even stipulated protective orders require 8 good cause showing
How later courts described this case
- even stipulated protective orders require 8 good cause showing
Written by the judges who cited it.
The opinion
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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
11
AMBER WIDBY, an individual; CASE NO. 2:25-cv-05648 DMG (JCx)
12
[Assigned to Hon. Dolly M. Gee in
13 Plaintiff, Courtroom 8C]
14
vs. STIPULATED PROTECTIVE
15
ORDER
16 COUNTY OF LOS ANGELES, a
California public entity; ELI [CHANGES MADE BY COURT TO
17
VERA, an individual; ANGELA PARAGRAPHS 3, 8, 9.3 &13]
18 CARRASCO, an individual; and
DOES 1-20, inclusive;
19
20 Defendants.
21
1. INTRODUCTION
22
1.1 Purposes and Limitations. This civil rights action alleges,
23
among other claims, an unreasonable seizure, an unlawful search, a
24
conspiracy to violate civil rights, failure to intervene, deliberate indifference
25
to serious medical needs while in custody, and municipal liability against
26
the County of Los Angeles and individual Los Angeles County Sheriff’s
27
1 2024 at Plaintiff’s residence, Plaintiff’s subsequent arrest and detention,
2 and her medical treatment and housing in the Century Regional Detention
3 Facility (Lynwood Jail) and transfer to other facilities. Discovery in this
4 action is likely to involve production of confidential, proprietary, or private
5 information for which special protection from public disclosure and from use
6 for any purpose other than prosecuting this litigation may be warranted.
7 Accordingly, the parties hereby stipulate to and petition the court to enter
8 the following Stipulated Protective Order. The parties acknowledge that
9 this Order does not confer blanket protections on all disclosures or
10 responses to discovery and that the protection it affords from public
11 disclosure and use extends only to the limited information or items that are
12 entitled to confidential treatment under the applicable legal principles. The
13 parties further acknowledge, as set forth in Section 12.3 (Filing Protected
14 Material), below, that this Stipulated Protective Order does not entitle
15 them to file confidential information under seal; Civil Local Rule 79-5 sets
16 forth the procedures that must be followed and the standards that will be
17 applied when a party seeks permission from the Court to file material under
18 seal.
19 1.2 Good Cause Statement.
20 This action is likely to involve body-worn camera recordings,
21 dispatch/incident reports, operational details concerning Los Angeles
22 Sheriff’s Department (“LASD”) response, protective sweeps, personal data
23 of civilians, Plaintiff’s probation information, Plaintiff’s correctional health
24 and jail security materials, including but not limited to Plaintiff’s personal
25 health information, medication records, medication administration records,
26 and Correctional Health Services’ (“CHS”) policies/protocols regarding
27 inmate medical care and medication handling within secured facilities, and
1 limited to witnesses and third parties identified in the pleadings, incident
2 reports, family members, medical staff, and other detainees, whose names,
3 contact information, and statements may appear in records and videos for
4 which special protection from public disclosure and from use for any
5 purpose other than prosecution of this action is warranted. Such
6 confidential and proprietary materials and information consist of, among
7 other things, information implicating privacy rights of third parties,
8 information otherwise generally unavailable to the public, or which may be
9 privileged or otherwise protected from disclosure under state or federal
10 statutes, court rules, case decisions, or common law. Accordingly, to
11 expedite the flow of information, to facilitate the prompt resolution of
12 disputes over confidentiality of discovery materials, to adequately protect
13 information the parties are entitled to keep confidential, to ensure that the
14 parties are permitted reasonable necessary uses of such material in
15 preparation for and in the conduct of trial, to address their handling at the
16 end of the litigation, and serve the ends of justice, a protective order for such
information is justified in this matter. It is the intent of the parties that
17
information will not be designated as confidential for tactical reasons and
18
that nothing be so designated without a good faith belief that it has been
19
maintained in a confidential, non-public manner, and there is good cause
20
why it should not be part of the public record of this case.
21
1.3 Acknowledgment of Procedure for Filing Under Seal. The
22
parties further acknowledge, as set forth in Section 12.3, below, that this
23
Stipulated Protective Order does not entitle them to file confidential
24
information under seal; Local Rule 79-5 sets forth the procedures that must
25
be followed and the standards that will be applied when a party seeks
26
permission from the court to file material under seal.
27
1 There is a strong presumption that the public has a right of access to
2 judicial proceedings and records in civil cases. In connection with non-
3 dispositive motions, good cause must be shown to support a filing under
4 seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176
5 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 F.3d
6 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., Inc., 187
7 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
8 good cause showing), and a specific showing of good cause or compelling
9 reasons with proper evidentiary support and legal justification, must be
10 made with respect to Protected Material that a party seeks to file under
11 seal. The parties’ mere designation of Disclosure or Discovery Material as
12 CONFIDENTIAL does not—without the submission of competent evidence
13 by declaration, establishing that the material sought to be filed under seal
14 qualifies as confidential, privileged, or otherwise protectable—constitute
15 good cause.
16 Further, if a party requests sealing related to a dispositive motion or
17 trial, then compelling reasons, not only good cause, for the sealing must be
18 shown, and the relief sought shall be narrowly tailored to serve the specific
19 interest to be protected. See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665,
20 677–79 (9th Cir. 2010). For each item or type of information, document, or
21 thing sought to be filed or introduced under seal in connection with a
22 dispositive motion or trial, the party seeking protection must articulate
23 compelling reasons, supported by specific facts and legal justification, for
24 the requested sealing order. Again, competent evidence supporting the
25 application to file documents under seal must be provided by declaration.
26 Any document that is not confidential, privileged, or otherwise
27 protectable in its entirety will not be filed under seal if the confidential
1 version for public viewing, omitting only the confidential, privileged, or
2 otherwise protectable portions of the document, shall be filed. Any
3 application that seeks to file documents under seal in their entirety should
4 include an explanation of why redaction is not feasible.
5 2. DEFINITIONS
6 2.1 Action: refers to Amber Widby v. County of Los Angeles, et al.,
7 United States District Court, Central District, Case No.: 2:24-cv-05648
8 DMG (JCx), and any appeals through FINAL DISPOSITION.
9 2.2 Challenging Party: a Party or Non-Party that challenges the
10 designation of information or items under this Order.
11 2.3 “CONFIDENTIAL” Information or Items: information
12 (regardless of how it is generated, stored or maintained) or tangible things
13 that qualify for protection under Rule 26(c) of the Federal Rules of Civil
14 Procedure, and as specified above in the Good Cause Statement.
15 2.4 Counsel: Outside Counsel of Record and House Counsel (as
16 well as their support staff).
17 2.5 Designating Party: a Party or Non-Party that designates
18 information or items that it produces in disclosures or in responses to
19 discovery as “CONFIDENTIAL.”
20 2.6 Disclosure or Discovery Material: all items or information,
21 regardless of the medium or manner in which it is generated, stored, or
22 maintained (including, among other things, testimony, transcripts, and
23 tangible things), that are produced or generated in disclosures or responses
24 to discovery in this matter.
25 2.7 Expert: a person with specialized knowledge or experience in a
26 matter pertinent to the litigation who has been retained by a Party or its
27 counsel to serve as an expert witness or as a consultant in this Action.
1 2.8 Final Disposition: the later of (1) dismissal of all claims and
2 defenses in this Action, with or without prejudice; and (2) final judgment
3 herein after the completion and exhaustion of all appeals, rehearings,
4 remands, trials, or reviews of this Action, including the time limits for filing
5 any motions or applications for extension of time pursuant to applicable
6 law.
7 2.9 In-House Counsel: attorneys who are employees of a party to
8 this Action. In-House Counsel does not include Outside Counsel of Record
9 or any other outside counsel.
10 2.10 Non-Party: any natural person, partnership, corporation,
11 association, or other legal entity not named as a Party to this action.
12 2.11 Outside Counsel of Record: attorneys who are not employees of
13 a party to this Action but are retained to represent or advise a party to this
14 Action and have appeared in this Action on behalf of that party or are
15 affiliated with a law firm which has appeared on behalf of that party, and
16 includes support staff.
17 2.12 Party: any party to this Action, including all of its officers,
18 directors, employees, consultants, retained experts, and Outside Counsel of
19 Record (and their support staffs).
20 2.13 Producing Party: a Party or Non-Party that produces Disclosure
21 or Discovery Material in this Action.
22 2.14 Professional Vendors: persons or entities that provide litigation-
23 support services (e.g., photocopying, videotaping, translating, preparing
24 exhibits or demonstrations, and organizing, storing, or retrieving data in
25 any form or medium) and their employees and subcontractors.
26 2.15 Protected Material: any Disclosure or Discovery Material that is
27 designated as “CONFIDENTIAL.”
1 2.16 Receiving Party: a Party that receives Disclosure or Discovery
2 Material from a Producing Party.
3 3. SCOPE
4 The protections conferred by this Stipulation and Order cover not
5 only Protected Material (as defined above), but also (1) any information
6 copied or extracted from Protected Material; (2) all copies, excerpts,
7 summaries, or compilations of Protected Material; and (3) any testimony,
8 conversations, or presentations by Parties or their Counsel that might
9 reveal Protected Material other than during a court hearing or at trial.
10 Any use of Protected Material during a court hearing or at trial shall
11 be governed by the orders of the presiding judge. This Stipulated
12 Protective Order does not govern the use of Protected Material during a
13 court hearing or at trial.
14 4. DURATION
15 Even after Final Disposition of this litigation, the confidentiality
16 obligations imposed by this Stipulated Protective Order shall remain in
17 effect until a Designating Party agrees otherwise in writing or a court order
18 otherwise directs. Final disposition shall be deemed to be the later of (1)
19 dismissal of all claims and defenses in this Action, with or without
20 prejudice; and (2) final judgment herein after the completion and
21 exhaustion of all appeals, rehearings, remands, trials, or reviews of this
22 Action, including the time limits for filing any motions or applications for
23 extension of time pursuant to applicable law.
24 5. DESIGNATING PROTECTED MATERIAL
25 5.1 Exercise of Restraint and Care in Designating Material for
26 Protection. Each Party or Non-Party that designates information or items
27 for protection under this Order must take care to limit any such designation
1 Designating Party must designate for protection only those parts of
2 material, documents, items, or oral or written communications that qualify
3 so that other portions of the material, documents, items, or communications
4 for which protection is not warranted are not swept unjustifiably within the
5 ambit of this Order.
6 Mass, indiscriminate, or routinized designations are prohibited.
7 Designations that are shown to be clearly unjustified or that have been
8 made for an improper purpose (e.g., to unnecessarily encumber the case
9 development process or to impose unnecessary expenses and burdens on
10 other parties) may expose the Designating Party to sanctions.
11 If it comes to a Designating Party’s attention that information or
12 items that it designated for protection do not qualify for protection, that
13 Designating Party must promptly notify all other Parties that it is
14 withdrawing the inapplicable designation.
15 5.2 Manner and Timing of Designations. Except as otherwise
16 provided in this Stipulated Protective Order (see, e.g., second paragraph of
17 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or
18 Discovery Material that qualifies for protection under this Stipulated
19 Protective Order must be clearly so designated before the material is
20 disclosed or produced.
21 Designation in conformity with this Stipulated Protective Order
22 requires:
23 (a) for information in documentary form (e.g., paper or electronic
24 documents, but excluding transcripts of depositions or other pretrial or
25 trial proceedings), that the Producing Party affix at a minimum, the legend
26 “CONFIDENTIAL” to each page that contains protected material. If only
27 a portion or portions of the material on a page qualifies for protection, the
1 Producing Party also must clearly identify the protected portion(s) (e.g., by
2 making appropriate markings in the margins).
3 A Party or Non-Party that makes original documents available for
4 inspection need not designate them for protection until after the inspecting
5 Party has indicated which documents it would like copied and produced.
6 During the inspection and before the designation, all of the material made
7 available for inspection shall be deemed CONFIDENTIAL. After the
8 inspecting Party has identified the documents it wants copied and
9 produced, the Producing Party must determine which documents, or
10 portions thereof, qualify for protection under this Stipulated Protective
11 Order. Then, before producing the specified documents, the Producing
12 Party must affix the “CONFIDENTIAL” legend to each page that contains
13 Protected Material. If only a portion or portions of the material on a page
14 qualifies for protection, the Producing Party also must clearly identify the
15 protected portion(s) (e.g., by making appropriate markings in the margins).
16 (b) for testimony given in depositions that the Designating Party
17 identify the Disclosure or Discovery Material on the record, before the close
18 of the deposition all protected testimony.
19 (c) for information produced in some form other than documentary
20 and for any other tangible items, that the Producing Party affix in a
21 prominent place on the exterior of the container or containers in which the
22 information is stored the “CONFIDENTIAL” legend. If only a portion or
23 portions of the information warrants protection, the Producing Party, to the
24 extent practicable, shall identify the protected portion(s).
25 5.3 Inadvertent Failures to Designate. If timely corrected, an
26 inadvertent failure to designate qualified information or items does not,
27 standing alone, waive the Designating Party’s right to secure protection
1 the Receiving Party must make reasonable efforts to assure that the
2 material is treated in accordance with the provisions of this Stipulated
3 Protective Order.
4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
5 6.1 Timing of Challenges. Any Party or Non-Party may challenge
6 a designation of confidentiality at any time that is consistent with the
7 court’s Scheduling Order.
8 6.2 Meet and Confer. The Challenging Party shall initiate the
9 dispute resolution process under Local Rule 37.1 et seq.
10 6.3 Joint Stipulation. If the Designating Party persists in
11 designating the document or other material in question as Confidential,
12 the objecting party may move the Court for an order removing or replacing
13 the “Confidential” designation. Any challenge submitted to the Court shall
14 be via a joint stipulation pursuant to Local Rule 37-2.
15 6.4 Burden of Persuasion. The burden of persuasion in any such
16 challenge proceeding shall be on the Designating Party. Frivolous
17 challenges, and those made for an improper purpose (e.g., to harass or
18 impose unnecessary expenses and burdens on other parties) may expose
19 the Challenging Party to sanctions. Unless the Designating Party has
20 waived or withdrawn the confidentiality designation, all parties shall
21 continue to afford the material in question the level of protection to which
22 it is entitled under the Producing Party’s designation until the court rules
23 on the challenge.
24 7. ACCESS TO AND USE OF PROTECTED MATERIAL
25 7.1 Basic Principles. A Receiving Party may use Protected Material
26 that is disclosed or produced by another Party or by a Non-Party in
27 connection with this Action only for prosecuting, defending, or attempting
1 categories of persons and under the conditions described in this Order.
2 When the Action reaches a Final Disposition, a Receiving Party must
3 comply with the provisions of section 13 below.
4 Protected Material must be stored and maintained by a Receiving
5 Party at a location and in a secure manner that ensures that access is
6 limited to the persons authorized under this Stipulated Protective Order.
7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
8 otherwise ordered by the court or permitted in writing by the Designating
9 Party, a Receiving Party may disclose any information or item designated
10 “CONFIDENTIAL” only:
11 (a) to the Receiving Party’s Outside Counsel of Record in this
12 Action, as well as employees of said Outside Counsel of Record to whom it
13 is reasonably necessary to disclose the information for this Action;
14 (b) to the officers, directors, and employees (including House
15 Counsel) of the Receiving Party to whom disclosure is reasonably necessary
16 for this Action;
17 (c) to Experts (as defined in this Order) of the Receiving Party to
18 whom disclosure is reasonably necessary for this Action and who have
19 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20 (d) to the court and its personnel;
21 (e) to court reporters and their staff;
22 (f) to professional jury or trial consultants, mock jurors, and
23 Professional Vendors to whom disclosure is reasonably necessary for this
24 Action and who have signed the “Acknowledgment and Agreement to Be
25 Bound” (Exhibit A);
26 (g) to the author or recipient of a document containing the
27 information or a custodian or other person who otherwise possessed or
1 (h) during their depositions, to witnesses, and attorneys for
2 witnesses, in the Action to whom disclosure is reasonably necessary,
3 provided: (1) the deposing party requests that the witness sign the
4 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
5 witness will not be permitted to keep any confidential information unless
6 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
7 unless otherwise agreed by the Designating Party or ordered by the court.
8 Pages of transcribed deposition testimony or exhibits to depositions that
9 reveal Protected Material may be separately bound by the court reporter
10 and may not be disclosed to anyone except as permitted under this
11 Stipulated Protective Order; and
12 (i) to any mediator or settlement officer, and their supporting
13 personnel, mutually agreed upon by any of the parties engaged in
14 settlement discussions.
15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
16 PRODUCED IN OTHER LITIGATION
17 If a Party is served with a subpoena or a court order issued in other
18 litigation that compels disclosure of any information or items designated
19 in this Action as “CONFIDENTIAL,” that Party must:
20 (a) promptly notify in writing the Designating Party. Such
21 notification shall include a copy of the subpoena or court order;
22 (b) promptly notify in writing the party who caused the subpoena
23 or order to issue in the other litigation that some or all of the material
24 covered by the subpoena or order is subject to this Protective Order. Such
25 notification shall include a copy of this Stipulated Protective Order; and
26 (c) cooperate with respect to all reasonable procedures sought to be
27 pursued by the Designating Party whose Protected Material may be
1 If the Designating Party timely seeks a protective order, the Party
2 served with the subpoena or court order shall not produce any information
3 designated in this action as “CONFIDENTIAL” before a determination by
4 the court from which the subpoena or order issued, unless the Party has
5 obtained the Designating Party’s permission or unless otherwise required
6 by the law or court order. The Designating Party shall bear the burden
7 and expense of seeking protection in that court of its confidential material
8 and nothing in these provisions should be construed as authorizing or
9 encouraging a Receiving Party in this Action to disobey a lawful directive
10 from another court.
11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
12 PRODUCED IN THIS LITIGATION
13 9.1 Application. The terms of this Stipulated Protective Order are
14 applicable to information produced by a Non-Party in this Action and
15 designated as “CONFIDENTIAL.” Such information produced by Non-
16 Parties in connection with this litigation is protected by the remedies and
17 relief provided by this Order. Nothing in these provisions should be
18 construed as prohibiting a Non-Party from seeking additional protections.
19 9.2 Notification. In the event that a Party is required, by a valid
20 discovery request, to produce a Non-Party’s confidential information in its
21 possession, and the Party is subject to an agreement with the Non-Party
22 not to produce the Non-Party’s confidential information, then the Party
23 shall:
24 (a) promptly notify in writing the Requesting Party and the Non-
25 Party that some or all of the information requested is subject to a
26 confidentiality agreement with a Non-Party;
27 (b) make the information requested available for inspection by the
1 9.3 Conditions of Production. If the Non-Party fails to seek a
2 protective order from this court within 14 days of receiving the notice and
3 accompanying information, the Receiving Party may produce the Non-
4 Party’s confidential information responsive to the discovery request. If the
5 Non-Party timely seeks a protective order, the Receiving Party shall not
6 produce any information in its possession or control that is subject to the
7 confidentiality agreement with the Non-Party before a determination by the
8 court unless otherwise required by the law or court order. Absent a court
9 order to the contrary, the Non-Party shall bear the burden and expense of
10 seeking protection in this court of its Protected Material.
11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
12 MATERIAL
13 If a Receiving Party learns that, by inadvertence or otherwise, it has
14 disclosed Protected Material to any person or in any circumstance not
15 authorized under this Stipulated Protective Order, the Receiving Party
16 must immediately (a) notify in writing the Designating Party of the
unauthorized disclosures, (b) use its best efforts to retrieve all
17
unauthorized copies of the Protected Material, (c) inform the person or
18
persons to whom unauthorized disclosures were made of all the terms of
19
this Order, and (d) request such person or persons to execute the
20
“Acknowledgment and Agreement to Be Bound” (Exhibit A).
21
11. INADVERTENT PRODUCTION OF PRIVILEGED OR
22
OTHERWISE PROTECTED MATERIAL
23
When a Producing Party gives notice to Receiving Parties that
24
certain inadvertently produced material is subject to a claim of privilege or
25
other protection, the obligations of the Receiving Parties are those set forth
26
in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision
27
1 discovery order that provides for production without prior privilege review.
2 Pursuant to Rules 502(d) and (e) of the Federal Rules of Evidence, insofar
3 as the parties reach an agreement on the effect of disclosure of a
4 communication or information covered by the attorney-client privilege or
5 work product protection, the parties may incorporate their agreement in
6 the stipulated protective order submitted to the court.
7 12. MISCELLANEOUS
8 12.1 Right to Further Relief. Nothing in this Stipulated Protective
9 Order abridges the right of any person to seek its modification by the court
10 in the future.
11 12.2 Right to Assert Other Objections. By stipulating to the entry of
12 this Stipulated Protective Order no Party waives any right it otherwise
13 would have to object to disclosing or producing any information or item on
14 any ground not addressed in this Stipulated Protective Order. Similarly,
15 no Party waives any right to object on any ground to use in evidence of any
16 of the material covered by this Stipulated Protective Order.
17
12.3 Filing Protected Material. A Party that seeks to file under seal
any Protected Material must comply with Local Rule 79-5. Protected
18
Material may only be filed under seal pursuant to a court order authorizing
19
the sealing of the specific Protected Material at issue. If a Party's request
20
to file Protected Material under seal is denied by the court, then the
21
Receiving Party may file the information in the public record unless
22
otherwise instructed by the court.
23
13. FINAL DISPOSITION
24
After the Final Disposition of this Action, as defined in paragraphs
25
2.8 & 4, within 60 days of a written request by the Designating Party, each
26
Receiving Party must return all Protected Material to the Producing Party
27
1 Material” includes all copies, abstracts, compilations, summaries, and any
2 other format reproducing or capturing any of the Protected Material.
3 Whether the Protected Material is returned or destroyed, the Receiving
4 Party must submit a written certification to the Producing Party (and, if
5 not the same person or entity, to the Designating Party) by the 60 day
6 deadline that (1) identifies (by category, where appropriate) all the
7 Protected Material that was returned or destroyed and (2) affirms that the
8 Receiving Party has not retained any copies, abstracts, compilations,
9 summaries or any other format reproducing or capturing any of the
10 Protected Material. Notwithstanding this provision, Counsel is entitled to
11 retain an archival copy of all pleadings, motion papers, trial, deposition,
12 and hearing transcripts, legal memoranda, correspondence, deposition and
13 trial exhibits, expert reports, attorney work product, and consultant and
14 expert work product, even if such materials contain Protected Material.
15 Any such archival copies that contain or constitute Protected Material
16 remain subject to this Protective Order as set forth in Section 4
(DURATION).
17
18
14. VIOLATION
Any violation of this Stipulated Protective Order may be punished by
19
any and all appropriate measures including, without limitation, contempt
20
proceedings and/or monetary sanctions.
21
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3 DATED: January 13, 2026 POINTER & BUELNA, LLP
4
/s/ Michael A. Slater
5 ________________________________
Adante D. Pointer, Esq.
6
Patrick M. Buelna, Esq.
7 Michael A. Slater, Esq.
Attorneys for Plaintiff, Amber Widby
8
9
DATED: January 13, 2026 COLLINS + COLLINS LLP
10
/s/ Robert C. Leiford, III
11
______________________________
12 Tomas A. Guterres, Esq.
Robert C. Leiford III, Esq.
13
Attorneys for Defendants, County of Los
14 Angeles, et al. )
15
16
17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED
18 AS MODIFIED.
19
20 DATED: January 16, 2026 _____________/s/____________________
21 HONORABLE JACQUELINE CHOOLJIAN
United States Magistrate Judge
22
23
24
25
26
27
1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
I, ________________________ [print or type full name], of
3
_________________ [print or type full address], declare under penalty of
4
perjury that I have read in its entirety and understand the Stipulated
5
6 Protective Order (“Order”) that was issued by the United States District
7 Court for the Central District of California on January 16, 2026 the
8 case of Amber Widby v. County of Los Angeles, et al. Case No.: 2:25-cv-
9 05648 DMG (JCx). I agree to comply with and to be bound by all the terms
10 of this 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
12 solemnly promise that I will not disclose in any manner any information or
13 item that is subject to this Order to any person or entity except in strict
14 compliance with the provisions of this Order.
15
I further agree to submit to the jurisdiction of the United States
16
District Court for the Central District of California for the purpose of
17
enforcing the terms of this Order, even if such enforcement proceedings
18
occur after termination of this action. I hereby appoint
19
________________________ [print or type full name] of _________ [print
20
or type full address and telephone number] as my California agent for
21
service of process in connection with this action or any proceedings related
22
to enforcement of this Order.
23
Date: ___________________________
24
25 C an it d y s a ig n n d e S d t : a te where sworn ___________________________
26 Printed name: ___________________________
27 Signature: ___________________________