The opinion
Case 2:21-cv-02115-DSF-JC Document 41 Filed 03/09/22 Page1of18 Page ID #:263
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 || ERICA MORA, an individual, Case No. 2:21-CV-02115 DSF (JCx)
12 Plaintiff, [Assigned to Judge Dale S. Fisher,
3 ourtroom 7D]
V.
MODIFIED STIPULATED
14 | CITY OF LOS ANGELES, a PROTECTIVE ORDER RE:
municipal entity, COUNTY OF LOS DISCLOSURE OF CONFIDENTIAL
15 || ANGELES, a municipal entity; DOES | INFORMATION
1-20, inclusive, individually and in
16 || their official capacities as police [Discovery Document: Referred to _
officers for the Los Angeles Police agistrate Judge Jacqueline Chooljian]
17 Department, and DOES 21-40,
inclusive, individually and in their | [CHANGE MADE TO § 6.1]
18 || Official capacities as sheriffs deputies
for the Los Angeles County Sheriff's
19 || Department,
20 Defendants.
21
22] 1. GENERAL
23 1.1. Purposes and Limitations.
24 Discovery in this action is likely to involve production of confidential,
25 || proprietary, and/or private information for which special protection from public
26 || disclosure and/or from use for any purpose other than prosecuting this litigation
27 || may be warranted. Accordingly, the parties to this action (hereinafter, the “Parties”
28 || collectively and a “Party” individually) hereby stipulate to and petition the Court to
BURKE, WILLIAMS &
Anions artaw #4886-1002-6514 v1 STIPULATED PROTECTIVE ORDER
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1 || enter the following Stipulated Protective Order. The Parties acknowledge that this
2 || Order does not confer blanket protections on all disclosures or responses to
3 || discovery, and that the protections it affords from public disclosure and use extends
4 || only to the limited information or items that are entitled to confidential treatment
5 || under the applicable legal principles and/or under this Stipulated Protective Order.
6 The Parties agree that any disclosures pursuant to the instant Stipulated
7 || Protective Order shall not be construed as a waiver of applicable privilege with
8 || regard to any subsequent third-party litigants. The Parties further agree that the
9 || production of documents pursuant to the instant Stipulated Protective Order has no
10 || bearing on their admissibility. Thus, documents otherwise admissible remain
11 || admissible, and documents otherwise inadmissible remain inadmissible.
12 1.2 Good Cause Statement.
13 This action involves the City of Los Angeles and members of the Los
14 || Angeles Police Department, as well as the County of Los Angeles and members of
15 || the Los Angeles County Sheriff’s Department. Plaintiff is seeking materials and
16 || information that Defendants City of Los Angeles and County of Los Angeles
17 || (collectively, “Defendants’’) maintain as confidential, such as personnel files of the
18 || law enforcement officers involved in the subject incident, Internal Affairs materials
19 || and information, video recordings (including Body-Worn Video recordings and
20 || Digital In-Car Video recordings), audio recordings, and information and other
21 || administrative materials and information currently in the possession of the
22 || Defendants and that the Defendants believe needs special protection from public
23 || disclosure and from use for any purpose other than prosecuting this litigation.
24 || Plaintiff may also seek official information contained in the personnel files of the
25 || law enforcement officers involved in the subject incident, which the Defendants
26 || maintain as strictly confidential and which the Defendants believe needs special
27 || protection from public disclosure and from use for any purpose other than
28 || prosecuting this litigation.
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l Defendants assert that the confidentiality of the materials and information
2 || sought by Plaintiff is recognized by California and federal law, as evidenced by,
3 || inter alia, California Penal Code section 832.7 and Kerr v. United States Dist. Ct.
4 || for N.D. Cal., 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976).
5 || Defendants have not publicly released the materials and information referenced
6 || above except under protective order or pursuant to a court order, if at all. These
7 || materials and information are of the type that has been used to initiate disciplinary
8 || action against Defendants’ officers, and has been used as evidence in disciplinary
9 || proceedings, where the officers’ conduct was considered to be contrary to policy.
10 Defendants contend that, absent a protective order delineating the
11 || responsibilities of nondisclosure on the part of the Parties hereto, there is a specific
12 || risk of unnecessary and undue disclosure by one or more of the many attorneys,
13 || secretaries, law clerks, paralegals, and/or expert witnesses involved in this case, as
14 || well as the corollary risk of embarrassment, harassment, and/or professional and/or
15 || legal harm on the part of the officers referenced in the materials and information.
16 Accordingly, to expedite the flow of information, to facilitate the prompt
17 || resolution of disputes over confidentiality of discovery materials, to adequately
18 || protect information the Parties are entitled to keep confidential, to ensure that the
19 || Parties are permitted reasonably necessary uses of such material in preparation for
20 || and in the conduct of trial, to address their handling at the end of the litigation, and
21 || to serve the ends of justice, a protective order for such information 1s justified in
22 || this matter. It is the intent of the Parties that information will not be designated as
23 || confidential for tactical reasons and that nothing be so designated without a good-
24 || faith belief that the information and/or documents in question have been maintained
25 || ina confidential, non-public manner, and that there is good cause why it should not
26 || be part of the public record of this case.
27 | ///
28 | ///
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1 || 2. DEFINITIONS
2 2.1. Action: Erica Mora v. City of Los Angeles, et al., Case No. 2:21-CV-
3 || 02115 DSF (JCx).
4 2.2 Challenging Party: A Party or Non-Party that challenges the
5 || designation of information or items under this Order.
6 2.33 “CONFIDENTIAL” Information or Items: Information (regardless
7 || of how it is generated, stored, or maintained) or tangible things that qualify for
8 || protection under Fed.R.Civ.P. Rule 26(c), and/or as specified above in the Good
9 || Cause Statement. This also includes (1) any information copied or extracted from
10 || the Confidential information; (2) all copies, excerpts, summaries, abstracts, or
11 || compilations of Confidential information; and (3) any testimony, conversations, or
12 || presentations that might reveal Confidential information.
13 2.4 Counsel: Counsel of record for the Parties to this civil litigation and
14 || their support staff.
15 2.5 Designating Party: A Party or Non-Party that designates information
16 || or items that it produces in disclosures or in responses to discovery as
17 || “CONFIDENTIAL.”
18 2.6 Disclosure or Discovery Material: All items or information,
19 || regardless of the medium or manner in which it is generated, stored, or maintained
20 || (including, among other things, testimony, transcripts, and tangible things), that are
21 || produced or generated in disclosures or responses to discovery in this matter.
22 2.7 Expert: A person with specialized knowledge or experience in a
23 || matter pertinent to the litigation who has been retained by a Party or its counsel to
24 || serve as an expert witness or as a consultant in this Action.
25 2.8 House Counsel: Attorneys other than Counsel (as defined in
26 || paragraph 2.4) and who are employees of a Party to this Action.
27 2.9 Non-Party: Any natural person, partnership, corporation, association,
28 || or other legal entity not named as a Party to this action.
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1 2.10 Outside Counsel of Record: Attorneys who are not employees of a
2 || Party to this Action but are retained to represent or advise a Party to this Action and
3 || have appeared in this Action on behalf of that Party or are affiliated with a law firm
4 || that has appeared on behalf of that Party, and includes support staff.
5 2.11 Party: Any Party to this Action, including all of its officers, directors,
6 || boards, departments, divisions, employees, consultants, retained experts, and
7 || Outside Counsel of Record (and their support staffs).
8 2.12 Producing Party: A Party or Non-Party that produces Disclosure or
9 || Discovery Material in this Action.
10 2.13 Professional Vendors: Persons or entities that provide litigation
11 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or
12 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
13 || and their employees and subcontractors.
14 2.14 Protected Material: Any Disclosure or Discovery Material that is
15 || designated as “CONFIDENTIAL.”
16 2.15 Receiving Party: A Party that receives Disclosure or Discovery
17 || Material from a Producing Party.
18 || 3. SCOPE
19 The protections conferred by this Stipulation and Order cover not only
20 || Protected Material (as defined above), but also (1) any information copied or
21 || extracted from Protected Material; (2) all copies, excerpts, abstracts, summaries, or
22 || compilations of Protected Material; and (3) any testimony, conversations, or
23 || presentations by Parties or their Counsel that might reveal Protected Material, other
24 || than during a court hearing or at trial.
25 Any use of Protected Material during a court hearing or at trial shall be
26 || governed by the orders of the presiding judge. This Order does not govern the use
27 || of Protected Material during a court hearing or at trial.
28 || ///
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1 || 4. DURATION
2 Even after final disposition of this litigation, the confidentiality obligations
3 || imposed by this Order shall remain in effect until a Designating Party agrees
4 || otherwise in writing or a court order otherwise directs. Final disposition shall be
5 || deemed to be the later of (1) dismissal of all claims and defenses in this Action,
6 || with or without prejudice; or (2) final judgment herein after the completion and
7 || exhaustion of all appeals, re-hearings, remands, trials, or reviews of this Action,
8 || including the time limits for filing any motions or applications for extension of time
9 || pursuant to applicable law.
10 || 5. DESIGNATING PROTECTED MATERIAL
11 5.1 Exercise of Restraint and Care in Designating Material for
12 || Protection.
13 Each Party or Non-Party that designates information or items for protection
14 || under this Order must take care to limit any such designation to specific material
15 || that qualifies under the appropriate standards. The Designating Party must
16 || designate for protection only those parts of material, documents, items, or oral or
17 || written communications that qualify, so that other portions of the material,
18 || documents, items, or communications for which protection is not warranted are not
19 || swept unjustifiably within the ambit of this Order.
20 Mass, indiscriminate, and/or routinized designations are prohibited.
21 || Designations that are shown to be clearly unjustified or that have been made for an
22 || improper purpose (e.g., to unnecessarily encumber the case-development process or
23 || to impose unnecessary expenses and burdens on other Parties) may expose the
24 || Designating Party to sanctions.
25 If it comes to a Designating Party’s attention that information or items that it
26 || designated for protection do not qualify for protection, the Designating Party must
27 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
28 ///
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1 5.2. Manner and Timing of Designations. Except as otherwise provided
2 || in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
3 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
4 || under this Order must be clearly so designated before the material is disclosed or
5 || produced.
6 Designation in conformity with this Order requires:
7 (a) For information in documentary form (e.g., paper or electronic
8 || documents, but excluding transcripts of depositions or other pretrial or trial
9 || proceedings), that the Producing Party affix, at a minimum, the legend
10 || “CONFIDENTIAL” or words of a similar effect, and the case name and case
11 || number (hereinafter “CONFIDENTIAL legend”), to each page that contains
12 || protected material. If only a portion of the material on a page qualifies for
13 || protection, the Producing Party also must clearly identify the protected portion(s)
14 || (e.g., by making appropriate markings in the margins).
15 (b) For testimony given in depositions, that the Designating Party
16 || identifies the Disclosure or Discovery Material on the record, before the close of
17 || the deposition.
18 (c) For information produced in some form other than documentary
19 || and for any other tangible items, that the Producing Party affix in a prominent place
20 || on the exterior of the container or containers in which the information is stored the
21 || legend “CONFIDENTIAL.” If only a portion or portions of the information
22 || warrants protection, the Producing Party, to the extent practicable, shall identify the
23 || protected portion(s).
24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
25 || failure to designate qualified information or items does not, standing alone, waive
26 || the Designating Party’s right to secure protection under this Order for such
27 || material. Upon timely correction of a designation, the Receiving Party must make
28 |) ///
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1 || reasonable efforts to assure that the material is treated in accordance with the
2 || provisions of this Order.
3 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4 6.1. Challenges. This Order shall be without prejudice to the right of the
5 || Parties, to the extent consistent with the Court’s Scheduling Order (1) to bring
6 || before the Court the question of whether any particular document or information is
7 || confidential or whether its use should be restricted or (11) to present a motion to the
8 || Court under Fed.R.Civ.P. Rule 26(c) for a separate protective order as to any
9 || particular document or information, including restrictions differing from those as
10 || specified herein. This Order shall not be deemed to prejudice the Parties in any
11 || way in any future application or modification of this Order.
12 6.2 Timing of Challenges. Any Party or Non-Party may challenge a
13 || designation of confidentiality at any time that is consistent with the Court’s
14 || Scheduling Order.
15 6.3 Meet and Confer. The Challenging Party shall initiate the dispute
16 || resolution process under Local Rule 37.1 et seg. To avoid ambiguity as to whether
17 || a challenge has been made, the written notice pursuant to Local Rule 37.1 must
18 || recite that the challenge to confidentiality is being made in accordance with this
19 || specific paragraph of the Protective Order. The Parties shall attempt to resolve
20 || each challenge in good faith and must begin the process by conferring directly
21 || within 14 days of the date of service of notice. In conferring, the Challenging Party
22 || must explain the basis for its belief that the confidentiality designation was not
23 || proper and must give the Designating Party an opportunity to review the designated
24 || material, to reconsider the circumstances, and, if no change in designation is
25 || offered, to explain the basis for the chosen designation. A Challenging Party may
26 || seek judicial intervention only if it has engaged in this meet-and-confer process first
27 || or establishes that the Designating Party is unwilling to participate in the meet-and-
28 || confer process in a timely matter.
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1 6.4 Burden. The burden of persuasion in any such challenge proceeding
2 || shall be on the Designating Party. Frivolous challenges, and those made for an
3 || improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
4 || other Parties) may expose the Challenging Party to sanctions. Unless the
5 || Designating Party has waived or withdrawn the confidentiality designation, all
6 || Parties shall continue to afford the material in question the level of protection to
7 || which it is entitled under the Producing Party’s designation until the Court rules on
8 || the challenge.
9 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL
10 7.1. Basic Principles. A Receiving Party may use Protected Material that
11 || is disclosed or produced by another Party or by a Non-Party in connection with this
12 || Action only for prosecuting, defending, or attempting to settle this Action. Such
13 || Protected Material may be disclosed only to the categories of persons and under the
14 || conditions described in this Order. When the Action has been terminated, a
15 || Receiving Party must comply with the provisions of section 13 below (FINAL
16 || DISPOSITION).
17 Protected Material must be stored and maintained by a Receiving Party at a
18 || location and in a secure manner that ensures that access is limited to the persons
19 || authorized under this Order. Receiving Parties shall take reasonable steps to
20 || prevent disclosure of Protected Material to any third party not authorized to receive
21 || the Protected Material pursuant to the terms of this Order.
22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
23 || otherwise ordered by the court or permitted in writing by the Designating Party, a
24 || Receiving Party may disclose any information or item designated
25 || “CONFIDENTIAL” only to:
26 (a) The Receiving Party’s Counsel of Record in this Action, as well
27 || as their respective associates, clerks, legal assistants, support personnel, and
28
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1 || investigators and litigation support services (photocopy services or transcription
2 || services) who have signed the “Nondisclosure Agreement” (Exhibit A);
3 (b) Any designated or retained Experts (as defined in this Order)
4 || and their employees, hired by any Party who has signed the “Nondisclosure
5 || Agreement” (Exhibit A);
6 (c) The Court and its personnel;
7 (d) Court reporters and their staff;
8 (e) Professional jury or trial consultants, mock jurors, and
9 || Professional Vendors to whom disclosure is reasonably necessary for this Action
10 || and who have signed the “Nondisclosure Agreement” (Exhibit A);
11 (f) The author or recipient of a document containing the
12 || information or a custodian or other person who otherwise possessed or knew the
13 || information before it was disclosed in this Action;
14 (g) During their depositions, witnesses, and attorneys for witnesses,
15 || in the Action to whom disclosure is reasonably necessary, provided (1) the
16 || deposing party requests that the witness sign the form attached as Exhibit “A”
17 || hereto; and (2) they will not be permitted to keep any confidential information
18 || unless they sign the “Nondisclosure Agreement” (Exhibit “A’’), unless otherwise
19 || agreed by the Designating Party or ordered by the Court. Pages of transcribed
20 || deposition testimony or exhibits to depositions that reveal Protected Material may
21 || be separately bound by the court reporter and may not be disclosed to anyone
22 || except as permitted under this Stipulated Protective Order; and
23 (h) Any mediator or settlement officer, and their supporting
24 || personnel, mutually agreed upon by any of the Parties engaged in settlement
25 || discussions and who have signed the “Nondisclosure Agreement” (Exhibit A).
26 7.3 Counsel making the disclosure to any qualified person described
27 || herein shall retain the original executed copy of the Nondisclosure Agreement until
28 || sixty (60) days after this litigation has become final, including any appellate review,
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1 || and any monitoring of an injunction. Counsel for the Receiving Party shall maintain
2 || all signed Nondisclosure Agreements and shall produce the original signature page
3 || upon reasonable written notice from opposing counsel. If an issue arises regarding a
4 || purported unauthorized disclosure of Confidential Information, upon noticed
5 || motion of contempt filed by the Designating Party, counsel for the Receiving Party
6 || may be required to file the signed Nondisclosure Agreements, as well as a list of the
7 || disclosed materials, in camera with the Court having jurisdiction of the Stipulation.
8 || 8. 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, including with
14 || such notice a copy of the subpoena or court order;
15 (b) Promptly notify in writing the Party who caused the subpoena or
16 || order to issue in the other litigation that some or all of the material covered by the
17 || subpoena or order is subject to this Protective Order, including with such notice a
18 || copy of this Stipulated Protective Order; and
19 (c) Cooperate with respect to all reasonable procedures sought to be
20 || pursued by the Designating Party whose Protected Material may be affected.
21 The Party served with the subpoena or court order shall not produce any
22 || information designated in this action as “CONFIDENTIAL” before a determination
23 || by the court from which the subpoena or order issued, unless the Party has obtained
24 || the Designating Party’s permission, or unless otherwise required by the law or court
25 || order. The Designating Party shall bear the burden and expense of seeking
26 || protection in that court of its confidential material and nothing in these provisions
27 || should be construed as authorizing or encouraging a Receiving Party in this Action
28 || to disobey a lawful directive from another court.
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1 | 9 ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced
4 || by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
5 || information produced by Non-Parties in connection with this litigation is protected
6 || by the remedies and relief provided by this Order. Nothing in these provisions
7 || should be construed as prohibiting a Non-Party from seeking additional protections.
8 (b) Inthe event that a Party is required, by a valid discovery
9 || request, to produce a Non-Party’s confidential information in its possession, and the
10 || Party is subject to an agreement with the Non-Party not to produce the Non-Party’s
11 || confidential information, then the Party shall:
12 (1) Promptly notify in writing the Requesting Party and the
13 || Non-Party that some or all of the information requested is subject to a
14 || confidentiality agreement with a Non-Party;
15 (2) Promptly provide the Non-Party with a copy of the
16 || Stipulated Protective Order in this Action, the relevant discovery request(s), and a
17 || reasonably specific description of the information requested; and
18 (3) Make the information requested available for inspection
19 || by the Non-Party, if requested.
20 (c) Ifthe Non-Party fails to seek a protective order from this court
21 || within 14 days of receiving the notice and accompanying information, the
22 || Receiving Party may produce the Non-Party’s confidential information responsive
23 || to the discovery request. If the Non-Party timely seeks a protective order, the
24 || Receiving Party shall not produce any information in its possession or control that
25 || is subject to the confidentiality agreement with the Non-Party before a
26 || determination by the court unless otherwise required by the law or court order.
27 || Absent a court order to the contrary, the Non-Party shall bear the burden and
28 || expense of seeking protection in this court of its Protected Material.
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1 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
3 || Protected Material to any person or in any circumstance not authorized under this
4 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in
5 || writing the Designating Party of the unauthorized disclosures, (b) use its best
6 || efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
7 || person or persons to whom unauthorized disclosures were made of all the terms of
8 || this Order, and (d) request such person or persons to execute the “Nondisclosure
9 || Agreement” that is attached hereto as Exhibit A.
10 | 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
11 PROTECTED MATERIAL
12 When a Producing Party gives notice to Receiving Parties that certain
13 || inadvertently produced material is subject to a claim of privilege or other
14 || protection, the obligations of the Receiving Parties are those set forth in Federal
15 || Rule of Civil Procedure 26(b)(5)(B). After being notified, the Receiving Parties
16 || must (1) promptly return, sequester, or destroy the specified information and any
17 || copies it has; (i1) not use or disclose the information until the claim is resolved; and
18 || (411) take reasonable steps to retrieve the information if any Receiving Party
19 || disclosed it before being notified. This provision is not intended to modify
20 || whatever procedure may be established in an e-discovery order that provides for
21 || production without prior privilege review. Pursuant to Federal Rule of Evidence
22 || 502(d) and (e), insofar as the Parties reach an agreement on the effect of disclosure
23 || of acommunication or information covered by the attorney-client privilege or
24 || work-product protection, the Parties may incorporate their agreement in the
25 || stipulated protective order submitted to the court.
26 | 12. MISCELLANEOUS
27 12.1 Right to Further Relief. Nothing in this Order abridges the right of
28 || any person to seek its modification by the Court in the future.
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1 12.2. Non-Waiver. By stipulating to the entry of this Protective Order, no
2 || Party waives any right it otherwise would have to object to disclosing or producing
3 || any information or item on any ground not addressed in this Stipulated Protective
4 | Order.
5 12.3 Right to Assert Other Objections. By stipulating to the entry of this
6 || Protective Order, no Party waives any right it otherwise would have to object to
7 || disclosing or producing any information or item on any ground not addressed in
8 || this Stipulated Protective Order. Similarly, no Party waives any right to object on
9 || any ground to use in evidence of any of the material covered by this Protective
10 || Order.
11 12.4 Filing Protected Material. A Party may not file in the public record
12 || in this action or in any other action Protected Material without first seeking to file
13 || the Protected Material under seal pursuant to this Paragraph. A Party that seeks to
14 || file under seal any Protected Material must comply with Local Civil Rule 79-5 and
15 || this Court’s Standing Orders. Protected Material may only be filed under seal
16 || pursuant to a court order authorizing the sealing of the specific Protected Material
17 || at issue. Pursuant to Central District of California Local Rule 79-5, a sealing order
18 || will issue only upon a written application establishing that the Protected Material is
19 || entitled to protection under the law. However, only the portions of documents,
20 || including briefs, exhibits, or any other moving or opposing papers that contain
21 || Protected Material need to be filed under seal. If a Party’s request to file Protected
22 || Material under seal is denied by the court, then the Receiving Party may file the
23 || information in the public record unless otherwise instructed by the court.
24 12.5 Enforceability. The validity, construction, and performance of this
25 || Stipulated Protective Order shall be governed and construed in accordance with the
26 || laws of the State of California applicable to contracts made and to be wholly
27 || performed within such state, without giving effect to any conflict of laws provisions
28 || thereof. The federal and state courts located in California shall have sole and
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1 || exclusive jurisdiction over any disputes arising under, or in any way connected with
2 || or related to, the terms of this Agreement and Receiving Party: (1) consents to
3 || personal jurisdiction therein; and (11) waives the right to raise forum non conveniens
4 || or any similar objection.
5 || 13. FINAL DISPOSITION
6 After the FINAL DISPOSITION of this Action, as defined in Paragraph 4,
7 || within 30 days of a written request by the Designating Party, each Receiving Party
8 || must return all Protected Material to the Producing Party. As used in this
9 || subdivision, “all Protected Material” includes all copies, abstracts, compilations,
10 || summaries, and any other format reproducing or capturing any of the Protected
11 || Material. The Receiving Party must submit a written certification to the Producing
12 || Party (and, if not the same person or entity, to the Designating Party) by the 30 day
13 || deadline that (1) identifies (by category, where appropriate) all the Protected
14 || Material that was returned and (2) affirms that the Receiving Party has not retained
15 || any copies, abstracts, compilations, summaries or any other format reproducing or
16 || capturing any of the Protected Material.
17 | 14. VIOLATION
18 Any violation of this Order may be punished by appropriate measures,
19 || including, without limitation, contempt proceedings and/or monetary sanctions.
20 | ///
21 ///
22 | ///
23 |) ///
24 | ///
25 | ///
26 || ///
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“Sorin LLP . LA #4886-1002-6514 vI 71S - STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02115-DSF-JC Document 41 Filed 03/09/22 Page 16o0f18 Page ID #:278
] IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
3 || Dated: March 2, 2022 LAW OFFICES OF JOHN L. BURRIS
5 By: /s/ DeWitt M. Lacey
DeWitt M. Lacey _
6 Attorneys for Plaintiff ERICA MORA
9 Dated: March 2, 2022 BURKE, WILLIAMS & SORENSEN,
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I By: _/s/ Mark J. Austin
12 Mark J. Austin
Attorneys for Defendant CITY OF
13 LOS ANGELES
14
15 || Dated: March 2, 2022 LAWRENCE BEACH ALLEN & CHOI,
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By:_/s/ Michael D. Allen
18 Michael D. Allen
Attorneys for Defendant COUNTY
19 OF LOS ANGELES
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PGORANSEN, LLP 2:21-CV-02115 DSF (JCx)
Rnomerearian EA #4886-1002-6514 v1 - 16 - STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02115-DSF-JC Document 41 Filed 03/09/22 Page17of18 Page ID#:279
l Having considered the papers, the finding that good cause exists, the Parties’
2 || Stipulated Protective Order is granted.
3 IT IS SO ORDERED.
/s/
5 || Dated: March 9, 2022 “UN HON JACQUELINE CHOOLITAN
6 UNITED STATES MAGISTRATE JUDGE
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PSORENSEN, LLP 14 nagge-too2ces14 v1 □□ 2:21-CV-02115 DSF (JCx)
Aone A La STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02115-DSF-JC Document 41 Filed 03/09/22 Page 180f18 Page ID #:280
1 ATTACHMENT “A”
2 NONDISCLOSURE AGREEMENT
3 I, [print or type full name] of
4 [print or type full
5 || address] do solemnly swear that I have read in its entirety and understand the terms
6 || of the Protective Order entered in Erica Mora v. City of Los Angeles, et al., United
7 || States District Court for the Central District of California, Central Division, Case
8 || No. 2:21-CV-02115 DSF (JCx), and hereby agree to comply with and be bound by
9 || the terms and conditions of said Order.
10 I understand and acknowledge that failure to comply could expose me to
11 || sanctions and/or punishment in the nature of contempt. I promise that I will not
12 || disclose in any manner any information or item that is subject to the Protective
13 || Order to any person or entity except in compliance with the provisions of this
14 || Order.
15 I hereby consent to the jurisdiction of the United States District Court for the
16 || Central District of California for purposes of enforcing this Order, even if such
17 || enforcement proceedings occur after the termination of the Erica Mora case.
18 Dated: Signed:
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