distinguishing “good cause” 5 ||showing for sealing documents produced in discovery from “compelling reasons” 6 ||standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 5 ||showing for sealing documents produced in discovery from “compelling reasons” 6 ||standard when merits-related documents are part of court record
Written by the judges who cited it.
The opinion
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page1lof15 Page ID #:1364
]
3 UNITED STATES DISTRICT COURT
4 CENTRAL DISTRICT OF CALIFORNIA
° JOSE VASQUEZ, individually and Case No. 2:21-cv-0693-FMO-ASx
6 on behalf of all those similarly CLASS ACTION
7 situated,
STIPULATED PROTECTIVE
8 Plaintiff, ORDER
9 Judge: Fernando M. Olguin
10 DRAPER AND KRAMER
MORTGAGE CORP., Complaint filed: 9/22/2020
11 Trial Date: TBD
Defendants,
12
13
4 1. A. PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,
proprietary, or private information for which special protection from public
disclosure and from use for any purpose other than prosecuting this litigation may
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
enter the following Stipulated Protective Order. The parties acknowledge that this
1 Order does not confer blanket protections on all disclosures or responses to
0 discovery and that the protection it affords from public disclosure and use extends
33 only to the limited information or items that are entitled to confidential treatment
oA under the applicable legal principles. The parties further acknowledge, as set forth in
35 Section 12.3, below, that this Stipulated Protective Order does not entitle them to
6 file confidential information under seal; Civil Local Rule 79-5 sets forth the
4 procedures that must be followed and the standards that will be applied when a party
3g seeks permission from the court to file material under seal.
TIMOTHY P. RUMDERGER
Sana Cat STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page2of15 Page ID #:1365
1 B. GOOD CAUSE STATEMENT
This action is likely to involve putative class and collective action member
3 |lidentities and contact information, wage and hour data, or other valuable
4 commercial, financial, technical and/or proprietary information for which special
> protection from public disclosure and from use for any purpose other than
6 prosecution of this action is warranted. Such confidential and proprietary materials
7 |land information consist of, among other things, confidential business or financial
8 information, information regarding confidential business practices, or other
? || confidential research, development, or commercial information (including
10" || information implicating privacy rights of third parties), information otherwise
i generally unavailable to the public, or which may be privileged or otherwise
V2 protected from disclosure under state or federal statutes, court rules, case decisions,
'3 ll or common law. Accordingly, to expedite the flow of information, to facilitate the
M4 prompt resolution of disputes over confidentiality of discovery materials, to
9 adequately protect information the parties are entitled to keep confidential, to ensure
16 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
18 litigation, and serve the ends of justice, a protective order for such information is
9 justified in this matter. It is the intent of the parties that information will not be
20 designated as confidential for tactical reasons and that nothing be so designated
2! without a good faith belief that it has been maintained in a confidential, non-public
22 manner, and there is good cause why it should not be part of the public record of this
°° case.
2. DEFINITIONS
» 2.1 Action: This pending federal law suit, Jose Vasquez, individually and on
*6 behalf of all those similarly situated, v. Draper and Kramer Mortgage Corp.
or Case No. 2:21-cv-00693-FMO-AS.
28
TIMOTHY P. RUMDERGER
1339 Bay Street
as0) 841-3500 STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page3of15 Page ID #:1366
1 2.2 Challenging Party: A Party or Non-Party that challenges the designation
2 of information or items under this Order.
3 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
4 how it is generated, stored or maintained) or tangible things that qualify for
5 protection under Federal Rule of Civil Procedure 26(c), and as specified
6 above in the Good Cause Statement.
7 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
8 support staff).
9 2.5 Designating Party: a Party or Non-Party that designates information or
10 items that it produces in disclosures or in responses to discovery as
11 “CONFIDENTIAL.”
12 2.6 Disclosure or Discovery Material: all items or information, regardless of
13 the medium or manner in which it is generated, stored, or maintained
14 (including, among other things, testimony, transcripts, and tangible things),
15 that are produced or generated in disclosures or responses to discovery in this
16 matter.
17 2.7 Expert: a person with specialized knowledge or experience in a matter
18 pertinent to the litigation who has been retained by a Party or its counsel to
19 serve as an expert witness or as a consultant in this Action.
20 2.8 House Counsel: attorneys who are employees of a party to this Action.
21 House Counsel does not include Outside Counsel of Record or any other
22 outside counsel.
23 2.9 Non-Party: any natural person, partnership, corporation, association, or
24 other legal entity not named as a Party to this action.
25 2.10 Outside Counsel of Record: attorneys who are not employees of a party
26 to this Action but are retained to represent or advise a party to this Action and
27 have appeared in this Action on behalf of that party or are affiliated with a
28
TIMOTHY P. RUMDERGER
1339 Bay Street
as0) 841-3500 STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page4of15 Page ID #:1367
1 law firm which has appeared on behalf of that party, and includes support
2 staff.
3 2.11 Party: any party to this Action, including all of its officers, directors,
4 employees, consultants, retained experts, and Outside Counsel of Record (and
5 their support staffs).
6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
7 Discovery Material in this Action.
8 2.13 Professional Vendors: persons or entities that provide litigation support
9 services (e.g., photocopying, videotaping, translating, preparing exhibits or
10 demonstrations, and organizing, storing, or retrieving data in any form or
1] medium) and their employees and subcontractors.
12 2.14 Protected Material: any Disclosure or Discovery Material that is
13 designated as “CONFIDENTIAL.”
14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
15 from a Producing Party.
16
7 3. SCOPE
18 The protections conferred by this Stipulation and Order cover not only
19 ||Protected Material (as defined above), but also (1) any information copied or
20 extracted from Protected Material; (2) all copies, excerpts, summaries, or
31 ||compilations of Protected Material; and (3) any testimony, conversations, or
39 ||presentations by Parties or their Counsel that might reveal Protected Material.
3 Any use of Protected Material at trial shall be governed by the orders of the
94 ||trial judge. This Order does not govern the use of Protected Material at trial.
25
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
swore
1339 Bay Street
as0) 841-3500 STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page5of15 Page ID #:1368
1 ||be presumptively available to all members of the public, including the press, unless
2 ||compelling reasons supported by specific factual findings to proceed otherwise are
3 ||made to the trial judge in advance of the trial. See Kamakana v. City and County of
4 || Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
5 ||showing for sealing documents produced in discovery from “compelling reasons”
6 ||standard when merits-related documents are part of court record). Accordingly, the
7 ||terms of this protective order do not extend beyond the commencement of the trial.
8 5. DESIGNATING PROTECTED MATERIAL
9 5.1 Exercise of Restraint and Care in Designating Material for Protection
10 Each Party or Non-Party that designates information or items for protection
11 ||under this Order must take care to limit any such designation to specific material
12 ||that qualifies under the appropriate standards. The Designating Party must designate
13 ||for protection only those parts of material, documents, items, or oral or written
14 |}communications that qualify so that other portions of the material, documents,
15 ||items, or communications for which protection is not warranted are not swept
16 |/unjustifiably within the ambit of this Order.
17 Mass, indiscriminate, or routinized designations are prohibited. Designations
18 ||that are shown to be clearly unjustified or that have been made for an improper
19 || purpose (e.g., to unnecessarily encumber the case development process or to impose
20 □□ unnecessary expenses and burdens on other parties) may expose the Designating
21 ||Party to sanctions.
22 If it comes to a Designating Party’s attention that information or items that it
23 ||designated for protection do not qualify for protection, that Designating Party must
24 |!promptly notify all other Parties that it is withdrawing the inapplicable designation.
25
26 5.2 Manner and Timing of Designations. Except as otherwise provided in
27 ||this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
28 ||stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
as0) 841-3500 STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page6of15 Page ID #:1369
1 |{under this Order must be clearly so designated before the material is disclosed or
2 ||produced.
3 Designation in conformity with this Order requires:
4 (a) for information in documentary form (e.g., paper or electronic documents,
5 ||but excluding transcripts of depositions or other pretrial or trial proceedings), that
6 ||the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
7 ||“CONFIDENTIAL legend”), to each page that contains protected material. If only a
8 ||portion or portions of the material on a page qualifies for protection, the Producing
9 ||Party also must clearly identify the protected portion(s) (e.g., by making appropriate
10 ||markings in the margins).
1] A Party or Non-Party that makes original documents available for inspection
12 ||need not designate them for protection until after the inspecting Party has indicated
13 which documents it would like copied and produced. During the inspection and
14 ||before the designation, all of the material made available for inspection shall be
15 ||deemed “CONFIDENTIAL.” After the inspecting Party has identified the
16 ||documents it wants copied and produced, the Producing Party must determine which
17 |/documents, or portions thereof, qualify for protection under this Order. Then, before
18 || producing the specified documents, the Producing Party must affix the
19 ||“CONFIDENTIAL legend” to each page that contains Protected Material. If only a
20 □□ portion or portions of the material on a page qualifies for protection, the Producing
21 |!Party also must clearly identify the protected portion(s) (e.g., by making appropriate
22 ||markings in the margins).
23 (b) for testimony given in depositions that the Designating Party identify the
24 |!Disclosure or Discovery Material on the record, before the close of the deposition all
25 || protected testimony.
26 (c) for information produced in some form other than documentary and for
27 |\any other tangible items, that the Producing Party affix in a prominent place on the
28
TIMOTHY P. RUMDERGER
Sana Cat STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page 7of15 Page ID #:1370
1 ||exterior of the container or containers in which the information is stored the legend
2 ||“CONFIDENTIAL.” If only a portion or portions of the information warrants
3 || protection, the Producing Party, to the extent practicable, shall identify the protected
4 ||portion(s).
5 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
6 ||failure to designate qualified information or items does not, standing alone, waive
7 ||the Designating Party’s right to secure protection under this Order for such material.
8 ||Upon timely correction of a designation, the Receiving Party must make reasonable
9 ||efforts to assure that the material is treated in accordance with the provisions of this
10 }|Order.
11
□ 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
15 Scheduling Order.
6 6.2 Meet and Confer. The Challenging Party shall initiate the informal
v7 dispute resolution process set forth in the Court's Procedures and Schedules. see
18 http://www.cacd.uscourts.gov/honorable-alka-sagar
19 6.3 The burden of persuasion in any such challenge proceeding shall be on
50 the Designating Party. Frivolous challenges, and those made for an improper
51 ||Purpose (e.g., to harass or impose unnecessary expenses and burdens on other
> parties) may expose the Challenging Party to sanctions. Unless the Designating
73 Party has waived or withdrawn the confidentiality designation, all parties shall
4 continue to afford the material in question the level of protection to which it is
95 entitled under the Producing Party’s designation until the Court rules on the
26 challenge.
27
28
TIMOTHY P. RUMDERGER
Sana Cat STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page 8of15 Page ID #:1371
1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected Material that
3 |]1s disclosed or produced by another Party or by a Non-Party in connection with this
4 ||Action only for prosecuting, defending, or attempting to settle this Action. Such
5 ||Protected Material may be disclosed only to the categories of persons and under the
6 ||conditions described in this Order. When the Action has been terminated, a
7 ||Receiving Party must comply with the provisions of section 13 below (FINAL
8 ||DISPOSITION).
9 Protected Material must be stored and maintained by a Receiving Party at a
10 |/location and in a secure manner that ensures that access is limited to the persons
11 ||authorized under this Order.
12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
13 ||otherwise ordered by the court or permitted in writing by the Designating Party, a
14 ||Receiving Party may disclose any information or item designated
15 ||}“CONFIDENTIAL” only to:
16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
17 |/employees of said Outside Counsel of Record to whom it is reasonably necessary to
18 || disclose the information for this Action;
19 (b) the Receiving Parties, their officers, directors, and employees (including
20 ||House Counsel) of the Receiving Party to whom disclosure is reasonably necessary
21 |! for this Action;
22 (c) Experts (as defined in this Order) of the Receiving Party to whom
23 □□ disclosure is reasonably necessary for this Action and who have signed the
24 ||Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (d) the court and its personnel;
26 (e) court reporters and their staff;
27 (f) professional jury or trial consultants, mock jurors, and Professional
28
TIMOTHY P. RUMDERGER
Sana Cat STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page9of15 Page ID #:1372
1 || Vendors to whom disclosure is reasonably necessary for this Action and who have
2 ||signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
3 (g) the author or recipient of a document containing the information or a
4 ||custodian or other person who otherwise possessed or knew the information;
5 (h) during their depositions, witnesses, and attorneys for witnesses, in the
6 ||Action to whom disclosure is reasonably necessary provided: (1) the deposing party
7 ||requests that the witness sign the form attached as Exhibit A hereto; and (2) they
8 || will not be permitted to keep any confidential information unless they sign the
9 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
10 ||agreed by the Designating Party or ordered by the court. Pages of transcribed
11 ||deposition testimony or exhibits to depositions that reveal Protected Material may
12 ||be separately bound by the court reporter and may not be disclosed to anyone except
13 ||as permitted under this Stipulated Protective Order; and
14 (1) any mediator or settlement officer, and their supporting personnel,
15 |/mutually agreed upon by any of the parties engaged in settlement discussions.
16
17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
8 PRODUCED IN OTHER LITIGATION
19 If a Party is served with a subpoena or a court order issued in other litigation
29 ||that compels disclosure of any information or items designated in this Action as
21 || “CONFIDENTIAL,” that Party must:
22 (a) promptly notify in writing the Designating Party. Such notification shall
23 ||include a copy of the subpoena or court order;
24 (b) promptly notify in writing the party who caused the subpoena or order to
25 |{1ssue in the other litigation that some or all of the material covered by the subpoena
26 |{or order is subject to this Protective Order. Such notification shall include a copy of
27 ||this Stipulated Protective Order; and
28
TIMOTHY P. RUMDERGER
Sana Cat STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page 10o0f15 Page ID #:1373
1 (c) cooperate with respect to all reasonable procedures sought to be pursued
2 ||by the Designating Party whose Protected Material may be affected.
3 If the Designating Party timely seeks a protective order, the Party served with
4 ||the subpoena or court order shall not produce any information designated in this
5 |laction as “CONFIDENTIAL” before a determination by the court from which the
6 ||subpoena or order issued, unless the Party has obtained the Designating Party’s
7 ||permission. The Designating Party shall bear the burden and expense of seeking
8 ||protection in that court of its confidential material and nothing in these provisions
9 ||should be construed as authorizing or encouraging a Receiving Party in this Action
10 ||to disobey a lawful directive from another court.
11
12 9. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
3 PRODUCED IN THIS LITIGATION
14 (a) The terms of this Order are applicable to information produced by a Non-
15 || Party in this Action and designated as “CONFIDENTIAL.” Such information
16 ||produced by Non-Parties in connection with this litigation is protected by the
17. |}/remedies and relief provided by this Order. Nothing in these provisions should be
1g |}construed as prohibiting a Non-Party from seeking additional protections.
19 (b) In the event that a Party is required, by a valid discovery request, to
29 ||produce a Non-Party’s confidential information in its possession, and the Party is
21 ||subject to an agreement with the Non-Party not to produce the Non-Party’s
22 ||confidential information, then the Party shall:
23 (1) promptly notify in writing the Requesting Party and the Non-Party that
24 ||some or all of the information requested is subject to a confidentiality agreement
25 || with a Non-Party;
26 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
27 Order in this Action, the relevant discovery request(s), and a reasonably specific
28 description of the information requested; and
TIMOTHY P. RUMBERGER 10
Sana Cat STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page11o0f15 Page ID #:1374
1 (3) make the information requested available for inspection by the Non-Party,
2 {lif requested.
3 (c) If the Non-Party fails to seek a protective order from this court within 14
4 |\days of receiving the notice and accompanying information, the Receiving Party
5 ||may produce the Non-Party’s confidential information responsive to the discovery
6 ||request. If the Non-Party timely seeks a protective order, the Receiving Party shall
7 ||not produce any information in its possession or control that is subject to the
8 ||confidentiality agreement with the Non-Party before a determination by the court.
9 □□ Absent a court order to the contrary, the Non-Party shall bear the burden and
10 |/expense of seeking protection in this court of its Protected Material.
11
12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
14 Protected Material to any person or in any circumstance not authorized under this
15 ||Stipulated Protective Order, the Receiving Party must immediately (a) notify in
16 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
17 ||to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
18 ||persons to whom unauthorized disclosures were made of all the terms of this Order,
19 ||and (d) request such person or persons to execute the “Acknowledgment and
20 ||Agreement to Be Bound” that is attached hereto as Exhibit A.
21
11. NADVERTENT PRODUCTION OF PRIVILEGED OR
33 OTHERWISE PROTECTED MATERIAL
74 When a Producing Party gives notice to Receiving Parties that certain
5 |}inadvertently produced material is subject to a claim of privilege or other protection,
26 ||the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
7 _ ||Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
4g ||may be established in an e-discovery order that provides for production without
TIMOTHY P. RUMDERGER tI
Sana Cat STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page12o0f15 Page ID #:1375
1 ||prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
2 |{as the parties reach an agreement on the effect of disclosure of a communication or
3 {information covered by the attorney-client privilege or work product protection, the
4 ||parties may incorporate their agreement in the stipulated protective order submitted
5 ||to the court.
6 12. MISCELLANEOUS
7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
8 ||person to seek its modification by the Court in the future.
9 12.2 Right to Assert Other Objections. By stipulating to the entry of this
10 || Protective Order no Party waives any right it otherwise would have to object to
11 |/disclosing or producing any information or item on any ground not addressed in this
12 ||Stipulated Protective Order. Similarly, no Party waives any right to object on any
13 || ground to use in evidence of any of the material covered by this Protective Order.
14 12.3 Filing Protected Material. A Party that seeks to file under seal any
15 ||Protected Material must comply with Civil Local Rule 79-5. Protected Material may
16 |/only be filed under seal pursuant to a court order authorizing the sealing of the
17 □□ specific Protected Material at issue. If a Party's request to file Protected Material
18 |/under seal is denied by the court, then the Receiving Party may file the information
19 |\in the public record unless otherwise instructed by the court.
20 13. FINAL DISPOSITION
21 |) As an initial matter, Plaintiff Vasquez and his counsel acknowledge that they were
22 ||provided with contact information belonging to all putative collective action
23 ||members as a result of the Court’s order granting them permission to send a notice
24 |/of collective action. Plaintiff Vasquez and his counsel acknowledge and agree that,
25 within 5 business days of executing this stipulated protective order, they will destroy
26 |/the contact information, whether maintained in electronic or physical form,
27
28
TIMOTHY P. RUMDERGER 12
1339 Bay Street
Sensi) 841-3500 STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page130f15 Page ID #:1376
1 ||concerning any putative collective action member who did not opt into the FLSA
2 |{collective or is not a Rule 23 putative class member.
3 In addition to the aforementioned representation, after the final disposition of
4 ||this Action, as defined in paragraph 4, within 60 days of a written request by the
5 ||Designating Party, each Receiving Party must return all Protected Material to the
6 ||Producing Party or destroy such material. As used in this subdivision, “all Protected
7 Material” includes all copies, abstracts, compilations, summaries, and any other
8 ||format reproducing or capturing any of the Protected Material. Whether the
9 ||Protected Material is returned or destroyed, the Receiving Party must submit a
10 || written certification to the Producing Party (and, if not the same person or entity, to
11 ||the Designating Party) by the 60 day deadline that (1) identifies (by category, where
12 ||appropriate) all the Protected Material that was returned or destroyed and (2)affirms
13 ||that the Receiving Party has not retained any copies, abstracts, compilations,
14 |!summaries or any other format reproducing or capturing any of the Protected
15 ||Material. Notwithstanding this provision, Counsel are entitled to retain an archival
16 |Ilcopy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
17 |}memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
18 |) work product, and consultant and expert work product, even if such materials
19 ||contain Protected Material. Any such archival copies that contain or
20 |/constitute Protected Material remain subject to this Protective Order as set forth in
21 |)/Section 4 (DURATION).
22 14. Any violation of this Order may be punished by any and all appropriate
23 ||measures including, without limitation, contempt proceedings and/or monetary
24 sanctions.
25
*° IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
27
28
TIMOTHY P. RUMDERGER 13
1339 Bay Street
as0) 841-3500 STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page14o0f15 Page ID #:1377
]
5 Counsel for Defendant
Draper & Kramer Mortgage Corp.
Dated: June 2022 =
5 McDERMOTT WILL & EMERY LLP
‘ Ronald J. Holland, Esq.
Christopher A. Braham, Esq.
7 Brian Casillas, Esq.
10 Counsel for Plaintiff and Class Counsel
for all Conditionally Certified Class Members
11
12
Dated: June 23, 2022
13 Timothy P. Rumberger, Es
4 Kevin R. Allen, Esq.
15
16
17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
18
19 ||Dated: 06/28/2022 /S/
20 Honorable Alka Sagar
United States Magistrate Judge
21
22
23
24
25
26
27
28
TIMOTHY > CuMEeROER 1 4
“ens 84100 STIPULATED PROTECTIVE ORDER
Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page15o0f15 Page ID #:1378
1 EXHIBIT A
5 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [print or type full name], of
4 [print
5 |]or type full address], declare under penalty of perjury that I have read in its entirety
6 ||and understand the Stipulated Protective Order that was issue by the United States
7 || District Court for the Central District of California on in the case of
8 ||Jose Vasquez, individually and on behalf of all those similarly situated, v. Draper
9 ||and Kramer Mortgage Corp. Case No. 2:21-cv-00693-FMO-AS. I agree to
10 ||comply with and to be bound by all the terms of this Stipulated Protective Order and
11 |/I understand and acknowledge that failure to so comply could expose me to
12 ||sanctions and punishment in the nature of contempt. I solemnly promise that I will
13 |/not disclose in any manner any information or item that is subject to this Stipulated
14 ||Protective Order to any person or entity except in strict compliance with the
15 provisions of this Order.
16 I further agree to submit to the jurisdiction of the United States District Court
17 || for the Central District of California for the purpose of enforcing the terms of this
18 || Stipulated Protective Order, even if such enforcement proceedings occur after
19 ||termination of this action. I hereby appoint [print or type
20 |! full name] of [print or type full address and
21 |/telephone number] as my California agent for service of process in connection with
22 ||this action or any proceedings related to enforcement of this Stipulated Protective
23 |! Order.
24 || Date:
25 ||City and State where sworn and signed:
26 Printed Name:
27
28 Signature:
TIMOTHY P. RUMDERGER 15
Sana Cat STIPULATED PROTECTIVE ORDER