distinguishing “good cause” 14 showing for sealing documents produced in discovery from “compelling reasons” 15 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 14 showing for sealing documents produced in discovery from “compelling reasons” 15 standard when merits-related documents are part of court record
- even stipulated protective orders require 9 good cause showing
Written by the judges who cited it.
The opinion
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 1 of 16 Page ID #:108
1
2
3
4
5
6
UNITED STATES DISTRICT COURT
7
CENTRAL DISTRICT OF CALIFORNIA
8
9
TERRY LOVETT, individually and Case No. 2:22-CV-07394-FMO-PD
10
as a successor in interest to JALANI
LOVETT,
11
STIPULATED PROTECTIVE
ORDER1
12
Plaintiff,
13 v.
14
COUNTY OF LOS ANGELES, a
municipal entity; SHERIFF
15
ALEJANDRO VILLANUEVA,
individually and in his official
16
capacity; DEPUTY MELERO, and
DOES 1 to 10, inclusive,
17
Defendants.
18
1 . A. PURPOSES AND LIMITATIONS
19
Discovery in this action is likely to involve production of confidential,
20
proprietary, or private information for which special protection from public
21
disclosure and from use for any purpose other than prosecuting this litigation may be
22
warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
23
the following Stipulated Protective Order. The parties acknowledge that this Order
24
does not confer blanket protections on all disclosures or responses to discovery and
25
that the protection it affords from public disclosure and use extends only to the
26
27
1 This Stipulated Protective Order is substantially based on the model protective
28 order provided under Magistrate Judge Patricia Donahue’s Procedures.
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 2 of 16 Page ID #:109
1 limited information or items that are entitled to confidential treatment under the
2 applicable legal principles.
3 B. GOOD CAUSE STATEMENT
4 Good cause exists for entry of this order. As Plaintiff is seeking and Defendants
5 may produce, among other things, internal, security sensitive, third party and law
6 enforcement private and confidential information, administrative and institutional
7 documents, which contain sensitive information that the County of Los Angeles
8 believes need special protection from public disclosure.
9 The documents identified in this Protective Order, which Defendants believe
10 in good faith constitute or embody confidential information which the County of Los
11 Angeles maintains as strictly confidential and are otherwise generally unavailable to
12 the public, or which may be privileged or otherwise protected from disclosure under
13 state or federal statutes, court rules, case decisions, or common law, are therefore
14 entitled to heightened protection from disclosure. Accordingly, to expedite the flow
15 of information, to facilitate the prompt resolution of disputes over confidentiality of
16 discovery materials, to adequately protect information the parties are entitled to keep
17 confidential, to ensure that the parties are permitted reasonable necessary uses of
18 such material in preparation for and in the conduct of trial, to address their handling
19 at the end of the litigation, and serve the ends of justice, a protective order for such
20 information is justified in this matter. It is the intent of the parties that information
21 will not be designated as confidential for tactical reasons and that nothing be so
22 designated without a good faith belief that it has been maintained in a confidential,
23 non-public manner, and there is good cause why it should not be part of the public
24 record of this case. C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING
25 UNDER SEAL
26 The parties further acknowledge, as set forth in Section 12.3, below, that this
27 Stipulated Protective Order does not entitle them to file confidential information
28 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
2
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 3 of 16 Page ID #:110
1 the standards that will be applied when a party seeks permission from the court to
2 file material under seal.
3 There is a strong presumption that the public has a right of access to judicial
4 proceedings and records in civil cases. In connection with non-dispositive motions,
5 good cause must be shown to support a filing under seal. See Kamakana v. City and
6 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
7 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
8 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
9 good cause showing), and a specific showing of good cause or compelling reasons
10 with proper evidentiary support and legal justification, must be made with respect to
11 Protected Material that a party seeks to file under seal. The parties’ mere designation
12 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the
13 submission of competent evidence by declaration, establishing that the material
14 sought to be filed under seal qualifies as confidential, privileged, or otherwise
15 protectable—constitute good cause.
16 Further, if a party requests sealing related to a dispositive motion or trial, then
17 compelling reasons, not only good cause, for the sealing must be shown, and the
18 relief sought shall be narrowly tailored to serve the specific interest to be protected.
19 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each
20 item or type of information, document, or thing sought to be filed or introduced under
21 seal in connection with a dispositive motion or trial, the party seeking protection
22 must articulate compelling reasons, supported by specific facts and legal
23 justification, for the requested sealing order. Again, competent evidence supporting
24 the application to file documents under seal must be provided by declaration.
25 Any document that is not confidential, privileged, or otherwise protectable in
26 its entirety will not be filed under seal if the confidential portions can be redacted. If
27 documents can be redacted, then a redacted version for public viewing, omitting only
28 the confidential, privileged, or otherwise protectable portions of the document, shall
3
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 4 of 16 Page ID #:111
1 be filed. Any application that seeks to file documents under seal in their entirety
2 should include an explanation of why redaction is not feasible.
3
4 2. DEFINITIONS
5 2.1 Action: this pending federal lawsuit.
6 2.2 Challenging Party: a Party or Non-Party that challenges
7 the designation of information or items under this Order.
8 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
9 how it is generated, stored or maintained) or tangible things that qualify for
10 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the
11 Good Cause Statement.
12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
13 their support staff).
14 2.5 Designating Party: a Party or Non-Party that designates information or
15 items that it produces in disclosures or in responses to discovery as
16 “CONFIDENTIAL.”
17 2.6 Disclosure or Discovery Material: all items or information, regardless
18 of the medium or manner in which it is generated, stored, or maintained (including,
19 among other things, testimony, transcripts, and tangible things), that are produced or
20 generated in disclosures or responses to discovery in this matter.
21 2.7 Expert: a person with specialized knowledge or experience in a matter
22 pertinent to the litigation who has been retained by a Party or its counsel to serve as
23 an expert witness or as a consultant in this Action.
24 2.8 House Counsel: attorneys who are employees of a party to this Action.
25 House Counsel does not include Outside Counsel of Record or any other outside
26 counsel.
27 2.9 Non-Party: any natural person, partnership, corporation, association, or
28 other legal entity not named as a Party to this action.
4
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1 2.10 Outside Counsel of Record: attorneys who are not employees of a party
2 to this Action but are retained to represent or advise a party to this Action and have
3 appeared in this Action on behalf of that party or are affiliated with a law firm which
4 has appeared on behalf of that party, and includes support staff.
5 2.11 Party: any party to this Action, including all of its officers, directors,
6 employees, consultants, retained experts, and Outside Counsel of Record (and their
7 support staffs).
8 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
9 Discovery Material in this Action.
10 2.13 Professional Vendors: persons or entities that provide litigation
11 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
12 demonstrations, and organizing, storing, or retrieving data in any form or medium)
13 and their employees and subcontractors.
14 2.14 Protected Material: any Disclosure or Discovery Material that is
15 designated as “CONFIDENTIAL.”
16 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
17 from a Producing Party.
18
19 3. SCOPE
20 The protections conferred by this Stipulation and Order cover not only
21 Protected Material (as defined above), but also (1) any information copied or
22 extracted from Protected Material; (2) all copies, excerpts, summaries, or
23 compilations of Protected Material; and (3) any testimony, conversations, or
24 presentations by Parties or their Counsel that might reveal Protected Material.
25 Any use of Protected Material at trial shall be governed by the orders of the
26 trial judge. This Order does not govern the use of Protected Material at trial.
27
28 4. DURATION
5
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1 FINAL DISPOSITION of the action is defined as the conclusion of any
2 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal
3 has run. Except as set forth below, the terms of this protective order apply through
4 FINAL DISPOSITION of the action. The parties may stipulate that the they will be
5 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
6 but will have to file a separate action for enforcement of the agreement once all
7 proceedings in this case are complete.
8 Once a case proceeds to trial, information that was designated as
9 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
10 as an exhibit at trial becomes public and will be presumptively available to all
11 members of the public, including the press, unless compelling reasons supported by
12 specific factual findings to proceed otherwise are made to the trial judge in advance
13 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
14 showing for sealing documents produced in discovery from “compelling reasons”
15 standard when merits-related documents are part of court record). Accordingly, for
16 such materials, the terms of this protective order do not extend beyond the
17 commencement of the trial.
18
19 5. DESIGNATING PROTECTED MATERIAL
20
5.1 Exercise of Restraint and Care in Designating Material for Protection.
21
Each Party or Non-Party that designates information or items for protection under
22
this Order must take care to limit any such designation to specific material that
23
qualifies under the appropriate standards. The Designating Party must designate for
24
protection only those parts of material, documents, items, or oral or written
25
communications that qualify so that other portions of the material, documents, items,
26
or communications for which protection is not warranted are not swept unjustifiably
27
within the ambit of this Order.
28
6
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1 Mass, indiscriminate, or routinized designations are prohibited. Designations
2 that are shown to be clearly unjustified or that have been made for an improper
3 purpose (e.g., to unnecessarily encumber the case development process or to impose
4 unnecessary expenses and burdens on other parties) may expose the Designating
5 Party to sanctions.
6 If it comes to a Designating Party’s attention that information or items that it
7 designated for protection do not qualify for protection, that Designating Party must
8 promptly notify all other Parties that it is withdrawing the inapplicable designation.
9 5.2 Manner and Timing of Designations. Except as otherwise provided in
10 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
12 under this Order must be clearly so designated before the material is disclosed or
13 produced.
14 Designation in conformity with this Order requires:
15 (a) for information in documentary form (e.g., paper or electronic
16 documents, but excluding transcripts of depositions or other pretrial or trial
17 proceedings), that the Producing Party affix at a minimum, the legend
18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
19 contains protected material. If only a portion or portions of the material on a page
20 qualifies for protection, the Producing Party also must clearly identify the protected
21 portion(s) (e.g., by making appropriate markings in the margins).
22 A Party or Non-Party that makes original documents available for inspection
23 need not designate them for protection until after the inspecting Party has indicated
24 which documents it would like copied and produced. During the inspection and
25 before the designation, all of the material made available for inspection shall be
26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
27 documents it wants copied and produced, the Producing Party must determine which
28 documents, or portions thereof, qualify for protection under this Order. Then, before
7
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 8 of 16 Page ID #:115
1 producing the specified documents, the Producing Party must affix the
2 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
3 portion or portions of the material on a page qualifies for protection, the Producing
4 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
5 markings in the margins).
6 (b) for testimony given in depositions that the Designating Party identify
7 the Disclosure or Discovery Material on the record, before the close of the deposition
8 all protected testimony.
9 (c) for information produced in some form other than documentary and for
10 any other tangible items, that the Producing Party affix in a prominent place on the
11 exterior of the container or containers in which the information is stored the legend
12 “CONFIDENTIAL.” If only a portion or portions of the information warrants
13 protection, the Producing Party, to the extent practicable, shall identify the protected
14 portion(s).
15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
16 failure to designate qualified information or items does not, standing alone, waive
17 the Designating Party’s right to secure protection under this Order for such material.
18 Upon timely correction of a designation, the Receiving Party must make reasonable
19 efforts to assure that the material is treated in accordance with the provisions of this
20 Order.
21
22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
24 designation of confidentiality at any time that is consistent with the Court’s
25 Scheduling Order.
26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
27 resolution process under Local Rule 37.1 et seq.
28 6.3 The burden of persuasion in any such challenge proceeding shall be on
8
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 9 of 16 Page ID #:116
1 the Designating Party. Frivolous challenges, and those made for an improper purpose
2 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
3 expose the Challenging Party to sanctions. Unless the Designating Party has waived
4 or withdrawn the confidentiality designation, all parties shall continue to afford the
5 material in question the level of protection to which it is entitled under the Producing
6 Party’s designation until the Court rules on the challenge.
7
8 7. ACCESS TO AND USE OF PROTECTED MATERIAL
9 7.1 Basic Principles. A Receiving Party may use Protected Material that is
10 disclosed or produced by another Party or by a Non-Party in connection with this
11 Action only for prosecuting, defending, or attempting to settle this Action. Such
12 Protected Material may be disclosed only to the categories of persons and under the
13 conditions described in this Order. When the Action has been terminated, a
14 Receiving Party must comply with the provisions of section 13 below (FINAL
15 DISPOSITION).
16 Protected Material must be stored and maintained by a Receiving Party at a
17 location and in a secure manner that ensures that access is limited to the persons
18 authorized under this Order.
19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
20 otherwise ordered by the court or permitted in writing by the Designating Party, a
21 Receiving Party may disclose any information or item designated
22 “CONFIDENTIAL” only to:
23 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
24 as employees of said Outside Counsel of Record to whom it is reasonably necessary
25 to disclose the information for this Action;
26 (b) the officers, directors, and employees (including House Counsel) of the
27 Receiving Party to whom disclosure is reasonably necessary for this Action;
28 (c) Experts (as defined in this Order) of the Receiving Party to whom
9
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 10 of 16 Page ID #:117
1 disclosure is reasonably necessary for this Action and who have signed the
2 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
3 (d) the court and its personnel;
4 (e) court reporters and their staff;
5 (f) professional jury or trial consultants, mock jurors, and Professional
6 Vendors to whom disclosure is reasonably necessary for this Action and who have
7 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
8 (g) the author or recipient of a document containing the information or a
9 custodian or other person who otherwise possessed or knew the information;
10 (h) during their depositions, witnesses ,and attorneys for witnesses, in the
11 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
12 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
13 not be permitted to keep any confidential information unless they sign the
14 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
15 agreed by the Designating Party or ordered by the court. Pages of transcribed
16 deposition testimony or exhibits to depositions that reveal Protected Material may
17 be separately bound by the court reporter and may not be disclosed to anyone except
18 as permitted under this Stipulated Protective Order; and
19 (i) any mediator or settlement officer, and their supporting personnel,
20 mutually agreed upon by any of the parties engaged in settlement discussions.
21
22 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
23 IN OTHER LITIGATION
24 If a Party is served with a subpoena or a court order issued in other litigation
25 that compels disclosure of any information or items designated in this Action as
26 “CONFIDENTIAL,” that Party must:
27
(a) promptly notify in writing the Designating Party. Such notification shall
28
10
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 11 of 16 Page ID #:118
1 include a copy of the subpoena or court order;
2 (b) promptly notify in writing the party who caused the subpoena or order
3 to issue in the other litigation that some or all of the material covered by the subpoena
4 or order is subject to this Protective Order. Such notification shall include a copy of
5 this Stipulated Protective Order; and
6 (c) cooperate with respect to all reasonable procedures sought to be pursued
7 by the Designating Party whose Protected Material may be affected.
8 If the Designating Party timely seeks a protective order, the Party served
9 with the subpoena or court order shall not produce any information designated in this
10 action as “CONFIDENTIAL” before a determination by the court from which the
11 subpoena or order issued, unless the Party has obtained the Designating Party’s
12 permission. The Designating Party shall bear the burden and expense of seeking
13 protection in that court of its confidential material and nothing in these provisions
14 should be construed as authorizing or encouraging a Receiving Party in this Action
15 to disobey a lawful directive from another court.
16
17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT
18 TO BE PRODUCED IN THIS LITIGATION
19 (a) The terms of this Order are applicable to information produced by a
20 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
21 produced by Non-Parties in connection with this litigation is protected by the
22 remedies and relief provided by this Order. Nothing in these provisions should be
23 construed as prohibiting a Non-Party from seeking additional protections.
24 (b) In the event that a Party is required, by a valid discovery request, to
25 produce a Non-Party’s confidential information in its possession, and the Party is
26 subject to an agreement with the Non-Party not to produce the Non-Party’s
27 confidential information, then the Party shall:
28
11
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 12 of 16 Page ID #:119
1 (1) promptly notify in writing the Requesting Party and the Non-Party
2 that some or all of the information requested is subject to a confidentiality agreement
3 with a Non-Party;
4 (2) promptly provide the Non-Party with a copy of the Stipulated
5 Protective Order in this Action, the relevant discovery request(s), and a reasonably
6 specific description of the information requested; and
7 (3) make the information requested available for inspection by the
8 Non-Party, if requested.
9 (c) If the Non-Party fails to seek a protective order from this court within
10 14 days of receiving the notice and accompanying information, the Receiving Party
11 may produce the Non-Party’s confidential information responsive to the discovery
12 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
13 not produce any information in its possession or control that is subject to the
14 confidentiality agreement with the Non-Party before a determination by the court.
15 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
16 of seeking protection in this court of its Protected Material.
17
18 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
20 Protected Material to any person or in any circumstance not authorized under this
21 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
22 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
23 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
24 persons to whom unauthorized disclosures were made of all the terms of this Order,
25 and (d) request such person or persons to execute the “Acknowledgment and
26 Agreement to Be Bound” that is attached hereto as Exhibit A.
27
28
12
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 13 of 16 Page ID #:120
1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
2 PROTECTED MATERIAL
3 When a Producing Party gives notice to Receiving Parties that certain
4 inadvertently produced material is subject to a claim of privilege or other protection,
5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
7 may be established in an e-discovery order that provides for production without prior
8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
9 parties reach an agreement on the effect of disclosure of a communication or
10 information covered by the attorney-client privilege or work product protection, the
11 parties may incorporate their agreement in the stipulated protective order submitted
12 to the court.
13
14 12. MISCELLANEOUS
15
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
16
person to seek its modification by the Court in the future.
17
12.2 Right to Assert Other Objections. By stipulating to the entry of this
18
Protective Order no Party waives any right it otherwise would have to object to
19
disclosing or producing any information or item on any ground not addressed in this
20
Stipulated Protective Order. Similarly, no Party waives any right to object on any
21
ground to use in evidence of any of the material covered by this Protective Order.
22
12.3 Filing Protected Material. A Party that seeks to file under seal any
23
Protected Material must comply with Civil Local Rule 79-5. Protected Material may
24
only be filed under seal pursuant to a court order authorizing the sealing of the
25
specific Protected Material at issue. If a Party's request to file Protected Material
26
under seal is denied by the court, then the Receiving Party may file the information
27
in the public record unless otherwise instructed by the court.
28
13
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 14 of 16 Page ID #:121
1
2 13. FINAL DISPOSITION
3 After the final disposition of this Action, as defined in paragraph 4, within 60
4 days of a written request by the Designating Party, each Receiving Party must return
5 all Protected Material to the Producing Party or destroy such material. As used in
6 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
7 summaries, and any other format reproducing or capturing any of the Protected
8 Material. Whether the Protected Material is returned or destroyed, the Receiving
9 Party must submit a written certification to the Producing Party (and, if not the same
10 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
11 (by category, where appropriate) all the Protected Material that was returned or
12 destroyed and (2)affirms that the Receiving Party has not retained any copies,
13 abstracts, compilations, summaries or any other format reproducing or capturing any
14 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
15 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
16 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
17 reports, attorney work product, and consultant and expert work product, even if such
18 materials contain Protected Material. Any such archival copies that contain or
19 constitute Protected Material remain subject to this Protective Order as set forth in
20 Section 4 (DURATION).
21
22
23
24
25
26
27
28
14
Case #:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 15o0f16 Page ID #:122
1 || 14. Any violation of this Order may be punished by any and all appropriate
2 || measures including, without limitation, contempt proceedings and/or monetary
3 || sanctions.
5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7 || DATED: November 3, 2022
9 || /s/ Christian Contreras Esq.
10
Attorneys for Plaintiff
12
13. || PATED: November 3, 2022
14
15 /s/ Laura Inlow Esq.
16 Attorneys for Defendant
17
18
'? || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
20
*! | DATED: November 08, 2022
22
23 Palau Mgakoe_
24 || Patricia Donahue
95 United States Magistrate Judge
26
27
28
15
Case 2:22-cv-07394-FMO-PD Document 11 Filed 11/08/22 Page 16 of 16 Page ID #:123
1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3
I, ________________________ [print or type full name], of
4
_________________ [print or type full address], declare under penalty of perjury
5
that I have read in its entirety and understand the Stipulated Protective Order that
6
was issued by the United States District Court for the Central District of California
7
on [date] in the case of Lovett v. County of Los Angeles, et al, case number 2:22-
8
CV-07394-FMO-PD . I agree to comply with and to be bound by all the terms of
9
this Stipulated Protective Order and I understand and acknowledge that failure to
10
so comply could expose me to sanctions and punishment in the nature of contempt.
11
I solemnly promise that I will not disclose in any manner any information or item
12
that is subject to this Stipulated Protective Order to any person or entity except in
13
strict compliance with the provisions of this Order.
14
I further agree to submit to the jurisdiction of the United States District Court for
15
the Central District of California for the purpose of enforcing the terms of this
16
Stipulated Protective Order, even if such enforcement proceedings occur after
17
termination of this action. I hereby appoint ________________________ [print or
18
type full name] of _________ [print or type full address and telephone number] as
19
my California agent for service of process in connection with this action or any
20
proceedings related to enforcement of this Stipulated Protective Order.
21
22 Date: __________________________
23
City and State where sworn and signed: _____________________________
24
25
Printed name: ____________________________________
26
27 Signature: ________________________________
28
16