even 15 || stipulated protective orders require good cause showing
How later courts described this case
- even 15 || stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 || BLANK ROME LLP
Jeffrey Rosenfeld (SBN 221625)
2 jeffrey.rosenfeld@blankrome.com
3 || 2029 Century Park East, 6th Floor
Los Angeles, CA 90067
4 || Telephone: (424) 239-3400
g Facsimile: (424) 239-3434
6 Attorneys for Plaintiff John Doe
7 UNITED STATES DISTRICT COURT
8 CENTRAL DISTRICT OF CALIFORNIA
JOHN DOE, an individual, Case No. 2:25-cv-01387-FMO-RAO
11
Plaintiff, STIPULATED PROTECTIVE
12 ORDER
13 |v. Judge: Hon. Rozella A. Oliver
14 io. Edward R. Roybal Federal
SAIGE STAR ROWLEY, an individual, Building and United States
15 Courthouse, Los Angeles
Defendant. Courtroom 590, 5th Floor
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ONNSON1R2 NNNN1/1f2ecm%weco 4
1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 || proprietary, or private information for which special protection from public
4 || disclosure and from use for any purpose other than pursuing this litigation may be
5 || warranted. Accordingly, the parties hereby stipulate to and petition the Court to
6 || grant the following Stipulated Protective Order (“Order”). The parties acknowledge
7 || that this Order does not confer blanket protections on all disclosures or responses tc
8 || discovery and that the protection it affords from public disclosure and use extends
9 || only to the limited information or items that are entitled to confidential treatment
10 || under the applicable legal principles.
11 B. GOOD CAUSE STATEMENT
12 This is an action filed for damages pursuant to 15 U.S.C. § 6851, which
13 || alleges the unauthorized disclosure and publication of intimate images. Discovery
14 |} in this action will therefore include intimate images and videos and other materials
15 || for which special protection from public disclosure and from use for any purpose
16 || other than this action is warranted, including materials and information previously
17 || ordered by the Court to be filed under seal. [See, ECF 43.] Consistent with that
18 || previous order, 15 U.S.C. § 6581(b)(3)(B), and Fed. R. Civ. P. 26(c)(1), the Court
19 || has good cause for the issuance of this Order.
20 Accordingly, to expedite the flow of information, to facilitate the prompt
21 || resolution of disputes over confidentiality of discovery materials, to adequately
22 || protect information the parties are entitled to keep confidential, to ensure that the
23 || parties are permitted reasonable necessary uses of such material in preparation for
24 || and in the conduct of trial, to address their handling at the end of the litigation, and
25 || serve the ends of justice, a protective order for such information is justified in this
26 || matter. It is the intent of the parties that information will not be designated as
27 confidential for tactical reasons and that nothing be so designated without a good
28
1 || faith belief that there is good cause as to why it should not be part of the public
2 || record of this case.
3 C. ACKNOWLEDGEMENT OF UNDER SEAL FILING
4 PROCEDURE
5 The parties further acknowledge, as set forth in Section 12.3, below, that this
6 || Stipulated Protective Order does not entitle them to file confidential information
7 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
8 || and the standards that will be applied when a party seeks permission from the court
9 || to file material under seal. There is a strong presumption that the public has a right
10 || of access to judicial proceedings and records in civil cases. In connection with non-
11 || dispositive motions, good cause must be shown to support a filing under seal. See
12 || Kamakana v. City and County of Honolulu, 447 F.3d 1 172, 1176 (9th Cir. 2006),
13 || Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
14 |) Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
15 || stipulated protective orders require good cause showing), and a specific showing of
16 || good cause or compelling reasons with proper evidentiary support and legal
17 || justification, must be made with respect to Protected Material that a party seeks to
18 || file under seal. The parties’ mere designation of Disclosure or Discovery Material
19 ||as CONFIDENTIAL does not—without the submission of competent evidence by
20 || declaration, establishing that the material sought to be filed under seal qualifies as
21 || confidential, privileged, or otherwise protectable—constitute good cause.
22 Further, if a party requests sealing related to a dispositive motion or trial,
23 || then compelling reasons, not only good cause, for the sealing must be shown, and
24 the relief sought shall be narrowly tailored to serve the specific interest to be
25 || protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 667-79 (9th Cir.
26 2010). For each item or type of information, document, or thing sought to be filed
27 || or introduced under seal, the party seeking protection must articulate compelling
28 reasons, supported by specific facts and legal justification, for the requested sealing
I |} order. Again, competent evidence supporting the application to file documents
2 || under seal must be provided by declaration.
3 Any document that is not confidential, privileged, or otherwise protectable ir
4 || its entirety will not be filed under seal if the confidential portions can be redacted.
5 || If documents can be redacted, then a redacted version for public viewing, omitting
6 || only the confidential, privileged, or otherwise protectable portions of the document
7 || shall be filed. Any application that seeks to file documents under seal in their
8 || entirety should include an explanation of why redaction is not feasible.
9 The foregoing is not intended to contradict ECF 43, which provides
10 || additional orders regarding the filing of matters under seal in this action.
11 2. DEFINITIONS
12 2.1 Action: This pending federal lawsuit entitled John Doe v. Saige Star
13 || Rowley, 2:25-cv-01387-FMO-RAO.
14 2.2 Challenging Party: A Party or Non-Party that challenges the
15 || designation of information or items under this Order.
16 2.3. “CONFIDENTIAL” Information or Items: Information (regardless of
17 || how it is generated, stored, or maintained) or tangible things that qualify for
18 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in
19 || the Good Cause Statement.
20 2.4 “CONFIDENTIAL □ ATTORNEYS’ EYES ONLY” Information or
21 |/ Items: Extremely sensitive “Confidential Information or Items,” which would
22 || create a substantial risk of serious harm if it were disclosed to another Party or Non-
23 || Party.
24 2.5 Counsel: Outside Counsel of Record (as well as their support staff).
2.6 Designating Party: A Party or Non-Party that designates information or
26 items that it produces in disclosures or in responses to discovery as
27 ||“CONFIDENTIAL” or “CONFIDENTIAL — ATTORNEYS’ EYES ONLY.”
28
2.7 Disclosure or Discovery Material: All items or information, regardles:
2 || of 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
4 || or generated in disclosures or responses to discovery in this matter.
5 2.8 Expert: A person with specialized knowledge or experience in a matte
6 || pertinent to the litigation who has been retained by a Party or his or her counsel to
7 || Serve as an expert witness or as a consultant in this Action.
8 2.9 Final Disposition: The later of (1) dismissal of all claims and defenses
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 2.10 Non-Party: Any natural person, partnership, corporation, association,
14 || or other legal entity not named as a Party to this action.
2.11 Outside Counsel of Record: Attorneys who are not employees of a
16 || party to this Action but are retained to represent or advise a party to this Action and
17 || have appeared in this Action on behalf of that party or are affiliated with a law firm
18 || that has appeared on behalf of that party, including support staff.
19 2.12 Party: Any party to this Action.
20 2.13 Producing Party: A Party or Non-Party that produces Disclosure or
21 || Discovery Material in this Action.
22 2.14 Professional Vendors: Persons or entities that provide litigation
23 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or
24 demonstrations, and organizing, storing, or retrieving data in any form or medium)
25 || and their employees and subcontractors.
26 2.15 Protected Material: Any Disclosure or Discovery Material that is
27 || designated as “CONFIDENTIAL” or “CONFIDENTIAL — ATTORNEYS’ EYES
28 || ONLY.”
1 2.16 Receiving Party: A Party that receives Disclosure or Discovery
2 || Material 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 and other applicable authorities. This Order does not govern the use of
11 || Protected Material at trial.
12 4. DURATION
13 Even after Final Disposition of this litigation, the confidentiality obligations
14 || imposed by this Order shall remain in effect until a Designating Party agrees
15 || otherwise in writing or a court order otherwise directs.
16 5: | DESIGNATING PROTECTED MAT ERIAL
17 5.1 Exercise of Restraint and Care in Designating Material for Protection.
18 || Each Party or Non-Party that designates information or items for protection under
19 |) this Order must take care to limit any such designation to specific material that
20 || qualifies under the appropriate standards. The Designating Party must designate for
21 || protection only those parts of material, documents, items, or oral or written
22 ||communications that qualify so that other portions of the material, documents,
23 |/items, or communications for which protection is not warranted are not swept
24 |/unjustifiably within the ambit of this Order.
25 Mass, indiscriminate, or routinized designations are prohibited. Designations
26 || that are shown to be clearly unjustified or that have been made for an improper
27 || purpose (e.g., to unnecessarily encumber the case development process or to
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1 || impose unnecessary expenses and burdens on other parties) may expose the
2 || Designating Party to sanctions.
3 If it comes to a Designating Party’s attention that information or items that it
4 || designated for protection do not qualify for protection, that Designating Party must
5 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
6 5.2 Manner and Timing of Designations. Except as otherwise provided in
7 || this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material
8 |/ that qualifies for protection under this Order must be clearly so designated before
9 || contemporaneous with disclosure or production. Nothing in this Order shall prevent
10 |)a Designating Party from using and disclosing its Protected Material in any way.
11 || Nothing in this Order shall restrict any Counsel from advising their client with
12 || respect to this Action and from relying in a general way upon an examination of
13 |) information designated pursuant to this Order in giving such advice; provided,
14 || however, that in giving such advice and communicating with the client, Counsel
15 || shall not disclose the substance or contents of any “CONFIDENTIAL —
16 || ATTORNEYS’ EYES ONLY” information except to persons permitted such access
17 || under this Order.
18 Designation in conformity with this Order requires:
19 (a) For information in documentary form (e.g., paper or electronic
20 || documents, but excluding transcripts of depositions or other pretrial or trial
21 || proceedings), that the Producing Party affix at a minimum, the legend
22 ||“CONFIDENTIAL” or “CONFIDENTIAL — ATTORNEYS’ EYES ONLY”
23 || (hereinafter “CONFIDENTIAL legend”), to each page that contains protected
24 material. If only a portion or portions of the material on a page qualifies for
25 || protection, the Producing Party also must clearly identify the protected portion(s)
26 || (e.g., by making appropriate markings in the margins).
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I (b) for testimony given in depositions that the Designating Party
2 || identifies the Disclosure or Discovery Material on the record, before the close of
3 || the deposition all protected testimony.
4 (c) for information produced in some form other than documentary an
5 || for any other tangible items, that the Producing Party affix in a prominent place on
6 || the exterior of the container or containers in which the information is stored the
7 || CONFIDENTIAL legend. If only a portion or portions of the information warrants
8 || protection, the Producing Party, to the extent practicable, shall identify the
9 || protected portion(s).
10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
11 || failure to designate qualified information or items does not, standing alone, waive
12 || the Designating Party’s right to secure protection under this Order for such
13 |) material. Upon timely correction of a designation, the Receiving Party must make
14 || reasonable efforts to assure that the material is treated in accordance with the
15 || provisions of this Order.
16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
18 || designation of confidentiality at any time that is consistent with the Court’s
19 || Scheduling Order.
20 6.2 Meet and Confer. The Challenging Party Shall initiate the dispute
21 || resolution process under Civil Local Rule 37-1 et seq.
6.3. The burden of persuasion in any such challenge proceeding shall be on
23 || the Designating Party. Frivolous challenges, and those made for an improper
24 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other
25 parties), may expose the Challenging Party to sanctions. Unless the Designating
26 || Party has waived or withdrawn the confidentiality designation, all parties shall
27 continue to afford the material in question the level of protection to which it is
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ONSN18 NNNN1 1 cect4eco.. 1 . rt
1 |/ entitled under the Producing Party’s designation until the Court rules on the
2 || challenge.
3 7. ACCESS TO AND USE OF PROT ECTED MATERIAL
4 7.1 Basic Principles. A Receiving Party may use Protected Material that is
5 || disclosed or produced by another Party or by a Non-Party in connection with this
6 || Action only for prosecuting, defending, or attempting to settle this Action. Such
7 || Protected Material may be disclosed only to the categories of persons and under the
8 || conditions described in this Order. When the Action has been terminated, a
9 || Receiving Party must comply with the provisions of Section 13 below (FINAL
10 || DISPOSITION).
1] Protected Material must be stored and maintained by a Receiving Party ata
12 || location and in a secure manner that ensures that access is limited to the persons
13 || authorized under this Order.
14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
15 || otherwise ordered by the Court or permitted in writing by the Designating Party, a
16 || Receiving Party may disclose any information or item designated
17 || “CONFIDENTIAL” only to:
18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
19 || well as employees of said Outside Counsel of Record to whom it is reasonably
20 ||necessary to disclose the information for this Action;
al (b) Experts (as defined in this Order) of the Receiving Party to whom
22 || disclosure is reasonably necessary for this Action and who have signed the
23 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
24 (c) the Court and its personnel;
25 (d) court reporters and their staff;
26 (e) professional jury or trial consultants, mock jurors, and Professional
27 || Vendors to whom disclosure is reasonably necessary for this Action and who have
28 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
1 (f) during their depositions, witnesses, and attorneys for witnesses, in
2 || the Action to whom disclosure is reasonably necessary provided: (1) the deposing
3 || party requests that the witness sign the form attached as Exhibit A hereto; and (2)
4 || they will not be permitted to keep any confidential information unless they sign the
5 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
6 || agreed by the Designating Party or ordered by the Court. Pages of transcribed
7 || deposition testimony or exhibits to depositions that reveal Protected Material may
8 || be separately bound by the court reporter and may not be disclosed to anyone
9 || except as permitted under this Stipulated Protective Order; and
10 (g) any mediator or settlement officers, and their supporting personnel,
11 mutually agreed upon by any of the parties engaged in settlement discussions.
12 7.3 Disclosure of “CONFIDENTIAL — ATTORNEYS’ EYES ONLY”
13 || Information or Items. Unless otherwise ordered by the Court or permitted in writing
14 || by the Designating Party, a Receiving Party may disclose any information or item
15 || designated “CONFIDENTIAL — ATTORNEYS’ EYES ONLY” only to:
16 (a) the Receiving Party’s Outside Counsel of Record and their
17 || employees to whom it is reasonably necessary to disclose the information for this
18 || litigation;
19 (b) Experts (as defined in the Order) of the Receiving Party to whom
20 || disclosure is reasonably necessary for this litigation and who have signed the
21 ||“Acknowledgement and Agreement to Be Bound” (Exhibit A);
(c) the Court, jury, and court personnel;
23 (d) court reporters and their staff;
24 (e) professional jury or trial consultants, and Professional Vendors to
25 || whom disclosure is reasonably necessary for this litigation and who have signed the
26 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (f) the author or recipient of a document containing the information or
28 |/a custodian or other person who otherwise possessed or knew the information;
FRR AY a iar Ee an
(g) during their depositions, the Designating Party; and
2 (h) any mediator who is assigned to hear this matter, and his or her
3 || staff, subject to their agreement to maintain confidentiality to the same degree as
4 || required by this Protective Order.
5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
6 || PRODUCED IN OTHER LITIGATION
7 If a Party is served with a subpoena or a court order issued in other litigation
8 || that compels disclosure of any information or items designated in this Action as
9 ||“CONFIDENTIAL” or “CONFIDENTIAL — ATTORNEYS’ EYES ONLY” that
10 || Party must:
11 (a) promptly notify in writing the Designating Party. Such notification
12 shall include a copy of the subpoena or court order;
13 (b) promptly notify in writing the party who caused the subpoena or
14 || order to issue in the other litigation that some or all of the material covered by the
15 || subpoena or order is subject to this Protective Order. Such notification shall include
16 |/a copy of this Stipulated Protective Order; and
17 (c) cooperate with respect to all reasonable procedures sought to be
18 || pursued by the Designating Party whose Protected Material may be affected.
19 If the Designating Party timely seeks a protective order, the Party served with
20 || the subpoena or court order shall not produce any information designated in this
21 action as “CONFIDENTIAL” or “CONF IDENTIAL — ATTORNEYS’ EYES
22 || ONLY” before a determination by the court from which the subpoena or order
23 issued, unless the Party has obtained the Designating Party’s permission. The
24 || Designating Party shall bear the burden and expense of seeking protection in that
25 || court of its confidential material, and nothing in these provisions should be
26 construed as authorizing or encouraging a Receiving Party in this Action to disobey
27 lawful directive from another court.
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Am oman ayaa oe
1 9. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 || PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by
4 || Non-Party in this Action and including a CONFIDENTIAL LEGEND. Such
5 || information produced by Non-Parties in connection with this litigation is protected
6 || by the remedies and relief provided by this Order. Nothing in these provisions
7 || should be construed as prohibiting a Non-Party from seeking additional protections
8 (b) In the event that a Party is required, by a valid discovery request, tc
9 || produce a Non-Party’s confidential information in its possession, and the Party is
10 || subject to an agreement with the Non-Party not to produce the Non-Party’s
11 |) confidential information, then the Party shall:
12 (1) promptly notify in writing the Requesting Party and the
13 Non-Party that some or all of the information requested is subject to a
14 confidentiality agreement with a Non-Party;
15 (2) promptly provide the Non-Party with a copy of the
16 Stipulated Protective Order in this Action, the relevant discovery
17 request(s), and a reasonably specific description of the information
18 requested; and
19 (3) make the information requested available for inspection by
20 the Non-Party, if requested.
(c) If the Non-Party fails to seek a protective order from this court
22 || within 14 days of receiving the notice and accompanying information, the
23 || Receiving Party may produce the Non-Party’s confidential information responsive
24 □□ the discovery request. If the Non-Party timely seeks a protective order, the
25 || Receiving Party shall not produce any information in its possession or control that
26 subject to the confidentiality agreement with the Non-Party before a
27 || determination by the court. Absent a court order to the contrary, the Non-Party
28
I || shall bear the burden and expense of seeking protection in this court of its Protecte
2 || Material.
3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
4 || MATERIAL
5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclose
6 || Protected Material to any person or in any circumstance not authorized under this
7 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in
8 || writing the Designating Party of the unauthorized disclosures, (b) use its best
9 || efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
10 || person or persons to whom unauthorized disclosures were made of all the terms of
11 ||/this Order, and (d) request such person or persons to execute the “Acknowledgment
12 |)and Agreement to Be Bound” that is attached hereto as Exhibit A.
13 ll. INADVERTENT PRODUCTION OF PRIVILEGED OR
14 || OTHERWISE PROTECTED MATERIAL
15 When a Producing Party gives notice to Receiving Parties that certain
16 || inadvertently produced material is subject to a claim of privilege or other
17 || protection, the obligations of the Receiving Parties are those set forth in Federal
18 || Rule of Civil Procedure 26(b)(S)(B). This provision is not intended to modify
19 || whatever procedure may be established in an e-discovery order that provides for
20 || production without prior privilege review. Pursuant to Federal Rule of Evidence
21 |}502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
22 || of a communication or information covered by the attorney-client privilege or work
23 || product protection, the parties may incorporate their agreement in the stipulated
24 || protective order submitted to the court.
25 12. INADVERTENT PRODUCTION OF PRIVILEGED OR
26 || OTHERWISE PROTECTED MATERIAL
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
28 || person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry of this
2 || Protective Order, no Party waives any right it otherwise would have to object to
3 || disclosing or producing any information or item on any ground not addressed in
4 || this Stipulated Protective Order. Similarly, no Party waives any right to object on
5 ground to use in evidence of any of the material covered by this Protective
6 || Order.
7 12.3 Filing Protected Material. A Party that seeks to file under seal any
8 || Protected Material must comply with Local Civil Rule 79-5 and ECF 43. Protected
9 || Material may only be filed under seal pursuant to a court order authorizing the
10 || sealing of the specific Protected Material at issue. Ifa Party’s request to file
11 || Protected Material under seal is denied by the court, then the Receiving Party may
12 || file the information in the public record unless otherwise instructed by the court.
13 13. FINAL DISPOSITION
14 After the final disposition of this Action, as defined in paragraph 4, within 60
15 || days of a written request by the Designating Party, each Receiving Party must
16 || return all Protected Material to the Producing Party or destroy such material. As
17 || used in this subdivision, “all Protected Material” includes all copies, abstracts,
18 || compilations, summaries, and any other format reproducing or capturing any of the
19 || Protected Material. Whether the Protected Material is returned or destroyed, the
20 || Receiving Party must submit a written certification to the Producing Party (and, if
21 |/not the same person or entity, to the Designating Party) by the 60 day deadline that
22 || (1) identifies (by category, where appropriate) all the Protected Material that was
23 returned or destroyed and (2) affirms that the Receiving Party has not retained any
24 || copies, abstracts, compilations, summaries or any other format reproducing or
25 || capturing any of the Protected Material. Notwithstanding this provision, Counsel
26 || are entitled to retain an archival copy of all pleadings, motion papers, trial,
27 || deposition, and hearing transcripts, legal memoranda, correspondence, deposition
28 || and trial exhibits, expert reports, attorney work product, and consultant and expert
1 || work product, even if such materials contain Protected Material. Any such archival
2 || copies that contain or constitute Protected Material remain subject to this Protective
3 || Order as set forth in Section 4 (DURATION).
4 14. VIOLATION
3 Any violation of this Order may be punished by appropriate measures
6 || including, without limitation, contempt proceedings and/or monetary sanctions.
IT IS SO STIPULATED BY THE PARTIES AND THROUGH COUNSEL
9 || OF RECORD.
10
11 |} DATED: October 2; , 2025 BLANK ROME LLP
12
13 By: _/s/ Jeffrey Rosenfeld
Jeffrey Rosenfeld
14 Attorneys for Plaintiff John Doe
15
16 ‘
DATED: October| | , 2025 SAIGE STAR ROWLEY (in pro per)
17
18
By:
19 Saige Star Rowley
20
21 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED
22 .
23 Reg phi. Q . Cit we DATED: October 22, 2025
HON. ROZELLA A. OLIVER
United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, Saige Star Rowley [print or type full name], of
4 || 28720 Roadside Drive #152 [print or type full address], declare under penalty of perjury
“Agoura Hills, 97301
5 || that I have read in its entirety and understand the Stipulated Protective Order that
6 || was issued by the United States District Court for the Central District of California
7 || on [date] in the case of John Doe v. Saige Star Rowley, 2:25-cv-01387-FMO-RAO.
8 ||I agree to comply with and to be bound by all the terms of this Stipulated Protective
9 || Order and I understand and acknowledge that failure to so comply could expose me
10 || to sanctions and punishment in the nature of contempt. I solemnly promise that I
11 || will not disclose in any manner any information or item that is subject to this
12 || Stipulated Protective Order to any person or entity except in strict compliance with
13 || the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court
15 || for the Central District of California for enforcing the terms of this Stipulated
16 || Protective Order, even if such enforcement proceedings occur after termination of
17 || this action. I hereby appoint Jeffrey Rosenfeld [print or type full
18 || name] of _ 2979 Century Park East, 6th Floor LA, CA 90067 [print or type full
19 || address and Glenhone number] as my California agent for service of process in
20 || connection with this action or any proceedings related to enforcement of this
21 || Stipulated Protective Order.
22 || Date: October 17th, 2025
23 || City and State where sworn and signed: Agoura Hills, CA
24
25 || Printed name: \ a JE, Star Kw nl
26
27 || Signature:
28