Opinion

Eli Schechter v. Chapman University

Court
District Court, C.D. California
Filed
May 20, 2026
Cited by
0 cases
Authority
More cited than 41.5%

The opinion

1 Bryan H. Heckenlively (State Bar No. 279140)

Bryan.Heckenlively@mto.com

2

Aditi N. Ghatlia (State Bar No. 347260)

3 Aditi.Ghatlia@mto.com

MUNGER, TOLLES & OLSON LLP

4

560 Mission Street, Twenty-Seventh Floor

5 San Francisco, California 94105-2907

Telephone: (415) 512-4000

6

Facsimile: (415) 512-4077

7

Carl Jiang (State Bar No. 355258)

8

MUNGER, TOLLES & OLSON LLP

9 350 South Grand Avenue, Fiftieth Floor

Los Angeles, California 90071-3426

10

Telephone: (213) 683-9100

11 Facsimile: (213) 687-3702

12

Attorneys for Defendants

13

14

UNITED STATES DISTRICT COURT

15 CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION

16

17 ELI SCHECHTER and TALYA Case No. 8:25-cv-2426

MALKA, individually and on behalf of

18

a class of similarly situated individuals, [DISCOVERY MATTER]

19

Plaintiffs, STIPULATED

20

PROTECTIVE ORDER

21 vs.

22

CHAPMAN UNIVERSITY, THE

23 BOARD OF TRUSTEES OF

CHAPMAN UNIVERSITY, and DOES

24

1-50,

25

Defendants.

26

27

1 1. PURPOSES AND LIMITATIONS

2 Disclosure and discovery activity in this action are likely to involve

3 production of proprietary or private information for which special protection from

4 public disclosure and from use for any purpose other than prosecuting this litigation

5 may be warranted. Accordingly, the parties hereby stipulate to and petition the

6 court to enter the following Stipulated Protective Order. The parties acknowledge

7 that this Order does not confer blanket protections on all disclosures or responses to

8 discovery and that the protection it affords from public disclosure and use extends

9 only to the limited information or items that are entitled to confidential treatment

10 under the applicable legal principles.

11 2. GOOD CAUSE STATEMENT

12 This action may involve materials containing information that may be

13 protected from disclosure under state or federal statutes, court rules, case decisions,

14 or common law. It is likely to involve materials implicating the privacy interests of

15 the Plaintiffs, Chapman University’s employees and agents, and third parties. These

16 materials may include educational records of current or former students at Chapman

17 (including Plaintiffs), private medical information, and Chapman employee personal

18 data and information and sensitive employment and personnel records. This action

19 may also include materials directly implicating Chapman’s legitimate business

20 interests, such as sensitive internal communications, reports, and analyses regarding

21 student and employee recruitment and retention strategies, resource allocation, and

22 marketing, unrestricted availability of which to peer institutions or other entities

23 operating in the higher education space may cause competitive harm. Educational

24 records are likely to fall under FERPA protection and as such are generally not

25 subject to disclosure without written consent of the subject individual(s), a lawful

26 subpoena and notice, or a court order and notice.

27 Accordingly, to expedite the flow of information, to facilitate the prompt

1 protect information the parties are entitled to keep confidential, to ensure that the

2 parties are permitted reasonable necessary uses of such material in preparation for

3 and in the conduct of trial, to address their handling at the end of the litigation, and

4 serve the ends of justice, a protective order for such information is justified in this

5 matter. It is the intent of the parties that information will not be designated as

6 confidential for tactical reasons and that nothing be so designated without a good

7 faith belief that it implicates the above delineated privacy interests or otherwise

8 qualifies for protection under Federal Rule of Civil Procedure 26(c), has been

9 maintained in a confidential, non-public manner, and there is good cause why it

10 should not be part of the public record of this case.

11 3. DEFINITIONS

12 3.1 Action: this pending federal lawsuit.

13 3.2 Challenging Party: a Party or Non-Party that challenges the designation

14 of information or items under this Order.

15 3.3 “CONFIDENTIAL” Information or Items: information (regardless of

16 how it is generated, stored or maintained) or tangible things that qualify for

17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in

18 the Good Cause Statement.

19 3.4 Counsel (without qualifier): Outside Counsel of Record and House

20 Counsel (as well as their support staff).

21 3.5 Designating Party: a Party or Non-Party that designates information or

22 items that it produces in disclosures or in responses to discovery as

23 “CONFIDENTIAL.”

24 3.6 Disclosure or Discovery Material: all items or information, regardless

25 of the medium or manner in which it is generated, stored, or maintained (including,

26 among other things, testimony, transcripts, and tangible things), that are produced or

27 generated in disclosures or responses to discovery in this matter.

1 3.7 Expert: a person with specialized knowledge or experience in a matter

2 pertinent to the litigation who has been retained by a Party or its counsel to serve as

3 an expert witness or as a consultant in this Action.

4 3.8 FERPA: the Family Educational Rights and Privacy Act, 20 U.S.C. §

5 1232g, and any regulations passed pursuant to that Act by the Department of

6 Education or any other federal agency.

7 3.9 FERPA Records: education records as defined by FERPA.

8 3.10 House Counsel: attorneys who are employees of a party to this Action.

9 House Counsel does not include Outside Counsel of Record or any other outside

10 counsel.

11 3.11 Non-Party: any natural person, partnership, corporation, association, or

12 other legal entity not named as a Party to this action.

13 3.12 Outside Counsel of Record: attorneys who are not employees of a party

14 to this Action but are retained to represent or advise a party to this Action and have

15 appeared in this action on behalf of that party or are affiliated with a law firm which

16 has appeared on behalf of that party.

17 3.13 Party: any party to this Action, including all of its officers, directors,

18 employees, consultants, retained experts, and Outside Counsel of Record (and their

19 support staffs).

20 3.14 Producing Party: a Party or Non-Party to this Action that produces

21 Disclosure or Discovery Material in this action.

22 3.15 Professional Vendors: persons or entities that provide litigation support

23 services (e.g., photocopying, videotaping, translating, preparing exhibits or

24 demonstrations, and organizing, storing, or retrieving data in any form or medium)

25 and their employees and subcontractors.

26 3.16 Protected Material: any Disclosure or Discovery Material that is

27 designated as “CONFIDENTIAL.”

1 3.17 Receiving Party: a Party that receives Disclosure or Discovery Material

2 from a Producing Party.

3 4. ACKNOWLEDGEMENT OF UNDER SEAL FILING PROCEDURE

4 The parties acknowledge that this stipulated Protective Order does not entitle

5 them to file confidential information under seal; Local Civil Rule 79-5 sets forth the

6 procedures that must be followed and the standards that will be applied when a party

7 seeks permission from the court to file material under seal. There is a strong

8 presumption that the public has a right of access to judicial proceedings and records

9 in civil cases. In connection with non-dispositive motions, good cause must be

10 shown to support a filing under seal. See Kamakana v. City and County of

11 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006). A specific showing of good cause

12 or compelling reasons with proper evidentiary support and legal justification must

13 be made with respect to Protected Material that a party seeks to file under seal. The

14 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL

15 does not— without the submission of competent evidence by declaration,

16 establishing that the material sought to be filed under seal qualifies as confidential,

17 privileged, or otherwise protectable—constitute good cause.

18 Further, if a party requests sealing related to a dispositive motion or trial, then

19 compelling reasons, not only good cause, for the sealing must be shown, and the

20 relief sought shall be narrowly tailored to serve the specific interest to be protected.

21 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For

22 each item or type of information, document, or thing sought to be filed or introduced

23 under seal, the party seeking protection must articulate compelling reasons,

24 supported by specific facts and legal justification, for the requested sealing order.

25 Again, competent evidence supporting the application to file documents under seal

26 must be provided by declaration. Any document that is not confidential, privileged,

27 or otherwise protectable in its entirety will not be filed under seal if the confidential

1 public viewing, omitting only the confidential, privileged, or otherwise protectable

2 portions of the document, shall be filed. Any application that seeks to file

3 documents under seal in their entirety should include an explanation of why

4 redaction is not feasible.

5 5. SCOPE

6 The protections conferred by this Stipulation and Order cover not only

7 Protected Material (as defined above), but also (1) any information copied or

8 extracted from Protected Material; (2) all copies, excerpts, summaries, or

9 compilations of Protected Material; and (3) any testimony, conversations, or

10 presentations by Parties or their Counsel that reveal Protected Material.

11 The protections conferred by this Stipulation and Order do not cover the

12 following information: (a) any information that is in the public domain at the time of

13 disclosure to a Receiving Party or becomes part of the public domain after its

14 disclosure to a Receiving Party as a result of publication not involving a violation of

15 this Order, including becoming part of the public record through trial or otherwise;

16 and (b) any information known to the Receiving Party prior to the disclosure or

17 obtained by the Receiving Party after the disclosure from a source who obtained the

18 information lawfully and under no obligation of confidentiality to the Designating

19 Party. Any use of Protected Material at trial shall be governed by a separate

20 agreement or order.

21 6. DURATION

22 Even after final disposition of this litigation, the confidentiality obligations

23 imposed by this Order shall remain in effect until a Designating Party (or, for

24 FERPA records, both the Designating Party and the (subject individual(s) to whom

25 the FERPA records concern) agrees otherwise in writing or a court order otherwise

26 directs. Final disposition shall be deemed to be the later of (1) dismissal of all

27 claims and defenses in this action, with or without prejudice; and (2) final judgment

1 trials, or reviews of this action, including the time limits for filing any motions or

2 applications for extension of time pursuant to applicable law.

3 7. DESIGNATING PROTECTED MATERIAL

4 7.1 Exercise of Restraint and Care in Designating Material for Protection.

5 Each Party or Non-Party that designates information or items for protection under

6 this Order must take care to limit any such designation to specific material that

7 qualifies under the appropriate standards as indicated in the above Good Cause

8 Statement. The Designating Party must designate for protection only those parts of

9 material, documents, items, or oral or written communications that qualify—so that

10 other portions of the material, documents, items, or communications for which

11 protection is not warranted are not swept unjustifiably within the ambit of this

12 Order.

13 Mass, indiscriminate, or routinized designations are prohibited. Designations

14 may not be made for an improper purpose (e.g., to unnecessarily encumber the case

15 development process or to impose unnecessary expenses and burdens on other

16 parties).

17 If it comes to a Designating Party’s attention that information or items that it

18 designated for protection do not qualify for protection, that Designating Party must

19 promptly notify all other Parties that it is withdrawing the mistaken designation.

20 7.2 Manner and Timing of Designations. Except as otherwise provided in

21 this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material

22 that qualifies for protection under this Order must be clearly so designated before

23 the material is disclosed or produced.

24 Designation in conformity with this Order requires:

25 (a) For information in documentary form (e.g., paper or electronic

26 documents, but excluding transcripts of depositions or other pretrial or trial

27 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each

1 a page qualifies for protection, the Producing Party also must clearly identify the

2 protected portion(s) (e.g., by making appropriate markings in the margins).

3 A Party or Non-Party that makes original documents or materials available for

4 inspection need not designate them for protection until after the inspecting Party has

5 indicated which material it would like copied and produced. During the inspection

6 and before the designation, all of the material made available for inspection shall be

7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

8 documents it wants copied and produced, the Producing Party must determine which

9 documents, or portions thereof, qualify for protection under this Order. Then,

10 before producing the specified documents, the Producing Party must affix the

11 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a

12 portion or portions of the material on a page qualifies for protection, the Producing

13 Party also must clearly identify the protected portion(s) (e.g., by making appropriate

14 markings in the margins).

15 (b) for testimony given in deposition or in other pretrial or trial

16 proceedings, that the Designating Party identify on the record, before the close of

17 the deposition, hearing, or other proceeding, all protected testimony.

18 (c) for information produced in some form other than documentary and

19 for any other tangible items, that the Producing Party affix in a prominent place on

20 the exterior of the container or containers in which the information or item is stored

21 the legend “CONFIDENTIAL.” If only a portion or portions of the information or

22 item warrant protection, the Producing Party, to the extent practicable, shall identify

23 the protected portion(s).

24 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

25 failure to designate qualified information or items does not, standing alone, waive

26 the Designating Party’s right to secure protection under this Order for such material.

27 Upon timely correction of a designation, the Receiving Party must make reasonable

1 efforts to assure that the material is treated in accordance with the provisions of this

2 Order.

3 Designating FERPA Records. The Designating Party shall designate as

4 “CONFIDENTIAL” any Documents, Testimony or Information that contains, is

5 reasonably believed to contain, or is claimed by another Party to contain FERPA

6 Records of any subject individual(s) who has not consented in writing to the

7 disclosure of such records.

8 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

9 8.1 Timing of Challenges. Unless a prompt challenge to a Designating

10 Party’s confidentiality designation is necessary to avoid foreseeable, substantial

11 unfairness, unnecessary economic burdens, or a significant disruption or delay of the

12 litigation, a Party does not waive its right to challenge a confidentiality designation

13 by electing not to mount a challenge promptly after the original designation is

14 disclosed.

15 8.2 Meet and Confer. The Challenging Party shall initiate the dispute

16 resolution process by providing written notice of each designation it is challenging

17 and describing the basis for each challenge. To avoid ambiguity as to whether a

18 challenge has been made, the written notice must recite that the challenge to

19 confidentiality is being made in accordance with this specific paragraph of the

20 Protective Order. The parties shall attempt to resolve each challenge in good faith

21 and must begin the process by conferring directly (in voice to voice dialogue; other

22 forms of communication are not sufficient) within 14 days of the date of service of

23 notice. In conferring, the Challenging Party must explain the basis for its belief that

24 the confidentiality designation was not proper and must give the Designating Party

25 an opportunity to review the designated material, to reconsider the circumstances,

26 and, if no change in designation is offered, to explain the basis for the chosen

27 designation.

1 8.3 Judicial Intervention. Any challenge submitted to the Court shall be

2 via a joint stipulation pursuant to Local Rule 37-2.

3 9. ACCESS TO AND USE OF PROTECTED MATERIAL

4 9.1 Basic Principles. A Receiving Party may use Protected Material that is

5 disclosed or produced by another Party or by a Non-Party in connection with this

6 case only for prosecuting, defending, or attempting to settle this Action. Such

7 Protected Material may be disclosed only to the categories of persons and under the

8 conditions described in this Order. When the litigation has been terminated, a

9 Receiving Party must comply with the provisions of section 13.4 below (FINAL

10 DISPOSITION).

11 Protected Material must be stored and maintained by a Receiving Party at a

12 location and in a secure manner that ensures that access is limited to the persons

13 authorized under this Order.

14 No party shall produce FERPA Records except with the written consent of the

15 subject individual(s) whose records are being produced, or pursuant to a court order

16 identifying the particular records to be produced, or pursuant to a lawfully issued

17 subpoena.

18 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

19 otherwise ordered by the court or permitted in writing by the Designating Party, a

20 Receiving Party may disclose any information or item designated

21 “CONFIDENTIAL” only to:

22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as

23 well as employees of said Outside Counsel of Record to whom it is reasonably

24 necessary to disclose the information for this litigation and who have signed the

25 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

26 A;

27

1 (b) the officers, directors, and employees (including House Counsel) of

2 the Receiving Party to whom disclosure is reasonably necessary for this Action and

3 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

4 (c) Experts (as defined in this Order) of the Receiving Party to whom

5 disclosure is reasonably necessary for this Action and who have signed the

6 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

7 (d) the court and its personnel;

8 (e) court reporters and their staff, professional jury or trial consultants,

9 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary

10 for this litigation and who have signed the “Acknowledgment and Agreement to Be

11 Bound” (Exhibit A);

12 (f) during their depositions, witnesses in the action to whom disclosure

13 is reasonably necessary and who have signed the “Acknowledgment and Agreement

14 to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or

15 ordered by the court. Pages of transcribed deposition testimony or exhibits to

16 depositions that reveal Protected Material must be separately bound by the court

17 reporter and may not be disclosed to anyone except as permitted under this

18 Stipulated Protective Order; and

19 (g) the author or recipient of a document containing the information or

20 a custodian or other person who otherwise possessed or knew the information.

21 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

22 IN OTHER LITIGATION

23 If a Party is served with a subpoena or a court order issued in other litigation

24 that compels disclosure of any information or items designated in this action as

25 “CONFIDENTIAL,” that Party must:

26 (a) promptly notify in writing the Designating Party. Such notification

27 shall include a copy of the subpoena or court order;

1 (b) promptly notify in writing the party who caused the subpoena or

2 order to issue in the other litigation that some or all of the material covered by the

3 subpoena or order is subject to this Protective Order. Such notification shall include

4 a copy of this Stipulated Protective Order; and

5 (c) cooperate with respect to all reasonable procedures sought to be

6 pursued by the Designating Party whose Protected Material may be affected.

7 If the Designating Party timely seeks a protective order, the Party served with

8 the subpoena or court order shall not produce any information designated in this

9 action as “CONFIDENTIAL” before a determination by the court from which the

10 subpoena or order issued, unless the Party has obtained the Designating Party’s

11 permission. The Designating Party shall bear the burden and expense of seeking

12 protection in that court of its confidential material – and nothing in these provisions

13 should be construed as authorizing or encouraging a Receiving Party in this action

14 to disobey a lawful directive from another court.

15 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

16 PRODUCED IN THIS LITIGATION

17 (a) The terms of this Order are applicable to information produced by a

18 Non-Party in this action and designated as “CONFIDENTIAL.” Such information

19 produced by Non-Parties in connection with this litigation is protected by the

20 remedies and relief provided by this Order. Nothing in these provisions should be

21 construed as prohibiting a Non-Party from seeking additional protections.

22 (b) In the event that a Party is required, by a valid discovery request, to

23 produce a Non-Party’s confidential information in its possession, except for FERPA

24 records, and the Party is subject to an agreement with the Non-Party not to produce

25 the Non-Party’s confidential information, then the Party shall:

26 (1) promptly notify in writing the Requesting Party and the Non-

27 Party that some or all of the information requested is subject to a confidentiality

1 (2) promptly provide the Non-Party with a copy of the Stipulated

2 Protective Order in this litigation, the relevant discovery request(s), and a

3 reasonably specific description of the information requested; and

4 (3) make the information requested available for inspection by

5 the Non-Party, if requested.

6 (c) If the Non-Party fails to object or seek a protective order from this

7 court within 14 days of receiving the notice and accompanying information, the

8 Receiving Party may produce the Non-Party’s confidential information responsive

9 to the discovery request. If the Non-Party timely seeks a protective order, the

10 Receiving Party shall not produce any information in its possession or control that is

11 subject to the confidentiality agreement with the Non-Party before a determination

12 by the court. Absent a court order to the contrary, the Non-Party shall bear the

13 burden and expense of seeking protection in this court of its Protected Material.

14 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

16 Protected Material to any person or in any circumstance not authorized under this

17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in

18 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

19 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

20 persons to whom unauthorized disclosures were made of all the terms of this Order,

21 and (d) request such person or persons to execute the “Acknowledgment and

22 Agreement to Be Bound” that is attached hereto as Exhibit A.

23 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

24 PROTECTED MATERIAL

25 When a Producing Party gives notice to Receiving Parties that certain

26 inadvertently produced material is subject to a claim of privilege or other protection,

27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

1 procedure may be established in an e-discovery order that provides for production

2 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

3 (e), insofar as the parties reach an agreement on the effect of disclosure of a

4 communication or information covered by the attorney-client privilege or work

5 product protection, the parties may incorporate their agreement in the stipulated

6 protective order submitted to the court.

7 13. MISCELLANEOUS

8 13.1 Right to Further Relief. Nothing in this Order abridges the right of any

9 person to seek its modification by the court in the future.

10 13.2 Right to Assert Other Objections. By stipulating to the entry of this

11 Protective Order no Party waives any right it otherwise would have to object to

12 disclosing or producing any information or item on any ground not addressed in this

13 Stipulated Protective Order. Similarly, no Party waives any right to object on any

14 ground to use in evidence of any of the material covered by this Protective Order,

15 nor any right to contest any Party’s right to contest that FERPA Records can or shall

16 be produced on any basis other than the written consent of the subject individuals or

17 pursuant to a court order or subpoena.

18 13.3 Filing Protected Material. A Party may file or refer to Protected

19 Material in filings with the Court, to the extent that it is pertinent to the filing,

20 without obtaining prior consent from the Designating Party or engaging in a meet-

21 and-confer process, and without filing such material under seal solely because it has

22 been designated “CONFIDENTIAL.” Pursuant to Civil Local Rule 79-5, a sealing

23 order will issue only upon a request establishing that the Protected Material at issue

24 is privileged, protectable as a trade secret, or otherwise entitled to protection under

25 the law. If a Receiving Party’s request to file Protected Material under seal pursuant

26 to Civil Local Rule 79-5 is denied by the court, then the Receiving Party may file

27 the information in the public record pursuant to Civil Local Rule 79-5 unless

1 of its obligations under applicable rules governing the protection of personal

2 identifying information (e.g., social security numbers, financial account numbers, or

3 other sensitive personal data).

4 13.4 FINAL DISPOSITION

5 Within 60 days after the final disposition of this action, as defined in

6 paragraph 6, each Receiving Party must return all Protected Material to the

7 Producing Party or destroy such material. As used in this subdivision, “all Protected

8 Material” includes all copies, abstracts, compilations, summaries, and any other

9 format reproducing or capturing any of the Protected Material. Whether the

10 Protected Material is returned or destroyed, the Receiving Party must submit a

11 written certification to the Producing Party (and, if not the same person or entity, to

12 the Designating Party) by the 60 day deadline that (1) identifies (by category, where

13 appropriate) all the Protected Material that was returned or destroyed and (2) affirms

14 that the Receiving Party has not retained any copies, abstracts, compilations,

15 summaries or any other format reproducing or capturing any of the Protected

16 Material. Notwithstanding this provision, Counsel are entitled to retain an archival

17 copy of all pleadings, motion papers and exhibits, trial, deposition, and hearing

18 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

19 reports, attorney work product, and consultant and expert work product, even if such

20 materials contain Protected Material. Any such archival copies that contain or

21 constitute Protected Material remain subject to this Protective Order as set forth in

22 Section 6 (DURATION).

23 ///

24 ///

25 ///

26 ///

27 ///

1}}14. VIOLATION

2 Any violation of this Order may be punished by appropriate measures

3 || including, without limitation, contempt proceedings and/or monetary sanctions.

4|/IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

5

DATED: May 15, 2026 MUNGER, TOLLES & OLSON LLP

7

8

9 By: /s/ Bryan H. Heckenlively

BRYAN H. HECKENLIVELY

10 Attorneys for Defendants

11

DATED: May 15, 2026

13

14

15 By: /s/ Matthew Mainen

MATTHEW MAINEN

16 Attorneys for Plaintiffs

17

18 || PURSUANT TO STIPULATION, IT IS SO ORDERED.

19

20 || DATED: May 20, 2026

21 }

22

Honorable Douglas F. McCormick

23 United States Magistrate Judge

24

25

26

27

28

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I hereby acknowledge that I, ___________________________________________ [NAME],

4

______________________________________________ [POSITION AND EMPLOYER], declare

5

under penalty of perjury that I have read in its entirety and understand the Stipulated Protective

6

Order that was issued by the United States District Court for the Central District of California in the

7

case of Schechter and Malka v. Chapman University, et al., No. 8:25-cv-2426. I agree to comply

8

with and to be bound by all the terms of this Stipulated Protective Order and I understand and

9

acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of

10

contempt. I solemnly promise that I will not disclose in any manner any information or item that is

11

subject to this Stipulated Protective Order to any person or entity except in strict compliance with the

12

provisions of this Order.

13

I further agree to submit to the jurisdiction of the United States District Court for the Central

14

District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even

15

if such enforcement proceedings occur after termination of this action.

16

I hereby appoint __________________________ [print or type full name] of

17

_______________________________________ [print or type full address and telephone number] as

18

my California agent for service of process in connection with this action or any proceedings related

19

to enforcement of this Stipulated Protective Order.

20

21

Date: ______________________________________

22

City and State where sworn and signed: _________________________________

23

24

Printed name: _______________________________

25

26

27

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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