The opinion
1 S. FRANK HARRELL – SBN#133437
sharrell@lynberg.com
2 MARLENA R. MLYNARSKA – SBN#328132
mmlynarska@lynberg.com
3 GARROS CHAN – SBN#320561
gchan@lynberg.com
4 LYNBERG & WATKINS
A Professional Corporation
5 1100 W. Town & Country Road, Suite #1450
Orange, California 92868
6 (714) 937-1010 Telephone
(714) 937-1003 Facsimile
7
Attorneys for Defendant CITY OF GARDEN GROVE
8
9 PHILIP J. KAPLAN – SBN#135735
philipkaplanlaw@gmail.com
10 LAW OFFICES OF PHILIP J. KAPLAN
3278 Wilshire Blvd., Suite 106
11 Los Angeles, CA 90010
(213) 820-2874 Telephone
12
Attorney for Plaintiff ANTON VU
13
14 UNITED STATES DISTRICT COURT
15 CENTRAL DISTRICT OF CALIFORNIA
16
ANTON VU, an individual, CASE NO. 8:25-cv-000624 FWS(KESx)
17
Plaintiff, Assigned to: Hon. Fred W. Slaughter –
18 Courtroom 10D
vs.
19 Magistrate Judge Karen E. Scott
CITY OF GARDEN GROVE; RYAN Court
20 RODRIGUEZ, an individual; and
DOES 1 through 5, inclusive,,
21 STIPULATED PROTECTIVE
Defendants. ORDER
22
DISCOVERY MATTER
23
Trial Date: October 27, 2026
24
Complaint filed: March 28, 2025
25
26
Defendants CITY OF GARDEN GROVE and RYAN RODRIGUEZ
27
(collectively, “Defendants”) and Plaintiff ANTON VU, by and through his attorneys
1 of record hereby stipulate, as follows:
2 1. A. PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential,
4 proprietary, or private information for which special protection from public disclosure
5 and from use for any purpose other than prosecuting this litigation may be warranted.
6 Accordingly, the parties hereby stipulate to and petition the Court to enter the
7 following Stipulated Protective Order. The parties acknowledge that this Order does
8 not confer blanket protections on all disclosures or responses to discovery and that
9 the protection it affords from public disclosure and use extends only to the limited
10 information or items that are entitled to confidential treatment under the applicable
11 legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
12 that this Stipulated Protective Order does not entitle them to file confidential
13 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
14 followed and the standards that will be applied when a party seeks permission from
15 the court to file material under seal.
16
17 B. GOOD CAUSE STATEMENT
18 This action is likely to involve
19 information which one or more of the parties contend special protection from
20 use for any purpose other than litigation in this action is warranted. Defendants
21 contend that such confidential information includes video footage and/or photographs
22 from within the possession and control of the City of Garden Grove containing
23 information possibly pertaining to third parties that are not parties to this lawsuit,
24 and/or containing images of third parties that are not parties to this lawsuit. Such
25 confidential information may also include documents that contain personal and
26 confidential information regarding individuals which information is generally
27 unavailable to the public, including peace officer and/or City employee personnel
1 individuals’ privacy rights, and its disclosure may impact the City of Garden Grove’s
2 Police Department’s operations and safety. Good cause therefore exists for
3 designating these materials as confidential for Defendants, its employees, and
4 officials to protect government interests, as well as the privacy rights of third parties
5 not subject to this litigation
6 . Plaintiff, as well, may produce certain documents in this case that contain personal
7 medical, employment or financial information. Such information may implicate the
8 privacy interests of the party and are properly protected through a Fed. R. Civ. P.
9 26(c) protective order. Seattle Times Co. v. Rhinehart, 467 U.S. 20, 35 n.21 (1984).
10 Accordingly, to expedite the flow of information, to facilitate the prompt resolution
11 of disputes over confidentiality of discovery materials, to adequately protect
12 information the parties are entitled to keep confidential, to ensure that the parties are
13 permitted reasonable necessary uses of such material in preparation for and in the
14 conduct of trial, to address their handling at the end of the litigation, and serve the
15 ends of justice, a protective order for such information is justified in this matter. It is
16 the intent of the parties that information will not be designated as confidential for
17 tactical reasons and that nothing be so designated without a good faith belief that it
18 has been maintained in a confidential, non-public manner, and there is good cause
19 why it should not be part of the public record of this case.
20
21 2. DEFINITIONS
22 2.1 Action: This pending federal law suit.
23 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
24 information or items under this Order.
25 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
26 it is generated, stored or maintained) or tangible things that qualify for protection
27 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
1 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
2 support staff).
3 2.5 Designating Party: a Party or Non-Party that designates information or
4 items that it produces in disclosures or in responses to discovery as
5 “CONFIDENTIAL.”
6 2.6 Disclosure or Discovery Material: all items or information, regardless of
7 the medium or manner in which it is generated, stored, or maintained (including,
8 among other things, testimony, transcripts, and tangible things), that are produced or
9 generated in disclosures or responses to discovery in this matter.
10 2.7 Expert: a person with specialized knowledge or experience in a matter
11 pertinent to the litigation who has been retained by a Party or its counsel to serve as
12 an expert witness or as a consultant in this Action.
13 2.8 House Counsel: attorneys who are employees of a party to this Action.
14 House Counsel does not include Outside Counsel of Record or any other outside
15 counsel.
16 2.9 Non-Party: any natural person, partnership, corporation, association, or
17 other legal entity not named as a Party to this action.
18 2.10 Outside Counsel of Record: attorneys who are not employees of a party
19 to this Action but are retained to represent or advise a party to this Action and have
20 appeared in this Action on behalf of that party or are affiliated with a law firm which
21 has appeared on behalf of that party, and includes support staff.
22 2.11 Party: any party to this Action, including all of its officers, directors,
23 employees, consultants, retained experts, and Outside Counsel of Record (and their
24 support staffs).
25 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
26 Discovery Material in this Action.
27 2.13 Professional Vendors: persons or entities that provide litigation support
1 demonstrations, and organizing, storing, or retrieving data in any form or medium)
2 and their employees and subcontractors.
3 2.14 Protected Material: any Disclosure or Discovery Material that is
4 designated as “CONFIDENTIAL” and includes Protected Health Information as
5 defined by HIPAA
6 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
7 from a Producing Party.
8
9 3. SCOPE
10 The protections conferred by this Stipulation and Order cover not only
11 Protected Material (as defined above), but also (1) any information copied or extracted
12 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
13 Protected Material; (3) any testimony, conversations, or presentations by Parties or
14 their Counsel that might reveal Protected Material;
15 and (4) if any information, documents, video, photographs, and/or other
16 materials which are the subject of this Protective Order are discussed, in any way,
17 during a deposition, said portion of the deposition transcript shall be treated as
18 confidential material subject to this Protective Order. Protected Material shall be used
19 solely in connection with the preparation and trial of the within case, Case No. 8:25-
20 cv-000624 FWS(KESx), or any related appellate proceeding, and not for any other
21 purpose, including any other litigation.
22 Any use of Protected Material at trial shall be governed by the orders of the trial judge.
23 This Order does not govern the use of Protected Material at trial.
24
25 4. DURATION
26 Once a case proceeds to trial, unless timely objected to, all trial exhibits that
27 were designated as confidential or maintained pursuant to this Protective Order
1 including the press, unless compelling reasons supported by specific factual findings
2 to proceed otherwise are made to the trial judge in advance of the trial. See Kamakana
3 v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006)
4 (distinguishing “good cause” showing for sealing documents produced in discovery
5 from “compelling reasons” standard when merits-related documents are part of court
6 record). Any trial exhibit containing the Confidential Designation that is to be used at
7 trial shall be reproduced without the Confidential Designation during the parties’
8 pretrial disclosures. Even after final disposition of this litigation, the confidentiality
9 obligations imposed by this Order shall remain in effect until a Designating Party
10 agrees otherwise in writing or a court order otherwise directs. Final disposition shall
11 be deemed to be the later of (1) dismissal of all claims and defenses in this Action,
12 with or without prejudice; and (2) final judgment herein after the completion and
13 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
14 including the time limits for filing any motions or applications for extension of time
15 pursuant to applicable law.
16
17 5. DESIGNATING PROTECTED MATERIAL
18 5.1 Exercise of Restraint and Care in Designating Material for Protection.
19 Each Party or Non-Party that designates information or items for protection under this
20 Order must take care to limit any such designation to specific material that qualifies
21 under the appropriate standards. The Designating Party must designate for protection
22 only those parts of material, documents, items, or oral or written communications that
23 qualify so that other portions of the material, documents, items, or communications
24 for which protection is not warranted are not swept unjustifiably within the ambit of
25 this Order.
26 Mass, indiscriminate, or routinized designations are prohibited. Designations
27 that are shown to be clearly unjustified or that have been made for an improper
1 unnecessary expenses and burdens on other parties) may expose the Designating Party
2 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 this
7 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
8 or ordered, Disclosure or Discovery Material that qualifies for protection under this
9 Order must be clearly so designated before the material is disclosed or produced.
10 Designation in conformity with this Order requires:
11 (a) for information in documentary form (e.g., paper or electronic
12 documents, but excluding transcripts of depositions or other pretrial or trial
13 proceedings), that the Producing Party affix at a minimum, the legend
14 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
15 contains protected material. If only a portion or portions of the material on a page
16 qualifies for protection, the Producing Party also must clearly identify the protected
17 portion(s) (e.g., by making appropriate markings in the margins).
18 A Party or Non-Party that makes original documents available for inspection
19 need not designate them for protection until after the inspecting Party has indicated
20 which documents it would like copied and produced. During the inspection and before
21 the designation, all of the material made available for inspection shall be deemed
22 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
23 copied and produced, the Producing Party must determine which documents, or
24 portions thereof, qualify for protection under this Order. Then, before producing the
25 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
26 to each page that contains Protected Material. If only a portion or portions of the
27 material on a page qualifies for protection, the Producing Party also must clearly
1 margins).
2 (b) for testimony given in depositions that the Designating Party identify
3 the Disclosure or Discovery Material on the record, before the close of the deposition
4 all protected testimony.
5 (c) for information produced in some form other than documentary and
6 for any other tangible items, that the Producing Party affix in a prominent place on
7 the exterior of the container or containers in which the information is stored the legend
8 “CONFIDENTIAL.” If only a portion or portions of the information warrants
9 protection, the Producing Party, to the extent practicable, shall identify the protected
10 portion(s).
11 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
12 failure to designate qualified information or items does not, standing alone, waive the
13 Designating Party’s right to secure protection under this Order for such material.
14 Upon timely correction of a designation, the Receiving Party must make reasonable
15 efforts to assure that the material is treated in accordance with the provisions of this
16 Order.
17
18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
20 designation of confidentiality at any time that is consistent with the Court’s
21 Scheduling Order.
22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
23 resolution process under Local Rule 37.1 et seq. or follow the procedures for informal,
24 telephonic discovery hearings on the Court's website.
25 6.3 The burden of persuasion in any such challenge proceeding shall be on the
26 Designating Party. Frivolous challenges, and those made for an improper purpose
27 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
1 or withdrawn the confidentiality designation, all parties shall continue to afford the
2 material in question the level of protection to which it is entitled under the Producing
3 Party’s designation until the Court rules on the challenge.
4
5 7. ACCESS TO AND USE OF PROTECTED MATERIAL
6 7.1 Basic Principles. A Receiving Party may use Protected Material that is
7 disclosed or produced by another Party or by a Non-Party in connection with this
8 Action only for prosecuting, defending, or attempting to settle this Action. Such
9 Protected Material may be disclosed only to the categories of persons and under the
10 conditions described in this Order. When the Action has been terminated, a Receiving
11 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
12 Protected Material must be stored and maintained by a Receiving Party at a
13 location and in a secure manner that ensures that access is limited to the persons
14 authorized under this Order.
15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
16 otherwise ordered by the court or permitted in writing by the Designating Party, a
17 Receiving Party may disclose any information or item designated
18 “CONFIDENTIAL” only to:
19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
20 well as employees of said Outside Counsel of Record to whom it is reasonably
21 necessary to disclose the information for this Action;
22 (b) the officers, directors, and employees (including House Counsel) of
23 the Receiving Party to whom disclosure is reasonably necessary for this Action;
24 (c) Experts (as defined in this Order) of the Receiving Party to whom
25 disclosure is reasonably necessary for this Action and who have signed the
26 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (d) the court and its personnel;
1 (f) professional jury or trial consultants, mock jurors, and Professional
2 Vendors to whom disclosure is reasonably necessary for this Action and who have
3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (g) the author or recipient of a document containing the information or a
5 custodian or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses, and attorneys for witnesses, in
7 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
8 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they
9 will not be permitted to keep any confidential information unless they sign the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
11 agreed by the Designating Party or ordered by the court. Pages of transcribed
12 deposition testimony or exhibits to depositions that reveal Protected Material may be
13 separately bound by the court reporter and may not be disclosed to anyone except as
14 permitted under this Stipulated Protective Order; and
15 (i) any mediator or settlement officer, and their supporting personnel,
16 mutually agreed upon by any of the parties engaged in settlement discussions.
17 (j)Nothing in paragraph 7.2 is intended to prevent officials or employees
18 of Defendants or other authorized governmental officials from having access to the
19 documents or other items if they would have had access in the normal course of their
20 job duties. Further, nothing in this order prevents a witness from disclosing events or
21 activities personal to him or her, that is, a witness can disclose to others information
22 previously given to Defendants or its employees with respect to what he or she saw,
23 heard, or otherwise sensed.
24 (k) Each person to whom disclosure of “confidential” documents is
25 made, with the exception of counsel, who are presumed to know the contents of this
26 Protective Order, shall be provided by the person furnishing him/her such material a
27 copy of this order, and shall agree that he/she understands the provisions of the
1 the presiding court with respect to any proceeding relating to enforcement of this
2 order, including without limitation, any proceeding for contempt. Unless made on
3 the record in this litigation, counsel making the disclosure to any person described
4 above shall retain the original executed copy of said agreement until final termination
5 of this litigation.
6
7 (j)Nothing in paragraph 7.2 is intended to prevent officials or employees
8 of Defendants or other authorized governmental officials from having access to the
9 documents or other items if they would have had access in the normal course of their
10 job duties. Further, nothing in this order prevents a witness from disclosing events or
11 activities personal to him or her, that is, a witness can disclose to others information
12 previously given to Defendants or its employees with respect to what he or she saw,
13 heard, or otherwise sensed.
14 (k) Each person to whom disclosure of “confidential” documents is
15 made, with the exception of counsel, who are presumed to know the contents of this
16 Protective Order, shall be provided by the person furnishing him/her such material a
17 copy of this order, and shall agree that he/she understands the provisions of the
18 Protective Order. Such person also must consent to be subject to the jurisdiction of
19 the presiding court with respect to any proceeding relating to enforcement of this
20 order, including without limitation, any proceeding for contempt. Unless made on
21 the record in this litigation, counsel making the disclosure to any person described
22 above shall retain the original executed copy of said agreement until final termination
23 of this litigation.
24
25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
26 OTHER LITIGATION
27 If a Party is served with a subpoena or a court order issued in other litigation
1 “CONFIDENTIAL,” that Party must:
2 (a) promptly notify in writing the Designating Party. Such notification
3 shall include a copy of the subpoena or court order;
4 (b)promptly notify in writing the party who caused the subpoena or order
5 to issue in the other litigation that some or all of the material covered by the subpoena
6 or order is subject to this Protective Order. Such notification shall include a copy of
7 this Stipulated Protective Order; and
8 (c) cooperate with respect to all reasonable procedures sought to be
9 pursued by the Designating Party whose Protected Material may be affected.
10 If the Designating Party timely seeks a protective order, the Party served with
11 the subpoena or court order shall not produce any information designated in this action
12 as “CONFIDENTIAL” before a determination by the court from which the subpoena
13 or order issued, unless the Party has obtained the Designating Party’s permission. The
14 Designating Party shall bear the burden and expense of seeking protection in that court
15 of its confidential material and nothing in these provisions should be construed as
16 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
17 directive from another court.
18
19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
20 PRODUCED IN THIS LITIGATION
21 (a) The terms of this Order are applicable to information produced by a Non-
22 Party in this Action and designated as “CONFIDENTIAL.” Such information
23 produced by Non-Parties in connection with this litigation is protected by the
24 remedies and relief provided by this Order. Nothing in these provisions should be
25 construed as prohibiting a Non-Party from seeking additional protections.
26 (b) In the event that a Party is required, by a valid discovery request, to produce
27 a Non-Party’s confidential information in its possession, and the Party is subject to an
1 information, then the Party shall:
2 (1) promptly notify in writing the Requesting Party and the Non-Party
3 that some or all of the information requested is subject to a confidentiality agreement
4 with a Non-Party;
5 (2) promptly provide the Non-Party with a copy of the Stipulated
6 Protective Order in this Action, the relevant discovery request(s), and a reasonably
7 specific description of the information requested; and
8 (3) make the information requested available for inspection by the Non-
9 Party, if requested.
10 (c) If the Non-Party fails to seek a protective order from this court within 14
11 days of receiving the notice and accompanying information, the Receiving Party may
12 produce the Non-Party’s confidential information responsive to the discovery request.
13 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
14 any information in its possession or control that is subject to the confidentiality
15 agreement with the Non-Party before a determination by the court. Absent a court
16 order to the contrary, the Non-Party shall bear the burden and expense of seeking
17 protection in this court of its Protected Material.
18
19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
20 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
21 Protected Material to any person or in any circumstance not authorized under this
22 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
23 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
24 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
25 persons to whom unauthorized disclosures were made of all the terms of this Order,
26 and (d) request such person or persons to execute the “Acknowledgment and
27 Agreement to Be Bound” that is attached hereto as Exhibit A.
1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
2 PROTECTED MATERIAL
3 When a Producing Party gives notice to Receiving Parties that certain
4 inadvertently produced material is subject to a claim of privilege or other protection,
5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
7 may be established in an e-discovery order that provides for production without prior
8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
9 parties reach an agreement on the effect of disclosure of a communication or
10 information covered by the attorney-client privilege or work product protection, the
11 parties may incorporate their agreement in the stipulated protective order submitted
12 to the court.
13
14 12. MISCELLANEOUS
15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
16 person to seek its modification by the Court in the future.
17 12.2 Right to Assert Other Objections. By stipulating to the entry of this
18 Protective Order no Party waives any right it otherwise would have to object to
19 disclosing or producing any information or item on any ground not addressed in this
20 Stipulated Protective Order. Similarly, no Party waives any right to object on any
21 ground to use in evidence of any of the material covered by this Protective Order.
22 12.3 Filing Protected Material. A Party that seeks to file under seal any
23 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
24 only be filed under seal pursuant to a court order authorizing the sealing of the specific
25 Protected Material at issue. If a Party’s request to file Protected Material under seal is
26 denied by the court, then the Receiving Party may file the information in the public
27 record unless otherwise instructed by the court.
1 13. FINAL DISPOSITION
2 After the final disposition of this Action, as defined in paragraph 4, within 60
3 days of a written request by the Designating Party, each Receiving Party must return
4 all Protected Material to the Producing Party or destroy such material. As used in this
5 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
6 summaries, and any other format reproducing or capturing any of the Protected
7 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
8 must submit a written certification to the Producing Party (and, if not the same person
9 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
10 category, where appropriate) all the Protected Material that was returned or destroyed
11 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
12 compilations, summaries or any other format reproducing or capturing any of the
13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
14 archival copy of all pleadings, motion papers, trial, deposition, and hearing
15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
16 reports, attorney work product, and consultant and expert work product, even if such
17 materials contain Protected Material. Any such archival copies that contain or
18 constitute Protected Material remain subject to this Protective Order as set forth in
19 Section 4 (DURATION).
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1 14. 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 IT IS SO STIPULATED.
5 Respectfully submitted,
6 DATED: December 10, 2025 LYNBERG & WATKINS
A Professional Corporation
7
8
By: /s/ Garros Chan1
9 S. FRANK HARRELL
MARLENA R. MLYNARSKA
10 GARROS CHAN
Attorneys for Defendant
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CITY OF GARDEN GROVE
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DATED: December 10, 2025 SMITH LAW OFFICES, LLP
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/s/ David P. Hall
15 DOUGLAS C. SMITH
DAVID P. HALL
16 Attorneys for Defendant
RYAN RODRIGUEZ
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DATED: December 10, 2025 LAW OFFICES OF PHILIP J.
KAPLAN
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/s/ Philip Kaplan
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PHILIP J. KAPLAN
22 Attorneys for Plaintiff
ANTON VU
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1 Pursuant to California Central District Local Rule 5-4.3.4, all other
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signatories listed, and on whose behalf the filing is submitted, concur in the
1 The Court has reviewed the Stipulated Protective Order (Dkt. 28). FOR
7 || GOOD CAUSE SHOWN, IT IS SO ORDERED.
3 DATED: 12/11/2025
4
iowa Es. Soett-
6 Hon. Karen E. Scott
United States Magistrate Judge
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DT
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
6 that I have read in its entirety and understand the Stipulated Protective Order that
7 was issued by the United States District Court for the Central District of California
8 on [date] in the case of Anton Vu. v. City of Garden Grove, et al., Case No. 8:25-cv-
9 000624-FWS-KES. 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
11 comply could expose me to sanctions and punishment in the nature of contempt. I
12 solemnly promise that I will not disclose in any manner any information or item that
13 is subject to this Stipulated Protective Order to any person or entity except in strict
14 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
17 such enforcement proceedings occur after termination of this action. I hereby
18 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
21 this action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
Printed name: _______________________________
26
27 Signature: __________________________________