# D.S. v. County of Los Angeles

> District Court, C.D. California · January 9, 2023

URL: https://www.frixlaw.com/law-library/cases/9982087

## Case

- **Court:** District Court, C.D. California
- **Decided:** January 9, 2023
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

Case 2:21-cv-07986-DMG-GJS Document 44 Filed 01/09/23 Page 1 of 17 Page ID #:260

1

2

3
4 UNITED STATES DISTRICT COURT
5 CENTRAL DISTRICT OF CALIFORNIA
6
D.S., a minor by and through his Case No. 2:21-cv-07986 DMG
7 parent, TAMMI COLLINS, M.G., a (GJSx)
minor by and through his parent
8 DERRICK GRAY; and, TITUS GIST,
STIPULATED PROTECTIVE
9 Plaintiffs, ORDER
10 vs.

11 COUNTY OF LOS ANGELES a
public entity, DEPUTY MENDEZ
12 (#636373), DEPUTY MARTINEZ
(#639674), DEPUTY GONZALEZ
13 (#641033), DEPUTY JAGIELLO
(#623588) and DOES 5 through 10,
14 Inclusive,

15 Defendants.
16
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
17
1. A. PURPOSES AND LIMITATIONS
18
Discovery in this action is likely to involve production of confidential,
19
proprietary or private information for which special protection from public
20
disclosure and from use for any purpose other than prosecuting this litigation may
21
be warranted. Accordingly, the parties hereby stipulate to and petition the Court
22
to enter the following Stipulated Protective Order. The parties acknowledge that
23
this Order does not confer blanket protections on all disclosures or responses to
24
discovery and that the protection it affords from public disclosure and use extends
25
only to the limited information or items that are entitled to confidential treatment
26
under the applicable legal principles.
27

28
1
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1 B. GOOD CAUSE STATEMENT
2 This action is likely to involve confidential information pertaining to
3 personnel records and other materials subject to privacy protections for which
4 special protection from public disclosure and from use for any purpose other than
5 prosecution of this action is warranted. Limiting disclosure of these documents to
6 the context of this litigation as provided herein will, accordingly, further important
7 law enforcement objections and interests, including the safety of personnel and the
8 public, as well as individual privacy rights of plaintiff, the individual defendants,
9 and third parties. Such confidential materials and information consist of, among
10 other things, materials entitled to privileges and/or protections under the
11 following: United States Constitution, First Amendment; the California
12 Constitution, Article I, Section 1; California Penal Code §§ 832.5, 832.7 and
13 832.8; California Evidence Code §§ 1040 and 1043 et. seq; the Privacy Act of
14 1974, 5 U.S.C. § 552; Health Insurance Portability and Accountability Act of 1996
15 (HIPPA); the right to privacy; decisional law relating to such provisions; and
16 information otherwise generally unavailable to the public, or which may be
17 privileged or otherwise protected from disclosure under state or federal statutes,
18 court rules, case decisions, or common law. Defendants also contend that such
19 confidential materials and information consist of materials entitled to the Official
20 Information Privilege.
21 Confidential information with respect to the Defendants may include, but is
22 not limited to: personnel files; internal investigative files and documents; email
23 and written correspondence records; and policies and procedures that are kept from
24 the public in the ordinary course of business, as well as other information that is
25 not generally available to the public and is subject to the Official Information
26 Privilege and other privileges. Confidential information with financial records;
27 email and written correspondence records; video footage and/or photographs of
28 the incident; and psychological and medical notes, evaluations, reports, and
2
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1 treatment plans.
2 Testimony taken at a deposition may be designated as Confidential by
3 making a statement to that effect on the record at the deposition. Arrangements
4 shall be made with the court reporter transcribing the deposition to separately bind
5 such portions of the transcript containing information designated as Confidential,
6 and to label such portions appropriately.
7 The parties reserve the right to challenge a designation of confidentiality
8 pursuant to the terms set forth under Paragraph 6 of this Order.
9 Accordingly, to expedite the flow of information, to facilitate the prompt
10 resolution of disputes over confidentiality of discovery materials, to adequately
11 protect information the parties are entitled to keep confidential, to ensure that the
12 parties are permitted to reasonably use such material in preparation for and in
13 conduct of trial, to address their handling at the end of the litigation, and serve the
14 ends of justice, a protective order for such information is justified in this matter. It
15 is the intent of the parties that information will not be designated as confidential
16 for tactical reasons and that nothing be so designated without a good faith belief
17 that it has been maintained in a confidential, non-public manner, and there is good
18 cause why it should not be part of the public record of this case.
19 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
20 SEAL
21 The parties further acknowledge, as set forth in Section 12.3, below, that
22 this Stipulated Protective Order does not entitle them to file confidential
23 information under seal; Local Civil Rule 79-5 sets forth the procedures that must
24 be followed and the standards that will be applied when a party seeks permission
25 from the court to file material under seal.
26 There is a strong presumption that the public has a right of access to judicial
27 proceedings and records in civil cases. In connection with non-dispositive
28 motions, good cause must be shown to support a filing under seal. See Kamakana
3
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1 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v.
2 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v.
3 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
4 protective orders require good cause showing), and a specific showing of good
5 cause or compelling reasons with proper evidentiary support and legal
6 justification, must be made with respect to Protected Material that a party seeks to
7 file under seal. The parties’ mere designation of Disclosure or Discovery Material
8 as CONFIDENTIAL does not—without the submission of competent evidence by
9 declaration, establishing that the material sought to be filed under seal qualifies as
10 confidential, privileged, or otherwise protectable—constitute good cause.
11 Further, if a party requests sealing related to a dispositive motion or trial,
12 then compelling reasons, not only good cause, for the sealing must be shown, and
13 the relief sought shall be narrowly tailored to serve the specific interest to be
14 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.
15 2010). For each item or type of information, document, or thing sought to be filed
16 or introduced under seal in connection with a dispositive motion or trial, the party
17 seeking protection must articulate compelling reasons, supported by specific facts
18 and legal justification, for the requested sealing order. Again, competent evidence
19 supporting the application to file documents under seal must be provided by
20 declaration.
21 Any document that is not confidential, privileged, or otherwise protectable
22 in its entirety will not be filed under seal if the confidential portions can be
23 redacted. If documents can be redacted, then a redacted version for public
24 viewing, omitting only the confidential, privileged, or otherwise protectable
25 portions of the document, shall be filed. Any application that seeks to file
26 documents under seal in their entirety should include an explanation of why
27 redaction is not feasible.
28 / / /
4
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1 2. DEFINITIONS
2 2.1 Action: D.S., a minor by and through his parent, TAMMI COLLINS,
3 et al. v. County of Los Angeles, et al., Case No. 2:21-cv-07986 DMG (GJS).
4 2.2 Challenging Party: a Party or Non-Party that challenges the
5 designation of information or items under this Order.
6 2.3 “CONFIDENTIAL” Information or Items: information (regardless
7 of how it is generated, stored or maintained) or tangible things that qualify for
8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
9 the Good Cause Statement.
10 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
11 their support staff).
12 2.5 Designating Party: a Party or Non-Party that designates information
13 or items that it produces in disclosures or in responses to discovery as
14 “CONFIDENTIAL.”
15 2.6 Disclosure or Discovery Material: all items or information,
16 regardless of the medium or manner in which it is generated, stored, or maintained
17 (including, among other things, testimony, transcripts, and tangible things), that
18 are produced or generated in disclosures or responses to discovery in this matter.
19 2.7 Expert: a person with specialized knowledge or experience in a
20 matter pertinent to the litigation who has been retained by a Party or its counsel to
21 serve as an expert witness or as a consultant in this Action.
22 2.8 House Counsel: attorneys who are employees of a party to this
23 Action. House Counsel does not include Outside Counsel of Record or any other
24 outside counsel.
25 2.9 Non-Party: any natural person, partnership, corporation, association
26 or other legal entity not named as a Party to this action.
27 2.10 Outside Counsel of Record: attorneys who are not employees of a
28 party to this Action but are retained to represent or advise a party to this Action
5
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1 and have appeared in this Action on behalf of that party or are affiliated with a law
2 firm that has appeared on behalf of that party, and includes support staff.
3 2.11 Party: any party to this Action, including all of its officers, directors,
4 employees, consultants, retained experts, and Outside Counsel of Record (and
5 their support staffs).
6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
7 Discovery Material in this Action.
8 2.13 Professional Vendors: persons or entities that provide litigation
9 support services (e.g., photocopying, videotaping, translating, preparing exhibits
10 or demonstrations, and organizing, storing, or retrieving data in any form or
11 medium) and their employees and subcontractors.
12 2.14 Protected Material: any Disclosure or Discovery Material that is
13 designated as “CONFIDENTIAL.”
14 2.15 Receiving Party: a Party that receives Disclosure or Discovery
15 Material from a Producing Party.
16 3. SCOPE
17 The protections conferred by this Stipulation and Order cover not only
18 Protected Material (as defined above), but also (1) any information copied or
19 extracted from Protected Material; (2) all copies, excerpts, summaries, or
20 compilations of Protected Material; and (3) any testimony, conversations, or
21 presentations by Parties or their Counsel that might reveal Protected Material.
22 Any use of Protected Material at trial shall be governed by the orders of the
23 trial judge. This Order does not govern the use of Protected Material at trial.
24 4. DURATION
25 FINAL DISPOSITION of the action is defined as the conclusion of any
26 appellate proceedings, or, if no appeal is taken, when the time for filing of an
27 appeal has run. Except as set forth below, the terms of this protective order apply
28 through FINAL DISPOSITION of the action. The parties may stipulate that the
6
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1 they will be contractually bound by the terms of this agreement beyond FINAL
2 DISPOSITION, but will have to file a separate action for enforcement of the
3 agreement once all proceedings in this case are complete.
4 Once a case proceeds to trial, information that was designated as
5 CONFIDENTIAL or maintained pursuant to this protective order used or
6 introduced as an exhibit at trial becomes public and will be presumptively
7 available to all members of the public, including the press, unless compelling
8 reasons supported by specific factual findings to proceed otherwise are made to
9 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
10 (distinguishing “good cause” showing for sealing documents produced in
11 discovery from “compelling reasons” standard when merits-related documents are
12 part of court record). Accordingly, for such materials, the terms of this protective
13 order do not extend beyond the commencement of the trial.
14 5. DESIGNATING PROTECTED MATERIAL
15 5.1 Exercise of Restraint and Care in Designating Material for Protection.
16 Each Party or Non-Party that designates information or items for protection under
17 this Order must take care to limit any such designation to specific material that
18 qualifies under the appropriate standards. The Designating Party must designate
19 for protection only those parts of material, documents, items or oral or written
20 communications that qualify so that other portions of the material, documents,
21 items or communications for which protection is not warranted are not swept
22 unjustifiably within the ambit of this Order.
23 Mass, indiscriminate or routinized designations are prohibited.
24 Designations that are shown to be clearly unjustified or that have been made for
25 an improper purpose (e.g., to unnecessarily encumber the case development
26 process or to impose unnecessary expenses and burdens on other parties) may
27 expose the Designating Party to sanctions.
28 / / /
7
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1 If it comes to a Designating Party’s attention that information or items that
2 it designated for protection do not qualify for protection, that Designating Party
3 must promptly notify all other Parties that it is withdrawing the inapplicable
4 designation.
5 5.2 Manner and Timing of Designations. Except as otherwise provided
6 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
7 stipulated or ordered, Disclosure or Discovery Material that qualifies for
8 protection under this Order must be clearly so designated before the material is
9 disclosed or produced.
10 Designation in conformity with this Order requires:
11 (a) for information in documentary form (e.g., paper or electronic
12 documents, but excluding transcripts of depositions or other pretrial or trial
13 proceedings), that the Producing Party affix at a minimum, the legend
14 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
15 contains protected material. If only a portion of the material on a page qualifies
16 for protection, the Producing Party also must clearly identify the protected
17 portion(s) (e.g., by making appropriate markings in the margins).
18 A Party or Non-Party that makes original documents available for
19 inspection need not designate them for protection until after the inspecting Party
20 has indicated which documents it would like copied and produced. During the
21 inspection and before the designation, all of the material made available for
22 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
23 identified the documents it wants copied and produced, the Producing Party must
24 determine which documents, or portions thereof, qualify for protection under this
25 Order. Then, before producing the specified documents, the Producing Party must
26 affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
27 If only a portion of the material on a page qualifies for protection, the Producing
28 / / /
8
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1 Party also must clearly identify the protected portion(s) (e.g., by making
2 appropriate markings in the margins).
3 (b) for testimony given in depositions that the Designating Party
4 identifies the Disclosure or Discovery Material on the record, before the close of
5 the deposition all protected testimony.
6 (c) for information produced in some form other than documentary and
7 for any other tangible items, that the Producing Party affix in a prominent place on
8 the exterior of the container or containers in which the information is stored the
9 legend “CONFIDENTIAL.” If only a portion or portions of the information
10 warrants protection, the Producing Party, to the extent practicable, shall identify
11 the protected portion(s).
12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
13 failure to designate qualified information or items does not, standing alone, waive
14 the Designating Party’s right to secure protection under this Order for such
15 material. Upon timely correction of a designation, the Receiving Party must make
16 reasonable efforts to assure that the material is treated in accordance with the
17 provisions of this Order.
18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
20 designation of confidentiality at any time that is consistent with the Court’s
21 Scheduling Order.
22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
23 resolution process under Local Rule 37.1 et seq.
24 6.3 The burden of persuasion in any such challenge proceeding shall be
25 on the Designating Party. Frivolous challenges, and those made for an improper
26 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
27 parties) may expose the Challenging Party to sanctions. Unless the Designating
28 Party has waived or withdrawn the confidentiality designation, all parties shall
9
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1 continue to afford the material in question the level of protection to which it is
2 entitled under the Producing Party’s designation until the Court rules on the
3 challenge.
4 7. ACCESS TO AND USE OF PROTECTED MATERIAL
5 7.1 Basic Principles. A Receiving Party may use Protected Material that
6 is disclosed or produced by another Party or by a Non-Party in connection with
7 this Action only for prosecuting, defending or attempting to settle this Action.
8 Such Protected Material may be disclosed only to the categories of persons and
9 under the conditions described in this Order. When the Action has been
10 terminated, a Receiving Party must comply with the provisions of section 13 below
11 (FINAL DISPOSITION).
12 Protected Material must be stored and maintained by a Receiving Party at a
13 location and in a secure manner that ensures that access is limited to the persons
14 authorized under this Order.
15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
16 otherwise ordered by the court or permitted in writing by the Designating Party, a
17 Receiving Party may disclose any information or item designated
18 “CONFIDENTIAL” only to:
19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
20 well as employees of said Outside Counsel of Record to whom it is reasonably
21 necessary to disclose the information for this Action;
22 (b) the officers, directors, and employees (including House Counsel) of
23 the Receiving Party to whom disclosure is reasonably necessary for this Action;
24 (c) Experts (as defined in this Order) of the Receiving Party to whom
25 disclosure is reasonably necessary for this Action and who have signed the
26 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (d) the court and its personnel;
28 (e) court reporters and their staff;
10
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1 (f) professional jury or trial consultants, mock jurors, and Professional
2 Vendors to whom disclosure is reasonably necessary for this Action and who have
3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (g) the author or recipient of a document containing the information or
5 a custodian or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses, and attorneys for witnesses, in
7 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
8 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2)
9 they will not be permitted to keep any confidential information unless they sign
10 the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
11 agreed by the Designating Party or ordered by the court. Pages of transcribed
12 deposition testimony or exhibits to depositions that reveal Protected Material may
13 be separately bound by the court reporter and may not be disclosed to anyone
14 except as permitted under this Stipulated Protective Order; and
15 (i) any mediator or settlement officer, and their supporting personnel,
16 mutually agreed upon by any of the parties engaged in settlement discussions.
17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
18 IN OTHER LITIGATION
19 If a Party is served with a subpoena or a court order issued in other litigation
20 that compels disclosure of any information or items designated in this Action as
21 “CONFIDENTIAL,” that Party must:
22 (a) promptly notify in writing the Designating Party. Such notification
23 shall include a copy of the subpoena or court order;
24 (b) promptly notify in writing the party who caused the subpoena or
25 order to issue in the other litigation that some or all of the material covered by the
26 subpoena or order is subject to this Protective Order. Such notification shall
27 include a copy of this Stipulated Protective Order; and
28 / / /
11
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1 (c) cooperate with respect to all reasonable procedures sought to be
2 pursued by the Designating Party whose Protected Material may be affected.
3 If the Designating Party timely seeks a protective order, the Party served
4 with the subpoena or court order shall not produce any information designated in
5 this action as “CONFIDENTIAL” before a determination by the court from which
6 the subpoena or order issued, unless the Party has obtained the Designating Party’s
7 permission. The Designating Party shall bear the burden and expense of seeking
8 protection in that court of its confidential material and nothing in these provisions
9 should be construed as authorizing or encouraging a Receiving Party in this Action
10 to disobey a lawful directive from another court.
11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
12 PRODUCED IN THIS LITIGATION
13 (a) The terms of this Order are applicable to information produced by a
14 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
15 produced by Non-Parties in connection with this litigation is protected by the
16 remedies and relief provided by this Order. Nothing in these provisions should be
17 construed as prohibiting a Non-Party from seeking additional protections.
18 (b) In the event that a Party is required, by a valid discovery request, to
19 produce a Non-Party’s confidential information in its possession, and the Party is
20 subject to an agreement with the Non-Party not to produce the Non-Party’s
21 confidential information, then the Party shall:
22 (1) promptly notify in writing the Requesting Party and the Non-
23 Party that some or all of the information requested is subject to a confidentiality
24 agreement with a Non-Party;
25 (2) promptly provide the Non-Party with a copy of the Stipulated
26 Protective Order in this Action, the relevant discovery request(s), and a reasonably
27 specific description of the information requested; and
28 / / /
12
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1 (3) make the information requested available for inspection by the
2 Non-Party, if requested.
3 (c) If the Non-Party fails to seek a protective order from this court within
4 14 days of receiving the notice and accompanying information, the Receiving
5 Party may produce the Non-Party’s confidential information responsive to the
6 discovery request. If the Non-Party timely seeks a protective order, the Receiving
7 Party shall not produce any information in its possession or control that is subject
8 to the confidentiality agreement with the Non-Party before a determination by the
9 court. Absent a court order to the contrary, the Non-Party shall bear the burden
10 and expense of seeking protection in this court of its Protected Material.
11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
12 If a Receiving Party learns that, by inadvertence or otherwise, it has
13 disclosed Protected Material to any person or in any circumstance not authorized
14 under this Stipulated Protective Order, the Receiving Party must immediately (a)
15 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
16 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
17 the person or persons to whom unauthorized disclosures were made of all the terms
18 of this Order, and (d) request such person or persons to execute the
19 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
20 A.
21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
22 PROTECTED MATERIAL
23 When a Producing Party gives notice to Receiving Parties that certain
24 inadvertently produced material is subject to a claim of privilege or other
25 protection, the obligations of the Receiving Parties are those set forth in Federal
26 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
27 whatever procedure may be established in an e-discovery order that provides for
28 production without prior privilege review. Pursuant to Federal Rule of Evidence
13
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1 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
2 of a communication or information covered by the attorney-client privilege or
3 work product protection, the parties may incorporate their agreement in the
4 stipulated protective order submitted to the court.
5 12. MISCELLANEOUS
6 12.1 Right to Further Relief. Nothing in this Order abridges the right of
7 any person to seek its modification by the Court in the future.
8 12.2 Right to Assert Other Objections. By stipulating to the entry of this
9 Protective Order, no Party waives any right it otherwise would have to object to
10 disclosing or producing any information or item on any ground not addressed in
11 this Stipulated Protective Order. Similarly, no Party waives any right to object on
12 any ground to use in evidence of any of the material covered by this Protective
13 Order.
14 12.3 Filing Protected Material. A Party that seeks to file under seal any
15 Protected Material must comply with Local Civil Rule 79-5. Protected Material
16 may only be filed under seal pursuant to a court order authorizing the sealing of
17 the specific Protected Material at issue. If a Party’s request to file Protected
18 Material under seal is denied by the court, then the Receiving Party may file the
19 information in the public record unless otherwise instructed by the court.
20 13. FINAL DISPOSITION
21 After the final disposition of this Action, as defined in paragraph 4, within
22 60 days of a written request by the Designating Party, each Receiving Party must
23 return all Protected Material to the Producing Party or destroy such material. As
24 used in this subdivision, “all Protected Material” includes all copies, abstracts,
25 compilations, summaries, and any other format reproducing or capturing any of
26 the Protected Material. Whether the Protected Material is returned or destroyed,
27 the Receiving Party must submit a written certification to the Producing Party
28 (and, if not the same person or entity, to the Designating Party) by the 60 day
14
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1 deadline that (1) identifies (by category, where appropriate) all the Protected
2 Material that was returned or destroyed and (2) affirms that the Receiving Party
3 has not retained any copies, abstracts, compilations, summaries or any other format
4 reproducing or capturing any of the Protected Material. Notwithstanding this
5 provision, Counsel are entitled to retain an archival copy of all pleadings, motion
6 papers, trial, deposition, and hearing transcripts, legal memoranda,
7 correspondence, deposition and trial exhibits, expert reports, attorney work
8 product, and consultant and expert work product, even if such materials contain
9 Protected Material. Any such archival copies that contain or constitute Protected
10 Material remain subject to this Protective Order as set forth in Section 4
11 (DURATION).
12 / / /
13 / //
14 / / /
15 / / /
16 / / /
17 / / /
18 / / /
19 / / /
20 / / /
21 / / /
22 / / /
23 / / /
24 / / /
25 / / /
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1 || 14. VIOLATION
2 |} Any violation of this Order may be punished by appropriate measures including,
3 || without limitation, contempt proceedings and/or monetary sanctions.
4 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6 || DATED: 01/03/2023
8 || __/s/Robert Brown
9 Attorneys for Plaintiffs

10
11 || DATED: 01/03/2023
12
13 /s/Marina Samson
4 Attorneys for Defendants

15
16
17
18 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
19
20 || DATED: January 9, 2023
21

23
24 || United States Magistrate Judge
25
26
27
28
16

Case 2:21-cv-07986-DMG-GJS Document 44 Filed 01/09/23 Page 17 of 17 Page ID #:276

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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
7 California on [date] in the case of ___________ D.S., a minor by and through his
8 parent, TAMMI COLLINS, et al. v. County of Los Angeles, et al., Case No. 2:21-
9 cv-07986 DMG (GJS). I agree to comply with and to be bound by all the terms
10 of this Stipulated Protective Order and I understand and acknowledge that failure
11 to so comply could expose me to sanctions and punishment in the nature of
12 contempt. I solemnly promise that I will not disclose in any manner any
13 information or item that is subject to this Stipulated Protective Order to any
14 person or entity except in strict compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for
16 the Central District of California for enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination
18 of this action. I hereby appoint __________________________ [print or type
19 full name] of _______________________________________ [print or type full
20 address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27
28 Signature: __________________________________
17

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9982087. Public record. Not legal advice.