even stipulated protective orders 9 || require good cause showing
How later courts described this case
- even stipulated protective orders 9 || require good cause showing
Written by the judges who cited it.
The opinion
1 || ROB BONTA
Attorney General of California
2 || GIAM M. NGUYEN
Supervising Deputy Attorney General
3 || JASON TORRES
Deputy Attomey General
4 || State Bar No. 285997
300 South Spring Street, Suite 1702
5 Los Angeles, CA 90013-1230
Telephone: (213) 269-6182
6 Fax: (916) 761-3641
E-mail: Jason. Torres@doj.ca.gov
7 Attorneys for Defendants C. Burkhammer, J. Stout, and M. Mangayao
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
VICTOR RUIZ,
11 . Case No. 2:21-cv-03300-DSF-RAO
Plaintiff,
12
v. STIPULATED PROTECTIVE
13 ORDER!
CORRECTION OFFICER
14 STOUT, et al.,
15 Defendants.
16
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 to
22 || enter the following Stipulated Protective Order. The parties acknowledge that this
23 || 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
9g || | This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Rozella A. Oliver’s Procedures.
1 B. GOOD CAUSE STATEMENT
2 Defendants C. Burkhammer, J. Stout, and M. Mangayao are producing
3 || documents which may contain confidential internal policies and procedures, which
4 || information and documents are generally unavailable to the public. The disclosure
5 || of this information may jeopardize the security of the operations of the California
6 || Department of Corrections and Rehabilitation or California Men’s Colony.
7 The documents Defendants are producing may also contain personal and
8 || confidential information regarding individuals which information is generally not
9 || available to the public, including third party personal identifying information and
10 || peace officer personnel records. The disclosure of this information to the public
11 || may violate those individuals’ privacy rights.
12 The documents Defendants are producing may also contain investigation
13 || reports, all of which are generally unavailable to the public, and the disclosure of
14 || which could violate individuals’ privacy rights and jeopardize the safety of officers.
15 Accordingly, to expedite the flow of information, to facilitate the prompt
16 || resolution of disputes over confidentiality of discovery materials, to adequately
17 || protect information the parties are entitled to keep confidential, to ensure that the
18 || parties are permitted reasonable necessary uses of such material in preparation for
19 || and in the conduct of trial, to address their handling at the end of the litigation, and
20 || serve the ends of justice, a protective order for such information is justified in this
21 || matter. It is the intent of the parties that information will not be designated as
22 || confidential for tactical reasons and that nothing be so designated without a good
23 || faith belief that it has been maintained in a confidential, non-public manner, and
24 || there is good cause why it should not be part of the public record of this case.
25 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
26 The parties further acknowledge, as set forth in Section 12.3, below, that this
27 || Stipulated Protective Order does not entitle them to file confidential information
28 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
1 || and the standards that will be applied when a party seeks permission from the court
2 || to file material under seal.
3 There is a strong presumption that the public has a right of access to judicial
4 || proceedings and records in civil cases. In connection with non-dispositive motions,
5 || good cause must be shown to support a filing under seal. See Kamakana v. City and
6 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
7 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,
8 || Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
9 || require good cause showing), and a specific showing of good cause or compelling
10 || reasons with proper evidentiary support and legal justification, must be made with
11 || respect to Protected Material that a party seeks to file under seal. The parties’ mere
12 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
13 || without the submission of competent evidence by declaration, establishing that the
14 || material sought to be filed under seal qualifies as confidential, privileged, or
15 || otherwise protectable—constitute good cause.
16 Further, if a party requests sealing related to a dispositive motion or trial, then
17 || compelling reasons, not only good cause, for the sealing must be shown, and the
18 || relief sought shall be narrowly tailored to serve the specific interest to be protected.
19 || See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
20 || each item or type of information, document, or thing sought to be filed or introduced
21 || under seal in connection with a dispositive motion or trial, the party seeking
22 || protection must articulate compelling reasons, supported by specific facts and legal
23 || justification, for the requested sealing order. Again, competent evidence supporting
24 || the application to file documents under seal must be provided by declaration.
25 Any document that is not confidential, privileged, or otherwise protectable in
26 || its entirety will not be filed under seal if the confidential portions can be redacted.
27 || If documents can be redacted, then a redacted version for public viewing, omitting
28 || only the confidential, privileged, or otherwise protectable portions of the document
1 || shall be filed. Any application that seeks to file documents under seal in their
2 || entirety should include an explanation of why redaction is not feasible.
3 | 2. DEFINITIONS
4 2.1 Action: Victor Ruiz v. Correction Officer Stout, et al.
5 2.2 Challenging Party: a Party or Non-Party that challenges the
6 || designation of information or items under this Order.
7 2.3. “CONFIDENTIAL” Information or Items: information (regardless of
8 || how it is generated, stored or maintained) or tangible things that qualify for
9 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in
10 || the Good Cause Statement.
11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
12 || their support staff).
13 2.5 Designating Party: a Party or Non-Party that designates information or
14 || items that it produces in disclosures or in responses to discovery as
15 || “CONFIDENTIAL.”
16 2.6 Disclosure or Discovery Material: all items or information, regardless
17 || of the medium or manner in which it is generated, stored, or maintained (including,
18 || among other things, testimony, transcripts, and tangible things) that are produced or
19 || generated in disclosures or responses to discovery in this matter.
20 2.7 Expert: a person with specialized knowledge or experience in a matter
21 || pertinent to the litigation who has been retained by a Party or its counsel to serve as
22 || an expert witness or as a consultant in this Action.
23 2.8 House Counsel: attorneys who are employees of a party to this Action.
24 || House Counsel does not include Outside Counsel of Record or any other outside
25 || counsel.
26 2.9 Non-Party: any natural person, partnership, corporation, association or
27 || other legal entity not named as a Party to this action.
28 2.10 Outside Counsel of Record: attorneys who are not employees of a
1 || party to this Action but are retained to represent or advise a party to this Action and
2 || have appeared in this Action on behalf of that party or are affiliated with a law firm
3 || that has appeared on behalf of that party, and includes support staff.
4 2.11 Party: any party to this Action, including all of its officers, directors,
5 || employees, consultants, retained experts, and Outside Counsel of Record (and their
6 || support staffs).
7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
8 || Discovery Material in this Action.
9 2.13 Professional Vendors: persons or entities that provide litigation
10 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or
11 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
12 || and their employees and subcontractors.
13 2.14 Protected Material: any Disclosure or Discovery Material that is
14 || designated as “CONFIDENTIAL.”
15 2.15 Receiving Party: a Party that receives Disclosure or Discovery
16 || Material from a Producing Party.
17 || 3. SCOPE
18 The protections conferred by this Stipulation and Order cover not only
19 || Protected Material (as defined above), but also (1) any information copied or
20 || extracted from Protected Material; (2) all copies, excerpts, summaries, or
21 || compilations of Protected Material; and (3) any testimony, conversations, or
22 || presentations by Parties or their Counsel that might reveal Protected Material.
23 Any use of Protected Material at trial shall be governed by the orders of the
24 || trial judge. This Order does not govern the use of Protected Material at trial.
25 || 4. DURATION
26 Even after final disposition of this litigation, the confidentiality obligations
27 || imposed by this Stipulated Protective Order shall remain in effect until a
28 || Designating Party agrees otherwise in writing or a court order otherwise directs.
1 || Final disposition shall be deemed to be the later of (1) dismissed of all claims and
2 || defenses in this Action, with or without prejudice; and (2) final judgment herein
3 || after the completion and exhaustion of all appeals, rehearings, remands, trials, or
4 || reviews of this Action, including the time limits for filing any motions or
5 || applications for extension of time pursuant to applicable law.
6 || 5. DESIGNATING PROTECTED MATERIAL
7 5.1 Exercise of Restraint and Care in Designating Material for Protection.
8 || Each Party or Non-Party that designates information or items for protection under
9 || this Order must take care to limit any such designation to specific material that
10 || qualifies under the appropriate standards. The Designating Party must designate for
11 || protection only those parts of material, documents, items or oral or written
12 || communications that qualify so that other portions of the material, documents, items
13 || or communications for which protection is not warranted are not swept unjustifiably
14 || within the ambit of this Order.
15 Mass, indiscriminate or routinized designations are prohibited. Designations
16 || that are shown to be clearly unjustified or that have been made for an improper
17 || purpose (e.g., to unnecessarily encumber the case development process or to impose
18 || unnecessary expenses and burdens on other parties) may expose the Designating
19 || Party to sanctions.
20 If it comes to a Designating Party’s attention that information or items that it
21 || designated for protection do not qualify for protection, that Designating Party must
22 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
23 5.2 Manner and Timing of Designations. Except as otherwise provided in
24 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
25 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
26 || under this Order must be clearly so designated before the material is disclosed or
27 || produced.
28 Designation in conformity with this Order requires:
1 (a) for information in documentary form (e.g., paper or electronic
2 || documents, but excluding transcripts of depositions or other pretrial or trial
3 || proceedings), that the Producing Party affix at a minimum, the legend
4 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
5 || contains protected material. If only a portion of the material on a page qualifies for
6 || protection, the Producing Party also must clearly identify the protected portion(s)
7 || (e.g., by making appropriate markings in the margins).
8 A Party or Non-Party that makes original documents available for inspection
9 || need not designate them for protection until after the inspecting Party has indicated
10 || which documents it would like copied and produced. During the inspection and
11 || before the designation, all of the material made available for inspection shall be
12 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the
13 || documents it wants copied and produced, the Producing Party must determine which
14 || documents, or portions thereof, qualify for protection under this Order. Then,
15 || before producing the specified documents, the Producing Party must affix the
16 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
17 || portion of the material on a page qualifies for protection, the Producing Party also
18 || must clearly identify the protected portion(s) (e.g., by making appropriate markings
19 || in the margins).
20 (b) for testimony given in depositions that the Designating Party identifies
21 || the Disclosure or Discovery Material on the record, before the close of the
22 || deposition all protected testimony.
23 (c) 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
25 || the exterior of the container or containers in which the information is stored the
26 || legend “CONFIDENTIAL.” If only a portion or portions of the information
27 || warrants protection, the Producing Party, to the extent practicable, shall identify the
28 || protected portion(s).
1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
2 || failure to designate qualified information or items does not, standing alone, waive
3 || the Designating Party’s right to secure protection under this Order for such material.
4 || Upon timely correction of a designation, the Receiving Party must make reasonable
5 || efforts to assure that the material is treated in accordance with the provisions of this
6 || Order.
7 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
9 || designation of confidentiality at any time that is consistent with the Court’s
10 || Scheduling Order.
11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
12 || resolution process under Local Rule 37.1 et seq.
13 6.3. The burden of persuasion in any such challenge proceeding shall be on
14 || 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
16 || parties) may expose the Challenging Party to sanctions. Unless the Designating
17 || Party has waived or withdrawn the confidentiality designation, all parties shall
18 || continue to afford the material in question the level of protection to which it is
19 || entitled under the Producing Party’s designation until the Court rules on the
20 || challenge.
21 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL
22 7.1 Basic Principles. A Receiving Party may use Protected Material that is
23 || disclosed or produced by another Party or by a Non-Party in connection with this
24 || Action only for prosecuting, defending or attempting to settle this Action. Such
25 || Protected Material may be disclosed only to the categories of persons and under the
26 || conditions described in this Order. When the Action has been terminated, a
27 || Receiving Party must comply with the provisions of section 13 below (FINAL
28 || DISPOSITION).
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 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
5 || otherwise ordered by the court or permitted in writing by the Designating Party, a
6 || Receiving Party may disclose any information or item designated
7 || “CONFIDENTIAL” only to:
8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
9 || well as employees of said Outside Counsel of Record to whom it is reasonably
10 || necessary to disclose the information for this Action;7
11 (b) Experts (as defined in this Order) of the Receiving Party to whom
12 || disclosure is reasonably necessary for this Action and who have signed the
13 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14 (d) the court and its personnel;
15 (e) court reporters and their staff;
16 (f) professional jury or trial consultants, mock jurors, and Professional
17 || Vendors to whom disclosure is reasonably necessary for this Action and who have
18 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
19 (g) the author or recipient of a document containing the information or a
20 || custodian or other person who otherwise possessed or knew the information;
21 (h) during their depositions, witnesses, and attorneys for witnesses, in the
22 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party
23 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they
24 || will not be permitted to keep any confidential information unless they sign the
25 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
26 || agreed by the Designating Party or ordered by the court. Pages of transcribed
27
28 veo IS not currently Tepresented but 7.2(a) should apply were Plaintiff to obtain
1 || deposition testimony or exhibits to depositions that reveal Protected Material may
2 || be separately bound by the court reporter and may not be disclosed to anyone except
3 || as permitted under this Stipulated Protective Order; and
4 (i) any mediator or settlement officer, and their supporting personnel,
5 || mutually agreed upon by any of the parties engaged in settlement discussions.
6 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
7 IN OTHER LITIGATION
8 If a Party is served with a subpoena or a court order issued in other litigation
9 || that compels disclosure of any information or items designated in this Action as
10 || “CONFIDENTIAL,” that Party must:
11 (a) promptly notify in writing the Designating Party. Such notification
12 || shall include a copy of the subpoena or court order;
13 (b) promptly notify in writing the party who caused the subpoena or order
14 || to issue in the other litigation that some or all of the material covered by the
15 || subpoena or order is subject to this Protective Order. Such notification shall include
16 || acopy of this Stipulated Protective Order; and
17 (c) cooperate with respect to all reasonable procedures sought to be
18 || pursued by the Designating Party whose Protected Material may be affected.
19 If the Designating Party timely seeks a protective order, the Party served with
20 || the subpoena or court order shall not produce any information designated in this
21 || action as “CONFIDENTIAL” before a determination by the court from which the
22 || subpoena or order issued, unless the Party has obtained the Designating Party’s
23 || permission. The Designating Party shall bear the burden and expense of seeking
24 || protection in that court of its confidential material and nothing in these provisions
25 || should be construed as authorizing or encouraging a Receiving Party in this Action
26 || to disobey a lawful directive from another court.
27 || 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
28 PRODUCED IN THIS LITIGATION
10
1 (a) The terms of this Order are applicable to information produced by a
2 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
3 || produced by Non-Parties in connection with this litigation is protected by the
4 || remedies and relief provided by this Order. Nothing in these provisions should be
5 || construed as prohibiting a Non-Party from seeking additional protections.
6 (b) In the event that a Party is required, by a valid discovery request, to
7 || produce a Non-Party’s confidential information in its possession, and the Party is
8 || subject to an agreement with the Non-Party not to produce the Non-Party’s
9 || confidential information, then the Party shall:
10 (1) promptly notify in writing the Requesting Party and the Non-Party
11 || that some or all of the information requested is subject to a confidentiality
12 || agreement with a Non-Party;
13 (2) promptly provide the Non-Party with a copy of the Stipulated
14 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
15 || specific description of the information requested; and
16 (3) make the information requested available for inspection by the
17 || Non-Party, if requested.
18 (c) If the Non-Party fails to seek a protective order from this court within
19 || 14 days of receiving the notice and accompanying information, the Receiving Party
20 || may produce the Non-Party’s confidential information responsive to the discovery
21 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall
22 || not produce any information in its possession or control that is subject to the
23 || confidentiality agreement with the Non-Party before a determination by the court.
24 || Absent a court order to the contrary, the Non-Party shall bear the burden and
25 || expense of seeking protection in this court of its Protected Material.
26 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
27 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
28 || Protected Material to any person or in any circumstance not authorized under this
11
1 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in
2 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
3 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
4 || persons to whom unauthorized disclosures were made of all the terms of this Order,
5 || and (d) request such person or persons to execute the “Acknowledgment and
6 || Agreement to Be Bound” that is attached hereto as Exhibit A.
7 || 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
8 PROTECTED MATERIAL
9 When a Producing Party gives notice to Receiving Parties that certain
10 || inadvertently produced material is subject to a claim of privilege or other protection,
11 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
12 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever
13 || procedure may be established in an e-discovery order that provides for production
14 || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
15 || (e), insofar as the parties reach an agreement on the effect of disclosure of a
16 || communication or information covered by the attorney-client privilege or work
17 || product protection, the parties may incorporate their agreement in the stipulated
18 || protective order submitted to the court.
19 || 12. MISCELLANEOUS
20 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
21 || abridges the right of any person to seek its modification by the Court in the future.
22 12.2 Right to Assert Other Objections. By stipulating to the entry of this
23 || Protective Order, no Party waives any right it otherwise would have to object to
24 || disclosing or producing any information or item on any ground not addressed in this
25 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
26 || ground to use in evidence of any of the material covered by this Protective Order.
27 12.3 Filing Protected Material. A Party that seeks to file under seal any
28 || Protected Material must comply with Local Civil Rule 79-5. Protected Material
12
1 || may only be filed under seal pursuant to a court order authorizing the sealing of the
2 || specific Protected Material at issue. If a Party’s request to file Protected Material
3 || under seal is denied by the court, then the Receiving Party may file the information
4 || in the public record unless otherwise instructed by the court.
5 || 13. FINAL DISPOSITION
6 After the final disposition of this Action, as defined in paragraph 4, within 60
7 || days of a written request by the Designating Party, each Receiving Party must return
8 || all Protected Material to the Producing Party or destroy such material. As used in
9 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
10 || summaries, and any other format reproducing or capturing any of the Protected
11 || Material. Whether the Protected Material is returned or destroyed, the Receiving
12 || Party must submit a written certification to the Producing Party (and, if not the same
13 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
14 || (by category, where appropriate) all the Protected Material that was returned or
15 || destroyed and (2) affirms that the Receiving Party has not retained any copies,
16 || abstracts, compilations, summaries or any other format reproducing or capturing any
17 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to
18 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
19 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
20 || reports, attorney work product, and consultant and expert work product, even if such
21 || materials contain Protected Material. Any such archival copies that contain or
22 || constitute Protected Material remain subject to this Protective Order as set forth in
23 || Section 4 (DURATION).
24 | /////
25 |} /////
26 | /////
27 | /////
28
13
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 aT [23
7
Victor Ruiz
9 |) In Pro Per
10
1]
DATED: July 28, 2023
12
13
/s/ Jason Torres
14 || Jason Torres
Deputy Attorney General
15 || Attorney for Defendants
16
17
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
18
19
DATED: August 3, 2023
20
"| Rapelln , OC—~
22 || HON. ROZELLA A. OLIVER
United States Magistrate Judge
24
25
26
27
28
14
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
4 || I, [print or type full name], of
5 [print or type full address], declare under penalty of perjury
6 || that I have read in its entirety and understand the Stipulated Protective Order that
7 || was issued by the United States District Court for the Central District of California
8 || on [date] in the case of [insert formal name of the case and the
9 || number and initials assigned to it by the court]. I agree to comply with and to be
10 || bound by all the terms of this Stipulated Protective Order and I understand and
11 || acknowledge that failure to so comply could expose me to sanctions and punishment
12 || in the nature of contempt. I solemnly promise that I will not disclose in any manner
13 || any 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 the
16 || Central District of California for enforcing the terms of this Stipulated Protective
17 || Order, even if such enforcement proceedings occur after termination of this action.
18 || [hereby appoint [print or type full name] of
19 [print or type full address and
20 || telephone number] as my California agent for service of process in connection with
21 || this action or any proceedings related to enforcement of this Stipulated Protective
22 || Order.
23 || Date:
24 || City and State where sworn and signed:
25
26 || Printed name:
27
28 || Signature:
15
CERTIFICATE OF SERVICE
Case Name: Ruiz, Victor v. Stout, et al. No. _2:21-cv-03300-DSF-RAO
I hereby certify that on August 1, 2023, I electronically filed the following documents with the
Clerk of the Court by using the CM/ECF system:
STIPULATED PROTECTIVE ORDER
Participants in the case who are registered CM/ECF users will be served by the CM/ECF system.
I declare under penalty of perjury under the laws of the State of California and the United States
of America the foregoing is true and correct and that this declaration was executed on August 1,
2023, at Los Angeles, California.
R. Hill /s/ R. Hill
Declarant for eFiling Signature
I am employed in the Office of the Attorney General, which is the office of a member of the
California State Bar at which member's direction this service is made. I am 18 years of age or
older and not a party to this matter. I] am familiar with the business practice at the Office of the
Attorney General for collection and processing of correspondence for mailing with the United
States Postal Service. In accordance with that practice, correspondence placed in the internal
mail collection system at the Office of the Attorney General is deposited with the United States
Postal Service with postage thereon fully prepaid that same day in the ordinary course of
business.
I further certify that some of the participants in the case are not registered CM/ECF users. On
August 1, 2023, the foregoing document(s) have been mailed in the Office of the Attorney
General's internal mail system, by First-Class Mail, postage prepaid, or have dispatched it to a
third party commercial carrier for delivery within three (3) calendar days to the following non-
CM/ECF participants:
Victor Ruiz
6247 State Street
Huntington Park, CA 90255
I declare under penalty of perjury under the laws of the State of California and the United States
of America the foregoing is true and correct and that this declaration was executed on August 1,
2023, at Los Angeles, California.
Lg □□
R. Busuego {ZL LM"
Declarant for Service by U.S. Mail EY Signat fe /
LA2021604355/66126719.docx