even stipulated protective orders require good cause 4 showing
How later courts described this case
- even stipulated protective orders require good cause 4 showing
Written by the judges who cited it.
The opinion
1 THE AGUILERA LAW GROUP, APLC
Eric Aguilera (SBN 192390)
2 Raymond Brown (SBN 164819)
V. René Daley (SBN 199914)
3
23046 Avenida De La Carlota, Suite 300
4 Laguna Hills, CA 92653
T: 714-384-6600 / F: 714-384-6601
5 eaguilera@aguileragroup.com
rbrown@aguileragroup.com
6 rdaley@aguileragroup.com
Attorneys for plaintiffs
7
8 Attorneys for plaintiffs A.I.C. (a minor), Anthony Charles Francisco Cachua, and Luz
Maria Cachua
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
12 A.I.C., et al., Case No.: 2:25-cv-02575 -SPG-(RAOx)
13 Plaintiffs, Complaint served: March 24, 2025
Trial: June 2, 2025
14 vs.
[PROPOSED] STIPULATED
15
VICTOR CORRAL, et al., PROTECTIVE ORDER
16
Defendants.
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1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential or private
3 information for which special protection from public disclosure and from use for any
4 purpose other than prosecuting this litigation may be warranted. Accordingly, the parties
5 hereby stipulate to and petition the Court to enter the following Stipulated Protective
6 Order. The parties acknowledge that this Order does not confer blanket protections on
7 all disclosures or responses to discovery and that the protection it affords from public
8 disclosure and use extends only to the limited information or items that are entitled to
9 confidential treatment under the applicable legal principles.
10
11 B. GOOD CAUSE STATEMENT
12 The Parties represent that pre-trial discovery in this case is likely to include the
13 production of information and/or documents that are confidential and/or privileged
14 including the production of medical records and the production of peace officer
15 personnel file information and/or documents which the Parties agree includes:
16 (1) personal data, including marital status, family members, educational and
17 employment history, home addresses, or similar information; (2) medical history;
18 (3) election of employee benefits; (4) employee advancement, appraisal, or discipline;
19 and (5) complaints, or investigations of complaints, concerning an event or transaction
20 in which a peace officer participated, or which a peace officer perceived, and pertaining
21 to the manner in which the peace officer performed his or her duties including compelled
22 statements by peace officers unless specifically denoted as “not confidential” pursuant
23 to Penal Code section 832.7. Defendants contend that such information is privileged as
24 official information. Sanchez v. City of Santa Ana, 936 F.2d 1027, 1033 (9th Cir. Cal.
25 1990); see also Kerr v. United States Dist. Ct. for N.D. Cal., 511 F.2d 192, 198 (9th
26 Cir.1975), aff'd, 426 U.S. 394, 96 S.Ct. 2119, 48 L.Ed.2d 725 (1976). Further, discovery
27 may require the production of certain Los Angeles Police Department policies,
28 procedures, and logs not available to the public and the public disclosure of which
1 Defendants contend could comprise officer safety, raise security issues, and/or impede
2 investigations.
3 Defendants contend that public disclosure of such material poses a substantial risk
4 of embarrassment, oppression and/or physical harm to peace officers. Defendants
5 further contend that the risk of harm to peace officers is greater than with other
6 government employees due to the nature of their profession. Finally, Defendants
7 contend that the benefit of public disclosure of the material discussed in the prior
8 paragraph is minimal while the potential disadvantages are great.
9 Accordingly, to expedite the flow of information, to facilitate the prompt
10 resolution of disputes over confidentiality of discovery materials, to adequately protect
11 information the parties are entitled to keep confidential, to ensure that the parties are
12 permitted reasonable necessary uses of such material in preparation for and in the
13 conduct of trial, to address their handling at the end of the litigation, and serve the ends
14 of justice, a protective order for such information is justified in this matter. It is the
15 intent of the parties that information will not be designated as confidential for tactical
16 reasons and that nothing be so designated without a good faith belief that it has been
17 maintained in a confidential, non-public manner, and there is good cause why it should
18 not be part of the public record of this case.
19
20 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
21 The parties further acknowledge, as set forth in Section 12.3, below, that this
22 Stipulated Protective Order does not entitle them to file confidential information under
23 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
24 standards that will be applied when a party seeks permission from the court to file
25 material under seal.
26 There is a strong presumption that the public has a right of access to judicial
27 proceedings and records in civil cases. In connection with non-dispositive motions, good
28 cause must be shown to support a filing under seal. See Kamakana v. City and County
1 of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors Corp., 307
2 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D.
3 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause
4 showing), and a specific showing of good cause or compelling reasons with proper
5 evidentiary support and legal justification, must be made with respect to Protected
6 Material that a party seeks to file under seal. The parties’ mere designation of Disclosure
7 or Discovery Material as CONFIDENTIAL does not—without the submission of
8 competent evidence by declaration, establishing that the material sought to be filed under
9 seal qualifies as confidential, privileged, or otherwise protectable—constitute good
10 cause.
11 Further, if a party requests sealing related to a dispositive motion or trial, then
12 compelling reasons, not only good cause, for the sealing must be shown, and the relief
13 sought shall be narrowly tailored to serve the specific interest to be protected. SeePintos
14 v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type
15 of information, document, or thing sought to be filed or introduced under seal in
16 connection with a dispositive motion or trial, the party seeking protection must articulate
17 compelling reasons, supported by specific facts and legal justification, for the requested
18 sealing order. Again, competent evidence supporting the application to file documents
19 under seal must be provided by declaration.
20 Any document that is not confidential, privileged, or otherwise protectable in its
21 entirety will not be filed under seal if the confidential portions can be redacted. If
22 documents can be redacted, then a redacted version for public viewing, omitting only
23 the confidential, privileged, or otherwise protectable portions of the document shall be
24 filed. Any application that seeks to file documents under seal in their entirety should
25 include an explanation of why redaction is not feasible.
26
27 2. DEFINITIONS
28 2.1. Action: This pending federal lawsuit.
1 2.2. Challenging Party: A Party or Non-Party that challenges the designation of
2 information or items under this Order.
3 2.3. “CONFIDENTIAL” Information or Items: Information (regardless of how
4 it is generated, stored or maintained) or tangible things that qualify for protection under
5 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
6 Statement.
7 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as their
8 support staff).
9 2.5. Designating Party: A Party or Non-Party that designates information or
10 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
11 2.6. Disclosure or Discovery Material: All items or information, regardless of
12 the medium or manner in which it is generated, stored, or maintained (including, among
13 other things, testimony, transcripts, and tangible things) that are produced or generated
14 in disclosures or responses to discovery in this matter.
15 2.7. Expert: A person with specialized knowledge or experience in a matter
16 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
17 expert witness or as a consultant in this Action.
18 2.8. House Counsel: Attorneys who are employees of a party to this Action.
19 House Counsel does not include Outside Counsel of Record or any other outside counsel.
20 2.9. Non-Party: Any natural person, partnership, corporation, association or
21 other legal entity not named as a Party to this action.
22 2.10. Outside Counsel of Record: Attorneys who are not employees of a party to
23 this Action but are retained to represent or advise a party to this Action and have
24 appeared in this Action on behalf of that party or are affiliated with a law firm that has
25 appeared on behalf of that party, and includes support staff.
26 2.11. Party: Any party to this Action, including all of its officers, directors,
27 employees, consultants, retained experts, and Outside Counsel of Record (and their
28 support staffs).
1 2.12. Producing Party: A Party or Non-Party that produces Disclosure or
2 Discovery Material in this Action.
3 2.13. Professional Vendors: Persons or entities that provide litigation support
4 services (e.g., photocopying, videotaping, translating, preparing exhibits or
5 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
6 their employees and subcontractors.
7 2.14. Protected Material: Any Disclosure or Discovery Material that is
8 designated as “CONFIDENTIAL.”
9 2.15. Receiving Party: A Party that receives Disclosure or Discovery Material
10 from a Producing Party.
11
12 3. SCOPE
13 The protections conferred by this Stipulation and Order cover not only Protected
14 Material (as defined above), but also (1) any information copied or extracted from
15 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
16 Material; and (3) any testimony, conversations, or presentations by Parties or their
17 Counsel that might reveal Protected Material.
18 Any use of Protected Material at trial shall be governed by the orders of the trial
19 judge. This Order does not govern the use of Protected Material at trial.
20
21 4. DURATION
22 Once a case proceeds to trial, information that was designated as
23 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as
24 an exhibit at trial becomes public and will be presumptively available to all members of
25 the public, including the press, unless compelling reasons supported by specific factual
26 findings to proceed otherwise are made to the trial judge in advance of the trial. See
27 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
28 documents produced in discovery from “compelling reasons” standard when merits-
1 related documents are part of court record). Accordingly, the terms of this protective
2 order do not extend beyond the commencement of the trial.
3
4 5. DESIGNATING PROTECTED
5 5.1. Exercise of Restraint and Care in Designating Material for Protection. Each
6 Party or Non-Party that designates information or items for protection under this Order
7 must take care to limit any such designation to specific material that qualifies under the
8 appropriate standards. The Designating Party must designate for protection only those
9 parts of material, documents, items or oral or written communications that qualify so
10 that other portions of the material, documents, items or communications for which
11 protection is not warranted are not swept unjustifiably within the ambit of this Order.
12 Mass, indiscriminate or routinized designations are prohibited. Designations
13 that are shown to be clearly unjustified or that have been made for an improper purpose
14 (e.g., to unnecessarily encumber the case development process or to impose
15 unnecessary expenses and burdens on other parties) may expose the Designating Party
16 to sanctions.
17 If it comes to a Designating Party’s attention that information or items that it
18 designated for protection do not qualify for protection, that Designating Party must
19 promptly notify all other Parties that it is withdrawing the inapplicable designation.
20 5.2. Manner and Timing of Designations. Except as otherwise provided in this
21 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
22 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
23 must be clearly so designated before the material is disclosed or produced. Action: This
24 pending federal lawsuit.
25 Designation in conformity with this Order requires:
26 (a) for information in documentary form (e.g., paper or electronic documents,
27 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
28 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
1 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
2 portion of the material on a page qualifies for protection, the Producing Party also must
3 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
4 margins).
5 A Party or Non-Party that makes original documents available for inspection need
6 not designate them for protection until after the inspecting Party has indicated which
7 documents it would like copied and produced. During the inspection and before the
8 designation, all of the material made available for inspection shall be deemed
9 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
10 copied and produced, the Producing Party must determine which documents, or portions
11 thereof, qualify for protection under this Order. Then, before producing the specified
12 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
13 that contains Protected Material. If only a portion of the material on a page qualifies for
14 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
15 by making appropriate markings in the margins).
16 (b) for testimony given in depositions that the Designating Party identifies the
17 Disclosure or Discovery Material on the record, before the close of the deposition all
18 protected testimony.
19 (c) for information produced in some form other than documentary and for any
20 other tangible items, that the Producing Party affix in a prominent place on the exterior
21 of the container or containers in which the information is stored the legend
22 “CONFIDENTIAL.” If only a portion or portions of the information warrants
23 protection, the Producing Party, to the extent practicable, shall identify the protected
24 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 the
27 Designating Party’s right to secure protection under this Order for such material. Upon
28 timely correction of a designation, the Receiving Party must make reasonable efforts to
1 assure that the material is treated in accordance with the provisions of this Order.
2
3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4 6.1. 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 Scheduling
6 Order.
7 6.2. Meet and Confer. The Challenging Party shall initiate the dispute
8 resolution process under Local Rule 37.1 et seq.
9 6.3. The burden of persuasion in any such challenge proceeding shall be on the
10 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
11 to harass or impose unnecessary expenses and burdens on other parties) may expose the
12 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
13 the confidentiality designation, all parties shall continue to afford the material in
14 question the level of protection to which it is entitled under the Producing Party’s
15 designation until the Court rules on the challenge.
16
17 7. ACCESS TO AND USE OF PROTECTED MATERIAL
18 7.1. Basic Principles. A Receiving Party may use Protected Material that is
19 disclosed or produced by another Party or by a Non-Party in connection with this Action
20 only for prosecuting, defending or attempting to settle this Action. Such Protected
21 Material may be disclosed only to the categories of persons and under the conditions
22 described in this Order. When the Action has been terminated, a Receiving Party must
23 comply with the provisions of section 13 below (FINAL DISPOSITION).
24 Protected Material must be stored and maintained by a Receiving Party at a
25 location and in a secure manner that ensures that access is limited to the persons
26 authorized under this Order.
27 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
28 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
1 may disclose any information or item designated “CONFIDENTIAL” only to:
2 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
3 employees of said Outside Counsel of Record to whom it is reasonably necessary to
4 disclose the information for this Action;
5 (b) the officers, directors, and employees (including House Counsel) of the
6 Receiving Party to whom disclosure is reasonably necessary for this Action;
7 (c) Experts (as defined in this Order) of the Receiving Party to whom
8 disclosure is reasonably necessary for this Action and who have signed the
9 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
10 (d) the court and its personnel;
11 (e) court reporters and their staff;
12 (f) professional jury or trial consultants, mock jurors, and Professional
13 Vendors to whom disclosure is reasonably necessary for this Action and who have
14 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
15 (g) the author or recipient of a document containing the information or a
16 custodian or other person who otherwise possessed or knew the information;
17 (h) during their depositions, witnesses, and attorneys for witnesses, in the
18 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
19 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
20 not be permitted to keep any confidential information unless they sign the
21 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
22 by the Designating Party or ordered by the court. Pages of transcribed deposition
23 testimony or exhibits to depositions that reveal Protected Material may be separately
24 bound by the court reporter and may not be disclosed to anyone except as permitted
25 under this Stipulated Protective Order; and
26 (i) any mediator or settlement officer, and their supporting personnel, mutually
27 agreed upon by any of the parties engaged in settlement discussions.
28
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
2 OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation that
4 compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification shall
7 include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order to
9 issue in the other litigation that some or all of the material covered by the subpoena or
10 order is subject to this Protective Order. Such notification shall include a copy of this
11 Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be pursued by
13 the Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with the
15 subpoena or court order shall not produce any information designated in this action as
16 “CONFIDENTIAL” before a determination by the court from which the subpoena or
17 order issued, unless the Party has obtained the Designating Party’s permission. The
18 Designating Party shall bear the burden and expense of seeking protection in that court
19 of its confidential material and nothing in these provisions should be construed as
20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
21 from another court.
22
23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
24 IN THIS LITIGATION
25 (a) The terms of this Order are applicable to information produced by a Non-
26 Party in this Action and designated as “CONFIDENTIAL.” Such information produced
27 by Non-Parties in connection with this litigation is protected by the remedies and relief
28 provided by this Order. Nothing in these provisions should be construed as prohibiting
1 a Non-Party from seeking additional protections.
2 (b) In the event that a Party is required, by a valid discovery request, to produce
3 a Non-Party’s confidential information in its possession, and the Party is subject to an
4 agreement with the Non-Party not to produce the Non-Party’s confidential information,
5 then the Party shall:
6 (1) promptly notify in writing the Requesting Party and the Non-Party
7 that some or all of the information requested is subject to a confidentiality agreement
8 with a Non-Party;
9 (2) promptly provide the Non-Party with a copy of the Stipulated
10 Protective Order in this Action, the relevant discovery request(s), and a reasonably
11 specific description of the information requested; and
12 (3) make the information requested available for inspection by the
13 Non-Party, if requested.
14 (c) If the Non-Party fails to seek a protective order from this court within 14
15 days of receiving the notice and accompanying information, the Receiving Party may
16 produce the Non-Party’s confidential information responsive to the discovery request.
17 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
18 any information in its possession or control that is subject to the confidentiality
19 agreement with the Non-Party before a determination by the court. Absent a court order
20 to the contrary, the Non-Party shall bear the burden and expense of seeking protection
21 in this court of its Protected Material.
22
23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
25 Protected Material to any person or in any circumstance not authorized under this
26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
27 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
28 all unauthorized copies of the Protected Material, (c) inform the person or persons to
1 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
2 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
3 that is attached hereto as Exhibit A.
4
5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
6 PROTECTED MATERIAL
7 When a Producing Party gives notice to Receiving Parties that certain
8 inadvertently produced material is subject to a claim of privilege or other protection, the
9 obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure
10 26(b)(5)(B). This provision is not intended to modify whatever procedure may be
11 established in an e-discovery order that provides for production without prior privilege
12 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach
13 an agreement on the effect of disclosure of a communication or information covered by
14 the attorney-client privilege or work product protection, the parties may incorporate their
15 agreement in the stipulated protective order submitted to the court.
16
17 12. MISCELLANEOUS
18 12.1. Right to Further Relief. Nothing in this Order abridges the right of any
19 person to seek its modification by the Court in the future.
20 12.2. Right to Assert Other Objections. By stipulating to the entry of this
21 Protective Order, no Party waives any right it otherwise would have to object to
22 disclosing or producing any information or item on any ground not addressed in this
23 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground
24 to use in evidence of any of the material covered by this Protective Order.
25 12.3. Filing Protected Material. A Party that seeks to file under seal any
26 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
27 only be filed under seal pursuant to a court order authorizing the sealing of the specific
28 Protected Material at issue. If a Party’s request to file Protected Material under seal is
1 denied by the court, then the Receiving Party may file the information in the public
2 record unless otherwise instructed by the court.
3
4 13. FINAL DISPOSITION
5 After the final disposition of this Action, as defined in paragraph 4, within 60 days
6 of a written request by the Designating Party, each Receiving Party must return all
7 Protected Material to the Producing Party or destroy such material. As used in this
8 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
9 summaries, and any other format reproducing or capturing any of the Protected Material.
10 Whether the Protected Material is returned or destroyed, the Receiving Party must
11 submit a written certification to the Producing Party (and, if not the same person or
12 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category,
13 where appropriate) all the Protected Material that was returned or destroyed and (2)
14 affirms that the Receiving Party has not retained any copies, abstracts, compilations,
15 summaries or any other format reproducing or capturing any of the Protected Material.
16 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
17 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
18 correspondence, deposition and trial exhibits, expert reports, attorney work product, and
19 consultant and expert work product, even if such materials contain Protected Material.
20 Any such archival copies that contain or constitute Protected Material remain subject to
21 this Protective Order as set forth in Section 4 (DURATION).
22
23 14. VIOLATION
24 Any violation of this Order may be punished by appropriate measures including,
25 without limitation, contempt proceedings and/or monetary sanctions.
26
27 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
28
1
2||DATED: November 19, 2025 THE AGUILERA LAW GROUP, APC
3 /s/ René Daley!
4 A. Eric Aguilera
Raymond E. Brown
5 V. René Daley |
Attorneys for Plaintiffs A.I-C. (a minor),
6 Anthony Charles Francisco Cachua, and Luz
Maria Cachua
7
8
DATED: November 19, 2025 LOS ANGELES CITY ATTORNEY
9
10 /s/ Emily Cohen
Hydee Feldstein Soto
11 Denise C. Mills
Kathleen Kenealy
2 Cory M. Brente
B Emily Cohen
Attorneys or Defendants City of Los Angeles
14 and the Los Angeles Police Department
15
16 DATED: November 19, 2025 JONES MAYER
17 . .
/s/ Denise Lynch Rocawich
18 James R. Touchstone
Denise Lynch Rocawich
19 Attorneys for defendant Victor Corral
20
GOOD CAUSE SHOWN, IT IS SO ORDERED.
22
23 .
DATED: _ 11/21/2025 Raped s, Qh. Q Cw
24 HON. ROZELLA A. OLIVER
United States Magistrate Judge
25
26 || ——__
' Filing counsel René Daley attests that both Emily Cohen and Denise Lynch Rocawich
concur in the content of the proposed protective order and have authorized the filing of
28 || this proposed protective order.
15
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 perjury that I
6 have read in its entirety and understand the Stipulated Protective Order that was issued
7 by the United States District Court for the Central District of California on [date] in the
8 case of A.I.C., a minor, et al. v Victor Corral, et al., Dist. Ct. C.D. Cal. Case No. 2:25-
9 cv-02575 -SPG-(RAOx). I agree to comply with and to be bound by all the terms of this
10 Stipulated Protective Order and I understand and acknowledge that failure to so comply
11 could expose me to sanctions and punishment in the nature of contempt. I solemnly
12 promise that I will not disclose in any manner any information or item that is subject to
13 this Stipulated Protective Order to any person or entity except in strict compliance with
14 the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for
16 the Central District of California for enforcing the terms of this Stipulated Protective
17 Order, even if such enforcement proceedings occur after termination of this action. I
18 hereby appoint __________________________ [print or type full name] of
19 _______________________________________ [print or type full address and
20 telephone number] as my California agent for service of process in connection with this
21 action 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