The opinion
Case 2:20-cv-05288-FLA-E Document 38 Filed 03/15/22 Page 1 of 16 Page ID #:169
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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11 NORVELL FOBI, an individual, CASE NO. CV20-05288 FLA (Ex)
Hon. Fernando L. Aenlle-Rocha, Crtm 6B
12 Plaintiff, Mag. Charles F. Eick, Ctrm 750, 7th Floor
13 vs.
___________
[PROPOSED] STIPULATED
14 CITY OF LOS ANGELES, a PROTECTIVE ORDER
municipal entity, OFFICER WINDLE
15 HAWKINS, an individual; OFFICER
RUDY LUCERO, an individual; and
16 DOES 1 through 10, inclusive,
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Defendants.
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21 1. PURPOSES AND LIMITATIONS
22 Discovery in this action is likely to involve production of confidential, proprietary,
23 or private information for which special protection from public disclosure and from use
24 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the
25 parties hereby stipulate to and petition the Court to enter the following Stipulated
26 Protective Order. The parties acknowledge that this Stipulated Protective Order does not
27 confer blanket protections on all disclosures or responses to discovery and that the
28 protection it affords from public disclosure and use extends only to the limited information
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STIPULATED PROTECTIVE ORDER
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1 or items that are entitled to confidential treatment under the applicable legal principles.
2 The parties further acknowledge, as set forth in Section 13.3 below, that this Stipulated
3 Protective Order does not entitle them to file confidential information under seal; Civil
4 Local Rule 79-5 sets forth the procedures that must be followed and the standards that will
5 be applied when a party seeks permission from the Court to file material under seal.
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7 2. GOOD CAUSE STATEMENT
8 This action involves the City of Los Angeles and members of the Los Angeles
9 Police Department. Plaintiffs are seeking materials and information that Defendants the
10 City of Los Angeles et al. (“City”) maintain as confidential, such as personnel files of the
11 police officers involved in this incident, Internal Affairs materials and information, video
12 recordings, audio recordings, photographs, Force Investigation Division materials and
13 information and other administrative materials and information currently in the possession
14 of the City and which the City believes need special protection from public disclosure and
15 from use for any purpose other than prosecuting this litigation. Plaintiffs are also seeking
16 official information contained in the personnel files of the police officers involved in the
17 subject incident, which the City maintains as strictly confidential and which the City
18 believes need special protection from public disclosure and from use for any purpose other
19 than prosecuting this litigation.
20 The City asserts that the confidentiality of the materials and information sought by
21 Plaintiffs is recognized by California and federal law, as evidenced inter alia by California
22 Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., 511 F.2d 192,
23 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City has not publicly released the
24 materials and information referenced above except under protective order or pursuant to
25 a court order, if at all. These materials and information are of the type that has been used
26 to initiate disciplinary action against Los Angeles Police Department (“LAPD”) officers,
27 and has been used as evidence in disciplinary proceedings, where the officers’ conduct
28 was considered to be contrary to LAPD policy.
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1 The City contends that absent a protective order delineating the responsibilities of
2 nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary and
3 undue disclosure by one or more of the many attorneys, secretaries, law clerks, paralegals
4 and expert witnesses involved in this case, as well as the corollary risk of embarrassment,
5 harassment and professional and legal harm on the part of the LAPD officers referenced
6 in the materials and information.
7 The City also contends that the unfettered disclosure of the materials and
8 information, absent a protective order, would allow the media to share this information
9 with potential jurors in the area, impacting the rights of the City herein to receive a fair
10 trial.
11 Accordingly, to expedite the flow of information, to facilitate the prompt resolution
12 of disputes over confidentiality of discovery materials, to adequately protect information
13 the parties are entitled to keep confidential, to ensure that the parties are permitted
14 reasonable necessary uses of such material in preparation for and in the conduct of trial,
15 to address their handling at the end of the litigation, and serve the ends of justice, a
16 protective order for such information is justified in this matter. It is the intent of the parties
17 that information will not be designated as confidential for tactical reasons and that nothing
18 be so designated without a good faith belief that it has been maintained in a confidential,
19 non-public manner, and there is good cause why it should not be part of the public record
20 of this case.
21 Plaintiffs agree that there is Good Cause for a Protective Order so as to preserve the
22 respective interests of the parties while streamlining the process of resolving any
23 disagreements.
24 The parties therefore stipulate that there is Good Cause for, and hereby jointly
25 request that the honorable Court issue a Protective Order regarding confidential
26 documents consistent with the terms and provisions of this Stipulation. However, the entry
27 of a Protective Order by the Court pursuant to this Stipulation shall not be construed as
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STIPULATED PROTECTIVE ORDER
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1 any ruling by the Court on the aforementioned legal statements or privilege claims in this
2 section, no shall this section be construed as part of any such Court Order.
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4 3. DEFINITIONS
5 3.1 Action: This pending federal lawsuit, Norvell Fobi, v. City of Los Angeles, et
6 al. CV20-05288 FLA (Ex)
7 3.2 Challenging Party: a Party or Non-Party that challenges the designation of
8 information or items under this Order.
9 3.3 “CONFIDENTIAL” Information or Items: Information (regardless of how
10 it is generated, stored or maintained) or tangible things that qualify for protection under
11 Federal Rule of Civil Procedure 26(c), and/or applicable federal privileges, and as
12 specified above in the Good Cause Statement. This also includes (1) any information
13 copied or extracted from the Confidential information; (2) all copies, excerpts, summaries,
14 abstracts or compilations of Confidential information; and (3) any testimony,
15 conversations, or presentations that might reveal Confidential information.
16 3.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
17 support staff), including counsel of record for the parties to this civil litigation and their
18 support staff.
19 3.5 Designating Party: A Party or Nonparty that designates information or items
20 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
21 3.6 Disclosure or Discovery Material: All items or information, regardless of
22 the medium or manner in which it is generated, stored, or maintained (including, among
23 other things, testimony, transcripts, and tangible things), that are produced or generated in
24 disclosures or responses to discovery by any Party in this matter.
25 3.7 Expert: A person with specialized knowledge or experience in a matter
26 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
27 expert witness or as a consultant in this Action.
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1 3.8 Final Disposition: when this Action has been fully and completely terminated
2 by way of settlement, dismissal, trial, appeal and/or remand to state court.
3 3.9 House Counsel: Attorneys who are employees of a party to this Action.
4 House Counsel does not include Outside Counsel of Record or any other outside counsel.
5 3.10 Non-party: Any natural person, partnership, corporation, association or other
6 legal entity not named as a Party to this action.
7 3.11 Outside Counsel of Record: Attorneys who are not employees of a party to
8 this Action but are retained to represent or advise a party to this Action and have appeared
9 in this Action on behalf of that party or are affiliated with a law firm that has appeared on
10 behalf of that party, and includes support staff.
11 3.12 Party: Any party to this Action, including all of its officers, directors, boards,
12 departments, divisions, employees, consultants, retained experts, House Counsel, and
13 Outside Counsel of Record (and their support staffs).
14 3.13 Producing Party: A Party or Nonparty that produces Disclosure or Discovery
15 Material in this Action, including a Party that is defending a deposition noticed or
16 subpoenaed by another Party.
17 3.14 Professional Vendors: Persons or entities that provide litigation support
18 services (e.g., photocopying, videotaping, translating, preparing exhibits or
19 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
20 their employees and subcontractors.
21 3.15 Protected Material: Any Disclosure or Discovery Material that is designated
22 as “CONFIDENTIAL.” (The term “Confidential Document” shall be synonymous with
23 the term “Protected Material” for the purposes of this Stipulation and any associated
24 Protective Order.)
25 3.16 Receiving Party: A Party that receives Disclosure or Discovery Material
26 from a Producing Party, including a Party that has noticed or subpoenaed and is taking a
27 deposition or comparable testimony.
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STIPULATED PROTECTIVE ORDER
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1 4. SCOPE
2 The protections conferred by this Stipulated and Order cover not only Protected
3 Material (as defined above), but also (1) any information copied or extracted from
4 Protected Material; (2) all copies, excerpts, abstracts, summaries, or compilations of
5 Protected Material; and (3) any testimony, conversations, or presentations by Parties or
6 their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the trial
8 judge. This Order does not govern the use of Protected Material at trial.
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10 5. DURATION
11 Even after Final Disposition, as set forth in Section 3.8 above, of this litigation, the
12 confidentiality obligations imposed by this Order shall remain in effect until a Designating
13 Party agrees otherwise in writing or a court order otherwise directs. Final disposition of
14 this pending federal Action shall be deemed to be the later of (1) dismissal of all claims
15 and defenses in this Action, with or without prejudice; and (2) final judgment herein after
16 the completion and exhaustion of all appeals, rehearings, remands (as it relates to appeals
17 of this federal Action), trials, or reviews of this Action, including the time limits for filing
18 any motions or applications for extension of time pursuant to applicable law.
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20 6. DESIGNATING PROTECTED MATERIAL
21 6.1 Exercise of Restraint and Care in Designating Material for Protection.
22 Each Party or Nonparty that designates information or items for protection under
23 this Order must take care to limit any such designation to specific material that qualifies
24 under the appropriate standards. The Designating Party must designate for protection only
25 those parts of material, documents, items or oral or written communications that qualify
26 so that other portions of the material, documents, items or communications for which
27 protection is not warranted are not swept unjustifiably within the ambit of this Order.
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STIPULATED PROTECTIVE ORDER
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1 Mass, indiscriminate or routinized designations are prohibited. Designations that
2 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
3 to unnecessarily encumber the case development process or to impose unnecessary
4 expenses and burdens on other parties) may expose the Designating Party to sanctions.
5 If it comes to a Designating Party’s attention that information or items that it
6 designated for protection do not qualify for protection, that Designating Party must
7 promptly notify all other Parties that it is withdrawing the inapplicable designation.
8 6.2 Manner and Timing of Designations. Except as otherwise provided in this
9 Order(see, e.g., second paragraph of section 6.2(a) below), or as otherwise stipulated or
10 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
11 must be clearly so designated before the material is disclosed or produced.
12 Designation in conformity with this Order requires:
13 (a) for information in documentary form (e.g., paper or electronic documents, but
14 excluding transcripts of depositions or other pretrial or trial proceedings), that the
15 Producing Party affix at a minimum, the legend “CONFIDENTIAL” of a similar effect,
16 and that includes the case name and case number (hereinafter “CONFIDENTIAL
17 legend”), to each page that contains protected material. If only a portion of the material
18 on a page qualifies for protection, the Producing Party also must clearly identify the
19 protected portion(s) (e.g., by making appropriate markings in the margins).
20 A Party or Nonparty that makes original documents available for inspection
21 need not designate them for protection until after the inspecting Party has indicated which
22 documents it would like copied and produced. During the inspection and before the
23 designation, all of the material made available for inspection shall be deemed
24 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
25 copied and produced, the Producing Party must determine which documents, or portions
26 thereof, qualify for protection under this Order. Then, before producing the specified
27 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
28 that contains Protected Material. If only a portion of the material on a page qualifies for
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STIPULATED PROTECTIVE ORDER
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1 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by
2 making appropriate markings in the margins).
3 (b) for testimony given in depositions that the Designating Party identifies the
4 Disclosure or Discovery Material on the record, before the close of the deposition all
5 protected testimony.
6 (c) for information produced in some form other than documentary and for any
7 other tangible items, that the Producing Party affix in a prominent place on the exterior of
8 the container or containers in which the information is stored the legend
9 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,
10 the Producing Party, to the extent practicable, shall identify the protected portion(s).
11 6.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
12 failure to designate qualified information or items does not, standing alone, waive the
13 Designating Party’s right to secure protection under this Order for such material. Upon
14 timely correction of a designation, the Receiving Party must make reasonable efforts to
15 assure that the material is treated in accordance with the provisions of this Order.
16 6.4 Alteration of Confidentiality Stamp Prohibited. A Receiving Party shall
17 not alter, edit, or modify any Protected Material so as to conceal, obscure, or remove a
18 “CONFIDENTIAL” stamp or legend thereon; nor shall a Receiving Party take any other
19 action so as to make it appear that Protected Material is not subject to the terms and
20 provisions of this Stipulation and its associated Order. However, nothing in this section
21 shall be construed so as to prevent a Receiving Party from challenging a confidentiality
22 designation subject to the provisions of section 7, infra.
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24 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS
25 7.1 Timing of Challenges. Any Party or Nonparty may challenge a designation
26 of confidentiality at any time that is consistent with the Court’s Scheduling Order.
27 7.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
28 process under Local Rule 37.1 et seq.
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STIPULATED PROTECTIVE ORDER
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1 7.3 Burden of Persuasion. The burden of persuasion in any such challenge
2 proceeding shall be on the Designating Party. Frivolous challenges, and those made for
3 an improper purpose (e.g., to harass or impose unnecessary expenses and burdens on other
4 parties) may expose the Challenging Party to sanctions. Unless the Designating Party has
5 waived or withdrawn the confidentiality designation, all parties shall continue to afford
6 the material in question the level of protection to which it is entitled under the Producing
7 Party’s designation until the Court rules on the challenge.
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9 8. ACCESS TO AND USE OF PROTECTED MATERIAL
10 8.1 Basic Principles. A Receiving Party may use Protected Material that is
11 disclosed or produced by another Party or by a Nonparty in connection with this Action
12 only for prosecuting, defending or attempting to settle this Action. Such Protected
13 Material may be disclosed only to the categories of persons and under the conditions
14 described in this Order. When the Action has been terminated, a Receiving Party must
15 comply with the provisions of section 14 below (FINAL DISPOSITION).
16 Protected Material must be stored and maintained by a Receiving Party at a
17 location and in a secure manner that ensures that access is limited to the persons authorized
18 under this Order.
19 8.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
20 otherwise ordered by the court or permitted in writing by the Designating Party, a
21 Receiving Party may disclose any information or item designated “CONFIDENTIAL”
22 only to:
23 (a) The Receiving Party’s Outside Counsel of Record in this Action, as well as
24 employees of said Outside Counsel of Record to whom it is reasonably necessary to
25 disclose the information for this Action;
26 (b) The officers, directors, and employees (including House Counsel) of the
27 Receiving Party to whom disclosure is reasonably necessary for this Action;
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STIPULATED PROTECTIVE ORDER
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1 (c) Experts of the Receiving Party to whom disclosure is reasonably necessary for
2 this Action and who have signed the “Acknowledgment and Agreement to Be Bound”
3 (Exhibit A);
4 (d) The Court and its personnel;
5 (e) Court reporters and their staff;
6 (f) Professional jury or trial consultants, mock jurors, and Professional Vendors to
7 whom disclosure is reasonably necessary for this Action and who have signed the
8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (g) The author or recipient of a document containing the information or a custodian
10 or other person who otherwise possessed or knew the information;
11 (h) During their depositions, witnesses, and attorneys for witnesses, in the Action
12 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that
13 the witness sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2)
14 they will not be permitted to keep any confidential information unless they sign the
15 “Acknowledgment and Agreement to Be Bound,” unless otherwise agreed by the
16 Designating Party or ordered by the Court. Pages of transcribed deposition testimony or
17 exhibits to depositions that reveal Protected Material may be separately bound by the court
18 reporter and may not be disclosed to anyone except as permitted under this Stipulated
19 Protective Order; and
20 (i) Any mediator or settlement officer, and their supporting personnel,
21 mutually agreed upon by any of the parties engaged in settlement discussions and who
22 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A).
23 8.3. Retention of Signed Agreement to Be Bound (Exhibit A). Counsel making
24 the disclosure to any qualified person described herein shall retain the original executed
25 copy of the “Acknowledgment and Agreement to Be Bound” (Exhibit A) until sixty (60)
26 days after this litigation has become final, including any appellate review, and monitoring
27 of an injunction. Counsel for the Receiving Party shall maintain all signed Nondisclosure
28 Agreements and shall produce the original signature page upon reasonable written notice
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STIPULATED PROTECTIVE ORDER
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1 from opposing counsel. If an issue arises regarding a purported unauthorized disclosure
2 of Confidential Information, upon noticed motion of contempt filed by the Designating
3 Party, counsel for the Receiving Party may be required to file the signed
4 “Acknowledgment and Agreement to Be Bound”, as well as a list of the disclosed
5 materials, in camera with the Court having jurisdiction of the Stipulation.
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7 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
8 OTHER LITIGATION
9 If a Party is served with a subpoena or a court order issued in other litigation that
10 compels disclosure of any information or items designated in this Action as
11 “CONFIDENTIAL,” that Party must:
12 (a) Promptly notify in writing the Designating Party. Such notification shall
13 include a copy of the subpoena or court order;
14 (b) Promptly notify in writing the party who caused the subpoena or order to issue
15 in the other litigation that some or all of the material covered by the subpoena or order is
16 subject to this Stipulated Protective Order. Such notification shall include a copy of this
17 Stipulated Protective Order; and
18 (c) Cooperate with respect to all reasonable procedures sought to be pursued by the
19 Designating Party whose Protected Material may be affected.
20 If the Designating Party timely seeks a protective order, the Party served with the
21 subpoena or court order shall not produce any information designated in this action as
22 “CONFIDENTIAL” before a determination by the court from which the subpoena or order
23 issued, unless the Party has obtained the Designating Party’s permission. The Designating
24 Party shall bear the burden and expense of seeking protection in that court of its
25 confidential material and nothing in these provisions should be construed as authorizing
26 or encouraging a Receiving Party in this Action to disobey a lawful directive from another
27 court.
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STIPULATED PROTECTIVE ORDER
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1 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
2 IN THIS LITIGATION
3 10.1 Application. The terms of this Stipulated Protective Order are applicable to
4 information produced by a Non-Party in this Action and designated as
5 “CONFIDENTIAL.” Such information produced by Non-parties in connection with this
6 litigation is protected by the remedies and relief provided by this Stipulated Protective
7 Order. Nothing in these provisions should be construed as prohibiting a Non-party from
8 seeking additional protections.
9 10.2 Notification. In the event that a Party is required, by a valid discovery request,
10 to produce a Non-party’s confidential information in its possession, and the Party is
11 subject to an agreement with the Non-party not to produce the Non-party’s confidential
12 information, then the Party shall:
13 (1) Promptly notify in writing the Requesting Party and the Non-party that some
14 or all of the information requested is subject to a confidentiality agreement with a Non-
15 party;
16 (2) Promptly provide the Non-party with a copy of the Stipulated Protective Order
17 in this Action, the relevant discovery request(s), and a reasonably specific description of
18 the information requested; and
19 (3) Make the information requested available for inspection by the Non-party, if
20 requested.
21 10.3 Conditions of Production. If the Non-party fails to seek a protective order
22 from this Court within fourteen (14) days of receiving the notice and accompanying
23 information, the Receiving Party may produce the Non-party’s confidential information
24 responsive to the discovery request. If the Non-party timely seeks a protective order, the
25 Receiving Party shall not produce any information in its possession or control that is
26 subject to the confidentiality agreement with the Non-party before a determination by the
27 Court. 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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STIPULATED PROTECTIVE ORDER
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1 11. 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 writing
5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
6 all unauthorized copies of the Protected Material, (c) inform the person or persons to
7 whom unauthorized disclosures were made of all the terms of this Stipulated Protective
8 Order, and (d) request such person or persons to execute the “Acknowledgment and
9 Agreement to Be Bound” (Exhibit A).
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11 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
12 PROTECTED MATERIAL
13 When a Producing Party gives notice to Receiving Parties that certain inadvertently
14 produced material is subject to a claim of privilege or other protection, the obligations of
15 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
16 This provision is not intended to modify whatever procedure may be established in an e-
17 discovery order that provides for production without prior privilege review. Pursuant to
18 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the
19 effect of disclosure of a communication or information covered by the attorney-client
20 privilege or work product protection, the parties may incorporate their agreement in the
21 Stipulated Protective Order submitted to the Court.
22
23 13. MISCELLANEOUS
24 13.1 Right to Further Relief. Nothing in this Stipulated Protective Order abridges
25 the right of any person to seek its modification by the Court in the future.
26 13.2 Right to Assert Other Objections. By stipulating to the entry of this
27 Stipulated Protective Order, no Party waives any right it otherwise would have to object
28 to disclosing or producing any information or item on any ground not addressed in this
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STIPULATED PROTECTIVE ORDER
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1 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground
2 to use in evidence of any of the material covered by this Stipulated Protective Order.
3 13.3 Filing Protected Material. A Party that seeks to file under seal any Protected
4 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed
5 under seal pursuant to a court order authorizing the sealing of the specific Protected
6 Material at issue. If a Party’s request to file Protected Material under seal is denied by the
7 court, then the Receiving Party may file the information in the public record unless
8 otherwise instructed by the Court.
9
10 14. FINAL DISPOSITION
11 After the FINAL DISPOSITION of this Action, as defined in paragraph 3.8, within
12 sixty (60) days of a written request by the Designating Party, each Receiving Party must
13 return all Protected Material to the Producing Party. As used in this subdivision, “all
14 Protected Material” includes all copies, abstracts, compilations, summaries, and any other
15 format reproducing or capturing any of the Protected Material. The Receiving Party must
16 submit a written certification to the Producing Party (and, if not the same person or entity,
17 to the Designating Party) by the 60-day deadline that (1) identifies (by category, where
18 appropriate) all the Protected Material that was returned and (2) affirms that the Receiving
19 Party has not retained any copies, abstracts, compilations, summaries or any other format
20 reproducing or capturing any of the Protected Material. Notwithstanding this provision,
21 Counsel is entitled to retain an archival copy of all pleadings; motion papers; trial,
22 deposition, and hearing transcripts; legal memoranda; correspondence; deposition and
23 trial exhibits; expert reports; attorney work product; and consultant and expert work
24 product, even if such materials contain Protected Material. Any such archival copies that
25 contain or constitute Protected Material remain subject to this Stipulated Protective Order
26 as set forth in Section 5 (DURATION).
27 / / /
28 / / /
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STIPULATED PROTECTIVE ORDER
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1 15. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished by any and all
3 appropriate measures including, without limitation, contempt proceedings and/or
4 monetary sanctions.
5
6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD:
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Dated: March 14, 2022 THE COCHRAN FIRM CALIFORNIA
9
By: /s/ Brian T. Dunn
10 BRIAN T. DUNN
EDWARD M. LYMAN
11 Attorneys for Plaintiff NORVELL FOBI
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13 Dated: March 14, 2022 MICHAEL N. FEUER, City Attorney
SCOTT MARCUS, Chief Asst. City Attorney
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CORY M. BRENTE,Senior Asst. City Attorney
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By: /s/ Colleen R. Smith
16 COLLEEN R. SMITH, Deputy City Attorney
Attorneys for Defendants, CITY OF LOS
17 ANGELES, et al.
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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21 Dated: 3/15/22 /s/ CHARLES F. EICK
HONORABLE CHARLES F. EICK
22
UNITED STATES MAGISTRATE JUDGE
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STIPULATED PROTECTIVE ORDER
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1 ATTACHMENT “A”
2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
3
4 I, [full name], of
5 [address], declare under penalty of perjury that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States District
7 Court for the Central District of California on [date] in the case of Norvell
8 Fobi, et al. v. City of Los Angeles, et al, United States District Court for the Central District
9 of California, Central Division, Case No. CV20-05288 FLA (Ex). I agree to comply with
10 and to be bound by all the terms of this Stipulated Protective Order, and I understand and
11 acknowledge that failure to so comply could expose me to sanctions and punishment in
12 the nature of contempt. I solemnly promise that I will not disclose in any manner any
13 information or item that is subject to this Stipulated Protective Order to any person or
14 entity except in strict compliance with the provisions of this Stipulated Protective Order.
15 I further agree to submit to the jurisdiction of the United States District Court for
16 the Central District of California for the purpose of enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of this
18 action. I hereby appoint [full name] of
19 [address and telephone number] as my California agent for
20 service of process in connection with this action or any proceedings related to enforcement
21 of this Stipulated Protective Order.
22
23 Signature:
24 Printed Name:
25 Date:
26 City and State Where Sworn and Signed:
27
28
16
STIPULATED PROTECTIVE ORDER