Sarah Jafari v. County of Los Angeles

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46 8 UNITED STATES DISTRICT COURT

3 ze 9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

qESs

z g5e 11 || SARAH JAFARI, Case No. 2:22-cv-00305-DSF (GJSx)

[888 12 Plaintiff, PROPOSED) STIPULATED

a pad ‘6 ROTECTIVE ORDER

Soe Assigned to Hon. Dale S. Fischer,

= unicipal entity: RONRAD THIEME, | “ou” "7

15 || an Individual, DOES 1-10, inclusive,

16 Defendants.

WW

18

19. A. PURPOSES AND LIMITATIONS

20 Discovery in this action is likely to involve production of confidential,

21 || proprietary or private information for which special protection from public

22 || disclosure and from use for any purpose other than prosecuting this litigation may

23 ||be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

24 || enter the following Stipulated Protective Order. The parties acknowledge that this

25

ae This Stipulated Protective Order is substantially based on the model protective

27 || order provided under Magistrate Judge Gail J. Standish’s Procedures.

28

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1 || Order does not confer blanket protections on all disclosures or responses to

2 || discovery and that the protection it affords from public disclosure and use extends

3 || only to the limited information or items that are entitled to confidential treatment

4 || under the applicable legal principles.

5 B. GOOD CAUSE STATEMENT

6 This action is likely to involve confidential information pertaining to

7 || personnel records and institutional procedures within the institution and other

8 || materials subject to privacy protections for which special protection from public

g 9 || disclosure and from use for any purpose other than prosecution of this action is

4 bee 10 || warranted. Defendants contend that limiting disclosure of these documents to the

: 5: 11 || context of this litigation as provided herein will, accordingly, further important law

G ecu 12 || enforcement objectives and interests, including the safety of law enforcement

3 ou 13 || personnel, institutional safety as a whole, and the public, as well as individual

14 || privacy rights of Plaintiff, Defendants, and third parties. Defendants further contend

15 || that such confidential materials and information consist of, among other things,

16 || materials entitled to privileges and/or protections under the following: the United

17 || States Constitution, First Amendment; the California Constitution, Article I, Section

18 || 1; California Penal Code §§ 832.5, 832.7, and 832.8; California Evidence Code §8§

19 || 1040 and 1043 et seq.; the Privacy Act of 1974, 5 U.S.C. § 552a; the right to

20 || privacy; decisional law relating to such provisions; and information otherwise

21 || generally unavailable to the public, or which may be privileged or otherwise

22 || protected from disclosure under state or federal statutes, court rules, case decisions,

23 ||or common law. Defendants also maintain that such confidential materials and

24 || information consist of materials entitled to the Official Information Privilege.

25 Confidential information with respect to the Defendants may include:

26 || personnel files; internal institutional procedures and policy, investigative files and

27 || documents; email and written correspondence records; and policies and procedures

28 || that are kept from the public in the ordinary course of business, as well as other

4.

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items subject to the Official Information Privilege and other privileges. The Parties

2 || reserve the right to challenge a designation of confidentiality pursuant to the terms

3 || set forth under Paragraph 6 of this Stipulated Protective Order.

4 Accordingly, to expedite the flow of information, to facilitate the prompt

5 || resolution of disputes over confidentiality of discovery materials, to adequately

6 || protect information the parties are entitled to keep confidential, to ensure that the

7 || parties are permitted to reasonable necessary uses of such material in preparation for

8 || and in conduct of trial, to address their handling at the end of the litigation, and

4 2 9 || serve the ends of justice, a protective order for such information is justified in this

a He 10 || matter. It is the intent of the parties that information will not be designated as

est 11 || confidential for tactical reasons and that nothing be so designated without a good

5 12 || faith belief that it has been maintained in a confidential, non-public manner, and

3 oa 13 || there is good cause why it should not be part of the public record of this case.

= 14 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

15 The parties further acknowledge, as set forth in Section 12.3, below, that this

16 || Stipulated Protective Order does not entitle them to file confidential information

17 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

18 || and the standards that will be applied when a party seeks permission from the court

19 || to file material under seal.

20 There is a strong presumption that the public has a right of access to judicial

21 || proceedings and records in civil cases. In connection with non-dispositive motions,

22 || good cause must be shown to support a filing under seal. See Kamakana v. City and

23 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

24 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,

25 || Jnc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

26 || require good cause showing), and a specific showing of good cause or compelling

27 || reasons with proper evidentiary support and legal justification, must be made with

28 || respect to Protected Material that a party seeks to file under seal. The parties’ mere

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1 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

2 || without the submission of competent evidence by declaration, establishing that the

3 || material sought to be filed under seal qualifies as confidential, privileged, or

4 || otherwise protectable—constitute good cause.

5 Further, if a party requests sealing related to a dispositive motion or trial, then

6 || compelling reasons, not only good cause, for the sealing must be shown, and the

7 || relief sought shall be narrowly tailored to serve the specific interest to be protected.

8 || See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For

2 9 || each item or type of information, document, or thing sought to be filed or introduced

4 BBs 10 || under seal in connection with a dispositive motion or trial, the party seeking

: 3: 11 || protection must articulate compelling reasons, supported by specific facts and legal

5 203 12 || justification, for the requested sealing order. Again, competent evidence supporting

zh 13 || the application to file documents under seal must be provided by declaration.

= 14 Any document that is not confidential, privileged, or otherwise protectable in

15 || its entirety will not be filed under seal if the confidential portions can be redacted.

16 || If documents can be redacted, then a redacted version for public viewing, omitting

17 || only the confidential, privileged, or otherwise protectable portions of the document,

18 || shall be filed. Any application that seeks to file documents under seal in their

19 || entirety should include an explanation of why redaction is not feasible.

20 |} 2. DEFINITIONS

21 2.1 Action: this pending federal lawsuit in the United States District Court

22 || for the Central District of California titled Sarah Jafari v. County of Los Angeles, et

23 || al., Case No.:2:22-cv-00305-DSF (GJSx).

24 2.2 Challenging Party: a Party or Non-Party that challenges the designation

25 || of information or items under this Order.

26 2.3. “CONFIDENTIAL” Information or Items: information (regardless of

27 || how it is generated, stored or maintained) or tangible things that qualify for

28 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in

ws

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1 || the Good Cause Statement.

2 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

3 || their support staff).

4 2.5 Designating Party: a Party or Non-Party that designates information or

5 || items that it produces in disclosures or in responses to discovery as

6 || “CONFIDENTIAL.”

7 2.6 Disclosure or Discovery Material: all items or information, regardless

8 || of the medium or manner in which it is generated, stored, or maintained (including,

9 || among other things, testimony, transcripts, and tangible things), that are produced or

a ie 10 || generated in disclosures or responses to discovery in this matter.

56 11 2.7 Expert: a person with specialized knowledge or experience in a matter

S oy 12 || pertinent to the litigation who has been retained by a Party or its counsel to serve as

5 ou 13 || an expert witness or as a consultant in this Action.

se 14 2.8 House Counsel: attorneys who are employees of a party to this Action.

7 15 || House Counsel does not include Outside Counsel of Record or any other outside

16 || counsel.

17 2.9 Non-Party: any natural person, partnership, corporation, association or

18 || other legal entity not named as a Party to this action.

19 2.10 Qutside Counsel of Record: attorneys who are not employees of a party

20 || to this Action but are retained to represent or advise a party to this Action and have

21 || appeared in this Action on behalf of that party or are affiliated with a law firm that

22 || has appeared on behalf of that party, and includes support staff.

23 2.11 Party: any party to this Action, including all of its officers, directors,

24 || employees, consultants, retained experts, and Outside Counsel of Record (and their

25 || support staffs).

26 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

27 || Discovery Material in this Action.

28 2.13 Professional Vendors: persons or entities that provide litigation support

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1 |) services (e.g., photocopying, videotaping, translating, preparing exhibits or

2 || demonstrations, and organizing, storing, or retrieving data in any form or medium)

3 || and their employees and subcontractors.

4 2.14 Protected Material: any Disclosure or Discovery Material that is

5 || designated as “CONFIDENTIAL.”

6 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

7 || from a Producing Party.

8]/3. SCOPE

g 9 The protections conferred by this Stipulation and Order cover not only

4 EBs 10 || Protected Material (as defined above), but also (1) any information copied or

sf 11 || extracted from Protected Material; (2) all copies, excerpts, summaries, or

5 ne 12 || compilations of Protected Material; and (3) any testimony, conversations, or

a zou 13 || presentations by Parties or their Counsel that might reveal Protected Material.

a 14 Any use of Protected Material at trial shall be governed by the orders of the

15 || trial judge. This Order does not govern the use of Protected Material at trial.

16)|4.. DURATION

17 FINAL DISPOSITION of the action is defined as the conclusion of any

18 || appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal

i9 ||has run. Except as set forth below, the terms of this protective order apply through

20 || FINAL DISPOSITION of the action. The parties may stipulate that they will be

21 || contractually bound by the terms of this agreement beyond FINAL DISPOSITION,

22 || but will have to file a separate action for enforcement of the agreement once all

23 || proceedings in this case are complete.

24 Once a case proceeds to trial, information that was designated as

25 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced

26 || as an exhibit at trial becomes public and will be presumptively available to all

27} members of the public, including the press, unless compelling reasons supported by

28 || specific factual findings to proceed otherwise are made to the trial judge in advance

Ge

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1 || of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” □

2 || showing for sealing documents produced in discovery from “compelling reasons”

3 || standard when merits-related documents are part of court record). Accordingly, for

4 || such materials, the terms of this protective order do not extend beyond the

5 || commencement of the trial.

6||5. | DESIGNATING PROTECTED MATERIAL

7 5.1 Exercise of Restraint and Care in Designating Material for Protection.

8 || Each Party or Non-Party that designates information or items for protection under

= 9 || this Order must take care to limit any such designation to specific material that

4 ei 10 || qualifies under the appropriate standards. The Designating Party must designate for

set 11 || protection only those parts of material, documents, items or oral or written

SG 12 || communications that qualify so that other portions of the material, documents, items

a oa 13 || or communications for which protection is not warranted are not swept unjustifiably

= 82° 14|| within the ambit of this Order.

15 Mass, indiscriminate or routinized designations are prohibited. Designations

16 || that are shown to be clearly unjustified or that have been made for an improper

17 || purpose (e.g., to unnecessarily encumber the case development process or to impose

18 || unnecessary expenses and burdens on other parties) may expose the Designating

19 || Party to sanctions.

20 If it comes to a Designating Party’s attention that information or items that it

21 || designated for protection do not qualify for protection, that Designating Party must

22 || promptly notify all other Parties that it is withdrawing the inapplicable designation.

23 5.2. Manner and Timing of Designations. Except as otherwise provided in

24 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

25 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

26 || under this Order must be clearly so designated before the material is disclosed or

27 || produced.

28 Designation in conformity with this Order requires:

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1 (a) for information in documentary form (e.g., paper or electronic documents,

2 || but excluding transcripts of depositions or other pretrial or trial proceedings), that

3 || the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

4 ||“CONFIDENTIAL legend”), to each page that contains protected material. If only a

5 || portion of the material on a page qualifies for protection, the Producing Party also

6 || must clearly identify the protected portion(s) (e.g., by making appropriate markings

7 the margins).

8 A Party or Non-Party that makes original documents available for inspection

4 8 9 ||need not designate them for protection until after the inspecting Party has indicated

4 bag 10 || which documents it would like copied and produced. During the inspection and

ag! 11 || before the designation, all of the material made available for inspection shall be

5 aoe 12 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the

3 ou 13 || documents it wants copied and produced, the Producing Party must determine which

14 || documents, or portions thereof, qualify for protection under this Order. Then,

15 || before producing the specified documents, the Producing Party must affix the

16 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

17 || portion of the material on a page qualifies for protection, the Producing Party also

18 || must clearly identify the protected portion(s) (e.g., by making appropriate markings

19 || in the margins).

20 (b) for testimony given in depositions that the Designating Party identifies

21 || the Disclosure or Discovery Material on the record, before the close of the

22 || deposition all protected testimony.

23 (c) for information produced in some form other than documentary and for

24 || any other tangible items, that the Producing Party affix in a prominent place on the

25 || exterior of the container or containers in which the information is stored the legend

26 || “CONFIDENTIAL.” If only a portion or portions of the information warrants

27 || protection, the Producing Party, to the extent practicable, shall identify the protected

28 || portion(s).

i.

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1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

2 || failure to designate qualified information or items does not, standing alone, waive

3 || the Designating Party’s right to secure protection under this Order for such material.

4 || Upon timely correction of a designation, the Receiving Party must make reasonable

5 || efforts to assure that the material is treated in accordance with the provisions of this

6 || Order.

7\;}6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

2 9 || designation of confidentiality at any time that is consistent with the Court’s

#8g 10]| Scheduling Order.

=! 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

S acy 12 || resolution process under Local Rule 37.1 et seq.

3 a 13 6.3. The burden of persuasion in any such challenge proceeding shall be on

= 37 14 || the Designating Party. Frivolous challenges, and those made for an improper

= 15 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other

16 || parties) may expose the Challenging Party to sanctions. Unless the Designating

17 || Party has waived or withdrawn the confidentiality designation, all parties shall

18 || continue to afford the material in question the level of protection to which it is

19 || entitled under the Producing Party’s designation until the Court rules on the

20 || challenge.

21||7. ACCESS TO AND USE OF PROTECTED MATERIAL

22 7.1 Basic Principles. A Receiving Party may use Protected Material that is

23 || disclosed or produced by another Party or by a Non-Party in connection with this

24 || Action only for prosecuting, defending or attempting to settle this Action. Such

25 || Protected Material may be disclosed only to the categories of persons and under the

26 || conditions described in this Order. When the Action has been terminated, a

27 || Receiving Party must comply with the provisions of section 13 below (FINAL

28 || DISPOSITION).

-9.

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1 Protected Material must be stored and maintained by a Receiving Party at a

2 || location and in a secure manner that ensures that access is limited to the persons

3 || authorized under this Order.

4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

5 || otherwise ordered by the court or permitted in writing by the Designating Party, a

6 || Receiving Party may disclose any information or item designated

7 \|“CONFIDENTIAL” only to:

8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well

3 9 || as employees of said Outside Counsel of Record to whom it is reasonably necessary

4 vee 10 || to disclose the information for this Action;

ae 11 (b) the officers, directors, and employees (including House Counsel) of the

S 12 || Receiving Party to whom disclosure is reasonably necessary for this Action;

3 13 (c) Experts (as defined in this Order) of the Receiving Party to whom

Ss a7 14 || disclosure is reasonably necessary for this Action and who have signed the

15 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);

16 (d) the court and its personnel;

17 (e) court reporters and their staff;

18 (f) professional jury or trial consultants, mock jurors, and Professional

19 || Vendors to whoin disclosure is reasonably necessary for this Action and who have

20 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

21 (g) the author or recipient of a document containing the information or a

22 || custodian or other person who otherwise possessed or knew the information;

23 (h) during their depositions, witnesses, and attorneys for witnesses, in the

24 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party

25 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

26 || not be permitted to keep any confidential information unless they sign the

27 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

28 || agreed by the Designating Party or ordered by the court. Pages of transcribed

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1 testimony or exhibits to depositions that reveal Protected Material may

2 || be separately bound by the court reporter and may not be disclosed to anyone except

3 || as permitted under this Stipulated Protective Order; and

4 (i) any mediator or settlement officer, and their supporting personnel,

5 || mutually agreed upon by any of the parties engaged in settlement discussions.

6|/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

IN OTHER LITIGATION

8 If a Party is served with a subpoena or a court order issued in other litigation

g 9 || that compels disclosure of any information or items designated in this Action as

328s ||“CONFIDENTIAL,” that Party must:

: sg: 11 (a) promptly notify in writing the Designating Party. Such notification shall

5 12 || include a copy of the subpoena or court order;

3 13 (b) promptly notify in writing the party who caused the subpoena or order to

2" 14 || issue in the other litigation that some or all of the material covered by the subpoena

15 || or order is subject to this Protective Order. Such notification shall include a copy of

16 || this Stipulated Protective Order; and

17 (c) cooperate with respect to all reasonable procedures sought to be pursued

18 || by the Designating Party whose Protected Material may be affected.

19 If the Designating Party timely seeks a protective order, the Party served with

20 || the subpoena or court order shall not produce any information designated in this

21 || action as “CONFIDENTIAL” before a determination by the court from which the

22 || subpoena or order issued, unless the Party has obtained the Designating Party’s

23 || permission. The Designating Party shall bear the burden and expense of seeking

24 || protection in that court of its confidential material and nothing in these provisions

25 || should be construed as authorizing or encouraging a Receiving Party in this Action

26 || to disobey a lawful directive from another court.

27 \|///

28 || ///

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1)/9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE !

2 PRODUCED IN THIS LITIGATION

3 (a) The terms of this Order are applicable to information produced by a Non-

4 || Party in this Action and designated as “CONFIDENTIAL.” Such information

5 || produced by Non-Parties in connection with this litigation is protected by the

6 || remedies and relief provided by this Order. Nothing in these provisions should be

7 || construed as prohibiting a Non-Party from seeking additional protections.

8 (b) In the event that a Party is required, by a valid discovery request, to

A g 9 || produce a Non-Party’s confidential information in its possession, and the Party is

4 Be 10 || subject to an agreement with the Non-Party not to produce the Non-Party’s

□ se: 11 || confidential information, then the Party shall:

5 12 (1) promptly notify in writing the Requesting Party and the Non-Party

rou 13 || that some or all of the information requested is subject to a confidentiality

fs ee" 14 || agreement with a Non-Party;

15 (2) promptly provide the Non-Party with a copy of the Stipulated

16 || Protective Order in this Action, the relevant discovery request(s), and a reasonably

17 || specific description of the information requested; and

18 (3) make the information requested available for inspection by the

19 || Non-Party, if requested.

20 (c) If the Non-Party fails to seek a protective order from this court within 14

21 || days of receiving the notice and accompanying information, the Receiving Party

22 || may produce the Non-Party’s confidential information responsive to the discovery

23 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall

24 || not produce any information in its possession or control that is subject to the

25 || confidentiality agreement with the Non-Party before a determination by the court.

26 || Absent a court order to the contrary, the Non-Party shall bear the burden and

27 || expense of seeking protection in this court of its Protected Material.

28 ||///

“J Du

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1)/}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

2 Ifa 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 efforts

6 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

7 || persons to whom unauthorized disclosures were made of all the terms of this Order,

8 || and (d) request such person or persons to execute the “Acknowledgment and

A g 9 || Agreement to Be Bound” that is attached hereto as Exhibit A.

a BB g 10\|}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

: af: 11 PROTECTED MATERIAL

5 acy 12 When a Producing Party gives notice to Receiving Parties that certain

5 He 13 || inadvertently produced material is subject to a claim of privilege or other protection,

a7 14 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

= 15 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever

16 || procedure may be established in an e-discovery order that provides for production

17 || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

18 || (e), insofar as the parties reach an agreement on the effect of disclosure of a

19 |) communication or information covered by the attorney-client privilege or work

20 || product protection, the parties may incorporate their agreement in the stipulated

21 || protective order submitted to the court.

22|}12. MISCELLANEOUS

23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

24 || person to seek its modification by the Court in the future.

25 12.2 Right to Assert Other Objections. By stipulating to the entry of this

26 || Protective Order, no Party waives any right it otherwise would have to object to

27 || disclosing or producing any information or item on any ground not addressed in this

28 || Stipulated Protective Order. Similarly, no Party waives any right to object on any

«f3-

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1 || ground to use in evidence of any of the material covered by this Protective Order.

2 12.3 Filing Protected Material. A Party that seeks to file under seal any

3 || Protected Material must comply with Local Civil Rule 79-5. Protected Material

4 || may only be filed under seal pursuant to a court order authorizing the sealing of the

5 || specific Protected Material at issue. Ifa Party’s request to file Protected Material

6 || under seal is denied by the court, then the Receiving Party may file the information

7 ||in the public record unless otherwise instructed by the court.

8|\13. FINAL DISPOSITION

4 8 9 After the final disposition of this Action, as defined in paragraph 4, within 60

4 eee 10 || days of a written request by the Designating Party, each Receiving Party must return

: sp! 11 || all Protected Material to the Producing Party or destroy such material. As used in

5 Sy 12 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

5 He 13 ||summaries, and any other format reproducing or capturing any of the Protected

BS 27 14 || Material. Whether the Protected Material is returned or destroyed, the Receiving

= 15 || Party must submit a written certification to the Producing Party (and, if not the same

16 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

17 || (by category, where appropriate) all the Protected Material that was returned or

18 || destroyed and (2) affirms that the Receiving Party has not retained any copies,

19 || abstracts, compilations, summaries or any other format reproducing or capturing any

20 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to

21 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

22 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

23 || reports, attorney work product, and consultant and expert work product, even if such

24 || materials contain Protected Material. Any such archival copies that contain or

25 || constitute Protected Material remain subject to this Protective Order as set forth in

26 || Section 4 (DURATION).

27:14. VIOLATION

28 Any violation of this Order may be punished by appropriate measures

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1 || including, without limitation, contempt proceedings and/or monetary sanctions.

2 ITT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

4 || DATED: May 9, 2022

5 || THE LAW OFFICES OF VINCENT MILLER

6 /s/ Vincent Miller

7 VINCENT MILLER

8 || NICK SAGE

9 Attorneys for Plaintiff Sarah Jafari

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□ ese DATED: May 9, 2022

0 $22 |? THURRELL CANTRALL LLP

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15 THOMAS C. HURRELL

FARID A. SHARABY

16 | ANAHIT ISAGHULYAN

17 Attorneys for Defendant County of Los Angeles

18

19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

20

3 DATE May 12, 2022

22

23 || ———

HON. (GAIL J. STANDISH

24 || United’States Magistrate Judge

25

26

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Case 2)22-cv-00305-DSF-GJS Document 32 Filed 05/12/22 Page 16o0f17 Page ID #:192

1 SIGNATURE CERTIFICATION

2 Pursuant to L.R. 5-4.3.4, I hereby certify that all other signatories listed, on

3 || whose behalf the filing is submitted, concur in the filing’s content and have

4 || authorized the filing.

6 || DATED: May 9, 2022 HURRELL CANTRALL LLP

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py By:

ag 9 THOMAS C. HURRELL

Ese 10 FARID A. SHARABY

Ruee ay ANAHIT ISAGHULYAN

Z ake Attorneys for Defendant, COUNTY OF

12 LOS ANGELES

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Case 2/P2-cv-00305-DSF-GJS Document 32 Filed 05/12/22 Page 17of17 Page ID #:193

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4 |(I, [print or type full name], of

5 [print or type full address], declare under penalty of perjury

6 that I have read in its entirety and understand the Stipulated Protective Order that

7 || was issued by the United States District Court for the Central District of California

8 || on [date] in the case of Sarah Jafari v. County of Los Angeles, et

g 9 || al., Case No.:2:22-cv-00305-DSF (GJSx). I agree to comply with and to be bound

4 EBs 10||by all the terms of this Stipulated Protective Order and I understand and

se: 11 || acknowledge that failure to so comply could expose me to sanctions and punishment

5 a8 12 || in the nature of contempt. I solemnly promise that I will not disclose in any manner

a 13 ||any information or item that is subject to this Stipulated Protective Order to any

ag 14 || person or entity except in strict compliance with the provisions of this Order.

= 15 I further agree to submit to the jurisdiction of the United States District Court

16 || for the Central District of California for enforcing the terms of this Stipulated

17 || Protective Order, even if such enforcement proceedings occur after termination of

18 |/this action. I hereby appoint [print or type full

19 || name] of [print or type full address

20 || and telephone number] as my California agent for service of process in connection

21 || with this action or any proceedings related to enforcement of this Stipulated

22 || Protective Order.

23

24 || Date:

25 || City and State where sworn and signed:

26 || Printed name:

27 || Signature: □

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