# Lowry McCray v. Westrock Services, LLC

> District Court, C.D. California · March 16, 2022

URL: https://www.frixlaw.com/law-library/cases/9979383

## Case

- **Court:** District Court, C.D. California
- **Decided:** March 16, 2022
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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-1-
STIPULATED PROTECTIVE ORDER
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Case 2:21-cv-09853-DMG-RAO Document 21 Filed 03/16/22 Page 1 of 18 Page ID #:284
LINH T. HUA (SBN: 247419)
lhua@grsm.com
WANJA S. GUY (SBN: 275734)
lhua@grsm.com
GORDON REES SCULLY MANSUKHANI, LLP
633 West Fifth Street, 52nd floor
Los Angeles, CA 90071
Telephone: (213) 270-7851
Facsimile: (213) 680-4470
Attorneys for Defendant
WESTROCK SERVICES, LLC
SHADIE L. BERENJI (SBN 235021)
berenji@employeejustice.law
DAVID C. HOPPER (SBN 306281)
hopper@employeejustice.law
KRISTOPHER N. TAYYEB (SBN 320126)
tayyeb@employeejustice.law
BERENJI LAW FIRM, APC
8383 Wilshire Boulevard, Suite 708
Beverly Hills, California 90211
Telephone: (310) 855-3270
Facsimile: (310) 855-3751
Attorneys for Plaintiff,
LOWRY MCCRAY
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
LOWRY MCCRAY, an individual ) CASE NO. 2:21-cv-09853 DMG (RAOx
)
Plaintiff, ) Hon. Judge: Dolly M. Gee
) Courtroom: 8C
vs. )
)
WESTROCK SERVICES, LLC, a STIPULATED PROTECTIVE
)
California limited liability company; ORDER )
and Does 1 through 30, inclusive,
)
Defendants. )
) Complaint filed: 11/19/2021
)
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STIPULATED PROTECTIVE ORDER
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Counsel for Plaintiff LOWRY MCCRAY (“Plaintiff) and Defendant
WESTROCK SERVICES, LLC (“Defendant”) jointly stipulate to the entry of
this Proposed Protective Order:
1. A. PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,
proprietary, or private information for which special protection from public
disclosure and from use for any purpose other than prosecuting this litigation
may be warranted. Accordingly, the parties hereby stipulate to and petition the
Court to enter the following Stipulated Protective Order. The parties
acknowledge that this Order does not confer blanket protections on all
disclosures or responses to discovery and that the protection it affords from
public disclosure and use extends only to the limited information or items that
are entitled to confidential treatment under the applicable legal principles. The
parties further acknowledge, as set forth in Section 12.3, below, that this Order
does not entitle them to file confidential information under seal. Rather, when
the parties seek permission from the court to file material under seal, the parties
must comply with Civil Local Rule 79-5 and with any pertinent orders of the
assigned District Judge and Magistrate Judge.
B. GOOD CAUSE STATEMENT
During the course of discovery it may be necessary to disclose certain
confidential information relating to the subject matter of this action. Such
confidential and proprietary materials and information consist of, among other
things, confidential business or financial information, information regarding
confidential business practices, or other confidential research, development, or
commercial information, otherwise generally unavailable to the public, or which
may be privileged or otherwise protected from disclosure under state or federal
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STIPULATED PROTECTIVE ORDER
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statutes, court rules, case decisions, or common law (such as personal medical or
financial information, including that of third-parties). Accordingly, to expedite
the flow of information, to facilitate the prompt resolution of disputes over
confidentiality of discovery materials, to adequately protect information the
parties are entitled to keep confidential, to ensure that the parties are permitted
reasonable necessary uses of such material in preparation for and in the conduct
of trial, to address their handling at the end of the litigation, and serve the ends of
justice, a protective order for such information is justified in this matter. It is the
intent of the parties that information will not be designated as confidential for
tactical reasons and that nothing be so designated without a good faith belief that
it has been maintained in a confidential, non-public manner, and there is good
cause why it should not be part of the public record of this case.
Accordingly, the parties respectfully submit that there is good cause for
the entry of this Protective Order.
C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
SEAL
The parties further acknowledge, as set forth in Section 12.3, below, that
this Stipulated Protective Order does not entitle them to file confidential
information under seal; Local Civil Rule 79-5 sets forth the procedures that must
be followed and the standards that will be applied when a party seeks permission
from the court to file material under seal.
There is a strong presumption that the public has a right of access to
judicial proceedings and records in civil cases. In connection with non-
dispositive motions, good cause must be shown to support a filing under seal.
See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir.
2006); Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002);
Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999)
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-4-
STIPULATED PROTECTIVE ORDER
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(even stipulated protective orders require good cause showing), and a specific
showing of good cause or compelling reasons with proper evidentiary support
and legal justification, must be made with respect to Protected Material that a
party seeks to file under seal. The parties’ mere designation of Disclosure or
Discovery Material as CONFIDENTIAL does not—without the submission of
competent evidence by declaration, establishing that the material sought to be
filed under seal qualifies as confidential, privileged, or otherwise protectable—
constitute good cause.
Further, if a party requests sealing related to a dispositive motion or trial,
then compelling reasons, not only good cause, for the sealing must be shown,
and the relief sought shall be narrowly tailored to serve the specific interest to be
protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.
2010). For each item or type of information, document, or thing sought to be
filed or introduced under seal in connection with a dispositive motion or trial, the
party seeking protection must articulate compelling reasons, supported by
specific facts and legal justification, for the requested sealing order. Again,
competent evidence supporting the application to file documents under seal must
be provided by declaration.
Any document that is not confidential, privileged, or otherwise protectable
in its entirety will not be filed under seal if the confidential portions can be
redacted. If documents can be redacted, then a redacted version for public
viewing, omitting only the confidential, privileged, or otherwise protectable
portions of the document shall be filed. Any application that seeks to file
documents under seal in their entirety should include an explanation of why
redaction is not feasible.
2. DEFINITIONS
2.1 Action: The instant action: Lowry McCray v. WestRock Services,
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STIPULATED PROTECTIVE ORDER
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LLC., et al, Case No. 2:21-cv-09853 DMG.
2.2 Challenging Party: a Party or Non-Party that challenges the
designation of information or items under this Order.
2.3 “CONFIDENTIAL” Information or Items: information (regardless
of how it is generated, stored or maintained) or tangible things that qualify for
protection under Federal Rule of Civil Procedure 26(c), and as specified above in
the Good Cause Statement. The following Disclosure or Discovery Material
may be designated as “CONFIDENTIAL”: trade secrets as defined in California
Civil Code section 3426.1(d), proprietary information, medical records, financial
records, technical knowledge, unpatented inventions, patent applications,
technical development plans and notes, manufacturing secrets, secret processes,
formulae, manufacturing procedures, methods and current and accumulated
experience which the Designating Party has acquired as the result of scientific
research or experience, as well as confidential information relating to the
Designating Party’s future market plans, proprietary data and/or other technical,
commercial, business or financial information, and non-public information
concerning Defendant’s current and/or former employees’ and other individuals,
such as social security numbers and private information contained in personnel
files. Nothing in this Order shall be used to restrict the Designating Party’s use of
its own CONFIDENTIAL Information.
2.4 Counsel: Counsel of Record and House Counsel (as well as their
support staff).
2.5 Designating Party: a Party or Non-Party that designates information
or items that it (or another Party or Non-Party produces) produces in disclosures
or in responses to discovery as “CONFIDENTIAL.”
2.6 Disclosure or Discovery Material: all items or information,
regardless of the medium or manner in which it is generated, stored, or
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maintained (including, among other things, testimony, transcripts, and tangible
things), that are produced or generated in disclosures or responses to discovery in
this matter.
2.7 Expert: a person with specialized knowledge or experience in a
matter pertinent to the litigation who has been retained by a Party or its counsel
to serve as an expert witness or as a consultant in this Action.
2.8 House Counsel: attorneys who are employees of a party to this
Action. House Counsel does not include Outside Counsel of Record or any other
outside counsel.
2.9 Non-Party: any natural person, partnership, corporation, association,
or other legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: attorneys who are not employees of a
party to this Action but are retained to represent or advise a party to this Action
and have appeared in this Action on behalf of that party or are affiliated with a
law firm which has appeared on behalf of that party, and includes support staff.
2.11 Party: any party to this Action, including all of its officers, directors,
employees, consultants, retained experts, and Outside Counsel of Record (and
their support staffs).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
2.13 Professional Vendors: persons or entities that provide litigation
support services (e.g., photocopying, videotaping, translating, preparing exhibits
or demonstrations, and organizing, storing, or retrieving data in any form or
medium) and their employees and subcontractors.
2.14 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery
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STIPULATED PROTECTIVE ORDER
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Material from a Producing Party.
3. SCOPE
The protections conferred by this Order cover not only Protected Material
(as defined above), but also (1) any information copied or extracted from
Protected Material; (2) all copies, excerpts, summaries, or compilations of
Protected Material; and (3) any testimony, conversations, or presentations by
Parties or their Counsel that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders of
the trial judge. This Order does not govern the use of Protected Material at trial.
4. DURATION
Once a case proceeds to trial, information that was designated as
CONFIDENTIAL or maintained pursuant to this protective order used or
introduced as an exhibit at trial becomes public and will be presumptively
available to all members of the public, including the press, unless compelling
reasons supported by specific factual findings to proceed otherwise are made to
the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
(distinguishing “good cause” showing for sealing documents produced in
discovery from “compelling reasons” standard when merits-related documents
are part of court record). Accordingly, the terms of this protective order do not
extend beyond the commencement of the trial.
5. DESIGNATING PROTECTED MATERIAL
5.1 Exercise of Restraint and Care in Designating Material for
Protection. Each Party or Non-Party that designates information or items for
protection under this Order must take care to limit any such designation to
specific material that qualifies under the appropriate standards. The Designating
Party must designate for protection only those parts of material, documents,
items, or oral or written communications that qualify so that other portions of the
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material, documents, items, or communications for which protection is not
warranted are not swept unjustifiably within the ambit of this Order.
Mass, indiscriminate, or routinized designations are prohibited.
Designations that are shown to be clearly unjustified or that have been made for
an improper purpose (e.g., to unnecessarily encumber the case development
process or to impose unnecessary expenses and burdens on other parties) may
expose the Designating Party to sanctions.
If it comes to a Designating Party’s attention that information or items that
it designated for protection do not qualify for protection, that Designating Party
must promptly notify all other Parties that it is withdrawing the inapplicable
designation.
5.2 Manner and Timing of Designations. Except as otherwise provided
in this Order (see, e.g., second or third paragraphs of Section 5.2(a) below), or as
otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies
for protection under this Order must be clearly so designated before the material
is disclosed or produced.
Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic
documents, but excluding transcripts of depositions or other pretrial or trial
proceedings), that the Producing Party affix at a minimum, the legend
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
contains protected material. If only a portion or portions of the material on a
page qualifies for protection, the Producing Party also must clearly identify the
protected portion(s) (e.g., by making appropriate markings in the margins).
A Party or Non-Party that makes original documents available for
inspection need not designate them for protection until after the inspecting Party
has indicated which documents it would like copied and produced. During the
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inspection and before the designation, all of the material made available for
inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
identified the documents it wants copied and produced, the Producing Party must
determine which documents, or portions thereof, qualify for protection under this
Order. Then, before producing the specified documents, the Producing Party
must affix the “CONFIDENTIAL legend” to each page that contains Protected
Material. If only a portion or portions of the material on a page qualifies for
protection, the Producing Party also must clearly identify the protected portion(s)
(e.g., by making appropriate markings in the margins).
Should a Party wish to designate any Disclosure or Discovery Material
produced by another Party or Non-Party as “CONFIDENTIAL,” the Designating
Party shall, within ten (10) business days after the production to that Party, or the
date that the Parties receive notice that this Protective Order has been signed by
the Court, whichever is later (the “Effective Date”), provide written notice to
counsel of record for all Parties of the bates-numbers or number range or other
sufficiently definite description of the Documents, Testimony, or Information to
be designated “Confidential.” The Documents, Testimony, or Information shall
not be distributed to persons beyond those specified in Section 7.2, supra, until ten
(10) business days after the production or the Effective Date, whichever is later,
to give Parties an opportunity to review and designate Documents, Testimony, or
Information as “Confidential” prior to further dissemination.
(b) for testimony given in depositions that the Designating Party identifies
on the record, before the close of the deposition as protected testimony.
(c) for information produced in some form other than documentary and
for any other tangible items, that the Producing Party affix in a prominent place
on the exterior of the container or containers in which the information is stored
the legend “CONFIDENTIAL.” If only a portion or portions of the information
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warrants protection, the Producing Party, to the extent practicable, shall identify
the protected portion(s).
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
failure to designate qualified information or items does not, standing alone,
waive the Designating Party’s right to secure protection under this Order for such
material. Upon timely correction of a designation, the Receiving Party must
make reasonable efforts to assure that the material is treated in accordance with
the provisions of this Order.
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
designation of confidentiality at any time that is consistent with the Court’s
Scheduling Order.
6.2 Meet and Confer. The Challenging Party shall initiate the dispute
resolution process under Local Rule 37-1 et seq.
6.3 The burden of persuasion in any such challenge proceeding shall be
on the Designating Party. Frivolous challenges, and those made for an improper
purpose (e.g., to harass or impose unnecessary expenses and burdens on other
parties) may expose the Challenging Party to sanctions. Unless the Designating
Party has waived or withdrawn the confidentiality designation, all parties shall
continue to afford the material in question the level of protection to which it is
entitled under the Producing Party’s designation until the Court rules on the
challenge
7. ACCESS TO AND USE OF PROTECTED MATERIAL
7.1 Basic Principles. A Receiving Party may use Protected Material that
is disclosed or produced by another Party or by a Non-Party in connection with
this Action only for prosecuting, defending, or attempting to settle this Action.
Such Protected Material may be disclosed only to the categories of persons and
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under the conditions described in this Order. When the Action has been
terminated, a Receiving Party must comply with the provisions of Section 13
below.
Protected Material must be stored and maintained by a Receiving Party at
a location and in a secure manner that ensures that access is limited to the
persons authorized under this Order.
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
otherwise ordered by the court or permitted in writing by the Designating Party,
a Receiving Party may disclose any information or item designated
“CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as
well as employees of said Outside Counsel of Record to whom it is reasonably
necessary to disclose the information for this Action;
(b) the officers, directors, and employees (including House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this Action;
(c) Experts (as defined in this Order) of the Receiving Party to whom
disclosure is reasonably necessary for this Action and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(d) the court and its personnel;
(e) court reporters and their staff;
(f) professional jury or trial consultants, mock jurors, and Professional
Vendors to whom disclosure is reasonably necessary for this Action and who
have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses, and attorneys for witnesses, in the
Action to whom disclosure is reasonably necessary provided: (1) the deposing
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party requests that the witness sign the “Acknowledgment and Agreement to Be
Bound” form attached as Exhibit A hereto; and (2) they will not be permitted to
keep any confidential information unless they sign the “Acknowledgment and
Agreement to Be Bound” attached as Exhibit A, unless otherwise agreed by the
Designating Party or ordered by the court. Pages of transcribed deposition
testimony or exhibits to depositions that reveal Protected Material may be
separately bound by the court reporter and may not be disclosed to anyone
except as permitted under this Protective Order; and
(i) any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions.
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
IN OTHER LITIGATION
If a Party is served with a subpoena or a court order issued in other
litigation that compels disclosure of any information or items designated in this
Action as “CONFIDENTIAL,” that Party must:
(a) promptly notify in writing the Designating Party. Such notification
shall include a copy of the subpoena or court order unless prohibited by law;
(b) promptly notify in writing the party who caused the subpoena or order
to issue in the other litigation that some or all of the material covered by the
subpoena or order is subject to this Protective Order. Such notification shall
include a copy of this Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be
pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served
with the subpoena or court order shall not produce any information designated in
this action as “CONFIDENTIAL” before a determination by the court from
which the subpoena or order issued, unless the Party has obtained the
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Designating Party’s permission, or unless otherwise required by the law or court
order. The Designating Party shall bear the burden and expense of seeking
protection in that court of its confidential material and nothing in these
provisions should be construed as authorizing or encouraging a Receiving Party
in this Action to disobey a lawful directive from another court.

9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a
Non-Party in this Action and designated as “CONFIDENTIAL.” Such
information produced by Non-Parties in connection with this litigation is
protected by the
remedies and relief provided by this Order. Nothing in these provisions should be
construed as prohibiting a Non-Party from seeking additional protections.
(b) In the event that a Party is required, by a valid discovery request, to
produce a Non-Party’s confidential information in its possession, and the Party is
subject to an agreement with the Non-Party not to produce the Non-Party’s
confidential information, then the Party shall:
(1) promptly notify in writing the Requesting Party and the Non-
Party that some or all of the information requested is subject to a confidentiality
agreement with a Non-Party;
(2) promptly provide the Non-Party with a copy of the Protective
Order in this Action, the relevant discovery request(s), and a reasonably specific
description of the information requested; and
(3) make the information requested available for inspection by the
Non-Party, if requested.
(c) If a Non-Party represented by counsel fails to commence the process
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called for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving the
notice and accompanying information or fails contemporaneously to notify the
Receiving Party that it has done so, the Receiving Party may produce the Non-
Party’s confidential information responsive to the discovery request. If an
unrepresented Non-Party fails to seek a protective order from this court within 14
days of receiving the notice and accompanying information, the Receiving Party
may produce the Non-Party’s confidential information responsive to the
discovery request. If the Non-Party timely seeks a protective order, the
Receiving Party shall not produce any information in its possession or control
that is subject to the confidentiality agreement with the Non-Party before a
determination by the court unless otherwise required by the law or court order.
Absent a court order to the contrary, the Non-Party shall bear the burden and
expense of seeking protection in this court of its Protected Material.
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has
disclosed Protected Material to any person or in any circumstance not authorized
under this Protective Order, the Receiving Party must immediately (a) notify in
writing the Designating Party of the unauthorized disclosures, (b) use its best
efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
the person or persons to whom unauthorized disclosures were made of all the
terms of this Order, and (d) request such person or persons to execute the
“Acknowledgment and Agreement to Be Bound” that is attached hereto as
Exhibit A.
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain
inadvertently produced material is subject to a claim of privilege or other
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protection, the obligations of the Receiving Parties are those set forth in Federal
Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
whatever procedure may be established in an e-discovery order that provides for
production without prior privilege review. Pursuant to Federal Rule of Evidence
502(d) and (e), insofar as the parties reach an agreement on the effect of
disclosure of a communication or information covered by the attorney-client
privilege or work product protection, the parties may incorporate their agreement
into this Protective Order.
12. MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of
any person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. No Party waives any right it
otherwise would have to object to disclosing or producing any information or
item on any ground not addressed in this Protective Order. Similarly, no Party
waives any right to object on any ground to use in evidence of any of the
material covered by this Protective Order.
12.3 Filing Protected Material. A Party that seeks to file under seal any
Protected Material must comply with Civil Local Rule 79-5 and with any
pertinent orders of the assigned District Judge and Magistrate Judge. If a Party's
request to file Protected Material under seal is denied by the court, then the
Receiving Party may file the information in the public record unless otherwise
instructed by the court.
13. FINAL DISPOSITION
After the final disposition of this Action, as defined in Section 4, within 60
days of a written request by the Designating Party, each Receiving Party must
return all Protected Material to the Producing Party or destroy such material. As
used in this subdivision, “all Protected Material” includes all copies, abstracts,
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compilations, summaries, and any other format reproducing or capturing any of
the Protected Material. Whether the Protected Material is returned or destroyed,
the Receiving Party must submit a written certification to the Producing Party
(and, if not the same person or entity, to the Designating Party) by the 60 day
deadline that (1) identifies (by category, where appropriate) all the Protected
Material that was returned or destroyed and (2) affirms that the Receiving Party
has not retained any copies, abstracts, compilations, summaries or any other
format reproducing or capturing any of the Protected Material. Notwithstanding
this provision, Counsel are entitled to retain an archival copy of all pleadings,
motion papers, trial, deposition, and hearing transcripts, legal memoranda,
correspondence, deposition and trial exhibits, expert reports, attorney work
product, and consultant and expert work product, even if such materials contain
Protected Material. Any such archival copies that contain or constitute Protected
Material remain subject to this Protective Order as set forth in Section 4.
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Case 2:2fl-cv-09853-DMG-RAO Document 21 Filed 03/16/22 Page 17o0f18 Page ID #:300

1 . . . . .
14. Any violation of this Order may be punished by any and all appropriate
measures including, without limitation, contempt proceedings and/or monetary
3 .
sanctions.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD:
6 .
Respectfully submitted,
7 || Dated: March 16, 2022 GORDON REES SCULLY MANSUKHANI, LLP
By: /s/ Wanja Guy
9 Linh T. Hua
10 Wanja S. Guy
Attorneys for Defendant
a 11 WESTROCK SERVICES, LLC
a:
= 8 12
= = Dated: March 16, 2022 BERENJI LAW FIRM, APC
#62 13
zs 14 By: /s/Kristopher Tayyeb
Bas Shadie L. Berenji
ge 2 15 David C. Hopper
S32 16 Kristopher N. Tayyeb
= Attorneys for Plaintiff
ES 17 LOWRY MCCRAY
° 18
IT IS SO ORDERED.
19
Re a, Q2-~
21 |! Dated: March 16, 2022 eee
22 MAGISTRATE JUDGE ROZELLA A. OLIVER
UNITED STATES DISTRICT COURT
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STIPULATED PROTECTIVE ORDER

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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I, __________________________________________ [print or type full name]
of __________________________ [print or type full address], declare under
penalty of perjury that I have read in its entirety and understand the Stipulated
Protective Order that was issued by the United States District Court for the
Central District of California on [date] in the case of
__________________________ [insert formal name of the case and the number
and initials assigned to it by the court]. I agree to comply with and to be bound
by all the terms of this Stipulated Protective Order and I understand and
acknowledge that failure to so comply could expose me to sanctions and
punishment in the nature of contempt. I solemnly promise that I will not disclose
any manner any information or item that is subject to this Stipulated Protective
Order to any person or entity except in strict compliance with the provisions of
this Order. I further agree to submit to the jurisdiction of the United States
District Court for the Central District of California for the purpose of enforcing
the terms of this Stipulated Protective Order, even if such enforcement
proceedings occur after termination of this action. I hereby appoint
____________________________________________ [print or type full name]
of __________________________ [print or type full address and telephone
number] ______________________________________ as my California agent
for service of process in connection with this action or any proceedings related to
the enforcement of this Stipulated Protective Order.
Date: ____________________________________________
City and State where sworn and signed: ________________________________
Printed name: ______________________________________
Signature: _________________________________________
1248894/65455934v1

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9979383. Public record. Not legal advice.