even stipulated protective orders 15 require good cause showing
How later courts described this case
- even stipulated protective orders 15 require good cause showing
Written by the judges who cited it.
The opinion
1 HYDEE FELDSTEIN SOTO, City Attorney (SBN 106866)
DENISE C. MILLS, Chief Deputy City Attorney (SBN 191992)
2 KATHLEEN KENEALY, Chief Assistant City Attorney (SBN 212289)
CHRISTIAN R. BOJORQUEZ, Deputy City Attorney (SBN 192872)
3 IRVING ESTRADA, Deputy City Attorney (SBN 314785)
200 North Main Street, 6th Floor, City Hall East
4
Los Angeles, CA 90012
5 Phone No.: (213) 978-2247 | Fax No.: (213) 978-8785
Email: irving.estrada@lacity.org
6
Attorneys for Defendants, CITY OF LOS ANGELES, GABRIEL DE ALBA,
7 VIVIENNE READ, ULYSSES ROBLES, and JUSTIN PETERS
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 RODNEY SHACKELFORD and CASE NO. 2:25-cv-09114-SRM-SSC
ERICA JONES, Hon. Serena R. Murillo; 1st St – Ctrm. 5D
12 Hon. Mag. Stephanie S. Christensen; Roybal –
Plaintiffs, Ctrm. 790
13
14 v.
STIPULATED PROTECTIVE
15 ORDER1
CITY OF LOS ANGELES, OFFICER
16
DEALBA, OFFICER READ, OFFICER
17 ROBLES, SERGEANT PETERS, and
DOE OFFICERS 1-10,
18
Defendants.
19
20
21
22 1. INTRODUCTION
23 1.1 Purposes and Limitations. Discovery in this action is likely to involve
24 production of confidential, proprietary, or private information for which special
25
26
1 This Stipulated Protective Order is substantially based on the model protective order
27
provided under Magistrate Judge Stephanie S. Christensen’s Procedures as of 24 July
1 protection from public disclosure and from use for any purpose other than prosecuting
2 this litigation may be warranted. Accordingly, the parties hereby stipulate to and
3 petition the court to enter the following Stipulated Protective Order. The parties
4 acknowledge that this Order does not confer blanket protections on all disclosures or
5 responses to discovery and that the protection it affords from public disclosure and use
6 extends only to the limited information or items that are entitled to confidential
7 treatment under the applicable legal principles.
8 1.2 Good Cause Statement.
9 This action is likely to involve confidential information pertaining to personnel
10 records and other materials subject to privacy protections for which special protection
11 from public disclosure and from use for any purpose other than prosecution of this
12 action is warranted. Limiting disclosure of these documents to the context of this
13 litigation as provided herein will, accordingly, further important law enforcement
14 objections and interests, including the safety of personnel and the public, as well as
15 individual privacy rights of plaintiffs, the individual defendants, and third parties. Such
16 confidential materials and information consist of, among other things, materials entitled
17 to privileges and/or protections under the following: United States Constitution, First
18 Amendment; the California Constitution, Article I, Section 1; California Penal Code §§
19 832.5, 832.7 and 832.8; California Evidence Code §§ 1040 and 1043 et. seq; the Privacy
20 Act of 1974, 5 U.S.C. § 552; Health Insurance Portability and Accountability Act of
21 1996 (HIPPA); the right to privacy; decisional law relating to such provisions; and
22 information otherwise generally unavailable to the public, or which may be privileged
23 or otherwise protected from disclosure under state or federal statutes, court rules, case
24 decisions, or common law. Defendant also contends that such confidential materials and
25 information consist of materials entitled to the Official Information Privilege.
26 Confidential information with respect to the Defendant and/or its employees may
27 include but is not limited to: personnel files; internal investigative files and documents;
1 from the public in the ordinary course of business, as well as other information that is
2 not generally available to the public and is subject to the Official Information Privilege
3 and other privileges. Confidential information with financial records; email and written
4 correspondence records; video footage and/or photographs of the incident; and
5 psychological and medical notes, evaluations, reports, and treatment plans.
6 Testimony taken at a deposition may be designated as Confidential by making a
7 statement to that effect on the record at the deposition. Arrangements shall be made
8 with the court reporter transcribing the deposition to separately bind such portions of
9 the transcript containing information designated as Confidential, and to label such
10 portions appropriately. Confidential photographs, video or audio footage obtained
11 through the course of discovery or otherwise may not be used for any purpose other
12 than litigating this lawsuit. The parties agree to refrain from directly or indirectly
13 disclosing or publicly disseminating confidential deposition testimony, and/or
14 photographs, video or audio footage obtained through the course of discovery or
15 otherwise, specifically including, but not limited to, dissemination via billboard
16 advertisements, print and online media organizations, or any other internet posting or
17 social media. If any party intends to use such confidential materials for any purpose
18 other than litigating this lawsuit, the party seeking public disclosure must first seek
19 approval from the Court.
20 In light of the nature of the claims and allegations in this case and the parties’
21 representations that discovery in this case will involve the production of confidential
22 records, and in order to expedite the flow of information, to facilitate the prompt
23 resolution of disputes over confidentiality of discovery materials, to adequately protect
24 information the parties are entitled to keep confidential, to ensure that the parties are
25 permitted reasonable necessary uses of such material in connection with this action, to
26 address their handling of such material at the end of the litigation, and to serve the ends
27 of justice, a protective order for such information is justified in this matter. The parties
1 belief that such information/documents have been maintained in a confidential, non-
2 public manner, and that there is good cause or a compelling reason why it should not be
3 part of the public record of this case.
4 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties further
5 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order
6 does not entitle them to file confidential information under seal; Local Rule 79-5 sets
7 forth the procedures that must be followed and the standards that will be applied when a
8 party seeks permission from the court to file material under seal.
9 There is a strong presumption that the public has a right of access to judicial
10 proceedings and records in civil cases. In connection with non-dispositive motions,
11 good cause must be shown to support a filing under seal. See Kamakana v. City and
12 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v.
13 Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
14 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
15 require good cause showing), and a specific showing of good cause or compelling
16 reasons with proper evidentiary support and legal justification, must be made with
17 respect to Protected Material that a party seeks to file under seal. The parties’ mere
18 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—without
19 the submission of competent evidence by declaration, establishing that the material
20 sought to be filed under seal qualifies as confidential, privileged, or otherwise
21 protectable—constitute good cause.
22 Further, if a party requests sealing related to a dispositive motion or trial, then
23 compelling reasons, not only good cause, for the sealing must be shown, and the relief
24 sought shall be narrowly tailored to serve the specific interest to be protected. See
25 Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or
26 type of information, document, or thing sought to be filed or introduced under seal in
27 connection with a dispositive motion or trial, the party seeking protection must articulate
1 sealing order. Again, competent evidence supporting the application to file documents
2 under seal must be provided by declaration.
3 Any document that is not confidential, privileged, or otherwise protectable in its
4 entirety will not be filed under seal if the confidential portions can be redacted. If
5 documents can be redacted, then a redacted version for public viewing, omitting only the
6 confidential, privileged, or otherwise protectable portions of the document, shall be
7 filed. Any application that seeks to file documents under seal in their entirety should
8 include an explanation of why redaction is not feasible.
9
10 2. DEFINITIONS
11 2.1 Action: Rodney Shackelford, et al. v. City of Los Angeles, et al.; United
12 States Central District Court Case No.: 2:25-cv-09114-SRM-SSC
13 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
14 information or items under this Order.
15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
16 it is generated, stored or maintained) or tangible things that qualify for protection under
17 Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in the Good
18 Cause Statement.
19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
20 support staff).
21 2.5 Designating Party: a Party or Non-Party that designates information or
22 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
23 2.6 Disclosure or Discovery Material: all items or information, regardless of the
24 medium or manner in which it is generated, stored, or maintained (including, among
25 other things, testimony, transcripts, and tangible things), that are produced or generated
26 in disclosures or responses to discovery in this matter.
27 2.7 Expert: a person with specialized knowledge or experience in a matter
1 expert witness or as a consultant in this Action.
2 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in
3 this Action, with or without prejudice; and (2) final judgment herein after the completion
4 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
5 including the time limits for filing any motions or applications for extension of time
6 pursuant to applicable law.
7 2.9 In-House Counsel: attorneys who are employees of a party to this Action.
8 In-House Counsel does not include Outside Counsel of Record or any other outside
9 counsel.
10 2.10 Non-Party: any natural person, partnership, corporation, association, or
11 other legal entity not named as a Party to this action.
12 2.11 Outside Counsel of Record: attorneys who are not employees of a party to
13 this Action but are retained to represent or advise a party to this Action and have
14 appeared in this Action on behalf of that party or are affiliated with a law firm which has
15 appeared on behalf of that party, and includes support staff.
16 2.12 Party: any party to this Action, including all of its officers, directors,
17 employees, consultants, retained experts, and Outside Counsel of Record (and their
18 support staffs).
19 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
20 Discovery Material in this Action.
21 2.14 Professional Vendors: persons or entities that provide litigation- support
22 services (e.g., photocopying, videotaping, translating, preparing exhibits or
23 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
24 their employees and subcontractors.
25 2.15 Protected Material: any Disclosure or Discovery Material that is designated
26 as “CONFIDENTIAL.”
27 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only Protected
3 Material (as defined above), but also (1) any information copied or extracted from
4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
5 Material; and (3) any testimony, conversations, or presentations by Parties or their
6 Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the trial
8 judge. This Stipulated Protective Order does not govern the use of Protected Material at
9 trial.
10
11 4. TRIAL AND DURATION
12 The terms of this Stipulated Protective Order apply through Final Disposition of
13 the Action.
14 Once a case proceeds to trial, information that was designated as
15 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and used or
16 introduced as an exhibit at trial becomes public and will be presumptively available to
17 all members of the public, including the press, unless compelling reasons supported by
18 specific factual findings to proceed otherwise are made to the trial judge in advance of
19 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing for
20 sealing documents produced in discovery from “compelling reasons” standard when
21 merits-related documents are part of court record). Accordingly, for such materials, the
22 terms of this Stipulated Protective Order do not extend beyond the commencement of
23 the trial.For all items not published or admitted at trial, the confidentiality obligations
24 imposed by this Stipulated Protective Order shall remain in effect until a Designating
25 Party agrees otherwise in writing or a court order otherwise directs.
26
27 5. DESIGNATING PROTECTED MATERIAL
1 Party or Non-Party that designates information or items for protection under this Order
2 must take care to limit any such designation to specific material that qualifies under the
3 appropriate standards. The Designating Party must designate for protection only those
4 parts of material, documents, items, or oral or written communications that qualify so
5 that other portions of the material, documents, items, or communications for which
6 protection is not warranted are not swept unjustifiably within the ambit of this Order.
7 Mass, indiscriminate, or routinized designations are prohibited. Designations that
8 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
9 to unnecessarily encumber the case development process or to impose unnecessary
10 expenses and burdens on other parties) may expose the Designating Party to sanctions.
11 If it comes to a Designating Party’s attention that information or items that it
12 designated for protection do not qualify for protection, that Designating Party must
13 promptly notify all other Parties that it is withdrawing the inapplicable designation.
14 5.2 Manner and Timing of Designations. Except as otherwise provided in this
15 Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), or as
16 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for
17 protection under this Stipulated Protective Order must be clearly so designated before
18 the material is disclosed or produced.
19 Designation in conformity with this Stipulated Protective Order requires:
20 (a) for information in documentary form (e.g., paper or electronic documents,
21 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
22 Producing Party affix at a minimum, the legend “CONFIDENTIAL” to each page that
23 contains protected material. If only a portion or portions of the material on a page
24 qualifies for protection, the Producing Party also must clearly identify the protected
25 portion(s) (e.g., by making appropriate markings in the margins).
26 A Party or Non-Party that makes original documents available for inspection need
27 not designate them for protection until after the inspecting Party has indicated which
1 designation, all of the material made available for inspection shall be deemed
2 CONFIDENTIAL. After the inspecting Party has identified the documents it wants
3 copied and produced, the Producing Party must determine which documents, or portions
4 thereof, qualify for protection under this Stipulated Protective Order. Then, before
5 producing the specified documents, the Producing Party must affix the
6 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a
7 portion or portions of the material on a page qualifies for protection, the Producing Party
8 also must clearly identify the protected portion(s) (e.g., by making appropriate markings
9 in the margins).
10 (b) for testimony given in depositions that the Designating Party identify the
11 Disclosure or Discovery Material on the record, before the close of the deposition all
12 protected testimony.
13 (c) for information produced in some form other than documentary and for any
14 other tangible items, that the Producing Party affix in a prominent place on the exterior
15 of the container or containers in which the information is stored the “CONFIDENTIAL”
16 legend. If only a portion or portions of the information warrants protection, the
17 Producing Party, to the extent practicable, shall identify the protected portion(s).
18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
19 failure to designate qualified information or items does not, standing alone, waive the
20 Designating Party’s right to secure protection under this Order for such material. Upon
21 timely correction of a designation, the Receiving Party must make reasonable efforts to
22 assure that the material is treated in accordance with the provisions of this Stipulated
23 Protective Order.
24
25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
26 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
27 designation of confidentiality at any time that is consistent with the court’s Scheduling
1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
2 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge
3 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2
4 6.3 The burden of persuasion in any such challenge proceeding shall be on the
5 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
6 to harass or impose unnecessary expenses and burdens on other parties) may expose the
7 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
8 the confidentiality designation, all parties shall continue to afford the material in
9 question the level of protection to which it is entitled under the Producing Party’s
10 designation until the court rules on the challenge.
11
12 7. ACCESS TO AND USE OF PROTECTED MATERIAL
13 7.1 Basic Principles. A Receiving Party may use Protected Material that is
14 disclosed or produced by another Party or by a Non-Party in connection with this Action
15 only for prosecuting, defending, or attempting to settle this Action. Such Protected
16 Material may be disclosed only to the categories of persons and under the conditions
17 described in this Order. When the Action reaches a Final Disposition, a Receiving Party
18 must comply with the provisions of section 13 below.
19 Protected Material must be stored and maintained by a Receiving Party at a
20 location and in a secure manner that ensures that access is limited to the persons
21 authorized under this Stipulated Protective Order.
22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
23 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
24 may disclose any information or item designated “CONFIDENTIAL” only:
25
(a) to the Receiving Party’s Outside Counsel of Record in this Action, as well
26
27
1 as employees of said Outside Counsel of Record to whom it is reasonably necessary to
2 disclose the information for this Action;
3 (b) to the officers, directors, and employees (including House Counsel) of the
4 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 a
14 custodian or other person who otherwise possessed or knew the information;
15 (h) during their depositions, to witnesses, and attorneys for witnesses, in the
16 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party
17 requests that the witness sign the “Acknowledgment and Agreement to Be Bound”
18 (Exhibit A); and (2) the witness will not be permitted to keep any confidential
19 information unless they sign the “Acknowledgment and Agreement to Be Bound”
20 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court.
21 Pages of transcribed deposition testimony or exhibits to depositions that reveal Protected
22 Material may be separately bound by the court reporter and may not be disclosed to
23 anyone except as permitted under this Stipulated Protective Order; and
24 (i) to any mediator or settlement officer, and their supporting personnel,
25 mutually agreed upon by any of the parties engaged in settlement discussions.
26
27
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
2 IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation that
4 compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification shall
7 include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order to
9 issue in the other litigation that some or all of the material covered by the subpoena or
10 order is subject to this Protective Order. Such notification shall include a copy of this
11 Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be pursued by
13 the Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with the
15 subpoena or court order shall not produce any information designated in this action as
16 “CONFIDENTIAL” before a determination by the court from which the subpoena or
17 order issued, unless the Party has obtained the Designating Party’s permission. The
18 Designating Party shall bear the burden and expense of seeking protection in that court
19 of its confidential material and nothing in these provisions should be construed as
20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
21 from another court.
22
23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
24 PRODUCED IN THIS LITIGATION
25 9.1 Application. The terms of this Stipulated Protective Order are applicable to
26 information produced by a Non-Party in this Action and designated as
27 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this
1 these provisions should be construed as prohibiting a Non-Party from seeking additional
2 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-Party’s
6 confidential information, then the Party shall:
7 (a) promptly notify in writing the Requesting Party and the Non-Party that
8 some or all of the information requested is subject to a confidentiality agreement with a
9 Non-Party;
10 (b) make the information requested available for inspection by the Non-Party,
11 if requested.
12 9.3 Conditions of Production. If the Non-Party fails to seek a protective order
13 from this court within 14 days of receiving the notice and accompanying information,
14 the Receiving Party may produce the Non-Party’s confidential information responsive to
15 the discovery request. If the Non-Party timely seeks a protective order, the Receiving
16 Party shall not produce any information in its possession or control that is subject to the
17 confidentiality agreement with the Non-Party before a determination by the court.
18 Absent a court order to the contrary, the Non-Party shall bear the burden and expense of
19 seeking protection in this court of its Protected Material.
20
21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
23 Protected Material to any person or in any circumstance not authorized under this
24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
25 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
26 all unauthorized copies of the Protected Material, (c) inform the person or persons to
27 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
1 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
2 (Exhibit A).
3
4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL
6 When a Producing Party gives notice to Receiving Parties that certain
7 inadvertently produced material is subject to a claim of privilege or other protection, the
8 obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the Federal
9 Rules of Civil Procedure. This provision is not intended to modify whatever procedure
10 may be established in an e-discovery order that provides for production without prior
11 privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules of Evidence,
12 insofar as the parties reach an agreement on the effect of disclosure of a communication
13 or information covered by the attorney-client privilege or work product protection, the
14 parties may incorporate their agreement in the stipulated protective order submitted to
15 the court.
16
17 12. MISCELLANEOUS
18 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
19 abridges the right of any person to seek its modification by the court in the future.
20 12.2 Right to Assert Other Objections. By stipulating to the entry of this
21 Stipulated Protective Order no Party waives any right it otherwise would have to object
22 to disclosing or producing any information or item on any ground not addressed in this
23 Stipulated Protective Order. Similarly, no Party waives any right to object on any
24 ground to use in evidence of any of the material covered by this Stipulated Protective
25 Order.
26 12.3 Filing Protected Material. A Party that seeks to file under seal any
27 Protected Material must comply with Local Rule 79-5. Protected Material may only be
1 Material at issue. If a Party's request to file Protected Material under seal is denied by
2 the court, then the Receiving Party may file the information in the public record unless
3 otherwise instructed by the court.
4
5 13. FINAL DISPOSITION
6 After the Final Disposition of this Action, as defined in paragraph 4, within 60
7 days of a written request by the Designating Party, each Receiving Party must return all
8 Protected Material to the Producing Party or destroy such material. As used in this
9 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
10 summaries, and any other format reproducing or capturing any of the Protected Material.
11 Whether the Protected Material is returned or destroyed, the Receiving Party must
12 submit a written certification to the Producing Party (and, if not the same person or
13 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category,
14 where appropriate) all the Protected Material that was returned or destroyed and (2)
15 affirms that the Receiving Party has not retained any copies, abstracts, compilations,
16 summaries or any other format reproducing or capturing any of the Protected Material.
17 Notwithstanding this provision, Counsel is entitled to retain an archival copy of all
18 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
19 correspondence, deposition and trial exhibits, expert reports, attorney work product, and
20 consultant and expert work product, even if such materials contain Protected Material.
21 Any such archival copies that contain or constitute Protected Material remain subject to
22 this Protective Order as set forth in Section 4.
23 ///
24 ///
25 ///
26 ///
27 ///
1 VIOLATION
2 Any violation of this Stipulated Protective Order may be punished by any and all
3 || appropriate measures including, without limitation, contempt proceedings and/or
4 ||monetary sanctions.
5
6 |} IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8 || DATED: _January 27, 2026 KIRAKOSIAN LAW, APC
9
10 /s/ Greg L. Kirakosian
Greg L. Kirakosian, Esq.
11 Raffi S. Batanian, Esq.
12 Astina T. Shakilyan, Esq.
Attorneys for Plaintiffs, RODNEY
13 SHACKELFORD and ERICA JONES
14
15 |] DATED: January 27, 2026 HYDEE FELDSTEIN SOTO, City Attorney
CHRISTIAN R. BOJORQUEZ, Deputy City Attorney
16
17 JEL
By: pi
18 IRVING ESTRADA, Deputy City Attorney
19 Attorneys for Defendants, CITY OF LOS ANGELES,
GABRIEL DE ALBA, VIVIENNE READ, ULYSSES
20 ROBLES, and JUSTIN PETERS
21
22 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
23
5 Ss ANIE S. CHRISTENSEN
United States Magistrate Judge
26
27
28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, ________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of perjury that
6 I have read in its entirety and understand the Stipulated Protective Order that was issued
7 by the United States District Court for the Central District of California on [date] in
8 the case of __________ [insert formal name of the case and the number and
9 initials assigned to it by the court]. I agree to comply with and to be bound by all the
10 terms of this Stipulated Protective Order and I understand and acknowledge that failure
11 to so 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 is
13 subject to this Stipulated Protective 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 District Court for
16 the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint ________________________ [print or
19 type full name] of _________ [print or type full address and telephone number] as
20 my California agent for service of process in connection with this action or any
21 proceedings related to enforcement of this Stipulated Protective Order.
22
23 Date: ___________________________
24 City and State where sworn and
25 signed: ___________________________
26 Printed name: ___________________________
27 Signature: ___________________________