# Opinion

> District Court, C.D. California · June 25, 2026

URL: https://www.frixlaw.com/law-library/cases/11384001

## Case

- **Full name:** Amber Medina v. DIRECTV, LLC; Credence Resource Management, LLC; and I.C. System, Inc.
- **Court:** District Court, C.D. California
- **Decided:** June 25, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/11384001

## Opinion text

1
UNITED STATES DISTRICT COURT
2
CENTRAL DISTRICT OF CALIFORNIA
3

4 AMBER MEDINA,
Case No.: 2:26-cv-01338-FLA-SSC
5 Plaintiff,

6 v.
STIPULATED PROTECTIVE

7 DIRECTV, LLC; CREDENCE ORDER1
RESOURCE MANAGEMENT,
8 LLC; AND I.C. SYSTEM, INC.,

9 Defendants.

10

11 1. INTRODUCTION
12 1.1 Purposes and Limitations. Discovery in this action is likely to
13
involve production of confidential, proprietary, or private information for
14
which special protection from public disclosure and from use for any
15
purpose other than prosecuting this litigation may be warranted.
16
Accordingly, the parties hereby stipulate to and petition the court to enter
17
the following Stipulated Protective Order. The parties acknowledge that
18
this Order does not confer blanket protections on all disclosures or
19
responses to discovery and that the protection it affords from public
20
disclosure and use extends only to the limited information or items that
21
are entitled to confidential treatment under the applicable legal principles.
22
1.2 Good Cause Statement.
23
This action is likely to involve private, confidential, proprietary,
24
25
26
27
1 This Stipulated Protective Order is substantially based on the model
protective order provided under Magistrate Judge Stephanie S.
1 and/or commercially-sensitive information for which special protection
2 from public disclosure and from use for any purpose other than prosecution
3 of this action is warranted. Such confidential and proprietary materials
4 and information consist of, among other things, private financial, credit,
5 and personal identifying information, as well as confidential business,
6 financial, and/or contractual information, information regarding
7 confidential business practices, or other confidential research,
8
development, or commercial information (including information
9
implicating privacy rights of third parties), information otherwise
10
generally unavailable to the public, or which may be privileged or
11
otherwise protected from disclosure under state or federal statutes, court
12
rules, case decisions, or common law. Accordingly, to expedite the flow of
13
information, to facilitate the prompt resolution of disputes over
14
confidentiality of discovery materials, to adequately protect information
15
the parties are entitled to keep confidential, to ensure that the parties are
16
permitted reasonable necessary uses of such material in preparation for
17
and in the conduct of trial, to address their handling at the end of the
18
litigation, and serve the ends of justice, a protective order for such
19
information is justified in this matter. It is the intent of the parties that
20
information will not be designated as confidential for tactical reasons and
21
22 that nothing be so designated without a good faith belief that it has been
23 maintained in a confidential, non-public manner, and there is good cause
24 why it should not be part of the public record of this case.
25 1.3 Acknowledgment of Procedure for Filing Under Seal. The
26 parties further acknowledge, as set forth in Section 12.3, below, that this
27 Stipulated Protective Order does not entitle them to file confidential
1 must be followed and the standards that will be applied when a party
2 seeks permission from the court to file material under seal.
3 There is a strong presumption that the public has a right of access to
4 judicial proceedings and records in civil cases. In connection with non-
5 dispositive motions, good cause must be shown to support a filing under
6 seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176
7 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 F.3d
8
1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., Inc., 187
9
F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
10
good cause showing), and a specific showing of good cause or compelling
11
reasons with proper evidentiary support and legal justification, must be
12
made with respect to Protected Material that a party seeks to file under
13
seal. The parties’ mere designation of Disclosure or Discovery Material as
14
CONFIDENTIAL does not—without the submission of competent
15
evidence by declaration, establishing that the material sought to be filed
16
under seal qualifies as confidential, privileged, or otherwise protectable—
17
constitute good cause.
18
Further, if a party requests sealing related to a dispositive motion or
19
trial, then compelling reasons, not only good cause, for the sealing must be
20
shown, and the relief sought shall be narrowly tailored to serve the
21
22 specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 605
23 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of information,
24 document, or thing sought to be filed or introduced under seal in
25 connection with a dispositive motion or trial, the party seeking protection
26 must articulate compelling reasons, supported by specific facts and legal
27 justification, for the requested sealing order. Again, competent evidence
1 by declaration.
2 Any document that is not confidential, privileged, or otherwise
3 protectable in its entirety will not be filed under seal if the confidential
4 portions can be redacted. If documents can be redacted, then a redacted
5 version for public viewing, omitting only the confidential, privileged, or
6 otherwise protectable portions of the document, shall be filed. Any
7 application that seeks to file documents under seal in their entirety
8
should include an explanation of why redaction is not feasible.
9

10
2. DEFINITIONS
11
2.1 Action: This pending federal lawsuit.
12
2.2 Challenging Party: a Party or Non-Party that challenges the
13
designation of information or items under this Order.
14
2.3 “CONFIDENTIAL” Information or Items: information
15
(regardless of how it is generated, stored or maintained) or tangible things
16
that qualify for protection under Rule 26(c) of the Federal Rules of Civil
17
18 Procedure, and as specified above in the Good Cause Statement.
19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well
20 as their support staff).
21 2.5 Designating Party: a Party or Non-Party that designates
22 information or items that it produces in disclosures or in responses to
23 discovery as “CONFIDENTIAL.”
24 2.6 Disclosure or Discovery Material: all items or information,
25 regardless of the medium or manner in which it is generated, stored, or
26 maintained (including, among other things, testimony, transcripts, and
27
tangible things), that are produced or generated in disclosures or responses
1 to discovery in this matter.
2 2.7 Expert: a person with specialized knowledge or experience in a
3 matter pertinent to the litigation who has been retained by a Party or its
4 counsel to serve as an expert witness or as a consultant in this Action.
5 2.8 Final Disposition: the later of (1) dismissal of all claims and
6 defenses in this Action, with or without prejudice; and (2) final judgment
7 herein after the completion and exhaustion of all appeals, rehearings,
8
remands, trials, or reviews of this Action, including the time limits for
9
filing any motions or applications for extension of time pursuant to
10
applicable law.
11
2.9 In-House Counsel: attorneys who are employees of a party to
12
this Action. In-House Counsel does not include Outside Counsel of Record
13
or any other outside counsel.
14
2.10 Non-Party: any natural person, partnership, corporation,
15
association, or other legal entity not named as a Party to this action.
16
2.11 Outside Counsel of Record: attorneys who are not employees of
17
a party to this Action but are retained to represent or advise a party to this
18
Action and have appeared in this Action on behalf of that party or are
19
affiliated with a law firm which has appeared on behalf of that party, and
20
includes support staff.
21
22 2.12 Party: any party to this Action, including all of its officers,
23 directors, employees, consultants, retained experts, and Outside Counsel of
24 Record (and their support staffs).
25 2.13 Producing Party: a Party or Non-Party that produces Disclosure
26 or Discovery Material in this Action.
27 2.14 Professional Vendors: persons or entities that provide litigation-
1 exhibits or demonstrations, and organizing, storing, or retrieving data in
2 any form or medium) and their employees and subcontractors.
3 2.15 Protected Material: any Disclosure or Discovery Material that is
4 designated as “CONFIDENTIAL.”
5 2.16 Receiving Party: a Party that receives Disclosure or Discovery
6 Material from a Producing Party.
7
8
3. SCOPE
9
The protections conferred by this Stipulation and Order cover not
10
only Protected Material (as defined above), but also (1) any information
11
copied or extracted from Protected Material; (2) all copies, excerpts,
12
summaries, or compilations of Protected Material; and (3) any testimony,
13
conversations, or presentations by Parties or their Counsel that might
14
reveal Protected Material.
15
Any use of Protected Material at trial shall be governed by the
16
orders of the trial judge. This Stipulated Protective Order does not govern
17
18 the use of Protected Material at trial.
19
20 4. TRIAL AND DURATION
21 The terms of this Stipulated Protective Order apply through Final
22 Disposition of the Action.
23
Once a case proceeds to trial, information that was designated as
24
CONFIDENTIAL or maintained pursuant to this Stipulated Protective
25
Order and used or introduced as an exhibit at trial becomes public and
26
will be presumptively available to all members of the public, including the
27
1 proceed otherwise are made to the trial judge in advance of the trial. See
2 Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing for
3 sealing documents produced in discovery from “compelling reasons”
4 standard when merits-related documents are part of court record).
5 Accordingly, for such materials, the terms of this Stipulated Protective
6 Order do not extend beyond the commencement of the trial.
7 Even after Final Disposition of this litigation, the confidentiality
8
obligations imposed by this Stipulated Protective Order shall remain in
9
effect until a Designating Party agrees otherwise in writing or a court
10
order otherwise directs.
11

12
5. DESIGNATING PROTECTED MATERIAL
13
5.1 Exercise of Restraint and Care in Designating Material for
14
Protection. Each Party or Non-Party that designates information or items
15
for protection under this Order must take care to limit any such
16
designation to specific material that qualifies under the appropriate
17
18 standards. The Designating Party must designate for protection only those
19 parts of material, documents, items, or oral or written communications
20 that qualify so that other portions of the material, documents, items, or
21 communications for which protection is not warranted are not swept
22 unjustifiably within the ambit of this Order.
23 Mass, indiscriminate, or routinized designations are prohibited.
24 Designations that are shown to be clearly unjustified or that have been
25 made for an improper purpose (e.g., to unnecessarily encumber the case
26 development process or to impose unnecessary expenses and burdens on
27
other parties) may expose the Designating Party to sanctions.
1 If it comes to a Designating Party’s attention that information or
2 items that it designated for protection do not qualify for protection, that
3 Designating Party must promptly notify all other Parties that it is
4 withdrawing the inapplicable designation.
5
5.2 Manner and Timing of Designations. Except as otherwise
6
provided in this Stipulated Protective Order (see, e.g., second paragraph of
7
section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or
8
Discovery Material that qualifies for protection under this Stipulated
9
Protective Order must be clearly so designated before the material is
10
disclosed or produced.
11
Designation in conformity with this Stipulated Protective Order
12
requires:
13
(a) for information in documentary form (e.g., paper or electronic
14
documents, but excluding transcripts of depositions or other pretrial or
15
trial proceedings), that the Producing Party affix at a minimum, the
16
17 legend “CONFIDENTIAL” to each page that contains protected material.
18 If only a portion or portions of the material on a page qualifies for
19 protection, the Producing Party also must clearly identify the protected
20 portion(s) (e.g., by making appropriate markings in the margins).
21 A Party or Non-Party that makes original documents available for
22 inspection need not designate them for protection until after the
23 inspecting Party has indicated which documents it would like copied and
24 produced. During the inspection and before the designation, all of the
25 material made available for inspection shall be deemed CONFIDENTIAL.
26
After the inspecting Party has identified the documents it wants copied
27
and produced, the Producing Party must determine which documents, or
1 portions thereof, qualify for protection under this Stipulated Protective
2 Order. Then, before producing the specified documents, the Producing
3 Party must affix the “CONFIDENTIAL” legend to each page that contains
4 Protected Material. If only a portion or portions of the material on a page
5 qualifies for protection, the Producing Party also must clearly identify the
6 protected portion(s) (e.g., by making appropriate markings in the
7 margins).
8
(b) for testimony given in depositions that the Designating Party
9
identify the Disclosure or Discovery Material either on the record, or
10
within 30 days of the Designating Party’s receipt of the certified transcript
11
of the deposition from the court reporter preparing the transcript.
12
(c) for information produced in some form other than documentary
13
and for any other tangible items, that the Producing Party affix in a
14
prominent place on the exterior of the container or containers in which the
15
information is stored the “CONFIDENTIAL” legend. If only a portion or
16
portions of the information warrants protection, the Producing Party, to
17
the extent practicable, shall identify the protected portion(s).
18
19 5.3 Inadvertent Failures to Designate. If timely corrected, an
20 inadvertent failure to designate qualified information or items does not,
21 standing alone, waive the Designating Party’s right to secure protection
22 under this Order for such material. Upon timely correction of a
23 designation, the Receiving Party must make reasonable efforts to assure
24 that the material is treated in accordance with the provisions of this
25 Stipulated Protective Order.
26
27
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
1 6.1 Timing of Challenges. Any Party or Non-Party may challenge
2 a designation of confidentiality at any time that is consistent with the
3 court’s Scheduling Order.
4 6.2 Meet and Confer. The Challenging Party shall initiate the
5 dispute resolution process under Local Rule 37.1 et seq. and with Section 2
6 of Judge Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion
7 Conference.”2
8
6.3 The burden of persuasion in any such challenge proceeding
9
shall be on the Designating Party. Frivolous challenges, and those made
10
for an improper purpose (e.g., to harass or impose unnecessary expenses
11
and burdens on other parties) may expose the Challenging Party to
12
sanctions. Unless the Designating Party has waived or withdrawn the
13
confidentiality designation, all parties shall continue to afford the
14
material in question the level of protection to which it is entitled under the
15
Producing Party’s designation until the court rules on the challenge.
16

17
7. ACCESS TO AND USE OF PROTECTED MATERIAL
18
19 7.1 Basic Principles. A Receiving Party may use Protected
20 Material that is disclosed or produced by another Party or by a Non-Party
21 in connection with this Action only for prosecuting, defending, or
22 attempting to settle this Action. Such Protected Material may be
23 disclosed only to the categories of persons and under the conditions
24 described in this Order. When the Action reaches a Final Disposition, a
25 Receiving Party must comply with the provisions of section 13 below.
26

27
2 Judge Christensen’s Procedures are available at
1 Protected Material must be stored and maintained by a Receiving
2 Party at a location and in a secure manner that ensures that access is
3 limited to the persons authorized under this Stipulated Protective Order.
4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
5 otherwise ordered by the court or permitted in writing by the Designating
6 Party, a Receiving Party may disclose any information or item designated
7 “CONFIDENTIAL” only:
8
(a) to the Receiving Party’s Outside Counsel of Record in this
9
Action, as well as employees of said Outside Counsel of Record to whom it
10
is reasonably necessary to disclose the information for this Action;
11
(b) to the officers, directors, and employees (including House
12
Counsel) of the Receiving Party to whom disclosure is reasonably
13
necessary for this Action;
14
(c) to Experts (as defined in this Order) of the Receiving Party to
15
whom disclosure is reasonably necessary for this Action and who have
16
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17
(d) to the court and its personnel;
18
(e) to court reporters and their staff;
19
(f) to professional jury or trial consultants, mock jurors, and
20
Professional Vendors to whom disclosure is reasonably necessary for this
21
22 Action and who have signed the “Acknowledgment and Agreement to Be
23 Bound” (Exhibit A);
24 (g) to the author or recipient of a document containing the
25 information or a custodian or other person who otherwise possessed or
26 knew the information;
27 (h) during their depositions, to witnesses, and attorneys for
1 provided: (1) the deposing party requests that the witness sign the
2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
3 witness will not be permitted to keep any confidential information unless
4 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
5 unless otherwise agreed by the Designating Party or ordered by the court.
6 Pages of transcribed deposition testimony or exhibits to depositions that
7 reveal Protected Material may be separately bound by the court reporter
8
and may not be disclosed to anyone except as permitted under this
9
Stipulated Protective Order; and
10
(i) to any mediator or settlement officer, and their supporting
11
personnel, mutually agreed upon by any of the parties engaged in
12
settlement discussions.
13

14
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
15
PRODUCED IN OTHER LITIGATION
16
If a Party is served with a subpoena or a court order issued in other
17
litigation that compels disclosure of any information or items designated
18
in this Action as “CONFIDENTIAL,” that Party must:
19
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
27
be pursued by the Designating Party whose Protected Material may be
1 affected.
2 If the Designating Party timely seeks a protective order, the Party
3 served with the subpoena or court order shall not produce any information
4 designated in this action as “CONFIDENTIAL” before a determination by
5 the court from which the subpoena or order issued, unless the Party has
6 obtained the Designating Party’s permission. The Designating Party shall
7 bear the burden and expense of seeking protection in that court of its
8
confidential material and nothing in these provisions should be construed
9
as authorizing or encouraging a Receiving Party in this Action to disobey a
10
lawful directive from another court.
11

12
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
13
PRODUCED IN THIS LITIGATION
14
9.1 Application. The terms of this Stipulated Protective Order are
15
applicable to information produced by a Non-Party in this Action and
16
designated as “CONFIDENTIAL.” Such information produced by Non-
17
Parties in connection with this litigation is protected by the remedies and
18
relief provided by this Order. Nothing in these provisions should be
19
construed as prohibiting a Non-Party from seeking additional protections.
20
21 9.2 Notification. In the event that a Party is required, by a valid
22 discovery request, to produce a Non-Party’s confidential information in its
23 possession, and the Party is subject to an agreement with the Non-Party
24 not to produce the Non-Party’s confidential information, then the Party
25 shall:
26 (a) promptly notify in writing the Requesting Party and the Non-
27 Party that some or all of the information requested is subject to a
1 (b) make the information requested available for inspection by the
2 Non-Party, if requested.
3 9.3 Conditions of Production. If the Non-Party fails to seek a
4 protective order from this court within 14 days of receiving the notice and
5 accompanying information, the Receiving Party may produce the Non-
6 Party’s confidential information responsive to the discovery request. If the
7 Non-Party timely seeks a protective order, the Receiving Party shall not
8
produce any information in its possession or control that is subject to the
9
confidentiality agreement with the Non-Party before a determination by
10
the court. Absent a court order to the contrary, the Non-Party shall bear
11
the burden and expense of seeking protection in this court of its Protected
12
Material.
13

14
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
15
If a Receiving Party learns that, by inadvertence or otherwise, it has
16
17 disclosed Protected Material to any person or in any circumstance not
18 authorized under this Stipulated Protective Order, the Receiving Party
19 must immediately (a) notify in writing the Designating Party of the
20 unauthorized disclosures, (b) use its best efforts to retrieve all
21 unauthorized copies of the Protected Material, (c) inform the person or
22 persons to whom unauthorized disclosures were made of all the terms of
23 this Order, and (d) request such person or persons to execute the
24 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
25
26
11. INADVERTENT PRODUCTION OF PRIVILEGED OR
27
OTHERWISE PROTECTED MATERIAL
1 When a Producing Party gives notice to Receiving Parties that
2 certain inadvertently produced material is subject to a claim of privilege
3 or other protection, the obligations of the Receiving Parties are those set
4 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
5 provision is not intended to modify whatever procedure may be
6 established in an e-discovery order that provides for production without
7 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
8
Rules of Evidence, insofar as the parties reach an agreement on the effect
9
of disclosure of a communication or information covered by the attorney-
10
client privilege or work product protection, the parties may incorporate
11
their agreement in the stipulated protective order submitted to the court.
12

13
12. MISCELLANEOUS
14
12.1 Right to Further Relief. Nothing in this Stipulated Protective
15
Order abridges the right of any person to seek its modification by the
16
17 court in the future.
18 12.2 Right to Assert Other Objections. By stipulating to the entry
19 of this Stipulated Protective Order no Party waives any right it otherwise
20 would have to object to disclosing or producing any information or item on
21 any ground not addressed in this Stipulated Protective Order. Similarly,
22 no Party waives any right to object on any ground to use in evidence of
23 any of the material covered by this Stipulated Protective Order.
24 12.3 Filing Protected Material. A Party that seeks to file under seal
25 any Protected Material must comply with Local Rule 79-5. Protected
26
Material may only be filed under seal pursuant to a court order
27
authorizing the sealing of the specific Protected Material at issue. If a
1 Party's request to file Protected Material under seal is denied by the
2 court, then the Receiving Party may file the information in the public
3 record unless otherwise instructed by the court.
4
5 13. FINAL DISPOSITION
6 Within 60 days of the Final Disposition of this Action, as defined in
7 paragraph 4, each Receiving Party must return all Protected Material to
8
the Producing Party or destroy such material. As used in this subdivision,
9
“all Protected Material” includes all copies, abstracts, compilations,
10
summaries, and any other format reproducing or capturing any of the
11
Protected Material. Whether the Protected Material is returned or
12
destroyed, the Receiving Party must submit a written certification to the
13
Producing Party (and, if not the same person or entity, to the Designating
14
Party) by the 60 day deadline that (1) identifies (by category, where
15
appropriate) all the Protected Material that was returned or destroyed
16
and (2) affirms that the Receiving Party has not retained any copies,
17
abstracts, compilations, summaries or any other format reproducing or
18
capturing any of the Protected Material. Notwithstanding this provision,
19
Counsel is entitled to retain an archival copy of all pleadings, motion
20
papers, trial, deposition, and hearing transcripts, legal memoranda,
21
22 correspondence, deposition and trial exhibits, expert reports, attorney
23 work product, and consultant and expert work product, even if such
24 materials contain Protected Material. Any such archival copies that
25 contain or constitute Protected Material remain subject to this Protective
26 Order as set forth in Section 4.
27 14. VIOLATION
1 by any and all appropriate measures including, without limitation,
2 contempt proceedings and/or monetary sanctions.
3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
4
Date: June 25, 2026 LOKER LAW, APC
5
6
BY: ___/S/ SHELBY J. RADECKI _
SHELBY J. RADECKI, ESQ.
7 ATTORNEY FOR PLAINTIFF
8
FAEGRE DRINKER BIDDLE & REATH LLP
9

10 By: _____/s/Kaylee A. Racs _
KAYLEE A. RACS, ESQ.
11
COUNSEL FOR DIRECTV, LLC
12
13
SESSIONS, ISRAEL AND SHARTLE, LLP

14 By: _____/s/ Kenneth Akira Ohashi _
15 KENNETH AKIRA OHASHI, ESQ.
COUNSEL FOR DEFENDANT
16
CREDENCE RESOURCE MANAGEMENT, LLC
17
YU MOHANDESI LLP
18

19 By: _____/s/ Brett B. Goodman _
20
BRETT B. GOODMAN, ESQ.
COUNSEL FOR DEFENDANT I.C. SYSTEM, INC.
21
22
SIGNATURE CERTIFICATION
23
Pursuant to Section 2(f)(44) of the Electronic Case Filing
24 Administrative Policies and Procedures Manual, I hereby certify that the
content of this document is acceptable to all defense counsel, and that I
25
have obtained their authorization to affix electronic signatures to this
26 document.

27
/s/ Kenneth Ohashi
1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2 LZ
3 DATED: June 25, 2026
4 STEPHANIE 8. CHRISTENSEN
5 United States Magistrate Judge
6
7
8
9
10
1]
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2

3
I, ________________________ [print or type full name], of
4
_________________ [print or type full address], declare under penalty
5
of perjury that I have read in its entirety and understand the Stipulated
6
Protective Order that was issued by the United States District Court for
7
the Central District of California on [date] in the case of __________
8
Amber Medina v. DirecTV, LLC, et al., United States District
9
Court for the Central District of California, Case No. 2:26-cv-
10
01338. I agree to comply with and to be bound by all the terms of this
11
Stipulated Protective Order and I understand and acknowledge that
12
failure to so comply could expose me to sanctions and punishment in the
13
14 nature of contempt. I solemnly promise that I will not disclose in any
15 manner any information or item that is subject to this Stipulated
16 Protective Order to any person or entity except in strict compliance with
17 the provisions of this Order.
18 I further agree to submit to the jurisdiction of the United States
19 District Court for the Central District of California for the purpose of
20 enforcing the terms of this Stipulated Protective Order, even if such
21 enforcement proceedings occur after termination of this action. I hereby
22 appoint ________________________ [print or type full name] of
23
_________ [print or type full address and telephone number] as
24
my California agent for service of process in connection with this action
25
or any proceedings related to enforcement of this Stipulated Protective
26
Order.
27
1 Date: ___________________________
2 City and State where sworn and
___________________________
3 signed:
4 Printed name: ___________________________
5 Signature: ___________________________
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11384001. Public record. Not legal advice.