The opinion
1 YOUNG W. RYU, ESQ. (SBN 266372)
young.ryu@loywr.com
2 ZACHARIAH E. MOURA, ESQ. (SBN 279508)
zach.moura@loywr.com
3 KEE S. MAH, ESQ. (SBN 345736)
kee.mah@loywr.com
4 HARLEY M. PHLEGER, ESQ. (SBN 351851)
harley.phleger@loywr.com
5 GUANCHEN LIU, ESQ. (SBN 359768)
guanchen.liu@loywr.com
6 LOYR,APC
1055 Wilshire Blvd., Suite 1460,
7 Los Angeles, CA90017
Telephone: 213-318-5323
8 Facsimile: 800-576-1170
9 Attorneys for Plaintiff
JEFFREY S. RUDOLPH
10
11 JASON E. MURTAGH (SBN 294830)
jason.murtagh@bipc.com
12 MARY R. HACKETT (SBN 326482)
mary.hackett@bipc.com
13 BUCHANAN INGERSOLL & ROONEY LLP
One America Plaza
14 600 W. Broadway, Suite 1100
San Diego, CA 92101
15 Telephone: 619-239-8700
Fax: 619-702-3898
16
Attorneys for Defendant
17 MARRIOTT HOTEL SERVICES, LLC
18
UNITED STATES DISTRICT COURT
19
CENTRAL DISTRICT OF CALIFORNIA
20
21 JEFFREY S. RUDOLPH, an individual, Case No.: 5:26-cv-02608-CV-SPx
22 Plaintiff,
23 vs. STIPULATED PROTECTIVE
ORDER
24 MARRIOTT HOTEL SERVICES, LLC,
et al.
25
Defendants.
26
27
28
1 1. INTRODUCTION
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 production of confidential, proprietary, or private information for which special
4 protection from public disclosure and from use for any purpose other than prosecuting
5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and
6 petition the court to enter the following Stipulated Protective Order. The parties
7 acknowledge that this Order does not confer blanket protections on all disclosures or
8 responses to discovery and that the protection it affords from public disclosure and use
9 extends only to the limited information or items that are entitled to confidential
10 treatment under the applicable legal principles.
11 1.2 Good Cause Statement.
12 This action is likely to involve trade secrets and other valuable research,
13 development, commercial, financial, technical and/or proprietary information for
14 which special protection from public disclosure and from use for any purpose other
15 than prosecution of this action is warranted. Such confidential and proprietary
16 materials and information consist of, among other things, confidential business or
17 financial information, information regarding confidential business practices, or other
18 confidential research, development, or commercial information (including information
19 implicating privacy rights of third parties), information otherwise generally unavailable
20 to the public, or which may be privileged or otherwise protected from disclosure under
21 state or federal statutes, court rules, case decisions, or common law. Accordingly, to
22 expedite the flow of information, to facilitate the prompt resolution of disputes over
23 confidentiality of discovery materials, to adequately protect information the parties are
24 entitled to keep confidential, to ensure that the parties are permitted reasonable
25 necessary uses of such material in preparation for and in the conduct of trial, to address
26 their handling at the end of the litigation, and serve the ends of justice, a protective
27 order for such information is justified in this matter. It is the intent of the parties that
28 information will not be designated as confidential for tactical reasons and that nothing
1 be so designated without a good faith belief that it has been maintained in a
2 confidential, non-public manner, and there is good cause why it should not be part of
3 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 13.3, 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
8 a 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—
19 without the submission of competent evidence by declaration, establishing that the
20 material 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
28 articulate compelling reasons, supported by specific facts and legal justification, for the
1 requested sealing order. Again, competent evidence supporting the application to file
2 documents 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
6 the 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 2. DEFINITIONS
10 2.1 Action: The case of JEFFREY S. RUDOLPH v. MARRIOTT HOTEL
11 SERVICES, LLC, et al., Case No. 5:26-cv-02608-CV-SP, United States District Court
12 for the Central District of California.
13 2.2 Challenging Party: a Party or Non-Party that challenges the designation
14 of 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 In-House Counsel (as referenced
20 in 2.9) as well as their 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
23 “CONFIDENTIAL.”
24 2.6 Disclosure or Discovery Material: all items or information, regardless of
25 the medium or manner in which it is generated, stored, or maintained (including, among
26 other things, testimony, transcripts, and tangible things), that are produced or generated
27 in disclosures or responses to discovery in this matter.
28 2.7 Expert: a person with specialized knowledge or experience in a matter
1 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
2 expert witness or as a consultant in this Action.
3 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in
4 this Action, with or without prejudice; and (2) final judgment herein after the
5 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this
6 Action, including the time limits for filing any motions or applications for extension of
7 time pursuant to applicable law.
8 2.9 In-House Counsel: attorneys who are employees of a party to this Action.
9 In-House Counsel does not include Outside Counsel of Record or any other outside
10 counsel.
11 2.10 Non-Party: any natural person, partnership, corporation, association, or
12 other legal entity not named as a Party to this action.
13 2.11 Outside Counsel of Record: attorneys who are not employees of a party to
14 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, and includes support staff.
17 2.12 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 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
21 Discovery Material in this Action.
22 2.14 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) and
25 their employees and subcontractors.
26 2.15 Protected Material: any Disclosure or Discovery Material that is
27 designated as “CONFIDENTIAL.”
28 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
1 from a Producing Party.
2 3. SCOPE
3 The protections conferred by this Stipulation and Order cover not only Protected
4 Material (as defined above), but also (1) any information copied or extracted from
5 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
6 Material; and (3) any testimony, conversations, or presentations by Parties or their
7 Counsel that might reveal Protected Material.
8 Any use of Protected Material at trial shall be governed by the orders of the trial
9 judge. This Stipulated Protective Order does not govern the use of Protected Material
10 at trial.
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 confidential or
15 maintained pursuant to this stipulated protective order and used or introduced as an
16 exhibit at trial becomes public and will be presumptively available to all members of
17 the public, including the press, unless compelling reasons supported by specific factual
18 findings to proceed otherwise are made to the trial judge in advance of the trial. See
19 Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing for sealing
20 documents produced in discovery from “compelling reasons” standard when merits-
21 related documents are part of court record). Accordingly, for such materials, the terms
22 of this stipulated protective order do not extend beyond the commencement of the trial.
23 Even after Final Disposition of this litigation, 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 5. DESIGNATING PROTECTED MATERIAL
27 5.1 Exercise of Restraint and Care in Designating Material for Protection.
28 Each Party or Non-Party that designates information or items for protection under this
1 Order must take care to limit any such designation to specific material that qualifies
2 under the appropriate standards. The Designating Party must designate for protection
3 only those parts of material, documents, items, or oral or written communications that
4 qualify so that other portions of the material, documents, items, or communications
5 for which protection is not warranted are not swept unjustifiably within the ambit of
6 this Order.
7 Mass, indiscriminate, or routinized designations are prohibited. Designations
8 that are shown to be clearly unjustified or that have been made for an improper purpose
9 (e.g., to unnecessarily encumber the case development process or to impose
10 unnecessary expenses and burdens on other parties) may expose the Designating Party
11 to sanctions.
12 If it comes to a Designating Party’s attention that information or items that it
13 designated for protection do not qualify for protection, that Designating Party must
14 promptly notify all other Parties that it is withdrawing the inapplicable designation.
15 5.2 Manner and Timing of Designations. Except as otherwise provided in this
16 Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), or as
17 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for
18 protection under this Stipulated Protective Order must be clearly so designated before
19 the material is disclosed or produced.
20 Designation in conformity with this Stipulated Protective Order requires:
21 (a) for information in documentary form (e.g., paper or electronic documents,
22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” to each page that
24 contains protected material. If only a portion or portions of the material on a page
25 qualifies for protection, the Producing Party also must clearly identify the protected
26 portion(s) (e.g., by making appropriate markings in the margins).
27 A Party or Non-Party that makes original documents available for inspection
28 need not designate them for protection until after the inspecting Party has indicated
1 which documents it would like copied and produced. During the inspection and before
2 the designation, all of the material made available for inspection shall be deemed
3 CONFIDENTIAL. After the inspecting Party has identified the documents it wants
4 copied and produced, the Producing Party must determine which documents, or
5 portions thereof, qualify for protection under this Stipulated Protective Order. Then,
6 before producing the specified documents, the Producing Party must affix the
7 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a
8 portion or portions of the material on a page qualifies for protection, the Producing
9 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
10 markings in the margins).
11 (b) for testimony given in depositions that the Designating Party identify the
12 Disclosure or Discovery Material on the record, before the close of the deposition all
13 protected testimony.
14 (c) for information produced in some form other than documentary and for
15 any other tangible items, that the Producing Party affix in a prominent place on the
16 exterior of the container or containers in which the information is stored the
17 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants
18 protection, the Producing Party, to the extent practicable, shall identify the protected
19 portion(s).
20 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
21 failure to designate qualified information or items does not, standing alone, waive the
22 Designating Party’s right to secure protection under this Order for such material. Upon
23 timely correction of a designation, the Receiving Party must make reasonable efforts
24 to assure that the material is treated in accordance with the provisions of this Stipulated
25 Protective Order.
26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
27 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
28 designation of confidentiality at any time that is consistent with the court’s Scheduling
1 Order.
2 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
3 resolution process under Local Rule 37.1 et seq.
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
7 the Challenging Party to sanctions. Unless the Designating Party has waived or
8 withdrawn the confidentiality designation, all parties shall continue to afford the
9 material in question the level of protection to which it is entitled under the Producing
10 Party’s designation until the court rules on the challenge.
11 7. ACCESS TO AND USE OF PROTECTED MATERIAL
12 7.1 Basic Principles. A Receiving Party may use Protected Material that is
13 disclosed or produced by another Party or by a Non-Party in connection with this
14 Action only for prosecuting, defending, or attempting to settle this Action. Such
15 Protected Material may be disclosed only to the categories of persons and under the
16 conditions described in this Order. When the Action reaches a Final Disposition, a
17 Receiving Party must comply with the provisions of section 13 below.
18 Protected Material must be stored and maintained by a Receiving Party at a
19 location and in a secure manner that ensures that access is limited to the persons
20 authorized under this Stipulated Protective Order.
21 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
22 otherwise ordered by the court or permitted in writing by the Designating Party, a
23 Receiving Party may disclose any information or item designated “CONFIDENTIAL”
24 only:
25 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as well
26 as employees of said Outside Counsel of Record to whom it is reasonably necessary to
27 disclose the information for this Action;
28 (b) to the officers, directors, and employees (including House Counsel) of the
1 Receiving Party to whom disclosure is reasonably necessary for this Action;
2 (c) to Experts (as defined in this Order) of the Receiving Party to whom
3 disclosure is reasonably necessary for this Action and who have signed the
4 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
5 (d) to the court and its personnel;
6 (e) to court reporters and their staff;
7 (f) to professional jury or trial consultants, mock jurors, and Professional
8 Vendors to whom disclosure is reasonably necessary for this Action and who have
9 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
10 (g) to the author or recipient of a document containing the information or a
11 custodian or other person who otherwise possessed or knew the information;
12 (h) during their depositions, to witnesses, and attorneys for witnesses, in the
13 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party
14 requests that the witness sign the “Acknowledgment and Agreement to Be Bound”
15 (Exhibit A); and (2) the witness will not be permitted to keep any confidential
16 information unless they sign the “Acknowledgment and Agreement to Be Bound”
17 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court.
18 Pages of transcribed deposition testimony or exhibits to depositions that reveal
19 Protected Material may be separately bound by the court reporter and may not be
20 disclosed to anyone except as permitted under this Stipulated Protective Order; and
21 (i) to any mediator or settlement officer, and their supporting personnel,
22 mutually agreed upon by any of the parties engaged in settlement discussions.
23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
24 PRODUCED IN OTHER LITIGATION
25 If a Party is served with a subpoena or a court order issued in other litigation that
26 compels disclosure of any information or items designated in this Action as
27 “CONFIDENTIAL,” that Party must:
28 (a) promptly notify in writing the Designating Party. Such notification shall
1 include a copy of the subpoena or court order;
2 (b) promptly notify in writing the party who caused the subpoena or order to
3 issue in the other litigation that some or all of the material covered by the subpoena or
4 order is subject to this Protective Order. Such notification shall include a copy of this
5 Stipulated Protective Order; and
6 (c) cooperate with respect to all reasonable procedures sought to be pursued
7 by the Designating Party whose Protected Material may be affected.
8 If the Designating Party timely seeks a protective order, the Party served with
9 the subpoena or court order shall not produce any information designated in this action
10 as “CONFIDENTIAL” before a determination by the court from which the subpoena
11 or order issued, unless the Party has obtained the Designating Party’s permission. The
12 Designating Party shall bear the burden and expense of seeking protection in that court
13 of its confidential material and nothing in these provisions should be construed as
14 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
15 directive from another court.
16 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
17 PRODUCED IN THIS LITIGATION
18 9.1 Application. The terms of this Stipulated Protective Order are applicable
19 to information produced by a Non-Party in this Action and designated as
20 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with
21 this litigation is protected by the remedies and relief provided by this Order. Nothing
22 in these provisions should be construed as prohibiting a Non-Party from seeking
23 additional protections.
24 9.2 Notification. In the event that a Party is required, by a valid discovery
25 request, to produce a Non-Party’s confidential information in its possession, and the
26 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s
27 confidential information, then the Party shall:
28 (a) promptly notify in writing the Requesting Party and the Non-Party that
1 some or all of the information requested is subject to a confidentiality agreement with
2 a Non-Party;
3 (b) make the information requested available for inspection by the Non-Party,
4 if requested.
5 9.3 Conditions of Production. If the Non-Party fails to seek a protective order
6 from this court within 14 days of receiving the notice and accompanying information,
7 the Receiving Party may produce the Non-Party’s confidential information responsive
8 to the discovery request. If the Non-Party timely seeks a protective order, the
9 Receiving Party shall not produce any information in its possession or control that is
10 subject to the confidentiality agreement with the Non-Party before a determination by
11 the court. Absent a court order to the contrary, the Non-Party shall bear the burden and
12 expense of seeking protection in this court of its Protected Material.
13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
15 Protected Material to any person or in any circumstance not authorized under this
16 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
17 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
18 all unauthorized copies of the Protected Material, (c) inform the person or persons to
19 whom unauthorized disclosures were made of all the terms of this Order, and (d)
20 request such person or persons to execute the “Acknowledgment and Agreement to Be
21 Bound” (Exhibit A).
22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
23 PROTECTED MATERIAL
24 When a Producing Party gives notice to Receiving Parties that certain
25 inadvertently produced material is subject to a claim of privilege or other protection,
26 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the
27 Federal Rules of Civil Procedure. This provision is not intended to modify whatever
28 procedure may be established in an e-discovery order that provides for production
1 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules
2 of Evidence, insofar as the parties reach an agreement on the effect of disclosure of a
3 communication or information covered by the attorney-client privilege or work product
4 protection, the parties may incorporate their agreement in the stipulated protective
5 order submitted to the court.
6 12. CLAWBACK PROVISIONS
7 The production of privileged or work-product protected documents,
8 electronically stored information (ESI) or information, whether inadvertent or
9 otherwise, is not a waiver of the privilege or protection from discovery in this case or
10 in any other federal or state proceeding.
11 This Order shall be interpreted to provide the maximum protection allowed by
12 Federal Rule of Evidence (FRE) 502(d) and shall be enforceable and granted full faith
13 and credit in all other state and federal proceedings by 28 U.S. Code § 1738.
14 Nothing contained herein is intended to or shall serve to limit a party’s right to
15 conduct a review of documents, ESI or information (including metadata) for relevance,
16 responsiveness and/or segregation of privileged and/or protected information before
17 production.
18 Where it is reasonably apparent to a receiving party that a produced document
19 or writing was inadvertently sent or produced, and the receiving party knows or
20 reasonably should know that the produced document or writing is privileged or subject
21 to the work product doctrine, then the receiving party shall refrain from examining the
22 writing any more than is necessary to determine that it is privileged or subject to the
23 work product doctrine, and promptly notify the producing party of the beginning
24 BATES number of the document or, if no BATES number is available, shall otherwise
25 inform the producing party of the information.
26 A producing party must give written notice to any receiving party asserting a
27 claim of privilege, work-product protection, or other ground for reclaiming documents
28 or information (a “clawback request”). After a clawback request is received, the
1 receiving party shall immediately sequester the document (if not already sequestered)
2 and shall not review or use that document, or any work product containing information
3 taken from that document, for any purpose. The parties shall meet and confer regarding
4 any clawback request.
5 13. MISCELLANEOUS
6 13.1 Right to Further Relief. Nothing in this Stipulated Protective Order
7 abridges the right of any person to seek its modification by the court in the future.
8 13.2 Right to Assert Other Objections. By stipulating to the entry of this
9 Stipulated Protective Order no Party waives any right it otherwise would have to object
10 to disclosing or producing any information or item on any ground not addressed in this
11 Stipulated Protective Order. Similarly, no Party waives any right to object on any
12 ground to use in evidence of any of the material covered by this Stipulated Protective
13 Order.
14 13.3 Filing Protected Material. A Party that seeks to file under seal any
15 Protected Material must comply with Local Rule 79-5. Protected Material may only be
16 filed under seal pursuant to a court order authorizing the sealing of the specific
17 Protected Material at issue. If a Party's request to file Protected Material under seal is
18 denied by the court, then the Receiving Party may file the information in the public
19 record unless otherwise instructed by the court.
20 14. FINAL DISPOSITION
21 After the Final Disposition of this Action, as defined in paragraph 4, within 60
22 days of a written request by the Designating Party, each Receiving Party must return
23 all Protected Material to the Producing Party or destroy such material. As used in this
24 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
25 summaries, and any other format reproducing or capturing any of the Protected
26 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
27 must submit a written certification to the Producing Party (and, if not the same person
28 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
1 category, where appropriate) all the Protected Material that was returned or destroyed
2 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
3 compilations, summaries or any other format reproducing or capturing any of the
4 Protected Material. Notwithstanding this provision, Counsel is entitled to retain an
5 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
6 legal memoranda, correspondence, deposition and trial exhibits, expert reports,
7 attorney work product, and consultant and expert work product, even if such materials
8 contain Protected Material. Any such archival copies that contain or constitute
9 Protected Material remain subject to this Protective Order as set forth in Section 4.
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1/15. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished by any and
3 all appropriate measures including, without limitation, contempt proceedings and/or
4 ||monetary sanctions.
5
6 | IT ISSO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8 || DATED: July 6, 2026 LOYR, APC
9
10
By: /s/ Guanchen Liu
11 YOUNG W. RYU
ZACHARIAH E. MOURA
12 KEE S. MAH
HARLEY M. PHLEGER
13 GUANCHEN LIU
Attorney for Plaintiff
14 JEFFREY S. RUDOLPH
15
16 || DATED: July 6, 2026 BUCHANAN INGERSOLL & ROONEY LLP
17
18 By: /s/Jason E. Murtagh
JASON E. MURTAGH
19 MARY R. HACKETT
Attomeys for Defendant
20 MARRIOTT HOTEL SERVICES, LLC
21
22 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
23
24 || DATED: July 30, 2026
HON. SHERI PYM
25 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
6 that I have read in its entirety and understand the Stipulated Protective Order that was
7 issued by the United States District Court for the Central District of California in the
8 case of Jeffrey S. Rudolph v. Marriott Hotel Services, LLC, et al.., Case No. 5:26-cv-
9 02608-CV-SP. I agree to comply with and to be bound by all the terms of this Stipulated
10 Protective Order and I understand and acknowledge that failure to so comply could
11 expose me to sanctions and punishment in the nature of contempt. I solemnly promise
12 that I will not disclose in any manner any information or item that is subject to this
13 Stipulated Protective Order to any person or entity except in strict compliance with the
14 provisions of this Orde I further agree to submit to the jurisdiction of the United
15 States District Court for the Central District of California for the purpose of enforcing
16 the terms of this Stipulated Protective Order, even if such enforcement proceedings
17 occur after termination of this action. I hereby appoint ________________________
18 [print or type full name] of _________ [print or type full address and telephone
19 number] as my California agent for service of process in connection with this action
20 or any proceedings related to enforcement of this Stipulated Protective Order.
21 Date: ___________________________
22 City and State where sworn and signed:
23 ___________________________
24 Printed name: ___________________________
25 Signature: ___________________________
26
27
28