Renee Maxwell v. American Airlines, Inc.

Case 2:22-cv-01803-FLA-KS Document 26 Filed 03/03/23 Page 1 of 16 Page ID #:196

1 Tanja L. Darrow, Bar No. 175502

tdarrow@littler.com

2 Melissa Velez, Bar No. 316714

mvelez@littler.com

3 LITTLER MENDELSON, P.C.

633 West 5th Street

4 63rd Floor

Los Angeles, California 90071

5 Telephone: 213.443.4300

Fax No.: 213.443.4299

6

Attorneys for Defendant

7 AMERICAN AIRLINES, INC.

8 Avi Burkwitz. Esq., Bar No.: 217225

aburkwitz@pDbllp.com

9

Sherry M. Gregorio, Esq., Bar No.: 263856

10 sgregorio@pbbllp.com

Irene Yousefi, Esq., Bar No.: 328432

11

iyousefi@pbbllp.com

12 PETERSON, BRADFORD, BURKWITZ,

GREGORIO, BURKWITZ & SU, LLP

13

100 North First Street, Suite 300

14 Burbank, California 91502

818.562.5800

15

16 Attorneys for Plaintiff,

RENEE MAXWELL

17

18

UNITED STATES DISTRICT COURT

19

CENTRAL DISTRICT OF CALIFORNIA

20

21

RENEE MAXWELL, an individual, Case No. 2:22−cv−01803−FLA−(KSx)

22

Plaintiff, [Assigned: Hon. Fernando L. Aenlle-

Rocha, Courtroom: 6B]

23

v.

24 STIPULATED PROTECTIVE

AMERICAN AIRLINES, INC.; and

DOES 1-50, inclusive, ORDER

25

Defendants.

26 FAC Filed: February 15, 2022

Complaint Filed: February 4, 2022

27

28

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1 I. PURPOSES AND LIMITATIONS OF STIPULATION AND

PROTECTIVE ORDER

2

3 Discovery in this action is likely to involve production of confidential,

4 proprietary, or private information for which special protection from public disclosure

5 and from use for any purpose other than prosecuting this litigation may be warranted.

6 Accordingly, the parties hereby stipulate to and petition the Court to enter the following

7 Stipulated Protective Order. The parties acknowledge that this Order does not confer

8 blanket protections on all disclosures or responses to discovery and that the protection

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

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

11 parties further acknowledge, as set forth in Section XIII.C., below, that this Stipulated

12 Protective Order does not entitle them to file confidential information under seal; Civil

13 Local Rule 79-5 sets forth the procedures that must be followed and the standards that

14 will be applied when a party seeks permission from the court to file material under seal.

15 II. GOOD CAUSE STATEMENT

16 This action is likely to involve the disclosure of material protected under the

17 constitutional, statutory, or common law right to privacy or protected as confidential

18 business, financial, proprietary, or private personnel, policy and payroll information.

19 Such confidential and proprietary materials and information consist of, among other

20 things, confidential information regarding current and/ or former employees,

21 confidential business or financial information, information regarding confidential

22 business practices, or other confidential commercial information (including information

23 implicating privacy rights of third parties), information otherwise generally unavailable

24 to the public, or which may be privileged or otherwise protected from disclosure under

25 state or federal statutes, court rules, case decisions, or common law. Accordingly, to

26 expedite the flow of information, to facilitate the prompt resolution of disputes over

27 confidentiality of discovery materials, to adequately protect information the parties are

28 entitled to keep confidential, to ensure that the parties are permitted reasonable

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1 necessary uses of such material in preparation for and in the conduct of trial, to address

2 their handling at the end of the litigation, and serve the ends of justice, a protective order

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

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

5 be so designated without a good faith belief that it has been maintained in a confidential,

6 non-public manner, and there is good cause why it should not be part of the public

7 record of this case.

8 III. DEFINITIONS

9 A. Action: Action refers to the above referenced matter titled Renee Maxwell

10 v. American Airlines, Inc., Case No. 2:22-cv-01 803-FLA-KS.

11 B. Challenging Party: a Party or Non-Party that challenges the designation of

12 information or items under this Order.

13 C. “CONFIDENTIAL” Information or Items: information that has not been

14 made public or is not otherwise available or accessible in the public

15 domain and that concerns or relates to the confidential or proprietary

16 information of: (1) Defendant American Airlines, Inc. (“Defendant”); (2)

17 Plaintiff Renee Maxwell (“Plaintiff”); or (3) any third parties, the

18 disclosure of which information is likely to have the effect of causing harm

19 to the competitive position of Defendants or to the organization or person

20 from whom the information was obtained, or to the parties’ privacy.

21 Confidential Information also includes private information pertaining to

22 Defendants’ or a third party’s employees, for which Defendants or a third

23 party has a duty to maintain the confidentiality of such information.

24 Information designated Confidential may be used only in connection with

25 this proceeding, and not for any other purpose. Such information may not

26 be disclosed to anyone except as provided in this Order.

27

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1 D. Counsel: “Counsel” means:

2 1. Littler Mendelson, a professional corporation, and its respective

3 support staff and other employees who are not employed by a Party

4 and to whom it is necessary to disclose Confidential Information for

5 the purpose of this action;

6 2. Peterson, Bradford, Burkwitz, Gregorio, Burkwitz & Su, LLP, and

7 their respective support staff and other employees who are not

8 employed by a Party and to whom it is necessary to disclose

9 Confidential Information for the purpose of this action;

10 E. Designating Party: a Party or Non-Party that designates information or

11 items that it produces in disclosures or in responses to discovery as

12 “CONFIDENTIAL.”

13 F. Disclosure or Discovery Material: all items or information, regardless of

14 the medium or manner in which it is generated, stored, or maintained

15 (including, among other things, testimony, transcripts, and tangible

16 things), that are produced or generated in disclosures or responses to

17 discovery in this matter.

18 G. Expert: a person with specialized knowledge or experience in a matter

19 pertinent to the litigation who has been retained by a Party or its counsel

20 to serve as an expert witness or as a consultant in this Action.

21 H. House Counsel: attorneys who are employees of a party to this Action.

22 House Counsel does not include Outside Counsel of Record or any other

23 outside counsel.

24 I. Non-Party: any natural person, partnership, corporation, association, or

25 other legal entity not named as a Party to this action.

26 J. Outside Counsel of Record: attorneys who are not employees of a party to

27 this Action but are retained to represent or advise a party to this Action and

28

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1 have appeared in this Action on behalf of that party or are affiliated with a

2 law firm that has appeared on behalf of that party, including support staff.

3 K. Party: any party to this Action, including all of its officers, directors,

4 employees, consultants, retained experts, and Outside Counsel of Record

5 (and their support staffs).

6 L. Producing Party: a Party or Non-Party that produces Disclosure or

7 Discovery Material in this Action.

8 M. Professional Vendors: persons or entities that provide litigation support

9 services (e.g., photocopying, videotaping, translating, preparing exhibits

10 or demonstrations, and organizing, storing, or retrieving data in any form

11 or medium) and their employees and subcontractors.

12 N. Protected Material: any Disclosure or Discovery Material that is

13 designated as “CONFIDENTIAL.”

14 O. Receiving Party: a Party that receives Disclosure or Discovery Material

15 from a Producing Party.

16 IV. SCOPE

17 The protections conferred by this Stipulation and Order cover not only Protected

18 Material (as defined above), but also (1) any information copied or extracted from

19 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

20 Material; and (3) any testimony, conversations, or presentations by Parties or their

21 Counsel that might reveal Protected Material.

22 Any use of Protected Material at trial shall be governed by the orders of the trial

23 judge. This Order does not govern the use of Protected Material at trial.

24 V. DURATION

25 Once a case proceeds to trial, all of the court-filed information to be introduced

26 that was previously designated as confidential or maintained pursuant to this protective

27 order becomes public and will be presumptively available to all members of the public,

28 including the press, unless compelling reasons supported by specific factual findings to

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1 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v.

2 City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing

3 “good cause” showing for sealing documents produced in discovery from “compelling

4 reasons” standard when merits-related documents are part of court record).

5 Accordingly, the terms of this protective order do not extend beyond the

6 commencement of the trial.

7 VI. DESIGNATING PROTECTED MATERIAL

8 A. Exercise of Restraint and Care in Designating Material for Protection.

9 Each Party or Non-Party that designates information or items for protection under this

10 Order must take care to limit any such designation to specific material that qualifies

11 under the appropriate standards. The Designating Party must designate for protection

12 only those parts of material, documents, items, or oral or written communications that

13 qualify so that other portions of the material, documents, items, or communications for

14 which protection is not warranted are not swept unjustifiably within the ambit of this

15 Order.

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

17 are shown to be clearly unjustified or that have been made for an improper purpose

18 (e.g., to unnecessarily encumber the case development process or to impose

19 unnecessary expenses and burdens on other parties) may expose the Designating Party

20 to sanctions.

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

22 designated for protection do not qualify for protection, that Designating Party must

23 promptly notify all other Parties that it is withdrawing the inapplicable designation.

24 B. Manner and Timing of Designations. Except as otherwise provided in this

25 Order or as otherwise stipulated or ordered, Disclosure or Discovery Material that

26 qualifies for protection under this Order must be clearly so designated before the

27 material is disclosed or produced.

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1 Designation in conformity with this Order requires:

2 1. for information in documentary form (e.g., paper or electronic

3 documents, but excluding transcripts of depositions or other pretrial or trial

4 proceedings), that the Producing Party affix, at a minimum, the legend

5 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

6 contains protected material. If only a portion or portions of the material on a page

7 qualifies for protection, the Producing Party also must clearly identify the protected

8 portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-Party

9 that makes original documents available for inspection need not designate them for

10 protection until after the inspecting Party has indicated which documents it would like

11 copied and produced. During the inspection and before the designation, all of the

12 material made available for inspection shall be deemed “CONFIDENTIAL.” After the

13 inspecting Party has identified the documents it wants copied and produced, the

14 Producing Party must determine which documents, or portions thereof, qualify for

15 protection under this Order. Then, before producing the specified documents, the

16 Producing Party must affix the “CONFIDENTIAL legend” to each page that contains

17 Protected Material. If only a portion or portions of the material on a page qualifies for

18 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,

19 by making appropriate markings in the margins).

20 2. for testimony given in depositions that the Designating Party

21 identify the Disclosure or Discovery Material on the record, before the close of the

22 deposition.

23 3. for information produced in some form other than documentary and

24 for any other tangible items, that the Producing Party affix in a prominent place on the

25 exterior of the container or containers in which the information is stored the legend

26 “CONFIDENTIAL.” If only a portion or portions of the information warrants

27 protection, the Producing Party, to the extent practicable, shall identify the protected

28 portion(s).

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1 C. Inadvertent Failures to Designate. If timely corrected, an inadvertent

2 failure to designate qualified information or items does not, standing alone, waive the

3 Designating Party’s right to secure protection under this Order for such material. Upon

4 timely correction of a designation, the Receiving Party must make reasonable efforts to

5 assure that the material is treated in accordance with the provisions of this Order.

6 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS

7 A. Timing of Challenges. Any Party or Non-Party may challenge a

8 designation of confidentiality at any time that is consistent with the Court’s Scheduling

9 Order.

10 B. Meet and Confer. The Challenging Party shall initiate the dispute

11 resolution process under Local Rule 37.1, et seq. Any discovery motion must strictly

12 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.

13 C. Burden. The burden of persuasion in any such challenge proceeding shall

14 be on the Designating Party. Frivolous challenges, and those made for an improper

15 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)

16 may expose the Challenging Party to sanctions. Unless the Designating Party has

17 waived or withdrawn the confidentiality designation, all parties shall continue to afford

18 the material in question the level of protection to which it is entitled under the Producing

19 Party’s designation until the Court rules on the challenge.

20 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL

21 A. Basic Principles. A Receiving Party may use Protected Material that is

22 disclosed or produced by another Party or by a Non-Party in connection with this Action

23 only for prosecuting, defending, or attempting to settle this Action. Such Protected

24 Material may be disclosed only to the categories of persons and under the conditions

25 described in this Order. When the Action has been terminated, a Receiving Party must

26 comply with the provisions of Section XV. below (FINAL DISPOSITION).

27

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

2 location and in a secure manner that ensures that access is limited to the persons

3 authorized under this Order.

4 B. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

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

6 may disclose any information or item designated “CONFIDENTIAL” only to:

7 1. the Receiving Party’s Outside Counsel of Record in this Action, as

8 well as employees of said Outside Counsel of Record to whom it is reasonably

9 necessary to disclose the information for this Action;

10 2. the officers, directors, and employees (including House Counsel) of

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

12 3. Experts (as defined in this Order) of the Receiving Party to whom

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

14 “Acknowledgment and Agreement to Be Bound by Protective Order” (Exhibit A);

15 4. the Court and its personnel;

16 5. court reporters and their staff;

17 6. professional jury or trial consultants, mock jurors, and Professional

18 Vendors to whom disclosure is reasonably necessary for this Action and who have

19 signed the “Acknowledgment and Agreement to Be Bound by Protective Order”

20 (Exhibit A);

21 7. the author or recipient of a document containing the information or

22 a custodian or other person who otherwise possessed or knew the information;

23 8. during their depositions, witnesses, and attorneys for witnesses, in

24 the Action to whom disclosure is reasonably necessary provided: (1) the deposing party

25 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will

26 not be permitted to keep any confidential information unless they sign the

27 “Acknowledgment and Agreement to Be Bound by Protective Order” (Exhibit A),

28 unless otherwise agreed by the Designating Party or ordered by the Court. Pages of

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1 transcribed deposition testimony or exhibits to depositions that reveal Protected

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

3 anyone except as permitted under this Stipulated Protective Order; and

4 9. any mediator or settlement officer, and their supporting personnel,

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

6 C. Protected Material Subpoenaed Or Ordered Produced In Other Litigation

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

8 compels disclosure of any information or items designated in this Action as

9 “CONFIDENTIAL,” that Party must:

10 1. promptly notify in writing the Designating Party. Such notification

11 shall include a copy of the subpoena or court order;

12 2. promptly notify in writing the party who caused the subpoena or

13 order to issue in the other litigation that some or all of the material covered by the

14 subpoena or order is subject to this Protective Order. Such notification shall include a

15 copy of this Stipulated Protective Order; and

16 3. cooperate with respect to all reasonable procedures sought to be

17 pursued by the Designating Party whose Protected Material may be affected.

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

19 subpoena or court order shall not produce any information designated in this action as

20 “CONFIDENTIAL” before a determination by the court from which the subpoena or

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

22 Designating Party shall bear the burden and expense of seeking protection in that court

23 of its confidential material and nothing in these provisions should be construed as

24 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive

25 from another court.

26 ///

27 ///

28 ///

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1 IX. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED

IN THIS LITIGATION

2

3 A. The terms of this Order are applicable to information produced by a Non-

4 Party in this Action and designated as “CONFIDENTIAL.” Such information produced

5 by Non-Parties in connection with this litigation is protected by the remedies and relief

6 provided by this Order. Nothing in these provisions should be construed as prohibiting

7 a Non-Party from seeking additional protections.

8 B. In the event that a Party is required, by a valid discovery request, to

9 produce a Non-Party’s confidential information in its possession, and the Party is

10 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential

11 information, then the Party shall:

12 1. promptly notify in writing the Requesting Party and the Non-Party

13 that some or all of the information requested is subject to a confidentiality agreement

14 with a Non-Party;

15 2. promptly provide the Non-Party with a copy of the Stipulated

16 Protective Order in this Action, the relevant discovery request(s), and a reasonably

17 specific description of the information requested; and

18 3. make the information requested available for inspection by the Non-

19 Party, if requested.

20 C. If the Non-Party fails to seek a protective order from this Court within

21 fourteen (14) days of receiving the notice and accompanying information, the Receiving

22 Party may produce the Non-Party’s confidential information responsive to the discovery

23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall not

24 produce any information in its possession or control that is subject to the confidentiality

25 agreement with the Non-Party before a determination by the Court. Absent a court order

26 to the contrary, the Non-Party shall bear the burden and expense of seeking protection

27 in this Court of its Protected Material.

28 ///

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1 X. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

3 Protected Material to any person or in any circumstance not authorized under this

4 Stipulated Protective Order, the Receiving Party must immediately (1) notify in writing

5 the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve

6 all unauthorized copies of the Protected Material, (3) inform the person or persons to

7 whom unauthorized disclosures were made of all the terms of this Order, and (4) request

8 such person or persons to execute the “Acknowledgment and Agreement to Be Bound

9 by Protective Order” that is attached hereto as Exhibit A.

10 XI. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

11

12 When a Producing Party gives notice to Receiving Parties that certain

13 inadvertently produced material is subject to a claim of privilege or other protection,

14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

16 may be established in an e-discovery order that provides for production without prior

17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

18 parties reach an agreement on the effect of disclosure of a communication or

19 information covered by the attorney-client privilege or work product protection, the

20 parties may incorporate their agreement in the stipulated protective order submitted to

21 the Court.

22 XIII. MISCELLANEOUS

23 A. Right to Further Relief. Nothing in this Order abridges the right of any

24 person to seek its modification by the Court in the future.

25 B. Right to Assert Other Objections. By stipulating to the entry of this

26 Protective Order, no Party waives any right it otherwise would have to object to

27 disclosing or producing any information or item on any ground not addressed in this

28 //

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1 Stipulated Protective Order. Similarly, no Party waives any right to object on any

2 ground to use in evidence of any of the material covered by this Protective Order.

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

4 Protected Material must comply with Civil Local Rule 79-5. Protected Material may

5 only be filed under seal pursuant to a court order authorizing the sealing of the specific

6 Protected Material at issue; good cause must be shown in the request to file under seal.

7 If a Party’s request to file Protected Material under seal is denied by the Court, then the

8 Receiving Party may file the information in the public record unless otherwise

9 instructed by the Court.

10 XIV. INFORMATION SECURITY

11 A. Any person in possession of another party’s CONFIDENTIAL

12 information shall maintain a written information security program that includes

13 reasonable administrative, technical, and physical safeguards designed to protect the

14 security and confidentiality of such CONFIDENTIAL information, protect against any

15 reasonably anticipated threats or hazards to the security of such CONFIDENTIAL

16 information, and protect against unauthorized access to or use of such

17 CONFIDENTIAL information.

18 B. If the Receiving Party discovers a breach of security, including any actual

19 or suspected unauthorized access, relating to another party’s CONFIDENTIAL

20 information, the Receiving Party shall:

21 1. promptly provide written notice to Designating Party of such breach;

22 2. investigate and take reasonable efforts to remediate the effects of the

23 breach, and provide Designating Party with assurances reasonably satisfactory to

24 Designating Party that such breach shall not recur; and

25 3. provide sufficient information about the breach that the Designating Party

26 can reasonably ascertain the size and scope of the breach. If required by any judicial or

27 governmental request, requirement or order to disclose such information, the Receiving

28 Party shall take all reasonable steps to give the Designating Party sufficient prior notice

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1 in order to contest such request, requirement or order through legal means. The

2 Receiving Party agrees to cooperate with the Designating Party or law enforcement in

3 investigating any such security incident. In any event, the Receiving Party shall

4 promptly take all necessary and appropriate corrective action to terminate the

5 unauthorized access.

6 XV. FINAL DISPOSITION

7 After the final disposition of this Action, within sixty (60) days of a written

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

9 Material to the Producing Party or destroy such material. As used in this subdivision,

10 “all Protected Material” includes all copies, abstracts, compilations, summaries, and

11 any other format reproducing or capturing any of the Protected Material. Whether the

12 Protected Material is returned or destroyed, the Receiving Party must submit a written

13 certification to the Producing Party (and, if not the same person or entity, to the

14 Designating Party) by the sixty (60) day deadline that (1) identifies (by category, where

15 appropriate) all the Protected Material that was returned or destroyed and (2) affirms

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

17 or any other format reproducing or capturing any of the Protected Material.

18 Notwithstanding this provision, counsel are entitled to retain an archival copy of all

19 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

20 correspondence, deposition and trial exhibits, expert reports, attorney work product, and

21 consultant and expert work product, even if such materials contain Protected Material.

22 Any such archival copies that contain or constitute Protected Material remain subject to

23 this Protective Order as set forth in Section V. above (DURATION).

24 Any violation of this Order may be punished by any and all appropriate measures

25 including, without limitation, contempt proceedings and/or monetary sanctions.

26

27

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LITTLER MENDELSON, P.C. 4862-1693-6787.1 / 086761-1323

Lo6 s3 A3 2n W 1g6 3e3e .lrs 4edt 4s 3F5 .tlC4ho 3A oS 0r t 09r e 0e 0t 7 1 14 STIPULATED PROTECTIVE

ORDER

Case 2:22-cv-01803-FLA-KS Document 26 Filed 03/03/23 Page 15o0f16 Page ID #:210

1 Once executed by all parties, the Stipulated Protective Order shall be by treated

2 | by the parties as an Order of Court until it is formally approved by the Court.

4 | ITISSOSTIPULATED, THROUGH COUNSEL OF RECORD.

6 Dated: February 28, 2023

7 /s/ Melissa Velez

Tanja Darrow

8 Melissa Velez

Littler Mendelson, P.C.

9 Attorneys for Defendant

10

11

12

Dated: February 28, 2023 /s/ Sherry M. Gregorio

13 Avi Burkwitz

14 Sherry M. Gregorio

Irene Yousefi

Peterson, Bradford, Burkwitz, Gregorio,

15 Burkwitz & Su, LLP

16 Attomeys for Plaintiff

17 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

18

19 | DATED: March 3, 2023 ty mn fs is iain

30 HON. KAREN L. STEVENSON

CHIEF MAGISTRATE JUDGE

21

22

23

24

25

26

27

28

LITTLER MENDELSON, P.cl| 4862-1693-6787.1 / 086761-1323

sce ee 15 STIPULATED PROTECTIVE

ORDER

Case 2:22-cv-01803-FLA-KS Document 26 Filed 03/03/23 Page 16 of 16 Page ID #:211

1 EXHIBIT A

2

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

3

4 RENEE MAXWELL, Case No.: No. 2:22−cv−01803−FLA−KS

5 Plaintiff,

ACKNOWLEDGMENT AND

6 v. AGREEMENT TO BE BOUND BY

PROTECTIVE ORDER

7

AMERICAN AIRLINES, INC., AND

8

DOES 1-50, INCLUSIVE

9

10 Defendant.

11

12 The undersigned hereby acknowledges that he/she having read the Stipulated Protective Order

13 entered in the above-captioned action and attached hereto, understands the terms thereof, and agrees

to be bound by its terms, ensuring that any employees and/or clerical assistants will also abide thereby.

14

The undersigned submits to the jurisdiction of this Court in matters relating to the Protective Order

15

and understands that the terms obligate him/her to use documents designated “CONFIDENTIAL” in

16

accordance with the Protective Order solely for the purposes of the above-captioned action, and not to

17 disclose any such documents or information derived directly therefrom to any other person, firm or

18 concern.

19 The undersigned acknowledges that violation of the Protective Order may result in penalties

for contempt of court.

20

21

Entered into on this _________ day of ______________________, 2023.

22

23

Signature: ______________________________________

24

Print Name: ______________________________________

25

Address: ______________________________________

26

27 ______________________________________

28

LITTLER MENDELSON, P.C. 4862-1693-6787.1 / 086761-1323

Lo6 s3 A3 2n W 1g6 3e3e .lrs 4edt 4s 3F5 .tlC4ho 3A oS 0r t 09r e 0e 0t 7 1 16 STIPULATED PROTECTIVE

ORDER