even stipulated 7 protective orders require good cause showing
How later courts described this case
- even stipulated 7 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 Eugenia Bagdassarian, State Bar No. 334898
E-Mail: eugenia@triallit.com
2 E-Service: service@triallit.com
TRIAL LIT ATTORNEYS, APC
3 600 West Broadway, Suite 235
Glendale, CA 91204
4 Telephone: (818) 584-3500
Facsimile: (877)565-0213
5
Attorneys for Plaintiff, KATHY JIRON
6
7
UNITED STATES DISTRICT COURT
8
CENTRAL DISTRICT OF CALIFORNIA
9
10
KATHY JIRON, an Individual, Case No. 5:25-cv-00520-JGB(SSCx)
11
Plaintiff, STIPULATED PROTECTIVE
12 ORDER1
v.
13 [Assigned to Hon. Jesus G. Bernal]
COUNTY OF SAN BERNARDINO;
14 GABRIELLE LEOS, an individual; [DISCOVERY MATTER]
AUSTIN DECOUD, an individual; and
15 DOES 1 to 10, inclusive,
16 Defendants.
17
18
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
23 prosecuting this litigation may be warranted. Accordingly, the parties hereby
24 stipulate to and petition the court to enter the following Stipulated Protective Order.
25
26 1 This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Stephanie S. Christensen’s Procedures. All
27
deviations or amendments to the model protective order have been red-lined in
1 The parties acknowledge that this Order does not confer blanket protections on all
2 disclosures or responses to discovery and that the protection it affords from public
3 disclosure and use extends only to the limited information or items that are entitled
4 to confidential treatment under the applicable legal principles.
5 1.2 Good Cause Statement
6 This action involves the County of San Bernardino and members of the San
7 Bernardino County Sheriff’s Department. This action is likely to involve the
8 exchange of protected health information (“PHI”), peace officer personnel
9 information, and materials from open investigations consisting of official
10 information for which special protection from public disclosure—and from use for
11 any purpose other than the prosecution of this action—is warranted. Such
12 confidential materials and information consist of, among other things, medical
13 records containing PHI, peace officer personnel records and investigations
14 containing official information, other administrative materials, as well as video
15 recordings, audio recordings, and photographs involving incidents to which law
16 enforcement responded.
17 Defendants contend that the disclosure of the confidential information
18 regarding the individuals may violate those individuals’ privacy rights. Defendants
19 also contend that the disclosure of the information may also jeopardize the security
20 of the County's operations and jeopardize the safety of its peace officers.
21 Defendants may seek information such as Plaintiff’s medical records that
22 Plaintiff believes are highly sensitive, confidential, and are legally protected from
23 disclosure. See Wooden v. Comprehensive Health Mgmt., No. 20-00053 LEK-WRP,
24 2021 U.S. Dist. LEXIS 101889, at *3 (D. Haw. May 28, 2021) (“[M]edical records
25 are confidential, as recognized under the Health Insurance Portability and
26 Accountability Act of 1996.”); Pratt v. Gamboa, No. 17-CV-04375-LHK, 2020 U.S.
27 Dist. LEXIS 90913, at *5 (N.D. Cal. May 22, 2020) (same). Plaintiff contends that
1 the undue disclosure of such information creates a specific risk of embarrassment,
2 emotional harm, and reputational harm.
3 Accordingly, to expedite the flow of information, to facilitate the prompt
4 resolution of disputes over confidentiality of discovery materials, to adequately
5 protect information the parties are entitled to keep confidential, to ensure that the
6 parties are permitted reasonable necessary uses of such material in preparation for
7 and in the conduct of trial, to address their handling at the end of the litigation, and
8 serve the ends of justice, a protective order for such information is justified in this
9 matter. It is the intent of the parties that information will not be designated as
10 confidential for tactical reasons and that nothing be so designated without a good
11 faith belief that it has been maintained in a confidential, non-public manner, and
12 there is good cause why it should not be part of the public record of this case.
13 The Parties agree that there is Good Cause for a Protective Order so as to
14 preserve the respective interests of the parties while streamlining the process of
15 resolving any disagreements.
16 The Parties therefore stipulate that there is Good Cause for, and hereby jointly
17 request that the honorable Court issue a Protective Order regarding confidential
18 documents consistent with the terms and provisions of this Stipulation. However,
19 the entry of a Protective Order by the Court pursuant to this Stipulation shall not be
20 construed as any ruling by the Court on the aforementioned legal statements or
21 privilege claims in this section, no shall this section be construed as part of any such
22 Court Order.
23 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties
24 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
25 Protective Order does not entitle them to file confidential information under seal;
26 Local Rule 79-5 sets forth the procedures that must be followed and the standards
27 that will be applied when a party seeks permission from the court to file material
1 There is a strong presumption that the public has a right of access to judicial
2 proceedings and records in civil cases. In connection with non-dispositive motions,
3 good cause must be shown to support a filing under seal. See Kamakana v. City and
4 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of
5 Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon
6 v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
7 protective orders require good cause showing), and a specific showing of good
8 cause or compelling reasons with proper evidentiary support and legal justification,
9 must be made with respect to Protected Material that a party seeks to file under seal.
10 The parties’ mere designation of Disclosure or Discovery Material as
11 CONFIDENTIAL does not—without the submission of competent evidence by
12 declaration, establishing that the material sought to be filed under seal qualifies as
13 confidential, privileged, or otherwise protectable—constitute good cause.
14 Further, if a party requests sealing related to a dispositive motion or trial, then
15 compelling reasons, not only good cause, for the sealing must be shown, and the
16 relief sought shall be narrowly tailored to serve the specific interest to be protected.
17 See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each
18 item or type of information, document, or thing sought to be filed or introduced
19 under seal in connection with a dispositive motion or trial, the party seeking
20 protection must articulate compelling reasons, supported by specific facts and legal
21 justification, for the requested sealing order. Again, competent evidence supporting
22 the application to file documents under seal must be provided by declaration.
23 Any document that is not confidential, privileged, or otherwise protectable in its
24 entirety will not be filed under seal if the confidential portions can be redacted. If
25 documents can be redacted, then a redacted version for public viewing, omitting
26 only the confidential, privileged, or otherwise protectable portions of the document,
27 shall be filed. Any application that seeks to file documents under seal in their
1 2. DEFINITIONS
2 2.1 Action: This pending federal lawsuit,encaptioned Kathy Jiron v.
3 County of San Bernardino, et. al. 5:25-cv-00520-JGB(SSCx).
4 2.2 Challenging Party: A Party or Non-Party that challenges the
5 designation of information or items under this Order.
6 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of
7 how it is generated, stored or maintained) or tangible things that qualify for
8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
9 the Good Cause Statement.
10 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
11 their support staff).
12 2.5 Designating Party: a Party or Non-Party that designates information or
13 items that it produces in disclosures or in responses to discovery as
14 “CONFIDENTIAL.”
15 2.6 Disclosure or Discovery Material: all items or information, regardless
16 of the medium or manner in which it is generated, stored, or maintained (including,
17 among other things, testimony, transcripts, and tangible things), that are produced or
18 generated in disclosures or responses to discovery in this matter.
19 2.7 Expert: a person with specialized knowledge or experience in a matter
20 pertinent to the litigation who has been retained by a Party or its counsel to serve as
21 an expert witness or as a consultant in this Action.
22 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses
23 in this Action, with or without prejudice; and (2) final judgment herein after the
24 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
25 this Action, including the time limits for filing any motions or applications for
26 extension of time pursuant to applicable law.
27
1 2.9 In-House Counsel: attorneys who are employees of a party to this
2 Action. In-House Counsel does not include Outside Counsel of Record or any other
3 outside counsel.
4 2.10 Non-Party: any natural person, partnership, corporation, association, or
5 other legal entity not named as a Party to this action.
6 2.11 Outside Counsel of Record: attorneys who are not employees of a party
7 to this Action but are retained to represent or advise a party to this Action and have
8 appeared in this Action on behalf of that party or are affiliated with a law firm which
9 has appeared on behalf of that party, and includes support staff.
10 2.12 Party: any party to this Action, including all of its officers, directors,
11 employees, consultants, retained experts, and Outside Counsel of Record (and their
12 support staffs).
13 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
14 Discovery Material in this Action.
15 2.14 Professional Vendors: persons or entities that provide litigation-
16 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
17 demonstrations, and organizing, storing, or retrieving data in any form or medium)
18 and their employees and subcontractors.
19 2.15 Protected Material: any Disclosure or Discovery Material that is
20 designated as “CONFIDENTIAL.”
21 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
22 from a Producing Party.
23 3. SCOPE
24 The protections conferred by this Stipulation and Order cover not only
25 Protected Material (as defined above), but also (1) any information copied or
26 extracted from Protected Material; (2) all copies, excerpts, summaries, or
27 compilations of Protected Material; and (3) any testimony, conversations, or
1 Any use of Protected Material at trial shall be governed by the orders of the
2 trial judge. This Stipulated Protective Order does not govern the use of Protected
3 Material at trial.
4 4. TRIAL AND DURATION
5 Even after Final Disposition of this litigation, the confidentiality obligations
6 imposed by this Stipulated Protective Order shall remain in effect until a
7 Designating Party agrees otherwise in writing or a court order otherwise directs.
8 Final disposition shall be deemed to be the later of (1) dismissal of all claims and
9 defenses in this Action, with or without prejudice; and (2) final judgment herein
10 after the completion and exhaustion of all appeals, rehearings, remands, trials, or
11 reviews of this Action, including the time limits for filing any motions or
12 applications for extension of time pursuant to applicable law.
13 Once a case proceeds to trial, information that was designated as
14 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and
15 used or introduced as an exhibit at trial becomes public and will be presumptively
16 available to all members of the public, including the press, unless compelling
17 reasons supported by specific factual findings to proceed otherwise are made to the
18 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81
19 (distinguishing “good cause” showing for sealing documents produced in discovery
20 from “compelling reasons” standard when merits-related documents are part of court
21 record). Accordingly, for such materials, the terms of this Stipulated Protective
22 Order do not extend beyond the commencement of the trial. A party may file a
23 motion for a protective order for any material, document, item, or communication
24 used as a trial exhibit during trial within thirty (30) days of the material, document,
25 item, or communication being admitted as a trial exhibit.
26 5. DESIGNATING PROTECTED MATERIAL
27
5.1 Exercise of Restraint and Care in Designating Material for Protection.
1 Each Party or Non-Party that designates information or items for protection under
2 this Order must take care to limit any such designation to specific material that
3 qualifies under the appropriate standards. The Designating Party must designate for
4 protection only those parts of material, documents, items, or oral or written
5 communications that qualify so that other portions of the material, documents,
6 items, or communications for which protection is not warranted are not swept
7 unjustifiably within the ambit of this Order.
8 Mass, indiscriminate, or routinized designations are prohibited. Designations
9 that are shown to be clearly unjustified or that have been made for an improper
10 purpose (e.g., to unnecessarily encumber the case development process or to
11 impose unnecessary expenses and burdens on other parties) may expose the
12 Designating Party to sanctions.
13 If it comes to a Designating Party’s attention that information or items that it
14 designated for protection do not qualify for protection, that Designating Party must
15 promptly notify all other Parties that it is withdrawing the inapplicable designation.
16
5.2 Manner and Timing of Designations. Except as otherwise provided in
17
this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a)
18
below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that
19
qualifies for protection under this Stipulated Protective Order must be clearly so
20
designated before the material is disclosed or produced.
21
Designation in conformity with this Stipulated Protective Order requires:
22
(a) for information in documentary form (e.g., paper or electronic
23
documents, but excluding transcripts of depositions or other pretrial or trial
24
proceedings), that the Producing Party affix at a minimum, the legend
25
“CONFIDENTIAL” to each page that contains protected material. If only a
26
portion or portions of the material on a page qualifies for protection, the Producing
27
Party also must clearly identify the protected portion(s) (e.g., by making
1 A Party or Non-Party that makes original documents available for inspection
2 need not designate them for protection until after the inspecting Party has indicated
3 which documents it would like copied and produced. During the inspection and
4 before the designation, all of the material made available for inspection shall be
5 deemed CONFIDENTIAL. After the inspecting Party has identified the documents
6 it wants copied and produced, the Producing Party must determine which
7 documents, or portions thereof, qualify for protection under this Stipulated
8 Protective Order. Then, before producing the specified documents, the Producing
9 Party must affix the “CONFIDENTIAL” legend to each page that contains
10 Protected Material. If only a portion or portions of the material on a page qualifies
11 for protection, the Producing Party also must clearly identify the protected
12 portion(s) (e.g., by making appropriate markings in the margins).
13 (b) for testimony given in depositions that the Designating Party identify
14 the Disclosure or Discovery Material on the record, before the close of the
15 deposition all protected testimony.
16 (c) for information produced in some form other than documentary and
17 for any other tangible items, that the Producing Party affix in a prominent place on
18 the exterior of the container or containers in which the information is stored the
19 “CONFIDENTIAL” legend. If only a portion or portions of the information
20 warrants protection, the Producing Party, to the extent practicable, shall identify the
21 protected portion(s).
22
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
23
failure to designate qualified information or items does not, standing alone, waive
24
the Designating Party’s right to secure protection under this Order for such material.
25
Upon timely correction of a designation, the Receiving Party must make reasonable
26
efforts to assure that the material is treated in accordance with the provisions of this
27
Stipulated Protective Order.
1 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
2 designation of confidentiality at any time that is consistent with the court’s
3 Scheduling Order.
4 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
5 resolution process under Local Rule 37.1 et seq.
6 6.3 The burden of persuasion in any such challenge proceeding shall be on
7 the Designating Party. Frivolous challenges, and those made for an improper
8 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
9 parties) may expose the Challenging Party to sanctions. Unless the Designating
10 Party has waived or withdrawn the confidentiality designation, all parties shall
11 continue to afford the material in question the level of protection to which it is
12 entitled under the Producing Party’s designation until the court rules on the
13 challenge.
14 7. ACCESS TO AND USE OF PROTECTED MATERIAL
15 7.1 Basic Principles. A Receiving Party may use Protected Material that
16 is disclosed or produced by another Party or by a Non-Party in connection with this
17 Action only for prosecuting, defending, or attempting to settle this Action. Such
18 Protected Material may be disclosed only to the categories of persons and under the
19 conditions described in this Order. When the Action reaches a Final Disposition, a
20 Receiving Party must comply with the provisions of Section 13 below.
21 Protected Material must be stored and maintained by a Receiving Party at a
22 location and in a secure manner that ensures that access is limited to the persons
23 authorized under this Stipulated Protective Order.
24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
25 otherwise ordered by the court or permitted in writing by the Designating Party, a
26 Receiving Party may disclose any information or item designated
27 “CONFIDENTIAL” only:
1 well as employees of said Outside Counsel of Record to whom it is reasonably
2 necessary to disclose the information for this Action;
3 (b) to the officers, directors, and employees (including House Counsel) of
4 the Receiving Party to whom disclosure is reasonably necessary for this Action;
5 (c) to Experts (as defined in this Order) of the Receiving Party to whom
6 disclosure is reasonably necessary for this Action and who have signed the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
8 (d) to the court and its personnel;
9 (e) to court reporters and their staff;
10 (f) to professional jury or trial consultants, mock jurors, and Professional
11 Vendors to whom disclosure is reasonably necessary for this Action and who have
12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13 (g) to the author or recipient of a document containing the information or
14 a custodian or other person who otherwise possessed or knew the information;
15
(h) during their depositions, to witnesses, and attorneys for witnesses, in
16
the Action to whom disclosure is reasonably necessary, provided: (1) the deposing
17
party requests that the witness sign the “Acknowledgment and Agreement to Be
18
Bound” (Exhibit A); and (2) the witness will not be permitted to keep any
19
confidential information unless they sign the “Acknowledgment and Agreement to
20
Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
21
ordered by the court. Pages of transcribed deposition testimony or exhibits to
22
depositions that reveal Protected Material may be separately bound by the court
23
reporter and may not be disclosed to anyone except as permitted under this
24
Stipulated Protective Order; and
25
(i) to any mediator or settlement officer, and their supporting personnel,
26
mutually agreed upon by any of the parties engaged in settlement discussions.
27
//
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2 PRODUCED IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation
4 that 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
7
shall include a copy of the subpoena or court order;
8
(b) promptly notify in writing the party who caused the subpoena or order
9
to issue in the other litigation that some or all of the material covered by the
10
subpoena or order is subject to this Protective Order. Such notification shall include
11
a copy of this Stipulated Protective Order; and
12
(c) cooperate with respect to all reasonable procedures sought to be
13
pursued by the Designating Party whose Protected Material may be affected.
14
If the Designating Party timely seeks a protective order, the Party served
15
with the subpoena or court order shall not produce any information designated in
16
this action as “CONFIDENTIAL” before a determination by the court from which
17
the subpoena or order issued, unless the Party has obtained the Designating Party’s
18
permission. The Designating Party shall bear the burden and expense of seeking
19
protection in that court of its confidential material and nothing in these provisions
20
should be construed as authorizing or encouraging a Receiving Party in this Action
21
to disobey a lawful directive from another court.
22
9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
23
PRODUCED IN THIS LITIGATION
24
9.1 Application. The terms of this Stipulated Protective Order are
25
applicable to information produced by a Non-Party in this Action and designated as
26
“CONFIDENTIAL.” Such information produced by Non-Parties in connection with
27
this litigation is protected by the remedies and relief provided by this Order.
1 Nothing in these provisions should be construed as prohibiting a Non-Party from
2 seeking additional protections.
3 9.2 Notification. In the event that a Party is required, by a valid discovery
4 request, to produce a Non-Party’s confidential information in its possession, and the
5 Party is subject to an agreement with the Non-Party not to produce the Non-
6 Party’s confidential information, then the Party shall:
7 (a) promptly notify in writing the Requesting Party and the Non-Party
8 that some or all of the information requested is subject to a confidentiality
9 agreement with a Non-Party;
10 (b) promptly provide the Non-Party with a copy of the Stipulated
11 Protective Order in this Action, the relevant discovery request(s), and a reasonably
12 specific description of the information requested; and
13 (c) make the information requested available for inspection by the Non-
14 Party, if requested.
15 9.3 Conditions of Production. If the Non-Party fails to seek a protective
16 order from this court within 14 days of receiving the notice and accompanying
17 information, the Receiving Party may produce the Non-Party’s confidential
18 information responsive to the discovery request. If the Non-Party timely seeks a
19 protective order, the Receiving Party shall not produce any information in its
20 possession or control that is subject to the confidentiality agreement with the Non-
21 Party before a determination by the court. Absent a court order to the contrary, the
22 Non-Party shall bear the burden and expense of seeking protection in this court of its
23 Protected Material.
24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
25
If a Receiving Party learns that, by inadvertence or otherwise, it has
26
disclosed Protected Material to any person or in any circumstance not authorized
27
under this Stipulated Protective Order, the Receiving Party must immediately (a)
1 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
2 the person or persons to whom unauthorized disclosures were made of all the terms
3 of this Order, and (d) request such person or persons to execute the
4 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
5 A.
6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
7 PROTECTED MATERIAL
8
When a Producing Party gives notice to Receiving Parties that certain
9
inadvertently produced material is subject to a claim of privilege or other
10
protection, the obligations of the Receiving Parties are those set forth in Rule
11
26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended
12
to modify whatever procedure may be established in an e-discovery order that
13
provides for production without prior privilege review. Pursuant to Rules 502(d)
14
and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement
15
on the effect of disclosure of a communication or information covered by the
16
attorney-client privilege or work product protection, the parties may incorporate
17
their agreement in the stipulated protective order submitted to the court.
18
12. MISCELLANEOUS
19
12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
20
abridges the right of any person to seek its modification by the court in the future.
21
12.2 Right to Assert Other Objections. By stipulating to the entry of this
22
Stipulated Protective Order no Party waives any right it otherwise would have to
23
object to disclosing or producing any information or item on any ground not
24
addressed in this Stipulated Protective Order. Similarly, no Party waives any right
25
to object on any ground to use in evidence of any of the material covered by this
26
Stipulated Protective Order.
27
12.3 Filing Protected Material. A Party that seeks to file under seal any
1 Protected Material must comply with Local Rule 79-5. Protected Material may
2 only be filed under seal pursuant to a court order authorizing the sealing of the
3 specific Protected Material at issue. If a Party's request to file Protected Material
4 under seal is denied by the court, then the Receiving Party may file the
5 information in the public record unless otherwise instructed by the court.
6 13. FINAL DISPOSITION
7
After the Final Disposition of this Action, as defined in paragraph 4, within
8
60 days of a written request by the Designating Party, each Receiving Party must
9
return all Protected Material to the Producing Party or destroy such material. As
10
used in this subdivision, “all Protected Material” includes all copies, abstracts,
11
compilations, summaries, and any other format reproducing or capturing any of the
12
Protected Material. Whether the Protected Material is returned or destroyed, the
13
Receiving Party must submit a written certification to the Producing Party (and, if
14
not the same person or entity, to the Designating Party) by the 60 day deadline that
15
(1) identifies (by category, where appropriate) all the Protected Material that was
16
returned or destroyed and (2) affirms that the Receiving Party has not retained any
17
copies, abstracts, compilations, summaries or any other format reproducing or
18
capturing any of the Protected Material. Notwithstanding this provision, Counsel is
19
entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
20
and hearing transcripts, legal memoranda, correspondence, deposition and trial
21
exhibits, expert reports, attorney work product, and consultant and expert work
22
product, even if such materials contain Protected Material. Any such archival
23
copies that contain or constitute Protected Material remain subject to this Protective
24
Order as set forth in Section 4.
25
26
27
1)}14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished by any
3 || and all appropriate measures including, without limitation, contempt proceedings
4 || and/or monetary sanctions.
5
6 || DATED: December 4, 2025 WESIERSKI & ZUREK LLP
7
8
9 By: /s/ Kathryn J. Harvey
KATHRYN J. HARVEY
10 Attorney for Defendant, COUNTY OF
11 SAN BERNARDINO
12 || DATED: December 4, 2025 TRIAL LIT ATTORNEYS APC
13
14
15 By: /s/ Eugenia Bagdassarian
EUGENIA BAGDASSARIAN
16 Attorney for Plaintiff, KATHY JIRON
17
18 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
19
20|| DATED: December 5, 2025 Z-—
1 Stephanie S. Christensen
United States Magistrate Judge
22
23
24
25
26
27
28
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 under penalty of perjury
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 ___________ [insert formal name of the case and the
8 number and initials assigned to it by the court]. I agree to comply with and to be
9 bound by all the terms of this Stipulated Protective Order and I understand and
10 acknowledge that failure to so comply could expose me to sanctions and punishment
11 in the nature of contempt. I solemnly promise that I will not disclose in any manner
12 any information or item that is subject to this Stipulated Protective Order to any
13 person or entity except in strict compliance with the provisions of this Order. I
14 further agree to submit to the jurisdiction of the United States District Court for the
15 Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint __________________________ [print or
18 type full name] of _______________________________________ [print or type
19 full address and telephone 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
23 Date: ______________________________________
24 City and State where sworn and signed: ____________________________
25 Printed name: _______________________________
26 Signature: __________________________________
27