a party’s privacy rights are to 18 be protected through a “carefully crafted protective order.”
How later courts described this case
- a party’s privacy rights are to 18 be protected through a “carefully crafted protective order.”
- even stipulated 20 protective orders require good cause showing
Written by the judges who cited it.
The opinion
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1 JILL WILLIAMS – State Bar No. 221793
jwilliams@crdlaw.com
2 DANIELLE C. FOSTER – State Bar No. 281385
dfoster@crdlaw.com
3 CARPENTER, ROTHANS & DUMONT
500 S. Grand Avenue, 19th Floor
4 Los Angeles, CA 90071
(213) 228-0400 / (213) 228-0401 (fax)
5
Attorneys for Defendant County of Los Angeles
6
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11
N.B, a minor, et al. ) Case No.: 2:21-cv-02165-FLA-PD
)
12 Plaintiffs, )
) ** DISCOVERY MATTER **
13 vs. )
)
14 COUNTY OF LOS ANGELES, et al. ) STIPULATED PROTECTIVE
) ORDER1
15 Defendants. )
)
16
)
) Hon. Patricia Donahue
17
) U.S. Magistrate Judge
18
19 IT IS HEREBY STIPULATED by and among the parties hereto, through
20 their respective counsel of record, as follows:
21 1A. PURPOSES AND LIMITATIONS
22 Discovery in this action is likely to involve production of confidential and
23 private information for which special protection from public disclosure and from
24 use for any purpose other than prosecuting this litigation may be warranted.
25 Accordingly, the parties hereby stipulate to and petition the Court to enter the
26
27
28 1 This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Patricia Donahue’s Procedures.
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1 following Stipulated Protective Order. The parties acknowledge that this Order
2 does not confer blanket protections on all disclosures or responses to discovery and
3 that the protection it affords from public disclosure and use extends only to the
4 limited information or items that are entitled to confidential treatment under the
5 applicable legal principles.
6 1B. GOOD CAUSE STATEMENT
7 This action is likely to involve confidential and private information for
8 which special protection from public disclosure and from use for any purpose other
9 than litigation of this action is warranted. Such information may implicate the
10 privacy interests of the parties and non-parties, and are properly protected through
11 a Federal Rule of Civil Procedure 26(c) protective order. See Seattle Times Co. v.
12 Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its express
13 purposes the protection of a ‘party or person from annoyance, embarrassment,
14 oppression or undue burden or expense.’ Although the Rule contains no specific
15 reference to privacy or to other rights or interests that may be implicated, such
16 matters are implicit in the broad purpose and language of the Rule.”); Soto v. City
17 of Concord, 162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s privacy rights are to
18 be protected through a “carefully crafted protective order.”).
19 Such confidential materials and information consist of, among other things,
20 peace officer investigations, sensitive reports, medical records, information
21 implicating privacy rights of parties and third parties, and information otherwise
22 generally unavailable to the public, or which may be privileged or otherwise
23 protected from disclosure under state or federal statutes, court rules, case decisions,
24 or common law. Accordingly, to expedite the flow of information, to facilitate the
25 prompt resolution of disputes over confidentiality of discovery materials, to
26 adequately protect information the parties are entitled to keep confidential, to
27 ensure that the parties are permitted reasonable necessary uses of such material in
28 preparation for and in the conduct of trial, to address their handling at the end of
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STIPULATED PROTECTIVE ORDER
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1 the litigation, and serve the ends of justice, a protective order for such information
2 is justified in this matter. It is the intent of the parties that information will not be
3 designated as confidential for tactical reasons and that nothing be so designated
4 without a good faith belief that it has been maintained in a confidential, non-public
5 manner, and there is good cause why it should not be part of the public record of
6 this case.
7 1C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
8 SEAL
9 The parties further acknowledge, as set forth in Section 12.3, below, that this
10 Stipulated Protective Order does not entitle them to file confidential information
11 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
12 and the standards that will be applied when a party seeks permission from the court
13 to file material under seal.
14 There is a strong presumption that the public has a right of access to judicial
15 proceedings and records in civil cases. In connection with non-dispositive
16 motions, good cause must be shown to support a filing under seal. See Kamakana
17 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v.
18 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v.
19 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
20 protective orders require good cause showing), and a specific showing of good
21 cause or compelling reasons with proper evidentiary support and legal justification,
22 must be made with respect to Protected Material that a party seeks to file under
23 seal. The parties’ mere designation of Disclosure or Discovery Material as
24 CONFIDENTIAL does not—without the submission of competent evidence by
25 declaration, establishing that the material sought to be filed under seal qualifies as
26 confidential, privileged, or otherwise protectable—constitute good cause.
27 Further, if a party requests sealing related to a dispositive motion or trial,
28 then compelling reasons, not only good cause, for the sealing must be shown, and
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1 the relief sought shall be narrowly tailored to serve the specific interest to be
2 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.
3 2010). For each item or type of information, document, or thing sought to be filed
4 or introduced under seal in connection with a dispositive motion or trial, the party
5 seeking protection must articulate compelling reasons, supported by specific facts
6 and legal justification, for the requested sealing order. Again, competent evidence
7 supporting the application to file documents under seal must be provided by
8 declaration.
9 Any document that is not confidential, privileged, or otherwise protectable
10 in its entirety will not be filed under seal if the confidential portions can be
11 redacted. If documents can be redacted, then a redacted version for public
12 viewing, omitting only the confidential, privileged, or otherwise protectable
13 portions of the document, shall be filed. Any application that seeks to file
14 documents under seal in their entirety should include an explanation of why
15 redaction is not feasible.
16 2. DEFINITIONS
17 2.1 Action: This pending federal lawsuit, bearing case number 2:21-cv-
18 02165-FLA-PD.
19 2.2 Challenging Party: A Party or Non-Party that challenges the
20 designation of information or items under this Order.
21 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of
22 how it is generated, stored or maintained) or tangible things that qualify for
23 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
24 the Good Cause Statement.
25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
26 their support staff).
27 2.5 Designating Party: A Party or Non-Party that designates information
28 or items that it produces in disclosures or in responses to discovery as
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1 “CONFIDENTIAL.”
2 2.6 Disclosure or Discovery Material: All items or information, regardless
3 of the medium or manner in which it is generated, stored, or maintained (including,
4 among other things, testimony, transcripts, and tangible things), that are produced
5 or generated in disclosures or responses to discovery in this matter.
6 2.7 Expert: A person with specialized knowledge or experience in a
7 matter pertinent to the litigation who has been retained by a Party or its counsel to
8 serve as an expert witness or as a consultant in this Action.
9 2.8 House Counsel: Attorneys who are employees of a Party to this
10 Action. House Counsel does not include Outside Counsel of Record or any other
11 outside counsel.
12 2.9 Non-Party: Any natural person, partnership, corporation, association,
13 or other legal entity not named as a Party to this Action.
14 2.10 Outside Counsel of Record: Attorneys who are not employees of a
15 Party to this Action but are retained to represent or advise a party to this Action
16 and have appeared in this Action on behalf of that Party or are affiliated with a law
17 firm which has appeared on behalf of that Party, and includes support staff.
18 2.11 Party: Any Party to this Action, including all of its officers, directors,
19 employees, consultants, retained experts, and Outside Counsel of Record (and their
20 support staffs).
21 2.12 Producing Party: A Party or Non-Party that produces Disclosure or
22 Discovery Material in this Action.
23 2.13 Professional Vendors: Persons or entities that provide litigation
24 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
25 demonstrations, and organizing, storing, or retrieving data in any form or medium)
26 and their employees and subcontractors.
27 2.14 Protected Material: Any Disclosure or Discovery Material that is
28 designated as “CONFIDENTIAL.”
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1 2.15 Receiving Party: A Party that receives Disclosure or Discovery
2 Material from a Producing Party.
3 3. SCOPE
4 The protections conferred by this Stipulation and Order cover not only
5 Protected Material (as defined above), but also: (1) any information copied or
6 extracted from Protected Material; (2) all copies, excerpts, summaries, or
7 compilations of Protected Material; and (3) any testimony, conversations, or
8 presentations by Parties or their Counsel that might reveal Protected Material.
9 Any use of Protected Material at trial shall be governed by the orders of the
10 trial judge. This Order does not govern the use of Protected Material at trial.
11 4. DURATION
12 FINAL DISPOSITION of the action is defined as the conclusion of any
13 appellate proceedings, or, if no appeal is taken, when the time for filing of an
14 appeal has run. Except as set forth below, the terms of this protective order apply
15 through FINAL DISPOSITION of the action. The parties may stipulate that the
16 they will be contractually bound by the terms of this agreement beyond FINAL
17 DISPOSITION, but will have to file a separate action for enforcement of the
18 agreement once all proceedings in this case are complete.
19 Once a case proceeds to trial, information that was designated as
20 CONFIDENTIAL or maintained pursuant to this protective order used or
21 introduced as an exhibit at trial becomes public and will be presumptively
22 available to all members of the public, including the press, unless compelling
23 reasons supported by specific factual findings to proceed otherwise are made to the
24 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
25 (distinguishing “good cause” showing for sealing documents produced in
26 discovery from “compelling reasons” standard when merits-related documents are
27 part of court record). Accordingly, for such materials, the terms of this protective
28 order do not extend beyond the commencement of the trial.
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1 5. DESIGNATING PROTECTED MATERIAL
2 5.1. Exercise of Restraint and Care in Designating Material for Protection.
3 Each Party or Non-Party that designates information or items for protection
4 under this Order must take care to limit any such designation to specific material
5 that qualifies under the appropriate standards. The Designating Party must
6 designate for protection only those parts of material, documents, items or oral or
7 written communications that qualify so that other portions of the material,
8 documents, items or communications for which protection is not warranted are not
9 swept unjustifiably within the ambit of this Order.
10 Mass, indiscriminate or routinized designations are prohibited. Designations
11 that are shown to be clearly unjustified or that have been made for an improper
12 purpose (e.g., to unnecessarily encumber the case development process or to
13 impose unnecessary expenses and burdens on other parties) may expose the
14 Designating Party to sanctions.
15 If it comes to a Designating Party’s attention that information or items that it
16 designated for protection do not qualify for protection, that Designating Party must
17 promptly notify all other Parties that it is withdrawing the inapplicable designation.
18 5.2 Manner and Timing of Designations. Except as otherwise provided in
19 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
21 under this Order must be clearly so designated before the material is disclosed or
22 produced.
23 Designation in conformity with this Order requires:
24 (a) For information in documentary form (e.g., paper or electronic
25 documents, but excluding transcripts of depositions or other pretrial or trial
26 proceedings), that the Producing Party affix at a minimum, the legend
27 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
28 contains protected material. If only a portion or portions of the material on a page
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1 qualifies for protection, the Producing Party also must clearly identify the
2 protected portion(s) (e.g., by making appropriate markings in the margins).
3 A Party or Non-Party that makes original documents available for inspection
4 need not designate them for protection until after the inspecting Party has indicated
5 which documents it would like copied and produced. During the inspection and
6 before the designation, all of the material made available for inspection shall be
7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
8 documents it wants copied and produced, the Producing Party must determine
9 which documents, or portions thereof, qualify for protection under this Order.
10 Then, before producing the specified documents, the Producing Party must affix
11 the “CONFIDENTIAL legend” to each page that contains Protected Material. If
12 only a portion or portions of the material on a page qualifies for protection, the
13 Producing Party also must clearly identify the protected portion(s) (e.g., by making
14 appropriate markings in the margins).
15 (b) For testimony given in depositions that the Designating Party
16 identify the Disclosure or Discovery Material on the record, before the close of the
17 deposition all protected testimony.
18 (c) For information produced in some form other than documentary
19 and for any other tangible items, that the Producing Party affix in a prominent
20 place on the exterior of the container or containers in which the information is
21 stored the legend “CONFIDENTIAL.” If only a portion or portions of the
22 information warrants protection, the Producing Party, to the extent practicable,
23 shall identify the protected portion(s).
24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
25 failure to designate qualified information or items does not, standing alone, waive
26 the Designating Party’s right to secure protection under this Order for such
27 material. Upon timely correction of a designation, the Receiving Party must make
28 reasonable efforts to assure that the material is treated in accordance with the
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1 provisions of this Order.
2 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
3 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
4 designation of confidentiality at any time that is consistent with the Court’s
5 Scheduling Order.
6 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
7 resolution process under Local Rule 37.1 et seq.
8 6.3 The burden of persuasion in any such challenge proceeding shall be
9 on the Designating Party. Frivolous challenges, and those made for an improper
10 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
11 parties) may expose the Challenging Party to sanctions. Unless the Designating
12 Party has waived or withdrawn the confidentiality designation, all parties shall
13 continue to afford the material in question the level of protection to which it is
14 entitled under the Producing Party’s designation until the Court rules on the
15 challenge.
16 7. ACCESS TO AND USE OF PROTECTED MATERIAL
17 7.1 Basic Principles. A Receiving Party may use Protected Material that
18 is disclosed or produced by another Party or by a Non-Party in connection with
19 this Action only for prosecuting, defending, or attempting to settle this Action.
20 Such Protected Material may be disclosed only to the categories of persons and
21 under the conditions described in this Order. When the Action has been
22 terminated, a Receiving Party must comply with the provisions of Section 13
23 below (FINAL DISPOSITION).
24 Protected Material must be stored and maintained by a Receiving Party at a
25 location and in a secure manner that ensures that access is limited to the persons
26 authorized under this Order.
27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
28 otherwise ordered by the court or permitted in writing by the Designating Party, a
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1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only to:
3 (a) The Receiving Party’s Outside Counsel of Record in this
4 Action, as well as employees of said Outside Counsel of Record to whom it is
5 reasonably necessary to disclose the information for this Action;
6 (b) The officers, directors, and employees (including House
7 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for
8 this Action;
9 (c) Experts (as defined in this Order) of the Receiving Party to
10 whom disclosure is reasonably necessary for this Action and who have signed the
11 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (d) The court and its personnel;
13 (e) Court reporters and their staff;
14 (f) Professional jury or trial consultants, mock jurors, and
15 Professional Vendors to whom disclosure is reasonably necessary for this Action
16 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
17 A);
18 (g) The author or recipient of a document containing the
19 information or a custodian or other person who otherwise possessed or knew the
20 information;
21 (h) During their depositions, witnesses, and attorneys for witnesses,
22 in the Action to whom disclosure is reasonably necessary provided: (i) the
23 deposing party requests that the witness sign the form attached as Exhibit A hereto;
24 and (ii) they will not be permitted to keep any confidential information unless they
25 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
26 otherwise agreed by the Designating Party or ordered by the court. Pages of
27 transcribed deposition testimony or exhibits to depositions that reveal Protected
28 Material may be separately bound by the court reporter and may not be disclosed
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1 to anyone except as permitted under this Stipulated Protective Order; and
2 (i) Any mediator or settlement officer, and their supporting
3 personnel, mutually agreed upon by any of the parties engaged in settlement
4 discussions.
5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
6 PRODUCED IN OTHER LITIGATION
7 If a Party is served with a subpoena or a court order issued in other litigation
8 that compels disclosure of any information or items designated in this Action as
9 “CONFIDENTIAL,” that Party must:
10 (a) Promptly notify in writing the Designating Party. Such notification
11 shall include a copy of the subpoena or court order;
12 (b) Promptly notify in writing the party who caused the subpoena or order
13 to issue in the other litigation that some or all of the material covered by the
14 subpoena or order is subject to this Protective Order. Such notification shall
15 include a copy of this Stipulated Protective Order; and
16 (c) Cooperate with respect to all reasonable procedures sought to be
17 pursued by the Designating Party whose Protected Material may be affected.
18 If the Designating Party timely seeks a protective order, the Party served
19 with the subpoena or court order shall not produce any information designated in
20 this action as “CONFIDENTIAL” before a determination by the court from which
21 the subpoena or order issued, unless the Party has obtained the Designating Party’s
22 permission. The Designating Party shall bear the burden and expense of seeking
23 protection in that court of its confidential material and nothing in these provisions
24 should be construed as authorizing or encouraging a Receiving Party in this Action
25 to disobey a lawful directive from another court.
26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
27 PRODUCED IN THIS LITIGATION
28 (a) The terms of this Order are applicable to information produced by a
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1 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
2 produced by Non-Parties in connection with this litigation is protected by the
3 remedies and relief provided by this Order. Nothing in these provisions should be
4 construed as prohibiting a Non-Party from seeking additional protections.
5 (b) In the event that a Party is required, by a valid discovery request, to
6 produce a Non-Party’s confidential information in its possession, and the Party is
7 subject to an agreement with the Non-Party not to produce the Non-Party’s
8 confidential information, then the Party shall:
9 (i) Promptly notify in writing the Requesting Party and the Non-
10 Party that some or all of the information requested is subject to a confidentiality
11 agreement with a Non-Party;
12 (ii) Promptly provide the Non-Party with a copy of the Stipulated
13 Protective Order in this Action, the relevant discovery request(s), and a reasonably
14 specific description of the information requested; and
15 (iii) Make the information requested available for inspection by the
16 Non-Party, if requested.
17 (c) If the Non-Party fails to seek a protective order from this court within
18 14 days of receiving the notice and accompanying information, the Receiving
19 Party may produce the Non-Party’s confidential information responsive to the
20 discovery request. If the Non-Party timely seeks a protective order, the Receiving
21 Party shall not produce any information in its possession or control that is subject
22 to the confidentiality agreement with the Non-Party before a determination by the
23 court. Absent a court order to the contrary, the Non-Party shall bear the burden
24 and expense of seeking protection in this court of its Protected Material.
25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
26 If a Receiving Party learns that, by inadvertence or otherwise, it has
27 disclosed Protected Material to any person or in any circumstance not authorized
28 under this Stipulated Protective Order, the Receiving Party must immediately: (a)
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1 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
2 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
3 the person or persons to whom unauthorized disclosures were made of all the terms
4 of this Order, and (d) request such person or persons to execute the
5 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
6 A.
7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
8 OTHERWISE PROTECTED MATERIAL
9 When a Producing Party gives notice to Receiving Parties that certain
10 inadvertently produced material is subject to a claim of privilege or other
11 protection, the obligations of the Receiving Parties are those set forth in Federal
12 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
13 whatever procedure may be established in an e-discovery order that provides for
14 production without prior privilege review. Pursuant to Federal Rule of Evidence
15 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
16 of a communication or information covered by the attorney-client privilege or
17 work product protection, the parties may incorporate their agreement in the
18 stipulated protective order submitted to the court.
19 12. MISCELLANEOUS
20 12.1 Right to Further Relief. Nothing in this Order abridges the right of
21 any person to seek its modification by the Court in the future.
22 12.2 Right to Assert Other Objections. By stipulating to the entry of this
23 Protective Order no Party waives any right it otherwise would have to object to
24 disclosing or producing any information or item on any ground not addressed in
25 this Stipulated Protective Order. Similarly, no Party waives any right to object on
26 any ground to use in evidence of any of the material covered by this Protective
27 Order.
28 12.3 Filing Protected Material. A Party that seeks to file under seal any
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1 Protected Material must comply with Civil Local Rule 79-5. Protected Material
2 may only be filed under seal pursuant to a court order authorizing the sealing of the
3 specific Protected Material at issue. If a Party’s request to file Protected Material
4 under seal is denied by the court, then the Receiving Party may file the information
5 in the public record unless otherwise instructed by the court.
6 13. FINAL DISPOSITION
7 After the final disposition of this Action, as defined in Section 4, within 60
8 days of a written request by the Designating Party, each Receiving Party must
9 return all Protected Material to the Producing Party or destroy such material. As
10 used in this subdivision, “all Protected Material” includes all copies, abstracts,
11 compilations, summaries, and any other format reproducing or capturing any of the
12 Protected Material. Whether the Protected Material is returned or destroyed, the
13 Receiving Party must submit a written certification to the Producing Party (and, if
14 not the same person or entity, to the Designating Party) by the 60 day deadline that
15 (1) identifies (by category, where appropriate) all the Protected Material that was
16 returned or destroyed and (2)affirms that the Receiving Party has not retained any
17 copies, abstracts, compilations, summaries or any other format reproducing or
18 capturing any of the Protected Material. Notwithstanding this provision, Counsel
19 are entitled to retain an archival copy of all pleadings, motion papers, trial,
20 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
21 and trial exhibits, expert reports, attorney work product, and consultant and expert
22 work product, even if such materials contain Protected Material. Any such archival
23 copies that contain or constitute Protected Material remain subject to this
24 Protective Order as set forth in Section 4 (DURATION).
25 14. VIOLATION
26 Any violation of this Order may be punished by any and all appropriate
27 measures including, without limitation, contempt proceedings and/or monetary
28 sanctions.
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Case 2:21-cv-02165-FLA-PD Document 28 Filed 05/18/22 Page 15o0f16 Page ID #:298
1 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
3 || DATED: May 18, 2022 LAW OFFICES OF DALE K. GALIPO
4 /s/ Dale K. Galipo
5 By:
6 DALE K. GALIPO
Attomey for Plaintiffs
-
8 || DATED: May 18, 2022 CARPENTER, ROTHANS & DUMONT
9 /s/ Danielle Foster
10 By
JILL WILLIAMS
i DANIELLE C. FOSTER
12 Attorneys for Defendant County of Los
B Angeles
14 Local Rule 5-4.3.4
15 All other signatories listed, and on whose behalf the filing is submitted,
16 || concur in the filing’s content and have authorized the filing.
17
18
19 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
20
21 IIDATED: May 19, 2022 biatiscur Donati
7 Honorable Patricia Donahue
United States Magistrate Judge
23
24
25
26
27
28
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STIPULATED PROTECTIVE ORDER
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, ______________________ [print or type full name], of
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_______________________________ [print or type full address], declare under
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penalty of perjury that I have read in its entirety and understand the Stipulated
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Protective Order that was issued by the United States District Court for the Central
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District of California on ________________ [date] in the case of N.B., et al. v.
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County of Los Angeles, Case No. 2:21-cv-02165-FLA-PD. I agree to comply with
and to be bound by all the terms of this Stipulated Protective Order and I
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understand and acknowledge that failure to so comply could expose me to
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sanctions and punishment in the nature of contempt. I solemnly promise that I will
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not disclose in any manner any information or item that is subject to this Stipulated
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Protective Order to any person or entity except in strict compliance with the
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provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District
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Court for the Central District of California for the purpose of enforcing the terms
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of this Stipulated Protective Order, even if such enforcement proceedings occur
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after termination of this action. I hereby appoint __________________________
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[print or type full name] of _____________________ [print or type full address
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and telephone number] as my California agent for service of process in connection
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with this action or any proceedings related to enforcement of this Stipulated
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Protective Order.
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Date: ______________________________________
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City and State where sworn and signed: _________________________________
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Printed name: _______________________________
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Signature: __________________________________
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STIPULATED PROTECTIVE ORDER