessments, and documents prepared at the direction of
21 |)counsel. See Kelly v. City of San Jose, 114 F.R.D. 654, 668-71 (N.D. Cal. 1987);
22 || Maricopa Audubon Soc’y v. U.S. Forest Serv., 108 F.3d 1089, 1092-95 (9th Cir.
23 || 1997); Tuite v. Henry, 181 F.R.D. 175, 176-77 (D.D.C. 1998); Admiral Ins. Co. v.
24 || U.S. Dist. Ct., 881 F.2d 1486, 1492, 1495 (9th Cir. 1988). Defendants contend that
25 || disclosure would undermine law enforcement’s ability to obtain candid input from
26 || witnesses, conduct effective investigations, and implement necessary reforms.
27 Third, Defendants note that peace officers may be compelled to provide
28 || statements in connection with internal investigations, unlike private citizens. They

1 |/argue that the involuntary nature of such disclosures makes public release
2 || fundamentally unfair. See Lybarger v. City of Los Angeles, 40 Cal. 3d 822, 828-30
3 || (1985); cf. U.S. Const. amend. V.
4 2. DEFINITIONS
5 2.1. Action: this pending federal law suit.
6 2.2 Challenging Party: a Party or Non-Party that challenges the designation
7 || of information or items under this Order.
8 2.3. “CONFIDENTIAL” Information or Items: information (regardless of
9 || how it is generated, stored or maintained) or tangible things that qualify for protection
”n 10 ||under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
2 11 || Cause Statement.
12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
13 || support staff).
14 2.5 Designating Party: a Party or Non-Party that designates information or
15 ||items that it produces in disclosures or in responses to discovery as
16 || “CONFIDENTIAL.”
17 2.6 Disclosure or Discovery Material: all items or information, regardless
18 || of the medium or manner in which it is generated, stored, or maintained (including,
19 among other things, testimony, transcripts, and tangible things), that are produced or
20 || generated in disclosures or responses to discovery in this matter.
21 2.7 Expert: a person with specialized knowledge or experience in a matter
22 || pertinent to the litigation who has been retained by a Party or its counsel to serve as
23 ||an expert witness or as a consultant in this Action.
24 2.8 House Counsel: attorneys who are employees of a party to this Action.
25 || House Counsel does not include Outside Counsel of Record or any other outside
26 || counsel.
27 2.9 Non-Party: any natural person, partnership, corporation, association, or
28 || other legal entity not named as a Party to this action.

l 2.10 Outside Counsel of Record: attorneys who are not employees of a party
2 ||to this Action but are retained to represent or advise a party to this Action and have
3 || appeared in this Action on behalf of that party or are affiliated with a law firm which
4 || has appeared on behalf of that party, and includes support staff.
5 2.11 Party: any party to this Action, including all of its officers, directors,
6 || employees, consultants, retained experts, and Outside Counsel of Record (and their
7 || support staffs).
8 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
9 || Discovery Material in this Action.
”n 10 2.13 Professional Vendors: persons or entities that provide litigation support
2 ||services (e.g., photocopying, videotaping, translating, preparing exhibits or
= 12 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
13 || and their employees and subcontractors.
14 2.14 Protected Material: any Disclosure or Discovery Material that is
15 || designated as “CONFIDENTIAL.”
16 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
17 || from a Producing Party.
"13. SCOPE
19 Once a case proceeds to trial, all of the information that was designated as
20 confidential or maintained pursuant to this protective order used or introduced as
I an exhibit at trial becomes public and will be presumptively available to all member
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
24 trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 □□□
25 Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in
26 discovery from “compelling reasons” standard when merits-related documents are
27 part of court record). Accordingly, the terms of this protective order do not extend
28

1 || beyond the commencement of the trial except as outlined in this Section.
2 || 4. DURATION
3 Even after final disposition of this litigation, the confidentiality obligations
4|/imposed by this Order shall remain in effect until a Designating Party agrees
5 || otherwise in writing or a court order otherwise directs. Final disposition shall be
6 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
7\|or without prejudice; and (2) final judgment herein after the completion and
8 ||exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
9 || including the time limits for filing any motions or applications for extension of time
”n 10 || pursuant to applicable law.
2 1/5. DESIGNATING PROTECTED MATERIAL
= 12 5.1 Exercise of Restraint and Care in Designating Material for
13 Protection.
14 Each Party or Non-Party that designates information or items for protection
15 || under this Order must take care to limit any such designation to specific material that
16 || qualifies under the appropriate standards. The Designating Party must designate for
17 || protection only those parts of material, documents, items, or oral or written
18 || communications that qualify so that other portions of the material, documents, items,
19 || or communications for which protection is not warranted are not swept unjustifiably
20 || within the ambit of this Order.
21 Mass, indiscriminate, or routinized designations are prohibited. Designations
22 ||that are shown to be clearly unjustified or that have been made for an improper
23 || purpose (e.g., to unnecessarily encumber the case development process or to impose
24 || unnecessary expenses and burdens on other parties) may expose the Designating Party
25 || to sanctions.
26 If it comes to a Designating Party’s attention that information or items that it
27 || designated for protection do not qualify for protection, that Designating Party must
28 || promptly notify all other Parties that it is withdrawing the inapplicable designation.

l 5.2. Manner and Timing of Designations.
2 Except as otherwise provided in this Order (see, e.g., second paragraph of
3 || section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery
4 || Material that qualifies for protection under this Order must be clearly so designated
5 || before the material is disclosed or produced.
6 Designation in conformity with this Order requires:
7 (a) for information in documentary form (e.g., paper or electronic documents,
8 || but excluding transcripts of depositions or other pretrial or trial proceedings), that the
9 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
”n 10 || “CONFIDENTIAL legend”), to each page that contains protected material. If only a
2 11 || portion or portions of the material on a page qualifies for protection, the Producing
= 12 || Party also must clearly identify the protected portion(s) (e.g., by making appropriate
13 || markings in the margins).
S 14 A Party or Non-Party that makes original documents available for inspection
15 ||need not designate them for protection until after the inspecting Party has indicated
16 || which documents it would like copied and produced. During the inspection and before
17||the designation, all of the material made available for inspection shall be deemed
18 || “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
|| copied and produced, the Producing Party must determine which documents, or
20 || portions thereof, qualify for protection under this Order. Then, before producing the
21 || specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
22 ||to each page that contains Protected Material. If only a portion or portions of the
23 ||material on a page qualifies for protection, the Producing Party also must clearly
24 |jidentify the protected portion(s) (e.g., by making appropriate markings in the
25 || margins).
26 (b) for testimony given in depositions that the Designating Party identify the
27 || Disclosure or Discovery Material on the record, before the close of the deposition all
28 || protected testimony.

l (c) for information produced in some form other than documentary and for any
2 || other tangible items, that the Producing Party affix in a prominent place on the exterior
3 ||of the container or containers in which the information is stored the legend
4||“CONFIDENTIAL.” If only a portion or portions of the information warrants
5 || protection, the Producing Party, to the extent practicable, shall identify the protected
6 || portion(s).
7 5.3. Inadvertent Failures to Designate.
8 If timely corrected, an inadvertent failure to designate qualified information or
9 |/items does not, standing alone, waive the Designating Party’s right to secure
”n 10 || protection under this Order for such material. Upon timely correction of a designation,
2 11 || the Receiving Party must make reasonable efforts to assure that the material is treated
12 || in accordance with the provisions of this Order.
13 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
14 6.1. Timing of Challenges. Any Party or Non-Party may challenge a
15 || designation of confidentiality at any time that is consistent with the Court’s
16 || Scheduling Order.
17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
18 || resolution process under Local Rule 37.1 et seq.
19 6.3. The burden of persuasion in any such challenge proceeding shall be on
20 || the Designating Party. Frivolous challenges, and those made for an improper purpose
21 ||(e.g., to harass or impose unnecessary expenses and burdens on other parties) may
22 || expose the Challenging Party to sanctions. Unless the Designating Party has waived
23 ||or withdrawn the confidentiality designation, all parties shall continue to afford the
24 || material in question the level of protection to which it is entitled under the Producing
25 || Party’s designation until the Court rules on the challenge.
26 ||7. ACCESS TO AND USE OF PROTECTED MATERIAL
27 7.1. Basic Principles. A Receiving Party may use Protected Material that is
28 || disclosed or produced by another Party or by a Non-Party in connection with this

1 || Action only for prosecuting, defending, or attempting to settle this Action. Such
2 || Protected Material may be disclosed only to the categories of persons and under the
3 || conditions described in this Order. When the Action has been terminated, a Receiving
4 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
5 || Protected Material must be stored and maintained by a Receiving Party at a location
6 || and in a secure manner that ensures that access is limited to the persons authorized
7 || under this Order.
8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
9 || otherwise ordered by the court or permitted in writing by the Designating Party, a
”n 10||Receiving Party may disclose any information or item designated
2 11 || “CONFIDENTIAL” only to:
= 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
13 ||}employees of said Outside Counsel of Record to whom it is reasonably necessary to
14 || disclose the information for this Action;
15 (b) the officers, directors, and employees (including House Counsel) of the
16 || Receiving Party to whom disclosure is reasonably necessary for this Action;
17 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure
18 || is reasonably necessary for this Action and who have signed the “Acknowledgment
19 ||and Agreement to Be Bound” (Exhibit A);
20 (d) the court and its personnel;
21 (e) court reporters and their staff;
22 (f) professional jury or trial consultants, mock jurors, and Professional Vendors
23 ||to whom disclosure is reasonably necessary for this Action and who have signed the
24 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (g) the author or recipient of a document containing the information or a
26 || custodian or other person who otherwise possessed or knew the information;
27 (h) during their depositions, witnesses ,and attorneys for witnesses, in the
28 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party

1 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
2||not be permitted to keep any confidential information unless they sign the
3 ||“‘Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
4||agreed by the Designating Party or ordered by the court. Pages of transcribed
5 || deposition testimony or exhibits to depositions that reveal Protected Material may be
6 || separately bound by the court reporter and may not be disclosed to anyone except as
7 || permitted under this Stipulated Protective Order; and
8 (1) any mediator or settlement officer, and their supporting personnel, mutually
9 || agreed upon by any of the parties engaged in settlement discussions.
”n 10 ||8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
2 11 |} OTHER LITIGATION
12 If a Party is served with a subpoena or a court order issued in other litigation
13 ||that compels disclosure of any information or items designated in this Action as
S 14 || “CONFIDENTIAL,” that Party must:
15 (a) promptly notify in writing the Designating Party. Such notification shall
16 || include a copy of the subpoena or court order;
17 (b) promptly notify in writing the party who caused the subpoena or order to
18 || issue in the other litigation that some or all of the material covered by the subpoena
19 || or order is subject to this Protective Order. Such notification shall include a copy of
20 || this Stipulated Protective Order; and
21 (c) cooperate with respect to all reasonable procedures sought to be pursued by
22 || the Designating Party whose Protected Material may be affected.
23 If the Designating Party timely seeks a protective order, the Party served with
24 || the subpoena or court order shall not produce any information designated in this action
25 |}as “CONFIDENTIAL” before a determination by the court from which the subpoena
26 || or order issued, unless the Party has obtained the Designating Party’s permission. The
27 || Designating Party shall bear the burden and expense of seeking protection in that court
28 || of its confidential material and nothing in these provisions should be construed as

1 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful
2 || directive from another court.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 || PRODUCED IN THIS LITIGATION
5 (a) The terms of this Order are applicable to information produced by a Non-
6||Party in this Action and designated as “CONFIDENTIAL.” Such information
7||produced by Non-Parties in connection with this litigation is protected by the
8 ||remedies and relief provided by this Order. Nothing in these provisions should be
9 || construed as prohibiting a Non-Party from seeking additional protections.
”n 10 (b) In the event that a Party is required, by a valid discovery request, to
2 11 || produce a Non-Party’s confidential information in its possession, and the Party is
= 12||subject to an agreement with the Non-Party not to produce the Non-Party’s
13 || confidential information, then the Party shall:
S 14 (1) promptly notify in writing the Requesting Party and the Non-Party
15 || that some or all of the information requested is subject to a confidentiality agreement
16 || with a Non-Party;
17 (2) promptly provide the Non-Party with a copy of the Stipulated
18 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
19 || specific description of the information requested; and
20 (3) make the information requested available for inspection by the Non-
21 || Party, if requested.
22 (c) Ifthe Non-Party fails to seek a protective order from this court within 14
23 || days of receiving the notice and accompanying information, the Receiving Party may
24 || produce the Non-Party’s confidential information responsive to the discovery request.
25 || If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
26 ||any information in its possession or control that is subject to the confidentiality
27 ||agreement with the Non-Party before a determination by the court. Absent a court
28 || order to the contrary, the Non-Party shall bear the burden and expense of seeking

1 || protection in this court of its Protected Material.
2 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
4 || Protected Material to any person or in any circumstance not authorized under this
5 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in
6 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
7 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
8 || persons to whom unauthorized disclosures were made of all the terms of this Order,
9|/and (d) request such person or persons to execute the “Acknowledgment and
”n 10 || Agreement to Be Bound” that is attached hereto as Exhibit A.
2 11]}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
12 PROTECTED MATERIAL
13 When a Producing Party gives notice to Receiving Parties that certain
14 || inadvertently produced material is subject to a claim of privilege or other protection,
15 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
16 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
17 || may be established in an e-discovery order that provides for production without prior
18 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
19 || parties reach an agreement on the effect of disclosure of a communication or
20 || information covered by the attorney-client privilege or work product protection, the
21 || parties may incorporate their agreement in the stipulated protective order submitted
22 || to the court.
23 |} 12. MISCELLANEOUS
24 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
25 || person to seek its modification by the Court in the future.
26 12.2 Right to Assert Other Objections. By stipulating to the entry of this
27 || Protective Order no Party waives any right it otherwise would have to object to
28 || disclosing or producing any information or item on any ground not addressed in this

1 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
2 || ground to use in evidence of any of the material covered by this Protective Order.
3 12.3 Filing Protected Material. A Party that seeks to file under seal any
4 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may
5 || only be filed under seal pursuant to a court order authorizing the sealing of the specific
6 || Protected Material at issue. If a Party's request to file Protected Material under seal is
7 || denied by the court, then the Receiving Party may file the information in the public
8 || record unless otherwise instructed by the court.
9 ||13. FINAL DISPOSITION
”n 10 After the final disposition of this Action, as defined in paragraph 4, within 60
2 11 || days of a written request by the Designating Party, each Receiving Party must return
= 12 || all Protected Material to the Producing Party or destroy such material. As used in this
13 || subdivision, “all Protected Material” includes all copies, abstracts, compilations,
S 14||summaries, and any other format reproducing or capturing any of the Protected
15 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party
16 || must submit a written certification to the Producing Party (and, if not the same person
or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
18 || category, where appropriate) all the Protected Material that was returned or destroyed
19 ||and (2)affirms that the Receiving Party has not retained any copies, abstracts,
20 || compilations, summaries or any other format reproducing or capturing any of the
21 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
22 ||archival copy of all pleadings, motion papers, trial, deposition, and hearing
23 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
24 || reports, attorney work product, and consultant and expert work product, even if such
25 ||materials contain Protected Material. Any such archival copies that contain or
26 || constitute Protected Material remain subject to this Protective Order as set forth in
27 || Section 4 (DURATION).
28/14. VIOLATIONS

l Any violation of this Order may be punished by any and all appropriate
2||measures including, without limitation, contempt proceedings and/or monetary
3 || sanctions.
4
5 IT IS SO STIPULATED THROUGH COUNSEL OF RECORD.
6
DATED: September 22, 2025 Respectfully submitted,
8 MANNING & KASS
9 ELLROD, RAMIREZ, TRESTER LLP
10 By: /s/ Kayleigh Andersen
2 11 Eugene P. Ramirez
x 2 Kayleigh Andersen
oO Attorneys for Defendant, Deputy CORRIN
z 13 CASSIDY
4
<x DATED: September 22, 2025 LAW OFFICES OF CHRISTIAN
= 15 CONTRERAS
16
17
18 By: /s/ Claire McCall
Christian Contreras
19 Claire McCall
20 Attorneys for Plaintiffs, Estate of Glenn
McCrary, et al.
21
22
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24
25
26
27
28

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
3 DATED: October 3, 2025
4
PRR

4 United States Magistrate Judge
8
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”n 10
< 11
— 12
2;
S 4
Ss
16

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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [print or type full name], of
4 [print or type full address],
5 declare 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 the
7||Central District of California on [date] in the case of
8 || ESTATE OF GLENN MCCRARY, et al, v. COUNTY OF SAN BERNARDINO,
9 || et al, Case No. 5:23-cv-02602 SSS (SPx). I agree to comply with and to be bound by
”n 10 || all the terms of this Stipulated Protective Order and I understand and acknowledge
2 11 || that failure to so comply could expose me to sanctions and punishment in the nature
= 12 || of contempt. I solemnly promise that I will not disclose in any manner any information
13 || or item that is subject to this Stipulated Protective Order to any person or entity except
S 14 || in strict compliance with the provisions of this Order. I further agree to submit to the
15 || jurisdiction of the United States District Court for the Central District of California
16 || for the purpose of enforcing the terms of this Stipulated Protective Order, even if such
17 enforcement proceedings occur after termination of this action. I hereby appoint
18 [print or type full name] of
19 [print or type full address and telephone
20 || number] as my California agent for service of process in connection with this action
21 || or any proceedings related to enforcement of this Stipulated Protective Order.
22 || Date:
23 || City and State where sworn and signed:
24
25 || Printed name:
26
27 || Signature:
28

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11170795. Public record. Not legal advice.