distinguishing “good cause” 16 showing for sealing documents produced in discovery from “compelling reasons” 17 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 16 showing for sealing documents produced in discovery from “compelling reasons” 17 standard when merits-related documents are part of court record
Written by the judges who cited it.
The opinion
Case 2:22-cv-01306-GW-JEM Document 28 Filed 07/27/22 Page 1 of 18 Page ID #:127
1 Charles E. Slyngstad (SBN 89103)
E-mail: cslyngstad@bwslaw.com
2 Brian S. Ginter (SBN 265786)
E-mail: bginter@bwslaw.com
3 BURKE, WILLIAMS & SORENSEN, LLP
444 South Flower Street, Suite 2400
4 Los Angeles, CA 90071-2953
Tel: 213.236.0600 Fax: 213.236.2700
5
Attorneys for Defendant
6
CITY OF LOS ANGELES
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 JESSICA WOODWARD, SCOTT Case No. 2:22-cv-01306-GW-JEM
TAYLOR, ERIK BOYD AND
12 VISHAL SINGH, [XPXRXOXPOXSXEXDX] STIPULATED
PROTECTIVE ORDER RE:
13 Plaintiffs, DISCLOSURE OF CONFIDENTIAL
INFORMATION
14 v.
15 CITY OF LOS ANGELES, a
municipal entity, and DOES 1-10, [Discovery Document: Referred to
16 inclusive, Magistrate Judge John E. McDermott]
17 Defendants.
18
19
20
21 1. GENERAL
22 1.1 Purposes and Limitations.
23 Discovery in this action is likely to involve production of confidential,
24 proprietary or private information for which special protection from public
25 disclosure and from use for any purpose other than prosecuting this litigation may
26 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
27 enter the following Stipulated Protective Order. The parties acknowledge that this
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 1.2 Good Cause Statement.
6 This action involves the City of Los Angeles and members of the Los
7 Angeles Police Department. Plaintiffs are seeking materials and information that
8 Defendant the City of Los Angeles et al. (“City”) maintains as confidential, such as
9 personnel files of the police officers involved in this incident, Internal Affairs
10 materials and information, video recordings (including Body-Worn Video
11 recordings and Digital In-Car Video recordings), audio recordings, and other
12 administrative materials and information currently in the possession of the City and
13 which the City believes needs special protection from public disclosure and from
14 use for any purpose other than prosecuting this litigation. Plaintiffs are also seeking
15 official information contained in the personnel files of the police officers involved
16 in the subject incident, which the City maintains as strictly confidential and which
17 the City believes needs special protection from public disclosure and from use for
18 any purpose other than prosecuting this litigation.
19 The City asserts that the confidentiality of the materials and information
20 sought by Plaintiffs is recognized by California and federal law, as evidenced by,
21 inter alia, California Penal Code section 832.7 and Kerr v. United States Dist. Ct.
22 for N.D. Cal., 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The
23 City has not publicly released the materials and information referenced above
24 except under protective order or pursuant to a court order, if at all. These materials
25 and information are of the type that has been used to initiate disciplinary action
26 against Los Angeles Police Department (“LAPD”) officers, and has been used as
27 evidence in disciplinary proceedings, where the officers’ conduct was considered to
28 be contrary to LAPD policy.
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1 The City contends that absent a protective order delineating the
2 responsibilities of nondisclosure on the part of the parties hereto, there is a specific
3 risk of unnecessary and undue disclosure by one or more of the many attorneys,
4 secretaries, law clerks, paralegals and expert witnesses involved in this case, as well
5 as the corollary risk of embarrassment, harassment and professional and legal harm
6 on the part of the LAPD officers referenced in the materials and information.
7 Defendants are likely to seek confidential medical records from Plaintiffs
8 which Plaintiffs contend should not be disseminated beyond this litigation.
9 Accordingly, to expedite the flow of information, to facilitate the prompt
10 resolution of disputes over confidentiality of discovery materials, to adequately
11 protect information the parties are entitled to keep confidential, to ensure that the
12 parties are permitted reasonably necessary uses of such material in preparation for
13 and in the conduct of trial, to address their handling at the end of the litigation, and
14 serve the ends of justice, a protective order for such information is justified in this
15 matter. It is the intent of the parties that information will not be designated as
16 confidential for tactical reasons and that nothing be so designated without a good
17 faith belief that it has been maintained in a confidential, non-public manner, and
18 there is good cause why it should not be part of the public record of this case.
19 1.3 Acknowledgment of Procedure for Filing Under Seal.
20 The parties agree that any pleadings, motions, briefs, declarations,
21 stipulations, exhibits or other written submissions to the Court in this litigation
22 which contain or incorporate Confidential Material shall be lodged with an
23 application and/or joint stipulation to file the papers or the portion thereof
24 containing the Confidential Material, under seal.
25 The parties agree that they will meet and confer regarding the necessity of
26 seeking an order from the Court filing under seal any pleadings, motions, briefs,
27 declarations, stipulations, exhibits or other documents and/or materials at least five
28 (5) days prior to filing any application and/or joint stipulation to file under seal, if
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1 feasible.
2 The parties further acknowledge, as set forth in Section 12.3, below, that this
3 Stipulated Protective Order does not automatically entitle them to file confidential
4 information under seal and that Local Civil Rule 79-5 sets forth the procedures that
5 must be followed and the standards that will be applied when a party seeks
6 permission from the Court to file material under seal.
7 2. DEFINITIONS
8 2.1 Action: Jessica Woodward, et al. v. City of Los Angeles, et al. Case
9 No. 2:22-CV-01306-GW-JEM.
10 2.2 Challenging Party: a Party or Non-Party that challenges the
11 designation of information or items under this Order.
12 2.3 “CONFIDENTIAL” Information or Items: information (regardless
13 of how it is generated, stored or maintained) or tangible things that qualify for
14 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
15 the Good Cause Statement. This also includes (1) any information copied or
16 extracted from the Confidential information; (2) all copies, excerpts, summaries,
17 abstracts or compilations of Confidential information; and (3) any testimony,
18 conversations, or presentations that might reveal Confidential information.
19 2.4 Counsel: Counsel of record for the parties to this civil litigation and
20 their support staff.
21 2.5 Designating Party: a Party or Non-Party that designates information
22 or items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL.”
24 2.6 Disclosure or Discovery Material: all items or information,
25 regardless of the medium or manner in which it is generated, stored, or maintained
26 (including, among other things, testimony, transcripts, and tangible things), that are
27 produced or generated in disclosures or responses to discovery in this matter.
28 2.7 Expert: a person with specialized knowledge or experience in a matter
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1 pertinent to the litigation who has been retained by a Party or its counsel to serve as
2 an expert witness or as a consultant in this Action.
3 2.8 Final Disposition: when this Action has been fully and completely
4 terminated by way of settlement, dismissal, trial and/or appeal.
5 2.9 House Counsel: attorneys other than Counsel (as defined in paragraph
6 2.4) and who are employees of a party to this Action.
7 2.10 Non-Party: any natural person, partnership, corporation, association
8 or other legal entity not named as a Party to this action.
9 2.11 Outside Counsel of Record: attorneys who are not employees of a
10 party to this Action but are retained to represent or advise a party to this Action and
11 have appeared in this Action on behalf of that party or are affiliated with a law firm
12 that has appeared on behalf of that party, and includes support staff.
13 2.12 Party: any party to this Action, including all of its officers, directors,
14 boards, departments, divisions, employees, consultants, retained experts, and
15 Outside Counsel of Record (and their support staffs).
16 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
17 Discovery Material in this Action.
18 2.14 Professional Vendors: persons or entities that provide litigation
19 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
20 demonstrations, and organizing, storing, or retrieving data in any form or medium)
21 and their employees and subcontractors.
22 2.15 Protected Material: any Disclosure or Discovery Material that is
23 designated as “CONFIDENTIAL.”
24 2.16 Receiving Party: a Party that receives Disclosure or Discovery
25 Material from a Producing Party.
26 3. SCOPE
27 The protections conferred by this Stipulation and Order cover not only
28 Protected Material (as defined above), but also (1) any information copied or
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1 extracted from Protected Material; (2) all copies, excerpts, abstracts, summaries, or
2 compilations of Protected Material; and (3) any testimony, conversations, or
3 presentations by Parties or their Counsel that might reveal Protected Material, other
4 than during a court hearing or trial.
5 Any use of Protected Material during a court hearing or at trial shall be
6 governed by the orders of the presiding judge. This Order does not govern the use
7 of Protected Material during a court hearing or at trial.
8 4. DURATION
9 Once a trial commences in this Action, information that was designated as
10 CONFIDENTIAL or maintained pursuant to this protective order and that is
11 introduced or admitted as an exhibit at trial becomes public and will be
12 presumptively available to all members of the public, including the press, unless
13 compelling reasons supported by specific factual findings to proceed otherwise are
14 made to the trial judge in advance of the trial. See Kamakana v. City and County of
15 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
16 showing for sealing documents produced in discovery from “compelling reasons”
17 standard when merits-related documents are part of court record). Accordingly, the
18 terms of this protective order do not extend beyond the commencement of the trial
19 as to the CONFIDENTIAL information and materials introduced or admitted as an
20 exhibit at trial.
21 5. DESIGNATING PROTECTED MATERIAL
22 5.1 Exercise of Restraint and Care in Designating Material for
23 Protection.
24 Each Party or Non-Party that designates information or items for protection
25 under this Order must take care to limit any such designation to specific material
26 that qualifies under the appropriate standards. The Designating Party must
27 designate for protection only those parts of material, documents, items or oral or
28 written communications that qualify so that other portions of the material,
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1 documents, items or communications for which protection is not warranted are not
2 swept unjustifiably within the ambit of this Order.
3 Mass, indiscriminate or routinized designations are prohibited. Designations
4 that are shown to be clearly unjustified or that have been made for an improper
5 purpose (e.g., to unnecessarily encumber the case development process or to
6 impose unnecessary expenses and burdens on other parties) may expose the
7 Designating Party to sanctions.
8 If it comes to a Designating Party’s attention that information or items that it
9 designated for protection do not qualify for protection, the Designating Party must
10 promptly notify all other Parties that it is withdrawing the inapplicable designation.
11 5.2 Manner and Timing of Designations. Except as otherwise provided
12 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
14 under this Order must be clearly so designated before the material is disclosed or
15 produced.
16 Designation in conformity with this Order requires:
17 (a) for information in documentary form (e.g., paper or electronic
18 documents, but excluding transcripts of depositions or other pretrial or trial
19 proceedings), that the Producing Party affix at a minimum, the legend
20 “CONFIDENTIAL” or words of a similar effect, and that includes the case name
21 and case number (hereinafter “CONFIDENTIAL legend”), to each page that
22 contains protected material. If only a portion of the material on a page qualifies for
23 protection, the Producing Party also must clearly identify the protected portion(s)
24 (e.g., by making appropriate markings in the margins).
25 A Party or Non-Party that makes original documents available for inspection
26 need not designate them for protection until after the inspecting Party has indicated
27 which documents it would like copied and produced. During the inspection and
28 before the designation, all of the material made available for inspection shall be
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1 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
2 documents it wants copied and produced, the Producing Party must determine
3 which documents, or portions thereof, qualify for protection under this Order. Then,
4 before producing the specified documents, the Producing Party must affix the
5 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a
6 portion of the material on a page qualifies for protection, the Producing Party also
7 must clearly identify the protected portion(s) (e.g., by making appropriate markings
8 in the margins).
9 (b) for testimony given in depositions that the Designating Party
10 identifies the Disclosure or Discovery Material on the record, before the close of
11 the deposition all protected testimony.
12 (c) for information produced in some form other than documentary
13 and for any other tangible items, that the Producing Party affix in a prominent place
14 on the exterior of the container or containers in which the information is stored the
15 legend “CONFIDENTIAL.” If only a portion or portions of the information
16 warrants protection, the Producing Party, to the extent practicable, shall identify the
17 protected portion(s).
18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
19 failure to designate qualified information or items does not, standing alone, waive
20 the Designating Party’s right to secure protection under this Order for such
21 material. Upon timely correction of a designation, the Receiving Party must make
22 reasonable efforts to assure that the material is treated in accordance with the
23 provisions of this Order.
24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
26 designation of confidentiality at any time that is consistent with the Court’s
27 Scheduling Order.
28 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
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1 resolution process under Local Rule 37.1, et seq. as follows. If a party disagrees
2 with the Designating Party's designation of information as "CONFIDENTIAL” they
3 shall advise counsel for the Designating Party, in writing, of their objections, the
4 specific Documents, Testimony or Confidential Information to which each
5 objection pertains, and the specific reasons and support for such objections (the
6 “Designation Objections”). Counsel for the Designating Party shall have fourteen
7 (14) days from receipt of the written Designation Objections to either (a) agree in
8 writing to de-designate Documents, Testimony or Information pursuant to any or all
9 of the Designation Objections and/or (b) participate in a telephonic conference of
10 counsel to discuss the Designation Objections. If the parties are unable to resolve
11 these issues informally, the Designating Party shall prepare a Joint Stipulation
12 pursuant to LR-37.2.2 and submit it to the Objecting Party within 7 days of the
13 conference. The Designating Party shall also be responsible for lodging any
14 disputed documents or materials under seal if necessary to resolve the dispute.
15 Pending a resolution of the Motion by the Court, any and all existing designations
16 on the Confidential Information at issue in such Motion shall remain in place. The
17 Designating Party shall have the burden on any Motion of establishing the
18 applicability of its “Confidential” designation. In the event that the Designation
19 Objections are neither timely agreed to nor timely addressed by Motion, then such
20 Documents, Testimony or Information shall no longer deemed to be “Confidential.”
21 6.3 Burden. The burden of persuasion in any such challenge proceeding
22 shall be on the Designating Party. Frivolous challenges, and those made for an
23 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
24 other parties) may expose the Challenging Party to sanctions. Unless the
25 Designating Party has waived or withdrawn the confidentiality designation, all
26 parties shall continue to afford the material in question the level of protection to
27 which it is entitled under the Producing Party’s designation until the Court rules on
28 the challenge.
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1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected Material that
3 is 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) Plaintiffs Jessica Woodward, Scott Taylor, Erik Boyd, and
17 Vishal Singh;
18 (b) the Receiving Party’s Counsel of Record in this Action, as well
19 as employees of said Counsel of Record to whom it is reasonably necessary to
20 disclose the information for this Action;
21 (c) Experts (as defined in this Order) of the Receiving Party to
22 whom disclosure is reasonably necessary for this Action and who have signed the
23 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
24 (d) the court and its personnel;
25 (e) court reporters and their staff;
26 (f) professional jury or trial consultants, mock jurors, and
27 Professional Vendors to whom disclosure is reasonably necessary for this Action
28
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1 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
2 A);
3 (g) the author or recipient of a document containing the information
4 or a custodian or other person who otherwise possessed or knew the information;
5 (h) during their depositions, witnesses, and attorneys for witnesses,
6 in the Action to whom disclosure is reasonably necessary provided: (1) the
7 deposing party requests that the witness sign the form attached as Exhibit “A”
8 hereto; and (2) they will not be permitted to keep any confidential information
9 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit
10 “A”), unless otherwise agreed by the Designating Party or ordered by the court.
11 Pages of transcribed deposition testimony or exhibits to depositions that reveal
12 Protected Material may be separately bound by the court reporter and may not be
13 disclosed to anyone except as permitted under this Stipulated Protective Order; and
14 (i) any mediator or settlement officer, and their supporting
15 personnel, mutually agreed upon by any of the parties engaged in settlement
16 discussions and who have signed the “Acknowledgment and Agreement to Be
17 Bound” (Exhibit A).
18 7.3 Counsel making the disclosure to any qualified person described
19 herein shall retain the original executed copy of the Nondisclosure Agreement until
20 sixty (60) days after this litigation has become final, including any appellate review,
21 and monitoring of an injunction. Counsel for the Receiving Party shall maintain all
22 signed Nondisclosure Agreements and shall produce the original signature page
23 upon reasonable written notice from opposing counsel. If an issue arises regarding a
24 purported unauthorized disclosure of Confidential Information, upon noticed
25 motion of contempt filed by the Designating Party, counsel for the Receiving Party
26 may be required to file the signed Nondisclosure Agreements, as well as a list of the
27 disclosed materials, in camera with the Court having jurisdiction of the Stipulation.
28
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1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2 PRODUCED IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation
4 that compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such
7 notification shall include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or
9 order to issue in the other litigation that some or all of the material covered by the
10 subpoena or order is subject to this Protective Order. Such notification shall include
11 a copy of this Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be
13 pursued by the Designating Party whose Protected Material may be affected.
14 The Party served with the subpoena or court order shall not produce any
15 information designated in this action as “CONFIDENTIAL” before a determination
16 by the court from which the subpoena or order issued, unless the Party has obtained
17 the Designating Party’s permission, or unless otherwise required by the law or court
18 order. The Designating Party shall bear the burden and expense of seeking
19 protection in that court of its confidential material and nothing in these provisions
20 should be construed as authorizing or encouraging a Receiving Party in this Action
21 to disobey a lawful directive from another court.
22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
23 PRODUCED IN THIS LITIGATION
24 (a) The terms of this Order are applicable to information produced
25 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
26 information produced by Non-Parties in connection with this litigation is protected
27 by the remedies and relief provided by this Order. Nothing in these provisions
28 should be construed as prohibiting a Non-Party from seeking additional protections.
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1 (b) In the event that a Party is required, by a valid discovery
2 request, to produce a Non-Party’s confidential information in its possession, and the
3 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s
4 confidential information, then the Party shall:
5 (1) promptly notify in writing the Requesting Party and the
6 Non-Party that some or all of the information requested is subject to a
7 confidentiality agreement with a Non-Party;
8 (2) promptly provide the Non-Party with a copy of the
9 Stipulated Protective Order in this Action, the relevant discovery request(s), and a
10 reasonably specific description of the information requested; and
11 (3) make the information requested available for inspection
12 by the Non-Party, if requested.
13 (c) If the Non-Party fails to seek a protective order from this court
14 within 14 days of receiving the notice and accompanying information, the
15 Receiving Party may produce the Non-Party’s confidential information responsive
16 to the discovery request. If the Non-Party timely seeks a protective order, the
17 Receiving Party shall not produce any information in its possession or control that
18 is subject to the confidentiality agreement with the Non-Party before a
19 determination by the court. Absent a court order to the contrary, the Non-Party shall
20 bear the burden and expense of seeking protection in this court of its Protected
21 Material.
22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
24 Protected Material to any person or in any circumstance not authorized under this
25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
26 writing the Designating Party of the unauthorized disclosures, (b) use its best
27 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
28 person or persons to whom unauthorized disclosures were made of all the terms of
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1 this Order, and (d) request such person or persons to execute the “Acknowledgment
2 and Agreement to Be Bound” that is attached hereto as Exhibit A.
3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
4 PROTECTED MATERIAL
5 When a Producing Party gives notice to Receiving Parties that certain
6 inadvertently produced material is subject to a claim of privilege or other
7 protection, the obligations of the Receiving Parties are those set forth in Federal
8 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
9 whatever procedure may be established in an e-discovery order that provides for
10 production without prior privilege review. Pursuant to Federal Rule of Evidence
11 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
12 of a communication or information covered by the attorney-client privilege or work
13 product protection, the parties may incorporate their agreement in the stipulated
14 protective order submitted to the court.
15 12. MISCELLANEOUS
16 12.1 Right to Further Relief. Nothing in this Order abridges the right of
17 any person to seek its modification by the Court in the future.
18 12.2 Right to Assert Other Objections. By stipulating to the entry of this
19 Protective Order, no Party waives any right it otherwise would have to object to
20 disclosing or producing any information or item on any ground not addressed in
21 this Stipulated Protective Order. Similarly, no Party waives any right to object on
22 any ground to use in evidence of any of the material covered by this Protective
23 Order.
24 12.3 Filing Protected Material. A Party that seeks to file under seal any
25 Protected Material must comply with Local Civil Rule 79-5. Protected Material
26 may only be filed under seal pursuant to a court order authorizing the sealing of the
27 specific Protected Material at issue. If a Party’s request to file Protected Material
28 under seal is denied by the court, then the Receiving Party may file the information
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1 in the public record unless otherwise instructed by the court.
2 13. FINAL DISPOSITION
3 After the final disposition of this Action, as defined in paragraph 2.8, within
4 60 days of a written request by the Designating Party, each Receiving Party must
5 return all Protected Material to the Producing Party or destroy such material. As
6 used in this subdivision, “all Protected Material” includes all copies, abstracts,
7 compilations, summaries, and any other format reproducing or capturing any of the
8 Protected Material. Whether the Protected Material is returned or destroyed, the
9 Receiving Party must submit a written certification to the Producing Party (and, if
10 not the same person or entity, to the Designating Party) by the 60 day deadline that
11 (1) identifies (by category, where appropriate) all the Protected Material that was
12 returned or destroyed and (2) affirms that the Receiving Party has not retained any
13 copies, abstracts, compilations, summaries or any other format reproducing or
14 capturing any of the Protected Material. Notwithstanding this provision, Counsel
15 are entitled to retain an archival copy of all pleadings, motion papers, trial,
16 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
17 and trial exhibits, expert reports, attorney work product, and consultant and expert
18 work product, even if such materials contain Protected Material. Any such archival
19 copies that contain or constitute Protected Material remain subject to this Protective
20 Order.
21 14. VIOLATION
22 Any violation of this Order may be punished by appropriate measures
23 including, without limitation, contempt proceedings and/or monetary sanctions.
24 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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Case 2:22-cv-01306-GW-JEM Document 28 Filed 07/27/22 Page 16 of 18 Page ID #:142
1 Dated: July 25, 2022 SCHONBRUN SEPLOW HARRIS
HOFFMAN & ZELDES LLP
2
3
By: /s/ Michael D. Seplow
4 Michael D. Seplow
Attorneys for Plaintiffs JESSICA
5 WOODWARD, SCOTT TAYLOR,
ERIK BOYD, & VISHAL SINGH
6
7 Dated: July 25, 2022 LAW OFFICES OF HUMBERTO
GUIZAR
8
9
By: /s/ Christian Contreras
10 Humberto Guizar
Christian Contreras
11 Attorneys for Plaintiffs JESSICA
WOODWARD, SCOTT TAYLOR,
12 ERIK BOYD, & VISHAL SINGH
13
14 Dated: July 25, 2022 BURKE, WILLIAMS & SORENSEN,
LLP
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By: /s/ Charles E. Slyngstad
17 Charles E. Slyngstad1
Attorneys for Defendant CITY OF
18 LOS ANGELES
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1 Filer attests that all signatories listed concur in the filing’s content and have
28 authorized the filing pursuant to Local Rule 5-4.3.4(a)(2)(i).
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Case 2:22-cv-01306-GW-JEM Document 28 Filed 07/27/22 Page17of18 Page ID #:143
1 Having considered the papers, the finding that good cause exists, the Parties’
2 || Stipulated Protective Order is granted.
3 IT IS SO ORDERED.
‘ □□□ EMedennat
° Dated: 7/27/22 ~~ HON. JOHNE.McDERMOTT —
6 UNITED STATES MAGISTRATE JUDGE
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Case 2:22-cv-01306-GW-JEM Document 28 Filed 07/27/22 Page 18 of 18 Page ID #:144
1 ATTACHMENT “A”
2 NONDISCLOSURE AGREEMENT
3 I, _____________________ do solemnly swear that I am fully familiar with
4 the terms of the Protective Order entered in Jessica Woodward, et al. v. City of Los
5 Angeles, et al., United States District Court for the Central District of California,
6 Central Division, Case No. 2:22-CV-01306-GW-JEM, and hereby agree to comply
7 with and be bound by the terms and conditions of said Order. I hereby consent to
8 the jurisdiction of the United States District Court for the Central District of
9 California for purposes of enforcing this Order.
10 Dated: Signed:
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