Opinion

Griselda Jauregui v. Roadrunner Transportation Services Inc.

Court: District Court, C.D. California
Filed: Dec 8, 2022
Cited by: 0 cases
Authority: More cited than 16.4%

even stipulated protective orders require good cause showing

How later courts described this case

even stipulated protective orders require good cause showing

Written by the judges who cited it.

The opinion

STIPULATED PROTECTIVE ORDER

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Edwin Aiwazian (Bar No. 232943)_

edwin@calljustice.com

Arby Aiwazian (Bar No. 269827)

arby@calljustice.com

Tara Zabehi (Bar No. 314706)

tara@calljustice.com

Travis Maher (Bar No. 327206)

travis@calljustice.com

410 West Arden Avenue, Suite 203

Glendale, CA 91203

Attorneys for Plaintiff GRISELDA JAUREGUI

Tyler M. Paetkau (Bar No. 146305)

Tyler.Paetkau@huschblackwell.com

Kathy M. Huynh (Bar No. 233314)

Kathy.Huynh@huschblackwell.com

HUSCH BLACKWELL LLP

1999 Harrison Street, Suite 700

Oakland, CA 94612

Telephone: 510.768.0650

Facsimile: 510.768.0651

Attorneys for Defendant

ROADRUNNER TRANSPORTATION

SERVICES, INC.

UNITED STATES DISTRICT COURT FOR THE

CENTRAL DISTRICT OF CALIFORNIA

GRISELDA JAUREGUI, individually, and CASE NO. 2:21-CV-04657-RGK-PD

on behalf of other members of the general

public similarly situated, Removed from Los Angeles County

Superior Court Case No. 21STCV12728

Plaintiff,

Hon. Sherilyn Peace Garnett, Courtroom 5C

STIPULATED PROTECTIVE ORDER1

ROADRUNNER

TRANSPORTATION SERVICES,

INC., an unknown business entity; and COMPLAINT FILED: April 2, 2021

DOES 1 through 100, inclusive, REMOVAL DATE: June 7, 2021

TRIAL DATE: None Set

Defendants.

1 This Stipulated Protective Order is substantially based on the model protective

order provided under Magistrate Judge Patricia Donahue’s Procedures.

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1. A. PURPOSES AND LIMITATIONS

Discovery in this action is likely to involve production of confidential, proprietary, or private

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

than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and

petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this

Order does not confer blanket protections on all disclosures or responses to discovery and that the

protection it affords from public disclosure and use extends only to the limited information or items

that are entitled to confidential treatment under the applicable legal principles.

B. GOOD CAUSE STATEMENT

In light of the nature of the claims and allegations in this case and the parties’ representations

that discovery in this case will involve the production of confidential records, and in order to expedite

the flow of information, to facilitate the prompt resolution of disputes over confidentiality of discovery

materials, to adequately protect information the parties are entitled to keep confidential, to ensure that

the parties are permitted reasonable necessary uses of such material in connection with this action, to

address their handling of such material at the end of the litigation, and to serve the ends of justice, a

protective order for such information is justified in this matter. It is the intent of the parties that

information will not be designated as confidential for tactical reasons and that nothing be so designated

without a good faith belief that it has been maintained in a confidential, non-public manner, and there

is good cause why it should not be part of the public record of this case.

C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated

Protective Order does not entitle them to file confidential information under seal; Local Civil Rule 79-

5 sets forth the procedures that must be followed and the standards that will be applied when a party

seeks permission from the court to file material under seal.

There is a strong presumption that the public has a right of access to judicial proceedings and

records in civil cases. In connection with non-dispositive motions, good cause must be shown to

support a filing under seal. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th

Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v.

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Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require

good cause showing), and a specific showing of good cause or compelling reasons with proper

evidentiary support and legal justification, must be made with respect to Protected Material that a party

seeks to file under seal. The parties’ mere designation of Disclosure or Discovery Material as

CONFIDENTIAL does not—without the submission of competent evidence by declaration,

establishing that the material sought to be filed under seal qualifies as confidential, privileged, or

otherwise protectable—constitute good cause.

Further, if a party requests sealing related to a dispositive motion or trial, then compelling

reasons, not only good cause, for the sealing must be shown, and the relief sought shall be narrowly

tailored to serve the specific interest to be protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d

665, 677-79 (9th Cir. 2010). For each item or type of information, document, or thing sought to be

filed or introduced under seal in connection with a dispositive motion or trial, the party seeking

protection must articulate compelling reasons, supported by specific facts and legal justification, for

the requested sealing order. Again, competent evidence supporting the application to file documents

under seal must be provided by declaration.

Any document that is not confidential, privileged, or otherwise protectable in its entirety will

not be filed under seal if the confidential portions can be redacted. If documents can be redacted, then

a redacted version for public viewing, omitting only the confidential, privileged, or otherwise

protectable portions of the document, shall be filed. Any application that seeks to file documents under

seal in their entirety should include an explanation of why redaction is not feasible.

2. DEFINITIONS

2.1 Action: The instant action: Case No. 2:21-cv-04657-RGK-PD

2.2 Challenging Party: A Party or Non-Party that challenges the designation of

information or items under this Order.

2.3 “CONFIDENTIAL” Information or Items: Information (regardless of how it is

generated, stored or maintained) or tangible things that qualify for protection under the Federal Rule

of Civil Procedure 26(c), and as specified above in the Good Cause Statement.

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2.4 “ATTORNEYS’ EYES ONLY” Information or Items: CONFIDENTIAL

Information of a type that is highly sensitive and competitive commercial information disclosure of

which may cause substantial harm, and thus cannot be shared with individuals other than as described

in this Stipulated Protective Order.

2.5 Counsel: Outside Counsel of Record and House Counsel (as well as their support

staff).

2.6 Designating Party: A Party or Non-Party that designates information or items that it

produces in disclosures or in responses to discovery as “CONFIDENTIAL” and/or “ATTORNEYS’

EYES ONLY INFORMATION.”

2.7 Disclosure or Discovery Material: All items or information, regardless of the medium

or manner in which it is generated, stored, or maintained (including, among other things, testimony,

transcripts, and tangible things), that are produced or generated in disclosures or responses to

discovery in this matter.

2.8 Expert: A person with specialized knowledge or experience in a matter pertinent to

the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a

consultant in this action.

2.9 House Counsel: Attorneys who are employees of a party to this action. House

Counsel does not include Outside Counsel of Record or any other outside counsel.

2.10 Non-Party: Any natural person, partnership, corporation, association, or other legal

entity not named as a Party to this action.

2.11 Outside Counsel of Record: Attorneys who are not employees of a party to this action

but are retained to represent or advise a party to this action and have appeared in this action on behalf

of that party or are affiliated with a law firm which has appeared on behalf of that party, and includes

support staff.

2.12 Party: Any party to this action, including all of its officers, directors, employees,

consultants, retained experts, and Outside Counsel of Record (and their support staffs).

2.13 Producing Party: A Party or Non-Party that produces Disclosure or Discovery

Material in this action.

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2.14 Professional Vendors: Persons or entities that provide litigation support services (e.g.,

photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing,

storing, or retrieving data in any form or medium) and their employees and subcontractors.

2.15 Protected Material: Any Disclosure or Discovery Material that is designated as

“CONFIDENTIAL” and/or “ATTORNEYS’ EYES ONLY INFORMATION.”

2.16 Receiving Party: A Party that receives Disclosure or Discovery Material from a

Producing Party.

3. SCOPE

The protections conferred by this Stipulation and Order cover not only Protected Material (as

defined above), but also (1) any information copied or extracted from Protected Material; (2) all

copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,

conversations, or presentations by Parties or their Counsel that might reveal Protected Material.

Any use of Protected Material during a court hearing or at trial shall be governed by the orders

of the presiding judge. This Order does not govern the use of Protected Material during a court hearing

or at trial.

4. DURATION

FINAL DISPOSITION of the action is defined as the conclusion of any appellate proceedings,

or, if no appeal is taken, when the time for filing of an appeal has run. Except as set forth below, the

terms of this protective order apply through FINAL DISPOSITION of the action. The parties may

stipulate that they will be contractually bound by the terms of this agreement beyond FINAL

DISPOSITION, but will have to file a separate action for enforcement of the agreement once all

proceedings in this case are complete.

Once a case proceeds to trial, information that was designated as CONFIDENTIAL or

maintained pursuant to this protective order used or introduced as an exhibit at trial becomes public

and will be presumptively available to all members of the public, including the press, unless

compelling reasons supported by specific factual findings to proceed otherwise are made to the trial

judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

showing for sealing documents produced in discovery from “compelling reasons” standard when

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merits-related documents are part of court record). Accordingly, for such materials, the terms of this

protective order do not extend beyond the commencement of the trial.

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or

Non-Party that designates information or items for protection under this Order must take care to limit

any such designation to specific material that qualifies under the appropriate standards. The

Designating Party must designate for protection only those parts of material, documents, items, or

oral or written communications that qualify so that other portions of the material, documents, items,

or communications for which protection is not warranted are not swept unjustifiably within the ambit

of this Order.

Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown

to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily

encumber the case development process or to impose unnecessary expenses and burdens on other

parties) may expose the Designating Party to sanctions.

If it comes to a Designating Party’s attention that information or items that it designated for

protection do not qualify for protection, that Designating Party must promptly notify all other Parties

that it is withdrawing the inapplicable designation.

5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see,

e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or

Discovery Material that qualifies for protection under this Order must be clearly so designated before

the material is disclosed or produced.

Designation in conformity with this Order requires:

(a) information in documentary form (e.g., paper or electronic documents, but excluding

transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix the

legend “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” (or similar designation sufficiently

demonstrating the intent of the protection), as applicable, to each page that contains Protected

Material. If only a portion or portions of the material on a page qualifies for protection, the Producing

Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the

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margins).

A Party or Non-Party that makes original documents or materials available for inspection need

not designate them for protection until after the inspecting Party has indicated which material it would

like copied and produced. During the inspection and before the designation, all of the material made

available for inspection shall be deemed “CONFIDENTIAL”. After the inspecting Party has identified

the documents it wants to be copied and produced, the Producing Party must determine which

documents, or portions thereof, qualify for protection under this Order. Then, before producing the

specified documents, the Producing Party must affix the “CONFIDENTIAL” or “ATTORNEYS’

EYES ONLY” legend to each page that contains Protected Material. If only a portion or portions of

the material on a page qualifies for protection, the Producing Party also must clearly identify the

protected portion(s) (e.g., by making appropriate markings in the margins).

(b) for testimony given in deposition or in other pretrial or trial proceedings, that the

Designating Party identifies for testimony given in depositions that the Designating Party identifies

on the record, before the close of the deposition as protected testimony.

items, that the Producing Party affix in a prominent place on the exterior of the container or containers

in which the information or item is stored the legend “CONFIDENTIAL” or “ATTORNEYS’ EYES

ONLY.” If only a portion or portions of the information or item warrant protection, the Producing

Party, to the extent practicable, shall identify the protected portion(s).

5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to

designate qualified information or items does not, standing alone, waive the Designating Party’s right

to secure protection under this Order for such material. Upon timely correction of a designation, the

Receiving Party must make reasonable efforts to assure that the material is treated in accordance with

the provisions of this Order.

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6. CHALLENGING “CONFIDENTIAL” AND/OR “ATTORNEYS’ EYES ONLY”

DESIGNATIONS

6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of

“CONFIDENTIAL” and/or “ATTORNEYS’ EYES ONLY” at any time that is consistent with the

Court’s Scheduling Order.

6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process

under Local Rule 37.1 et seq.

6.3 The burden of persuasion in any such challenge proceeding shall be on the

Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or

impose unnecessary expenses and burdens on other parties) may expose the Challenging Party to

sanctions. Unless the Designating Party has waived the confidentiality designation in accordance

with the preceding paragraph, all parties shall continue to afford the material in question the level of

protection to which it is entitled under the Producing Party’s designation until the Court rules on the

challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or

produced by another Party or by a Non-Party in connection with this case only for prosecuting,

defending, or attempting to settle this Action. Such Protected Material may be disclosed only to the

categories of persons and under the conditions described in this Order. When the Action has been

terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL

DISPOSITION).

Protected Material must be stored and maintained by a Receiving Party at a location and in a

secure manner that ensures that access is limited to the persons authorized under this Order.

7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered

by the Court or permitted in writing by the Designating Party, a Receiving Party may disclose any

information or item designated “CONFIDENTIAL” only to:

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(a) the Receiving Party’s Outside Counsel of Record in this action, as well as

employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the

information for this Action;

(b) the officers, directors, and employees (including House Counsel) of the

Receiving Party to whom disclosure is reasonably necessary for this Action;

is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement

to Be Bound” (Exhibit A);

(d) the court and its personnel;

(e) court reporters and their staff;

(f) professional jury or trial consultants, mock jurors, and Professional Vendors

to whom disclosure is reasonably necessary for this Action and who have signed the

“Acknowledgment and Agreement to Be Bound” (Exhibit A);

(g) the author or recipient of a document containing the information or a custodian

or other person who otherwise possessed or knew the information.

(h) during their depositions, witnesses, and attorneys for witnesses, in the Action

to whom disclosure is reasonably necessary provided: (1) the deposing party requests that the witness

sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) they will not be

permitted to keep any confidential information unless they sign the “Acknowledgment and

Agreement to Be Bound” (Exhibit A hereto), unless otherwise agreed by the Designating Party or

ordered by the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal

Protected Material may be separately bound by the court reporter and may not be disclosed to anyone

except as permitted under this Stipulated Protective Order; and

(i) any mediator or settlement officer, and their supporting personnel, mutually

agreed upon by any of the parties engaged in settlement discussions.

7.3 Disclosure of “ATTORNEYS’ EYES ONLY” Information or Items. Unless

otherwise ordered by the Court or permitted in writing by the Designating Party, a Receiving Party

may disclose any information or item designated “ATTORNEYS’ EYES ONLY” only to:

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(a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees

of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for

this Action;

(b) the Receiving Party’s House Counsel;

reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to

Be Bound” (Exhibit A);

(d) the court and its personnel;

(e) court reporters and their staff, to whom disclosure is reasonably necessary for this

Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

(f) professional jury or trial consultants, mock jurors, and Professional Vendors to whom

disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and

Agreement to Be Bound” (Exhibit A);

(g) the author or original recipient of a document containing the information;

(h) any mediator or settlement officer, and their supporting personnel, mutually agreed

upon by any of the parties engaged in settlement discussions.

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER

LITIGATION

If a Party is served with a subpoena or a court order issued in other litigation that compels

disclosure of any information or items designated in this action as “CONFIDENTIAL” and/or

“ATTORNEYS’ EYES ONLY,” that Party must:

(a) promptly notify in writing the Designating Party. Such notification shall include a

copy of the subpoena or court order;

(b) promptly notify in writing the party who caused the subpoena or order to issue in the

other litigation that some or all of the material covered by the subpoena or order is subject to this

Stipulated Protective Order. Such notification shall include a copy of this Stipulated Protective Order;

and

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Designating Party whose Protected Material may be affected.

If the Designating Party timely seeks a protective order, the Party served with the subpoena or

court order shall not produce any information designated in this Action as “CONFIDENTIAL” and/or

“ATTORNEYS’ EYES ONLY” before a determination by the court from which the subpoena or order

issued, unless the Party has obtained the Designating Party’s permission. The Designating Party shall

bear the burden and expense of seeking protection in that court of its confidential and/or attorneys’

eyes only material and nothing in these provisions should be construed as authorizing or encouraging

a Receiving Party in this action to disobey a lawful directive from another court.

9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS

LITIGATION

(a) The terms of this Order are applicable to information produced by a Non-Party in this

Action and designated as “CONFIDENTIAL” and/or “ATTORNEYS’ EYES ONLY.” Such

information produced by Non-Parties in connection with this litigation is protected by the remedies

and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a

Non-Party from seeking additional protections.

(b) In the event that a Party is required, by a valid discovery request, to produce a

Non-Party’s confidential information in its possession, and the Party is subject to an agreement with

the Non-Party not to produce the Non-Party’s confidential information, then the Party shall:

(1) promptly notify in writing the Requesting Party and the Non-Party that some or

all of the information requested is subject to a confidentiality agreement with a Non-Party;

(2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in

this Action, the relevant discovery request(s), and a reasonably specific description of the information

requested; and

(3) make the information requested available for inspection by the Non-Party, if

requested.

receiving the notice and accompanying information, the Receiving Party may produce the

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Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely

seeks a protective order, the Receiving Party shall not produce any information in its possession or

control that is subject to the confidentiality agreement with the Non-Party before a determination by

the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of

seeking protection in this Court of its Protected Material.

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected

Material to any person or in any circumstance not authorized under this Stipulated Protective Order,

the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized

disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material,

Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be

Bound” that is attached hereto as Exhibit A.

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED

MATERIAL

When a Producing Party gives notice to Receiving Parties that certain inadvertently produced

material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties

are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to

modify whatever procedure may be established in an e-discovery order that provides for production

without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

parties reach an agreement on the effect of disclosure of a communication or information covered by

the attorney-client privilege or work product protection, the parties may incorporate their agreement

in the stipulated protective order submitted to the court.

12. MISCELLANEOUS

1.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek

its modification by the Court in the future.

12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order

no Party waives any right it otherwise would have to object to disclosing or producing any

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information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no

Party waives any right to object on any ground to use in evidence of any of the material covered by

this Protective Order.

12.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material

must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant

to a court order authorizing the sealing of the specific Protected Material at issue. If a Party’s request

to file Protected Material under seal is denied by the court, then the Receiving Party may file the

information in the public record unless otherwise instructed by the court.

13. FINAL DISPOSITION

After the final disposition of this Action, as defined in Section 4, upon the receipt of a written

request by the Designating Party, each Receiving Party must return all Protected Material to the

Producing Party or destroy such material within a reasonable time. As used in this subdivision, “all

Protected Material” includes all copies, abstracts, compilations, summaries, and any other format

reproducing or capturing any of the Protected Material. Whether the Protected Material is returned

or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if

not the same person or entity, to the Designating Party) within a reasonable time that (1) identifies

(by category, where appropriate) all the Protected Material that was returned or destroyed and (2)

affirms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or

any other format reproducing or capturing any of the Protected Material. Notwithstanding this

provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial,

deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,

expert reports, attorney work product, and consultant and expert work product, even if such materials

contain Protected Material. Any such archival copies that contain or constitute Protected Material

remain subject to this Protective Order as set forth in Section 4.

\ \

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14. Any violation of this Order may be punished by any and all appropriate measures including,

without limitation, contempt proceedings and/or monetary sanctions.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

Dated: December 9, 2022 LAWYERS FOR JUSTICE, PC

By: /s/ Travis J. Maher

TARA ZABEHI

Travis J. Maher

Attorneys for Plaintiff

GRISELDA JAUREGUI

Dated: December 9, 2022 HUSCH BLACKWELL LLP

By: /s/ Kathy M. Huynh

TYLER M. PAETKAU

Kathy M. Huynh

Attorneys for Defendant

ROADRUNNER TRANSPORTATION

SERVICES, INC.

Case 4/21-cv-04657-SPG-PD Document 41 Filed 12/08/22 Page 15o0f17 Page ID #:302

1 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

3 || DATED: December 8, 2022

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5 Folica Lona

6 Patricia Donahue

United States Magistrate Judge

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STIPULATED PROTECTIVE ORDER

HB: 4815-2014-07811

PLL LLEWKCALB HCSUH

17009 AC ,SELEGNA SOL ,0051 ETIUS ,DNARG HTUOS 003

0556-733 )312(

Case 2:21-cv-04657-SPG-PD Document 41 Filed 12/08/22 Page 16 of 17 Page ID #:303

EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, _____________________________ [print or type full name], of

_________________ [print or type full address], declare under penalty of perjury that

I have read in its entirety and understand the Stipulated Protective Order that was

issued by the United States District Court for the Central District of California on

_________________________ in the case of

_____________________________________. I agree to comply with and to be

bound by all the terms of this Protective Order and I understand and acknowledge that

failure to so comply could expose me to sanctions and punishment in the nature of

contempt. I solemnly promise that I will not disclose in any manner any information

or item that is subject to this Stipulated Protective Order to any person or entity except

in strict compliance with the provisions of this Order.

I further agree to submit to the jurisdiction of the United States District Court

for the Central District of California for the purpose of enforcing the terms of this

Stipulated Protective Order, even if such enforcement proceedings occur after

termination of this action. I hereby appoint __________________________ [print or

type full name] of _______________________________________ [print or type full

address and telephone number] as my California agent for service of process in

connection with this action or any proceedings related to enforcement of this

Protective Order.

Date: ______________________________________

City and State where sworn and signed: _________________________________

Printed name: _______________________________

Signature: __________________________________

PROOF OF SERVICE

HB: 4815-2014-07811

PLL LLEWKCALB HCSUH

21649 AC ,DNALKAO ,007 ETIUS ,.TS NOSIRRAH 9991

0560-867 )015(

Case 2:21-cv-04657-SPG-PD Document 41 Filed 12/08/22 Page 17 of 17 Page ID #:304

CERTIFICATE OF SERVICE

At the time of service, I was over 18 years of age and not a party to this

action. I am employed in the County of Los Angeles, State of California. My

business address is 355 South Grand, Suite 2850, Los Angeles, CA 90071.

On December 9, 2022, I served a true copy of the following document

described as:

[PROPOSED] STIPULATED PROTECTIVE ORDER

on the interested parties in this action as follows:

☒ BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically

filed the document(s) with the Clerk of the Court by using the CM/ECF

system. Participants in the case who are registered CM/ECF users will be

served by the CM/ECF system. Participants in the case who are not

registered CM/ECF users will be served by mail or by other means

permitted by the court rules.

☒ BY U.S. MAIL: I am readily familiar with this firm’s practice for

collection and processing of correspondence for mailing with the United

States Postal Service. I placed with this firm at the above address for

deposit with the United States Postal Service a true and correct copy of the

document(s) in a sealed envelope, postage fully paid, addressed as

follows:

LAWYERS for JUSTICE, PC

Edwin Aiwazian

edwin@calljustice.com

Arby Aiwazian

arby@calljustice.com

Travis Maher

travis@calljustice.com

410 West Arden Avenue, Suite 203

Glendale, CA 91203

I declare under penalty of perjury under the laws of the United States of

America that the foregoing is true and correct and that I am employed in the office

of a member of the bar of this Court at whose direction the service was made.

Executed on December 9, 2022, at Los Angeles, California.

/s/Dana Chan

DANA CHAN

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