even stipulated protective orders require 23 good cause showing
How later courts described this case
- even stipulated protective orders require 23 good cause showing
Written by the judges who cited it.
The opinion
Case 2:21-cv-06840-RGK-MAA Document 52 Filed 01/10/22 Page 1 of 21 Page ID #:301
Youssef H. Hammoud (SBN: 321934)
1
Lauren Tegan Rodkey (SBN: 275830)
2 PRICE LAW GROUP, APC
6345 Balboa Blvd., Suite 247
3 Encino, CA 91316
T: (818) 600-5596
4
F: (818) 600-5496
5 E: youssef@pricelawgroup.com
E: tegan@pricelawgroup.com
6
Attorneys for Plaintiff,
7 Keith Dorsey
8
UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 KEITH DORSEY, Case No.: 2:21-cv-06840-RGK-MAA
11
STIPULATED PROTECTIVE
Plaintiff,
12 ORDER
13 v.
14
ACE RENT A CAR
15 RESERVATIONS, INC. d/b/a ACE
RENT A CAR; ROCKPORT AUTO
16 CLAIMS; ACCOUNT SERVICES
17 COLLECTIONS, INC.; and
VANRENTALS-R-US LLC d/b/a ACE
18 RENT A CAR – LA.,
19
Defendants.
20
1. PURPOSES AND LIMITATIONS
21
Discovery in this action is likely to involve production of confidential,
22
proprietary, or private information for which special protection from public
23
disclosure and from use for any purpose other than prosecuting this litigation may
24
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
25
- 1 -
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1 enter the following Stipulated Protective Order. The parties acknowledge that this
2 Stipulated Protective Order does not confer blanket protections on all disclosures or
3 responses to discovery and that the protection it affords from public disclosure and
4 use extends only to the limited information or items that are entitled to confidential
5 treatment under the applicable legal principles. The parties further acknowledge, as
6 set forth in Section 14.3 below, that this Stipulated Protective Order does not entitle
7 them to file confidential information under seal; Local Rule 79-5 sets forth the
8 procedures that must be followed and the standards that will be applied when a party
9 seeks permission from the Court to file material under seal. Discovery in this action
10 is likely to involve production of confidential, proprietary, or private information for
11 which special protection from public disclosure and from use for any purpose other
12 than prosecuting this litigation may be warranted.
13
14 2. GOOD CAUSE STATEMENT
15 This action is likely to involve trade secrets, private financial information, or
16 company specific policies and procedure and/or proprietary information for which
17 special protection from public disclosure and from use for any purpose other than
18 prosecution of this action is warranted. Such confidential and proprietary materials
19 and information consist of, among other things, confidential business or financial
20 information, information regarding confidential business practices, or other
21 confidential research, development, or commercial information (including
22 information implicating privacy rights of third parties), information otherwise
23 generally unavailable to the public, or which may be privileged or otherwise
24 protected from disclosure under state or federal statutes, court rules, case decisions,
25 or common law. Accordingly, to expedite the flow of information, to facilitate the
- 2 -
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1 prompt resolution of disputes over confidentiality of discovery materials, to
2 adequately protect information the parties are entitled to keep confidential, to ensure
3 that the parties are permitted reasonable necessary uses of such material in
4 preparation for and in the conduct of trial, to address their handling at the end of the
5 litigation, and to serve the ends of justice, a protective order for such information is
6 justified in this matter. It is the intent of the parties that information will not be
7 designated as confidential for tactical reasons and that nothing be so designated
8 without a good faith belief that it has been maintained in a confidential, non-public
9 manner, and there is good cause why it should not be part of the public record of this
10 case.
11 3. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
12 The parties further acknowledge, as set forth in Section 14.3, below, that this
13 Stipulation Protective Order does not entitle them to file confidential information
14 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
15 and the standards that will be applied when a party seeks permission from the Court
16 to file material under seal.
17
There is a strong presumption that the public has a right of access to judicial
18
proceedings and records in civil cases. In connection with non-dispositive motions,
19
good cause must be shown to support a filing under seal. See Kamakana v. City and
20
County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
21
Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,
22
Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
23
good cause showing), and a specific showing of good cause or compelling reasons
24
with proper evidentiary support and legal justification, must be made with respect to
25
Protected Material that a party seeks to file under seal. The parties’ mere designation
- 3 -
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1 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the
2 submission of competent evidence by declaration, establishing that the material
3 sought to be filed under seal qualifies as confidential, privileged, or otherwise
4 protectable—constitute good cause.
5 Further, if a party requests sealing related to a dispositive motion or trial, then
6 compelling reasons, not only good cause, for the sealing must be shown, and the
7 relief sought shall be narrowly tailored to serve the specific interest to be protected.
8 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each
9 item or type of information, document, or thing sought to be filed or introduced
10 under seal in connection with a dispositive motion or trial, the party seeking
11 protection must articulate compelling reasons, supported by specific facts and legal
12 justification, for the requested sealing order. Again, competent evidence supporting
13 the application to file documents under seal must be provided by declaration.
14
Any document that is not confidential, privileged, or otherwise protectable in its
15
entirety will not be filed under seal if the confidential portions can be redacted. If
16
documents can be redacted, then a redacted version for public viewing, omitting only
17
the confidential, privileged, or otherwise protectable portions of the document shall
18
be filed. Any application that seeks to file documents under seal in their entirety
19
should include an explanation of why redaction is not feasible.
20
21
4. DEFINITIONS
22
4.1. Action: Dorsey v. Ace Rent A Car Reservations, Inc., et al.; No. 2:21-
23
cv-06840-RGK-MAA
24
4.2. Challenging Party: A Party or Nonparty that challenges the designation
25
of information or items under this Stipulated Protective Order
- 4 -
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4.3. “CONFIDENTIAL” Information or Items: Information (regardless of
1
how it is generated, stored or maintained) or tangible things that qualify
2
for protection under Federal Rule of Civil Procedure 26(c), and as
3
specified above in the Good Cause Statement.
4
4.4. Counsel: Outside Counsel of Record and In-House Counsel (as well as
5
their support staff).
6
4.5. Designating Party: A Party or Nonparty that designates information or
7
items that it produces in disclosures or in responses to discovery as
8
“CONFIDENTIAL.”
9 4.6. Disclosure or Discovery Material: All items or information, regardless
10 of the medium or manner in which it is generated, stored, or maintained
11 (including, among other things, testimony, transcripts, and tangible
12 things), that is produced or generated in disclosures or responses to
13 discovery in this matter.
14 4.7. Expert: A person with specialized knowledge or experience in a matter
15 pertinent to the litigation who has been retained by a Party or its counsel
16 to serve as an expert witness or as a consultant in this Action.
4.8. In-House Counsel: Attorneys who are employees of a party to this
17
Action. In-House Counsel does not include Outside Counsel of Record
18
or any other outside counsel.
19
4.9. Nonparty: Any natural person, partnership, corporation, association, or
20
other legal entity not named as a Party to this action.
21
4.10. Outside Counsel of Record: Attorneys who are not employees of a party
22
to this Action but are retained to represent or advise a party to this Action
23
and have appeared in this Action on behalf of that party or are affiliated
24
with a law firm which has appeared on behalf of that party, and includes
25
support staff.
- 5 -
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4.11. Party: Any party to this Action, including all of its officers, directors,
1
employees, consultants, retained experts, In-House Counsel, and
2
Outside Counsel of Record (and their support staffs).
3
4.12. Producing Party: A Party or Nonparty that produces Disclosure or
4
Discovery Material in this Action.
5
4.13. Professional Vendors: Persons or entities that provide litigation support
6
services (e.g., photocopying, videotaping, translating, preparing exhibits
7
or demonstrations, and organizing, storing, or retrieving data in any
8
form or medium) and their employees and subcontractors.
9 4.14. Protected Material: Any Disclosure or Discovery Material that is
10 designated as “CONFIDENTIAL.”
11 4.15. Receiving Party: A Party that receives Disclosure or Discovery Material
12 from a Producing Party
13
14 5. SCOPE
15 The protections conferred by this Stipulated Protective Order cover not only
16 Protected Material, but also (1) any information copied or extracted from Protected
17 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;
18 and (3) any testimony, conversations, or presentations by Parties or their Counsel
19 that might reveal Protected Material.
20
Any use of Protected Material at trial shall be governed by the orders of the
21
trial judge. This Stipulated Protective Order does not govern the use of Protected
22
Material at trial.
23
24
6. DURATION
25
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1 Even after final disposition of this litigation, the confidentiality obligations
2 imposed by this Stipulated Protective Order shall remain in effect until a Designating
3 Party agrees otherwise in writing or a court order otherwise directs. Final disposition
4 shall be deemed to be the later of (1) dismissal of all claims and defenses in this
5 Action, with or without prejudice; and (2) final judgment herein after the completion
6 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
7 including the time limits for filing any motions or applications for extension of time
8 pursuant to applicable law.
9
10 7. DESIGNATING PROTECTED MATERIAL
11 7.1 Exercise of Restraint and Care in Designating Material for Production
12
Each Party or Nonparty that designates information or items for
13
protection under this Stipulated Protective Order must take care to limit
14
any such designation to specific material that qualifies under the
15
appropriate standards. The Designating Party must designate for
16
protection only those parts of material, documents, items, or oral or
17
written communications that qualify so that other portions of the
18
material, documents, items, or communications for which protection is
19
not warranted are not swept unjustifiably within the ambit of this
20
Stipulated Protective Order.
21
Mass, indiscriminate, or routinized designations are prohibited.
22
Designations that are shown to be clearly unjustified or that have been
23
made for an improper purpose (e.g., to unnecessarily encumber the case
24
development process or to impose unnecessary expenses and burdens
25
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1 on other parties) may expose the Designating Party to sanctions.
2 If it comes to a Designating Party’s attention that information or
3 items that it designated for protection do not qualify for protection, that
4 Designating Party must promptly notify all other Parties that it is
5 withdrawing the inapplicable designation.
6
7.2 Manner and Timing of Designations.
7
Except as otherwise provided in this Stipulated Protective
8
Order (see, e.g., Section 7.2(a)), or as otherwise stipulated or ordered,
9
Disclosure or Discovery Material that qualifies for protection under
10
this Stipulated Protective Order must be clearly so designated before
11
the material is disclosed or produced.
12
13 Designation in conformity with this Stipulated Protective Order
14 requires the following:
15 a) For information in documentary form (e.g., paper or electronic
16 documents, but excluding transcripts of depositions or other
17 pretrial or trial proceedings), that the Producing Party affix at a
18 minimum, the legend “CONFIDENTIAL” to each page that
19 contains protected material. If only a portion or portions of the
20 material on a page qualifies for protection, the Producing Party
21 also must clearly identify the protected portion(s) (e.g., by
22 making appropriate markings in the margins).
23 A Party or Nonparty that makes original documents
24 available for inspection need not designate them for protection
25 until after the inspecting Party has indicated which documents it
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1 would like copied and produced. During the inspection and
2 before the designation, all of the material made available for
3 inspection shall be deemed “CONFIDENTIAL.” After the
4 inspecting Party has identified the documents it wants copied and
5 produced, the Producing Party must determine which documents,
6 or portions thereof, qualify for protection under this Stipulated
7 Protective Order. Then, before producing the specified
8 documents, the Producing Party must affix the legend
9 “CONFIDENTIAL” to each page that contains Protected
10 Material. If only a portion or portions of the material on a page
11 qualifies for protection, the Producing Party also must clearly
12 identify the protected portion(s) (e.g., by making appropriate
13 markings in the margins).
14 b) For testimony given in depositions, that the Designating Party
15 identify the Disclosure or Discovery Material on the record
16 before the close of the deposition, all protected testimony.
17 c) For information produced in nondocumentary form, and for any
18 other tangible items, that the Producing Party affix in a
19 prominent place on the exterior of the container or containers in
20 which the information is stored the legend “CONFIDENTIAL.”
21 If only a portion or portions of the information warrants
22 protection, the Producing Party, to the extent practicable, shall
23 identify the protected portion(s)
24 7.3 Inadvertent Failure to Designate.
25
If timely corrected, an inadvertent failure to designate qualified
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1 information or items does not, standing alone, waive the Designating
2 Party’s right to secure protection under this Stipulated Protective Order
3 for such material. Upon timely correction of a designation, the
4 Receiving Party must make reasonable efforts to assure that the
5 material is treated in accordance with the provisions of this Stipulated
6 Protective Order.
7
8 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
9
8.1 Timing of Challenges.
10
Any Party or Nonparty may challenge a designation of
11
confidentiality at any time that is consistent with the Court’s
12
Scheduling Order.
13
8.2 Meet and Confer.
14
15 The Challenging Party shall initiate the dispute resolution
16 process, which shall comply with Local Rule 37.1 et seq., and with
17 Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic
18 Conference for Discovery Disputes”).1
19 8.3. Burden of Persuasion.
20
The burden of persuasion in any such challenge proceeding shall
21
be on the Designating Party. Frivolous challenges, and those made for
22
an improper purpose (e.g., to harass or impose unnecessary expenses
23
and burdens on other parties) may expose the Challenging Party to
24
25 1 Judge Audero’s Procedures are available at
https://www.cacd.uscourts.gov/honorable-maria-audero
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1 sanctions. Unless the Designating Party has waived or withdrawn the
2 confidentiality designation, all parties shall continue to afford the
3 material in question the level of protection to which it is entitled under
4 the Producing Party’s designation until the Court rules on the challenge.
5
6 9. ACCESS TO AND USE OF PROTECTED MATERIALS
9.1. Basic Principles.
7
A Receiving Party may use Protected Material that is disclosed
8
or produced by another Party or by a Nonparty in connection with this
9
Action only for prosecuting, defending, or attempting to settle this
10
Action. Such Protected Material may be disclosed only to the
11
categories of persons and under the conditions described in this
12
Stipulated Protective Order. When the Action reaches a final
13
disposition, a Receiving Party must comply with the provisions of
14
Section 15 below.
15
Protected Material must be stored and maintained by a
16
Receiving Party at a location and in a secure manner that ensures that
17
access is limited to the persons authorized under this Stipulated
18
Protective Order.
19
9.2. Disclosure of “CONFIDENTIAL” Information or Items.
20
Unless otherwise ordered by the Court or permitted in writing
21
by the Designating Party, a Receiving Party may disclose any
22
information or item designated “CONFIDENTIAL” only to:
23
24
25
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1 a) The Receiving Party’s Outside Counsel of Record, as well as
2 employees of said Outside Counsel of Record to whom it is reasonably
3 necessary to disclose the information for this Action;
4 b) The officers, directors, and employees (including In-House Counsel) of
5 the Receiving Party to whom disclosure is reasonably necessary for this
6 Action;
7 c) Experts of the Receiving Party to whom disclosure is reasonably
8 necessary for this Action and who have signed the “Acknowledgment
9 and Agreement to Be Bound” (Exhibit A)
10 d) The Court, its personnel and any juror or alternate juror;
11 e) Court reporters and their staff;
12 f) Professional jury or trial consultants, mock jurors, and Professional
13 Vendors to whom disclosure is reasonably necessary or this Action and
14 who have signed the “Acknowledgment and Agreement to be Bound”
15 (Exhibit A);
16 g) The author or recipient of a document containing the information or a
17 custodian or other person who otherwise possessed or knew the
18 information;
19 h) During their depositions, witnesses, and attorneys for witnesses in the
20 Action to whom disclosure is reasonably necessary provided: (i) the
21 deposing party requests that the witness sign the “Acknowledgment and
22 Agreement to Be Bound” (Exhibit A); and (ii) the witness will not be
23 permitted to keep any confidential information unless they sign the
24 “Acknowledgment and Agreement to Be Bound,” unless otherwise
25 agreed by the Designating Party or ordered by the Court. Pages of
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1 transcribed deposition testimony or exhibits to depositions that reveal
2 Protected Material may be separately bound by the court reporter and
3 may not be disclosed to anyone except as permitted under this
4 Stipulated Protective Order; and (iii) Any mediator or settlement
5 officer, and their supporting personnel, mutually agreed upon by any of
6 the parties engaged in settlement discussions.
7
8 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
9 PRODUCED IN OTHER LITIGATION
10 If a Party is served with a subpoena or a court order issued in other litigation
11 that compels disclosure of any information or items designated in this Action as
12 “CONFIDENTIAL,” that Party must:
13 a) Promptly notify in writing the Designating Party. Such notification
14 shall include a copy of the subpoena or court order;
15 b) Promptly notify in writing the party who cased the subpoena or order
16 to issue in the other litigation that some or all of the material covered
17 by the subpoena or order is subject to this Stipulated Protective Order.
18 Such notification shall include a copy of this Stipulated Protective
19 Order; and
20 c) Cooperate with respect to all reasonable procedures sought to be
21 pursued by the Designating Party whose Protected Material may be
22 affected.
23 If the Designating Party timely seeks a protective order, the Party served with the
24 subpoena or court order shall not produce any information designated in this action
25 as “CONFIDENTIAL” before a determination by the Court from which the
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1 subpoena or order issued, unless the Party has obtained the Designating Party’s
2 permission. The Designating Party shall bear the burden and expense of seeking
3 protection in that court of its confidential material and nothing in these provisions
4 should be construed as authorizing or encouraging a Receiving Party in this Action
5 to disobey a lawful directive from another court.
6
7 11. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE
8 PRODUCED IN THIS LITIGATION
9 11.1. Application.
10 The terms of this Stipulated Protective Order are applicable to
11 information produced by a Nonparty in this Action and designated as
12 “CONFIDENTIAL.” Such information produced by Nonparties in
13 connection with this litigation is protected by the remedies and relief
14 provided by this Stipulated Protective Order. Nothing in these
15 provisions should be construed as prohibiting a Nonparty from seeking
16 additional protections.
17 11.2. Notification.
18 In the event that a Party is required, by a valid discovery request,
19 to produce a Nonparty’s confidential information in its possession, and
20 the Party is subject to an agreement with the Nonparty not to produce
21 the Nonparty’s confidential information, then the Party shall:
22 a) Promptly notify in writing the Requesting Party and the Nonparty
23 that some or all of the information requested is subject to a
24 confidentiality agreement with a Nonparty;
25
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1 b) Promptly provide the Nonparty with a copy of the Stipulated
2 Protective Order in this Action, the relevant discovery request(s), and
3 a reasonably specific description of the information requested; and
4 c) Make the information requested available for inspection by the
5 Nonparty, if requested.
6 11.3. Conditions of Production.
7 If the Nonparty fails to seek a protective order from this Court
8 within fourteen (14) days after receiving the notice and accompanying
9 information, the Receiving Party may produce the Nonparty’s
10 confidential information responsive to the discovery request. If the
11 Nonparty timely seeks a protective order, the Receiving Party shall not
12 produce any information in its possession or control that is subject to
13 the confidentiality agreement with the Nonparty before a determination
14 by the Court. Absent a court order to the contrary, the Nonparty shall
15 bear the burden and expense of seeking protection in this Court of its
16 Protected Material.
17
12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
18
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
19
Protected Material to any person or in any circumstance not authorized under this
20
Stipulated Protective Order, the Receiving Party immediately must (1) notify in
21
writing the Designating Party of the unauthorized disclosures, (2) use its best efforts
22
to retrieve all unauthorized copies of the Protected Material, (3) inform the person
23
or persons to whom unauthorized disclosures were made of all the terms of this
24
25
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1 Stipulated Protective Order, and (4) request such person or persons to execute the
2 “Acknowledgment and Agreement to be Bound” (Exhibit A).
13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
3
PROTECTED MATERIAL
4 When a Producing Party gives notice to Receiving Parties that certain
5 inadvertently produced material is subject to a claim of privilege or other protection,
6 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
7 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
8 may be established in an e-discovery order that provides for production without prior
9 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
10 parties reach an agreement on the effect of disclosure of a communication or
11 information covered by the attorney-client privilege or work product protection, the
12 parties may incorporate their agreement in the Stipulated Protective Order submitted
13 to the Court.
14
15 14. MISCELLANEOUS
14.1. Right to Further Relief.
16
Nothing in this Stipulated Protective Order abridges the right of
17
any person to seek its modification by the Court in the future.
18
14.2. Right to Assert Other Objections.
19
By stipulating to the entry of this Stipulated Protective Order, no
20
Party waives any right it otherwise would have to object to disclosing
21
or producing any information or item on any ground not addressed in
22
this Stipulated Protective Order. Similarly, no Party waives any right to
23
object on any ground to use in evidence of any of the material covered
24
by this Stipulated Protective Order.
25
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1 14.3. Filing Protected Material.
2 A Party that seeks to file under seal any Protected Material must
3 comply with Local Rule 79-5. Protected Material may only be filed
4 under seal pursuant to a court order authorizing the sealing of the
5 specific Protected Material at issue. If a Party's request to file Protected
6 Material under seal is denied by the Court, then the Receiving Party
7 may file the information in the public record unless otherwise instructed
8 by the Court.
9
15. FINAL DISPOSITION
10
After the final disposition of this Action, within sixty (60) days of a written
11
request by the Designating Party, each Receiving Party must return all Protected
12
Material to the Producing Party or destroy such material. As used in this subdivision,
13
“all Protected Material” includes all copies, abstracts, compilations, summaries, and
14
any other format reproducing or capturing any of the Protected Material. Whether
15
the Protected Material is returned or destroyed, the Receiving Party must submit a
16
written certification to the Producing Party (and, if not the same person or entity, to
17
the Designating Party) by the 60-day deadline that (1) identifies (by category, where
18
appropriate) all the Protected Material that was returned or destroyed and (2) affirms
19
that the Receiving Party has not retained any copies, abstracts, compilations,
20
summaries or any other format reproducing or capturing any of the Protected
21
Material. Notwithstanding this provision, Counsel is entitled to retain an archival
22
copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; legal
23
memoranda; correspondence; deposition and trial exhibits; expert reports; attorney
24
work product; and consultant and expert work product, even if such materials
25
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1 contain Protected Material. Any such archival copies that contain or constitute
2 Protected Material remain subject to this Stipulated Protective Order as set forth in
3 Section 6.
4
16. VIOLATION
5
Any violation of this Stipulated Order may be punished by any and all
6
appropriate measures including, without limitation, contempt proceedings and/or
7
monetary sanctions.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
DATED: January 10, 2022 By: /s/Youssef H. Hammoud
3
Youssef H. Hammoud (SBN: 321934)
4 PRICE LAW GROUP, APC
6345 Balboa Blvd., Suite 247
5 Encino, CA 91316
T: (818) 600-5596
6
F: (818) 600-5496
7 E: youssef@pricelawgroup.com
Attorneys for Plaintiff Keith Dorsey
8
9 DATED: January 10, 2022 By: /s/ John A. Kelly
THOMAS F. LANDERS [SBN 207335]
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tlanders@swsslaw.com
11 JOHN A. KELLY [SBN 324463]
jkelly@swsslaw.com
12 SOLOMON WARD SEIDENWURM &
SMITH, LLP
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401 B Street, Suite 1200
14 San Diego, California 92101
(t) 619.231.0303
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(f) 619.231.4755
16 Attorneys for Defendants,
Ace Rent A Car Reservations, Inc.
17 d/b/a Ace Rent A Car and
18 VAN-RENTALS-R-US LLC
d/b/a Ace Rent A Car – LA
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DATED: January 10, 2022 By: /s/ Mark Ellis
20
Mark E. Ellis - 127159
21 ELLIS LAW GROUP LLP
1425 River Park Drive, Suite 400
22
Sacramento, CA 95815
23 Tel: (916) 283-8820
Fax: (916) 283-8821
24 mellis@ellislawgrp.com
Attorneys for Defendant
25
Rockport Auto Claims
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Case 2:21-cv-06840-RGK-MAA Document 52 Filed 01/10/22 Page 20 of 21 Page ID #:320
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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January 10, 2022
3 Dated: ___________________ _________________________
Maria A. Audero
4 United States Magistrate Judge
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Case 2:21-cv-06840-RGK-MAA Document 52 Filed 01/10/22 Page 21 of 21 Page ID #:321
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO COMPLY
3 I, _____________________[full name], of
4 _________________________[address], declare under penalty of perjury that I
5 have read in its entirety and understand the Stipulated Protective Order that was
6 issued by the United States District Court for the Central District of California on
7 [date] in the case of Dorsey v. Ace Rent A Car Reservations, Inc., et al; No. 2:21-
8 cv-06840-RGK-MAA. I agree to comply with all the terms of this Stipulated
9 Protective Order, and I understand and acknowledge that failure to so comply
10 could expose me to sanctions and punishment in the nature of contempt. I solemnly
11 promise that I will not disclose in any manner any information or item that is
12 subject to this Stipulated Protective Order to any person or entity except in strict
13 compliance with the provisions of this Stipulated Protective Order. I further agree
14 to submit to the jurisdiction of the United States District Court for the Central
15 District of California for the purpose of enforcing the terms of this Stipulated
16 Protective Order, even if such enforcement proceedings occur after termination of
17 this action. I hereby appoint _______________________ [full name] of
18 _____________________________________[address and telephone number] as
19 my California agent for service of process in connection with this action or any
20 proceedings related to enforcement of this Stipulated Protective Order.
21 Signature:_________________________
22 Printed Name:______________________
23 Date:________________
24 City and State Where Sworn and Signed:________________________________
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