Opinion

Zaira S. Azocar v. Delta Air Lines, Inc.

Court: District Court, C.D. California
Filed: Jun 10, 2022
Cited by: 0 cases

The opinion

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 1 of 14 Page ID #:388

1 Scott D. Cunningham (State Bar No.: 200413)

Email: scunningham@condonlaw.com

2 Justin M. Schmidt (State Bar No.: 309656)

Email: jschmidt@condonlaw.com

3 CONDON & FORSYTH LLP

1901 Avenue of the Stars, Suite 1050

4 Los Angeles, California 90067-6036

Telephone: (310) 557-2030

5 Facsimile: (310) 557-1299

6 Attorneys for Defendant

AEROVÍAS DE MÉXICO, S.A. DE C.V.

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

11 ZAIRA S. LLANCAN AZOCAR, ) Case No. 2:21-cv-02969-ODW-SK

)

12 Plaintiff, ) STIPULATED PROTECTIVE

) ORDER

13 vs. )

)

14 DELTA AIR LINES, INC.; GRUPO )

AEROMEXICO; AEROVIAS DE )

15 MEXICO, S/A/ DE C.V. dba )

Aeromexico Airlines and DOES 1 )

16 through 50, Inclusive, )

)

17 Defendants. )

)

18 )

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

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

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

28 under the applicable legal principles. The parties further acknowledge, as set forth

STIPULATED PROTECTIVE ORDER.

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 2 of 14 Page ID #:389

in Section 12.3 (Filing Protected Material), below, that this Stipulated Protective

Order does not entitle them to a file confidential information under seal; Civil

Local 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.

B. GOOD CAUSE STATEMENT

This action is likely to involve private, confidential, personal, medical,

HIPPA protected, commercial, financial, technical and/or proprietary information

for which special protection from public disclosure and from use for any purpose

other than prosecution of this action is warranted. Such confidential and

proprietary materials and information consist of, among other things, HIPPA

protected medical information, confidential and proprietary airline operations and

training manuals and materials, confidential business or financial information,

information regarding confidential business practices, , information otherwise

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

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

or common law. 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.

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 3 of 14 Page ID #:390

2. DEFINITIONS

2.1. Action: this pending federal law suit.

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.

2.4. Counsel: Outside 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 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 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

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 4 of 14 Page ID #:391

firm which has appeared on behalf of that party, including support staff.

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

employees, consultants, retained experts, insurers, 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

Material from a Producing Party.

3. SCOPE

The protections conferred by this Stipulation and 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, all of the information that was designated as

confidential or maintained pursuant to this protective order 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 v. City

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 5 of 14 Page ID #:392

and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (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 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 paragraph 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:

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 6 of 14 Page ID #:393

(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

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).

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

identify the Disclosure or Discovery Material on the record, before the close of the

deposition all protected testimony.

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 warrants protection, the Producing Party, to the extent practicable,

shall identify the protected portion(s).

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 7 of 14 Page ID #:394

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 Civil 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 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 (FINAL

DISPOSITION).

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 8 of 14 Page ID #:395

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, insurers, and employees (including House

Counsel) of the Receiving Party to whom disclosure is reasonably necessary for

this Action;

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 party requests that the witness sign the form attached as Exhibit A hereto;

and (2) they will not be permitted to keep any confidential information unless they

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 9 of 14 Page ID #:396

sign the “Acknowledgment and Agreement to Be Bound” (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 Stipulated 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;

(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 Stipulated Protective Order; and

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 Designating Party’s

permission. 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

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 10 of 14 Page ID #:397

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 Stipulated

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.

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. Absent a court order to the contrary, the Non-Party

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 11 of 14 Page ID #:398

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 Stipulated 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

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

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 in the

stipulated protective order submitted to the Court.

12. MISCELLANEOUS

12.1 Right to 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. By stipulating to the entry of this

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STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

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Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 12 of 14 Page ID #:399

Protective Order, 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 Stipulated 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. Protected Material

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

specific Protected Material at issue. 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

(DURATION), within 60 days of a written request by the Designating Party, each

Receiving Party must return or destroy all Protected Material to the Producing

Party or destroy such material. As used in this subdivision, “all Protected

Material” includes all copies, abstracts, 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

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Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 130f14 Page ID #:400

1 ||such materials contain Protected Material. Any such archival copies that contain

2 || or constitute Protected Material remain subject to this Protective Order as set forth

3 ||in Section 4 (DURATION).

4}14. Any violation of this Order may be punished by any and all appropriate

5 || measures including, without limitation, contempt proceedings and/or monetary

6 || sanctions.

7 |}IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

9 || DATED: June 8, 2022 /s/ Gennady L. Lebedev (with permission)

10 Gennady L. Lebedev

Attorneys for Plaintiff

11 ZAIRA S. LLANCAN AZOCAR

E BS 43 || DATED: June 8, 2022 /s/ Scott D. Cunningham

Oeee Scott D. Cunningham

OfE= 14 Justin M. Schmidt

Ss y Attorneys for Defendant

1S AEROVIAS DE MEXICO, S.A. DE C.V.

Oss 7 DATED: June 8, 2022 /s/ Richard G. Grotch (with permission)

Richard G. Grotch

18 Attorneys for Defendant

9 DELTA AIR LINES, INC

20 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

22 ||/DATED: _ June 10, 2022

25 || Honorable Steve Kim

United States Magistrate Judge

STIPULATED PROTECTIVE ORDER -13-

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

STIPULATED PROTECTIVE ORDER

CASE NO.: 2:21-cv-02969-ODW-SK LAOFFICE 280074V.1

PLL HTYSROF & NODNOC 0501 etiuS ,sratS eht fo eunevA 1091 6306-76009 ainrofilaC ,selegnA soL

0302-755 )013( :enohpeleT

Case 2:21-cv-02969-ODW-SK Document 67 Filed 06/10/22 Page 14 of 14 Page ID #:401

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 Zaira S. Llancan Azocar v. Delta Air

Lines, Inc., et al., Case No. 2:21-cv-02969-ODW-SK. 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

in 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 enforcement of

this Stipulated Protective Order.

Date: ______________________________________

City and State where sworn and signed: _________________________________

Printed name: _______________________________

Signature: __________________________________

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LAOFFICE 282280v.1

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.