even stipulated 77 protective orders require good cause showing
How later courts described this case
- even stipulated 77 protective orders require good cause showing
Written by the judges who cited it.
The opinion
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 1 of 16 Page ID #:220
11
22
33
44
55
66
77
UNITED STATES DISTRICT COURT
88
CENTRAL DISTRICT OF CALIFORNIA
99
PATRICIA MEDINA, individual and as
1100 Case No. 8:22-cv-00235-JVS-JDEx
guardian ad litem for V.P., J.G., S.M., and
1111 B.P; VALORIE PEREZ, individually and
as guardian ad litem for E.M. and T.M.;
1122 STIPULATED PROTECTIVE
MARIA ELENA MIRANDA, ORDER
1133
Plaintiffs,
1144
vs.
1155
CITY OF GARDEN GROVE; and DOES
1166 1 through 10, inclusive,
1177
Defendants.
1188
1199 Per the parties’ Stipulation (Dkt. 36) and for good cause shown, the Court
2200 finds and orders as follows.
1. PURPOSES AND LIMITATIONS
2211
Discovery in this action is likely to involve production of confidential,
2222
proprietary or private information for which special protection from public
2233
disclosure and from use for any purpose other than pursuing this litigation may
2244
be warranted. Accordingly, the parties hereby stipulate to and petition the
2255
Court to enter the following Stipulated Protective Order. The parties
2266
acknowledge that this Order does not confer blanket protections on all
2277
disclosures or responses to discovery and that the protection it affords from
2288
-1-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 2 of 16 Page ID #:221
11 public disclosure and use extends only to the limited information or items that
22 are entitled to confidential treatment under the applicable legal principles.
33 2. GOOD CAUSE STATEMENT
44 This action is likely to involve information which one or more of the parties
55 contend special protection from use for any purpose other than litigation of this
66 action is warranted. Such confidential and proprietary materials and information
77 consist of, among other things, documents that contain personal and confidential
88 information regarding individuals which information is generally unavailable to the
99 public, including third party identities and information who are not involved with
1100 the present litigation. The disclosure of these types of information to the public
1111 may violate these individuals’ privacy rights.
1122 Accordingly, to expedite the flow of information, to facilitate the prompt
1133 resolution of disputes over confidentiality of discovery materials, to adequately
1144 protect information the parties are entitled to keep confidential, to ensure that the
1155 parties are permitted reasonable necessary uses of such material in preparation for
1166 and in the conduct of trial, to address their handling at the end of the litigation, and
1177 serve the ends of justice, a protective order for such information is justified in this
1188 matter. It is the intent of the parties that the information will not be designated as
1199 confidential for tactical reasons and that nothing be so designated without a good
2200 faith belief that is has been maintained in a confidential, non-public manner, and
2211
there is a good cause why it should not be part of the public record of this case.
2222
3. ACKNOWLEDGMENT OF UNDER SEAL FILING
2233
PROCEDURE
2244
The parties further acknowledge, as set forth in Section 14.3, below, that
2255
this Stipulated Protective Order does not entitle them to file confidential
2266
information under seal; Local Civil Rule 79-5 sets forth the procedures that
2277
must be followed and the standards that will be applied when a party seeks
2288
permission from the court to file material under seal. There is a strong
-2-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 3 of 16 Page ID #:222
11 presumption that the public has a right of access to judicial proceedings and
22 records in civil cases. In connection with non-dispositive motions, good cause
33 must be shown to support a filing under seal. See Kamakana v. City and
44 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.
55 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony
66 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
77 protective orders require good cause showing), and a specific showing of good
88 cause or compelling reasons with proper evidentiary support and legal
99 justification, must be made with respect to Protected Material that a party
1100 seeks to file under seal. The parties’ mere designation of Disclosure or
1111 Discovery Material as CONFIDENTIAL does not— without the submission
1122 of competent evidence by declaration, establishing that the material sought to
1133 be filed under seal qualifies as confidential, privileged, or otherwise
1144
protectable—constitute good cause.
1155
Further, if a party requests sealing related to a dispositive motion or trial,
1166
then compelling reasons, not only good cause, for the sealing must be shown,
1177
and the relief sought shall be narrowly tailored to serve the specific interest to
1188
be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th
1199
Cir. 2010). For each item or type of information, document, or thing sought to
2200
be filed or introduced under seal, the party seeking protection must articulate
2211
compelling reasons, supported by specific facts and legal justification, for the
2222
requested sealing order. Again, competent evidence supporting the application
2233
to file documents under seal must be provided by declaration.
2244
Any document that is not confidential, privileged, or otherwise protectable in
2255
its entirety will not be filed under seal if the confidential portions can be
2266
redacted. If documents can be redacted, then a redacted version for public
2277
viewing, omitting only the confidential, privileged, or otherwise protectable
2288
-3-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 4 of 16 Page ID #:223
11 portions of the document, shall be filed. Any application that seeks to file
22 documents under seal in their entirety should include an explanation of why
33 redaction is not feasible.
44 4. DEFINITIONS
55 4.1 Action: This pending federal lawsuit.
66 4.2 Challenging Party: a Party or Non-Party that challenges the
77 designation of information or items under this Order.
88 4.3 “CONFIDENTIAL” Information or Items: information
99 (regardless of how it is generated, stored or maintained) or tangible things that
1100 qualify for protection under Federal Rule of Civil Procedure 26(c), and as
1111 specified above in the Good Cause Statement.
1122
4.4 Counsel: Outside Counsel of Record and House Counsel (as well
1133
as their support staff).
1144
4.5 Designating Party: a Party or Non-Party that designates
1155
information or items that it produces in disclosures or in responses to discovery
1166
as “CONFIDENTIAL.”
1177
4.6 Disclosure or Discovery Material: all items or information,
1188
regardless of the medium or manner in which it is generated, stored, or
1199
maintained (including, among other things, testimony, transcripts, and tangible
2200
things), that are produced or generated in disclosures or responses to discovery.
2211
4.7 Expert: a person with specialized knowledge or experience in a
2222
matter pertinent to the litigation who has been retained by a Party or its
2233
counsel to serve as an expert witness or as a consultant in this Action.
2244
4.8 House Counsel: attorneys who are employees of a party to this
2255
Action. House Counsel does not include Outside Counsel of Record or any
2266
other outside counsel.
2277
4.9 Non-Party: any natural person, partnership, corporation,
2288
-4-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 5 of 16 Page ID #:224
11 association or other legal entity not named as a Party to this action.
22 4.10 Outside Counsel of Record: attorneys who are not employees of a
33 party to this Action but are retained to represent a party to this Action and
44 have appeared in this Action on behalf of that party or are affiliated with a law
55 firm that has appeared on behalf of that party, and includes support staff.
66 4.11 Party: any party to this Action, including all of its officers,
77 directors, employees, consultants, retained experts, and Outside Counsel of
88 Record (and their support staffs).
99 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
1100 Discovery Material in this Action.
1111 4.13 Professional Vendors: persons or entities that provide litigation
1122 support services (e.g., photocopying, videotaping, translating, preparing
1133 exhibits or demonstrations, and organizing, storing, or retrieving data in any
1144
form or medium) and their employees and subcontractors.
1155
4.14 Protected Material: any Disclosure or Discovery Material that is
1166
designated as “CONFIDENTIAL.”
1177
4.15 Receiving Party: a Party that receives Disclosure or Discovery
1188
Material from a Producing Party.
1199
5. SCOPE
2200
The protections conferred by this Stipulation and Order cover not only
2211
Protected Material (as defined above), but also (1) any information copied or
2222
extracted from Protected Material; (2) all copies, excerpts, summaries, or
2233
compilations of Protected Material; and (3) any testimony, conversations, or
2244
presentations by Parties or their Counsel that might reveal Protected Material.
2255
Any use of Protected Material at trial shall be governed by the orders of
2266
the trial judge and other applicable authorities. This Order does not govern the
2277
use of Protected Material at trial.
2288
-5-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 6 of 16 Page ID #:225
11 6. DURATION
22 Once a case proceeds to trial, information that was designated as
33 CONFIDENTIAL or maintained pursuant to this protective order used or
44 introduced as an exhibit at trial becomes public and will be presumptively
55 available to all members of the public, including the press, unless compelling
66 reasons supported by specific factual findings to proceed otherwise are made to
77 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
88 (distinguishing “good cause” showing for sealing documents produced in
99 discovery from “compelling reasons” standard when merits-related documents
1100 are part of court record). Accordingly, the terms of this protective order do not
1111 extend beyond the commencement of the trial.
1122 7. DESIGNATING PROTECTED MATERIAL
1133 7.1 Exercise of Restraint and Care in Designating Material for
1144
Protection. Each Party or Non-Party that designates information
1155
or items for protection under this Order must take care to limit any such
1166
designation to specific material that qualifies under the appropriate standards.
1177
The Designating Party must designate for protection only those parts of
1188
material, documents, items or oral or written communications that qualify so
1199
that other portions of the material, documents, items or communications for
2200
which protection is not warranted are not swept unjustifiably within the ambit
2211
of this Order.
2222
Mass, indiscriminate or routinized designations are prohibited.
2233
Designations that are shown to be clearly unjustified or that have been made
2244
for an improper purpose (e.g., to unnecessarily encumber the case development
2255
process or to impose unnecessary expenses and burdens on other parties) may
2266
expose the Designating Party to sanctions.
2277
If it comes to a Designating Party’s attention that information or items
2288
-6-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 7 of 16 Page ID #:226
11 that it designated for protection do not qualify for protection, that Designating
22 Party must promptly notify all other Parties that it is withdrawing the
33 inapplicable designation.
44 7.2 Manner and Timing of Designations. Except as otherwise
55 provided in this Order, or as otherwise stipulated or ordered, Disclosure of
66 Discovery Material that qualifies for protection under this Order must be
77 clearly so designated before the material is disclosed or produced.
88 Designation in conformity with this Order requires:
99 (a) for information in documentary form (e.g., paper or electronic
1100 documents, but excluding transcripts of depositions or other pretrial or trial
1111 proceedings), that the Producing Party affix at a minimum, the legend
1122 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page
1133 that contains protected material. If only a portion of the material on a page
1144
qualifies for protection, the Producing Party also must clearly identify the
1155
protected portion(s) (e.g., by making appropriate markings in the margins).
1166
A Party or Non-Party that makes original documents available for
1177
inspection need not designate them for protection until after the inspecting
1188
Party has indicated which documents it would like copied and produced.
1199
During the inspection and before the designation, all of the material made
2200
available for inspection shall be deemed “CONFIDENTIAL.” After the
2211
inspecting Party has identified the documents it wants copied and produced,
2222
the Producing Party must determine which documents, or portions thereof,
2233
qualify for protection under this Order. Then, before producing the specified
2244
documents, the Producing Party must affix the “CONFIDENTIAL legend” to
2255
each page that contains Protected Material. If only a portion of the material on
2266
a page qualifies for protection, the Producing Party also must clearly identify
2277
the protected portion(s) (e.g., by making appropriate markings in the margins).
2288
-7-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 8 of 16 Page ID #:227
11 (b) for testimony given in depositions that the Designating Party
22 identifies the Disclosure or Discovery Material on the record, before the close
33 of the deposition all protected testimony.
44 (c) for information produced in some form other than
55 documentary and for any other tangible items, that the Producing Party affix
66 in a prominent place on the exterior of the container or containers in which the
77 information is stored the legend “CONFIDENTIAL.” If only a portion or
88 portions of the information warrants protection, the Producing Party, to the
99 extent practicable, shall identify the protected portion(s).
1100 7.3 Inadvertent Failures to Designate. If timely corrected, an
1111 inadvertent failure to designate qualified information or items does not,
1122 standing alone, waive the Designating Party’s right to secure protection under
1133 this Order for such material. Upon timely correction of a designation, the
1144
Receiving Party must make reasonable efforts to assure that the material is
1155
treated in accordance with the provisions of this Order.
1166
8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
1177
8.1. Timing of Challenges. Any Party or Non-Party may challenge a
1188
designation of confidentiality at any time that is consistent with the Court’s
1199
Scheduling Order.
2200
8.2 Meet and Confer. The Challenging Party shall initiate the dispute
2211
resolution process under Local Rule 37-1 et seq.
2222
8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
2233
joint stipulation pursuant to Local Rule 37-2.
2244
8.4 The burden of persuasion in any such challenge proceeding shall be
2255
on the Designating Party. Frivolous challenges, and those made for an
2266
improper purpose (e.g., to harass or impose unnecessary expenses and burdens
2277
on other parties) may expose the Challenging Party to sanctions. Unless the
2288
-8-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 9 of 16 Page ID #:228
11 Designating Party has waived or withdrawn the confidentiality designation, all
22 parties shall continue to afford the material in question the level of protection
33 to which it is entitled under the Producing Party’s designation until the Court
44 rules on the challenge.
55
9. ACCESS TO AND USE OF PROTECTED MATERIAL
66
9.1 Basic Principles. A Receiving Party may use Protected Material that
77
is disclosed or produced by another Party or by a Non-Party in connection
88
with this Action only for prosecuting, defending or attempting to settle this
99
Action. Such Protected Material may be disclosed only to the categories of
1100
persons and under the conditions described in this Order. When the Action has
1111
been terminated, a Receiving Party must comply with the provisions of section
1122
15 below (FINAL DISPOSITION).
1133
Protected Material must be stored and maintained by a Receiving Party
1144
at a location and in a secure manner that ensures that access is limited to the
1155
persons authorized under this Order.
1166
9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
1177
otherwise ordered by the court or permitted in writing by the Designating
1188
Party, a Receiving Party may disclose any information or item designated
1199
“CONFIDENTIAL” only to:
2200
(a) the Receiving Party’s Outside Counsel of Record in this
2211
Action, as well as employees of said Outside Counsel of Record to whom it is
2222
reasonably necessary to disclose the information for this Action;
2233
(b) the officers, directors, and employees (including House
2244
Counsel) of the Receiving Party to whom disclosure is reasonably necessary
2255
for this Action;
2266
(c) Experts (as defined in this Order) of the Receiving Party to
2277
whom disclosure is reasonably necessary for this Action and who have signed
2288
-9-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 10 of 16 Page ID #:229
11 the “Acknowledgment and Agreement to Be Bound” (Exhibit A)
22 (d) the court and its personnel;
33 (e) court reporters and their staff;
44 (f) professional jury or trial consultants, mock jurors, and
55 Professional Vendors to whom disclosure is reasonably necessary for this
66 Action and who have signed the “Acknowledgment and Agreement to Be
77 Bound” (Exhibit A);
88 (g) the author or recipient of a document containing the
99 information or a custodian or other person who otherwise possessed or knew
1100 the information;
1111 (h) during their depositions, witnesses, and attorneys for witnesses,
1122 in the Action to whom disclosure is reasonably necessary provided: (1) the
1133 deposing party requests that the witness sign the form attached as Exhibit A
1144
hereto; and (2) they will not be permitted to keep any confidential information
1155
unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit
1166
A), unless otherwise agreed by the Designating Party or ordered by the court.
1177
Pages of transcribed deposition testimony or exhibits to depositions that reveal
1188
Protected Material may be separately bound by the court reporter and may not
1199
be disclosed to anyone except as permitted under this Stipulated Protective
2200
Order; and
2211
(i) any mediators or settlement officers and their supporting
2222
personnel, mutually agreed upon by any of the parties engaged in settlement
2233
discussions.
2244
10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2255 PRODUCED IN OTHER LITIGATION
2266
If a Party is served with a subpoena or a court order issued in other
2277
litigation that compels disclosure of any information or items designated in this
2288
-10-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 11 of 16 Page ID #:230
11 Action as “CONFIDENTIAL,” that Party must:
22 (a) promptly notify in writing the Designating Party. Such
33 notification shall include a copy of the subpoena or court order;
44 (b) promptly notify in writing the party who caused the subpoena
55 or order to issue in the other litigation that some or all of the material covered
66 by the subpoena or order is subject to this Protective Order. Such notification
77 shall include a copy of this Stipulated Protective Order; and
88 (c) cooperate with respect to all reasonable procedures sought to be
99 pursued by the Designating Party whose Protected Material may be affected. If
1100 the Designating Party timely seeks a protective order, the Party served with the
1111 subpoena or court order shall not produce any information designated in this
1122 action as “CONFIDENTIAL” before a determination by the court from which
1133 the subpoena or order issued, unless the Party has obtained the Designating
1144
Party’s permission. The Designating Party shall bear the burden and expense
1155
of seeking protection in that court of its confidential material and nothing in
1166
these provisions should be construed as authorizing or encouraging a
1177
Receiving Party in this Action to disobey a lawful directive from another court.
1188
11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
1199
BE PRODUCED IN THIS LITIGATION
2200
(a) The terms of this Order are applicable to information produced
2211
by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
2222
information produced by Non-Parties in connection with this litigation is
2233
protected by the remedies and relief provided by this Order. Nothing in these
2244
provisions should be construed as prohibiting a Non-Party from seeking
2255
additional protections.
2266
(b) In the event that a Party is required, by a valid discovery
2277
request, to produce a Non-Party’s confidential information in its possession,
2288
-11-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 12 of 16 Page ID #:231
11 and the Party is subject to an agreement with the Non-Party not to produce the
22 Non-Party’s confidential information, then the Party shall:
33 (1) promptly notify in writing the Requesting Party and the Non-
44 Party that some or all of the information requested is subject to a
55 confidentiality agreement with a Non-Party;
66 (2) promptly provide the Non-Party with a copy of the Stipulated
77 Protective Order in this Action, the relevant discovery request(s), and a
88 reasonably specific description of the information requested; and
99 (3) make the information requested available for inspection by the
1100 Non-Party, if requested.
1111 (c) If the Non-Party fails to seek a protective order from this court
1122 within 14 days of receiving the notice and accompanying information, the
1133 Receiving Party may produce the Non-Party’s confidential information
1144
responsive to the discovery request. If the Non-Party timely seeks a protective
1155
order, the Receiving Party shall not produce any information in its possession
1166
or control that is subject to the confidentiality agreement with the Non-Party
1177
before a determination by the court. Absent a court order to the contrary, the
1188
Non-Party shall bear the burden and expense of seeking protection in this court
1199
of its Protected Material.
2200
12. UNAUTHORIZED DISCLOSURE OF PROTECTED
2211 MATERIAL
2222
If a Receiving Party learns that, by inadvertence or otherwise, it has
2233
disclosed Protected Material to any person or in any circumstance not
2244
authorized under this Stipulated Protective Order, the Receiving Party must
2255
immediately (a) notify in writing the Designating Party of the unauthorized
2266
disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
2277
Protected Material, (c) inform the person or persons to whom unauthorized
2288
-12-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 13 of 16 Page ID #:232
11 disclosures were made of all the terms of this Order, and (d) request such
22 person or persons to execute the “Acknowledgment an Agreement to Be
33 Bound” attached hereto as Exhibit A.
44 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL
55
66 When a Producing Party gives notice to Receiving Parties that certain
77 inadvertently produced material is subject to a claim of privilege or other
88 protection, the obligations of the Receiving Parties are those set forth in
99 Federal Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to
1100 modify whatever procedure may be established in an e-discovery order that
1111 provides for production without prior privilege review. Pursuant to Federal
1122 Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on
1133 the effect of disclosure of a communication or information covered by the
1144
attorney-client privilege or work product protection, the parties may
1155
incorporate their agreement in the stipulated protective order submitted to the
1166
court.
1177
14. MISCELLANEOUS
1188
14.1 Right to Further Relief. Nothing in this Order abridges the right of
1199
any person to seek its modification by the Court in the future.
2200
14.2 Right to Assert Other Objections. By stipulating to the entry of this
2211
Protective Order, no Party waives any right it otherwise would have to object
2222
to disclosing or producing any information or item on any ground not
2233
addressed in this Stipulated Protective Order. Similarly, no Party waives any
2244
right to object on any ground to use in evidence of any of the material covered
2255
by this Protective Order.
2266
14.3 Filing Protected Material. A Party that seeks to file under seal any
2277
Protected Material must comply with Local Civil Rule 79-5. Protected
2288
-13-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 14 of 16 Page ID #:233
11 Material may only be filed under seal pursuant to a court order authorizing the
22 sealing of the specific Protected Material. If a Party’s request to file Protected
33 Material under seal is denied by the court, then the Receiving Party may file
44 the information in the public record unless otherwise instructed by the court.
55 15. FINAL DISPOSITION
66 After the final disposition of this Action, as defined in paragraph 6,
77 within 60 days of a written request by the Designating Party, each Receiving
88 Party must return all Protected Material to the Producing Party or destroy such
99 material. As used in this subdivision, “all Protected Material” includes all
1100 copies, abstracts, compilations, summaries, and any other format reproducing
1111 or capturing any of the Protected Material. Whether the Protected Material is
1122 returned or destroyed, the Receiving Party must submit a written certification
1133 to the Producing Party (and, if not the same person or entity, to the
1144
Designating Party) by the 60-day deadline that (1) identifies (by category,
1155
where appropriate) all the Protected Material that was returned or destroyed
1166
and (2) affirms that the Receiving Party has not retained any copies, abstracts,
1177
compilations, summaries or any other format reproducing or capturing any of
1188
the Protected Material. Notwithstanding this provision, Counsel are entitled to
1199
retain an archival copy of all pleadings, motion papers, trial, deposition, and
2200
hearing transcripts, legal memoranda, correspondence, deposition and trial
2211
exhibits, expert reports, attorney work product, and consultant and expert
2222
work product, even if such materials contain Protected Material. Any such
2233
archival copies that contain or constitute Protected Material remain subject to
2244
this Protective Order as set forth in Section 6 (DURATION).
2255
16. VIOLATION
2266
Any violation of this Order may be punished by appropriate measures
2277
including, without limitation, contempt proceedings and/or monetary
2288
-14-
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 15o0f16 Page ID #:234
1 || sanctions.
3 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: August 24, 2022
!
8 D. EARLY
9 nited States Magistrate Judge
10
1]
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATED PROTECTIVE ORDER
Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 16 of 16 Page ID #:235
11
22
33 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
44
I, _____________________________ [print or type full name], of
55
____________________________________________ [print or type full address],
66
declare under penalty of perjury that I have read in its entirety and understand the
77
Stipulated Protective Order that was issued by the United States District Court for
88
the Central District of California on August 24, 2022, in the case of Patricia
99
Median, et al. v. City of Garden Grove, et al., Case No. 8:22-cv-00235-JVS-
1100
JDE. I agree to comply with and to be bound by all the terms of this Stipulated
1111
Protective Order and I understand and acknowledge that failure to so comply could
1122
expose me to sanctions and punishment in the nature of contempt. I solemnly
1133
promise that I will not disclose in any manner any information or item that is
1144
subject to this Stipulated Protective Order to any person or entity except in strict
1155
compliance with the provisions of this Order.
1166
I further agree to submit to the jurisdiction of the United States District
1177
Court for the Central District of California for the purpose of enforcing the terms
1188
of this Stipulated Protective Order, even if such enforcement proceedings occur
1199
after termination of this action. I hereby appoint __________________________
2200
[print or type full name] of _______________________________________ [print
2211
or type full address and telephone number] as my California agent for service of
2222
process in connection with this action or any proceedings related to enforcement of
2233
this Stipulated Protective Order.
2244
Date: ______________________________________
2255
2266 City and State where sworn and signed: _________________________________
2277 Printed name: _______________________________
2288 Signature: _________________
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STIPULATED PROTECTIVE ORDER