Opinion

Sebastian Palma v. County of Los Angeles

Court
District Court, C.D. California
Filed
Apr 2, 2024
Cited by
0 cases
Authority
More cited than 16.5%

distinguishing “good cause” showing for sealing documents 13 produced in discovery from “compelling reasons” standard when merits- 14 related documents are part of court record

How later courts described this case

  • distinguishing “good cause” showing for sealing documents 13 produced in discovery from “compelling reasons” standard when merits- 14 related documents are part of court record

Written by the judges who cited it.

The opinion

1 SEKI, NISHIMURA & WATASE, PLC

2 JOSEPH P. ESPOSITO (142785)

jesposito@snw-law.com

3 JANET L. KEUPER (SBN 128417) NOTE: CHANGES MADE BY THE COURT

4 jkeuper@snw-law.com

600 Wilshire Boulevard, Suite 1250

5 Los Angeles, California 90017

6 Tel.: (213) 481-2869 | Fax: (213) 481-2871

7

Attorneys for Defendant COUNTY OF LOS ANGELES

8

UNITED STATES DISTRICT COURT

9

10 CENTRAL DISTRICT OF CALIFORNIA

11

SEBASTIAN PALMA, Case No.: 2:23-cv-06829-AB-JPR

12

13 Plaintiff, (Hon. Judge Andre Birotte, Jr.)

14

vs. STIPULATED PROTECTIVE

15 ORDER

COUNTY OF LOS ANGELES;

16

DEPUTY NAVARRO; and DOES 1

17 through 10 inclusive, Complaint Filed: August 18, 2023

18

Defendants.

19

20 Plaintiff SEBASTIAN PALMA, and Defendant, COUNTY OF LOS

21 ANGELES, by and through their respective counsel, hereby stipulate and

22 agree as follows:

23 1. INTRODUCTION

24 1.1 PURPOSES AND LIMITATIONS

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

26 proprietary or private information for which special protection from public

27

28

1

disclosure and from use for any purpose other than prosecuting this litigation

2

may be warranted.

3

Accordingly, the parties hereby stipulate to and petition the Court to

4

enter the following Stipulated Protective Order. The parties acknowledge

5

that this Order does not confer blanket protections on all disclosures or

6

responses to discovery and that the protection it affords from public

7

disclosure and use extends only to the limited information or items that are

8

entitled to confidential treatment under the applicable legal principles.

9

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

10

that this Stipulated Protective Order does not automatically entitle them to

11

file confidential information under seal and that Local Civil Rule 79-5 sets

12

forth the procedures that must be followed and the standards that will be

13

applied when a party seeks permission from the Court to file material under

14

seal. The parties agree that this protective order does not waive the parties’

15

rights to object to discovery demands or requests for documents and/or

16

information.

17

1.2 GOOD CAUSE STATEMENT

18

This civil action arises out of the arrest of plaintiff, Sebastian Palma

19

on May 9, 2022 by Los Angeles County Sheriff’s deputies. Plaintiff claims

20

he was arrested on a false charge of molesting his ex-girlfriend’s daughter.

21

He further claims that he was denied medical care, missed his arraignment,

22

and that although the District Attorney declined to file charges against

23

Plaintiff on May 11, 2022, he was not released until May 13, 2022 and on

24

May 12, 2022, he was battered by other inmates causing severe pain and

25

injuries.

26

This action is likely to involve confidential, proprietary, official,

27

and/or private law enforcement and police personnel information for which

28

1

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

2

than prosecution of this action may be warranted. Such confidential and

3

proprietary materials and information may consist of, among other things,

4

confidential proprietary information/or private personnel police information,

5

contained in police personnel files, official law enforcement investigative

6

information, information otherwise generally unavailable to the public, or

7

which may be privileged or otherwise protected from disclosure under state

8

or federal statutes, court rules, case decisions, or common law.

9

Additionally, the action is likely to involve confidential information

10

regarding Plaintiff, including medical records, as well as information

11

regarding the allegations of the minor victim.

12

Accordingly, to expedite the flow of information, to facilitate the

13

prompt resolution of disputes over confidentiality of discovery materials, to

14

adequately protect information the parties are entitled to keep confidential,

15

to ensure that the parties are permitted reasonable necessary uses of such

16

material in preparation for and in the conduct of trial, to address their

17

handling at the end of the litigation, and serve the ends of justice, a

18

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

19

of the parties that information will not be designated as confidential for

20

tactical reasons and that nothing be so designated without a good faith belief

21

that it has been maintained as confidential.

22

2. DEFINITIONS

23

2.1 Action: Sebastian Palma v. County of Los Angeles, et al., 2:23-

24

cv-06829-AB-JPR.

25

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

26

designation of information or items under this Order.

27

28

1

2.3 “CONFIDENTIAL” Information or Items: Information

2

(regardless of how it is generated, stored or maintained) or tangible things

3

that a Designating Party believes is entitled to confidential treatment under

4

Federal Rule of Civil Procedure 26(c), and as specified above in the

5

Purposes and Limitations Statement. This also includes (1) any information

6

copied or extracted from the Confidential information; (2) all copies,

7

excerpts, summaries, abstracts or compilations of Confidential information;

8

and (3) any testimony, conversations, or presentations that might reveal

9

Confidential information.

10

2.4 Counsel: Counsel of record for the parties to this civil litigation

11

and their support staff.

12

2.5 Designating Party: A Party or Non-Party that designates

13

information or items that it produces in disclosures or in responses to

14

discovery as “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

17

maintained (including, among other things, testimony, transcripts, and

18

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

19

to discovery in this matter.

20

2.7 Expert: A person with specialized knowledge or experience in

21

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

22

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

23

2.8 Final Disposition: When this Action has been fully and

24

completely terminated by way of settlement, dismissal, trial and/or appeal.

25

2.9 House Counsel: Attorneys other than Counsel (as defined in

26

paragraph 2.4) and who are employees of a party to this Action.

27

28

1

2.10 Non-Party: Any natural person, partnership, corporation,

2

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

3

2.11 Outside Counsel of Record: Attorneys who are not employees

4

of a party to this Action but are retained to represent or advise a party to this

5

Action and have appeared in this Action on behalf of that party or are

6

affiliated with a law firm that has appeared on behalf of that party, and

7

includes support staff.

8

2.12 Party: Any party to this Action, including all of its officers,

9

directors, boards, departments, divisions, employees, consultants, retained

10

experts, and Outside Counsel of Record (and their support staff).

11

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

12

Disclosure or Discovery Material in this Action.

13

2.14 Professional Vendors: Persons or entities that provide

14

litigation support services (e.g., photocopying, videotaping, translating,

15

preparing exhibits or demonstrations, and organizing, storing, or retrieving

16

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

17

2.15 Protected Material: Any Disclosure or Discovery Material

18

that is designated as “CONFIDENTIAL.”

19

2.16 Receiving Party: A Party that receives Disclosure or Discovery

20

Material from a Producing Party.

21

3. SCOPE

22

The protections conferred by this Stipulation and Order cover not only

23

Protected Material (as defined above), but also (1) any information copied or

24

extracted from Protected Material; (2) all copies, excerpts, abstracts,

25

summaries, or compilations of Protected Material; and (3) any deposition

26

testimony, conversations, or presentations by Parties or their Counsel that

27

might reveal Protected Material.

28

1

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

2

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

3

at trial.

4

4. DURATION

5

Once a trial commences in this Action, information that was

6

designated as CONFIDENTIAL or maintained pursuant to this protective

7

order and that is introduced or admitted as an exhibit at trial becomes public

8

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

9

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

10

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

11

Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th

12

Cir. 2006) (distinguishing “good cause” showing for sealing documents

13

produced in discovery from “compelling reasons” standard when merits-

14

related documents are part of court record). Accordingly, the terms of this

15

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

16

5. DESIGNATING PROTECTED MATERIAL

17

5.1 Exercise of Restraint and Care in Designating Material for

18

Protection.

19

Each Party or Non-Party that designates information or items for

20

protection under this Order must take care to limit any such designation to

21

specific material that qualifies under the appropriate standards. To the extent

22

practicable, the Designating Party must designate for protection only those

23

parts of material, documents, items or oral or written communications that

24

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

25

communications for which protection is not warranted are not swept

26

unjustifiably within the ambit of this Order.

27

28

1

Indiscriminate or routinized designations are prohibited. Designations

2

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

3

improper purpose (e.g., to unnecessarily encumber the case development

4

process or to impose unnecessary expenses and burdens on other parties)

5

may expose the Designating Party to sanctions.

6

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

7

that it designated for protection do not qualify for protection, that

8

Designating Party must promptly notify all other Parties that it is

9

withdrawing the inapplicable designation.

10

5.2 Manner and Timing of Designations. Except as otherwise

11

provided in this Order (see, e.g., second paragraph of section 5.2(a) below),

12

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

13

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

14

the material is disclosed or produced.

15

Designation in conformity with this Order requires:

16

(a) for information in documentary form (e.g., paper or electronic

17

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

18

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

19

“CONFIDENTIAL” or words of a similar effect, and that includes the case

20

name and case number (hereinafter “CONFIDENTIAL legend”), to each

21

page that contains protected material. To the extent practicable, if only a

22

portion of the material on a page qualifies for protection, the Producing

23

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

24

appropriate markings in the margins).

25

A Party or Non-Party that makes original documents available for

26

inspection need not designate them for protection until after the inspecting

27

Party has indicated which documents it would like copied and produced.

28

1

During the inspection and before the designation, all of the material made

2

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

3

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

4

the Producing Party must determine which documents, or portions thereof,

5

qualify for protection under this Order. Then, before producing the specified

6

documents, the Producing Party must affix the “CONFIDENTIAL legend”

7

to each page that contains Protected Material. To the extent practicable, if

8

only a portion of the material on a page qualifies for protection, the

9

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

10

making appropriate markings in the margins):

11

(b) for testimony given in depositions that the Designating Party

12

identifies the Disclosure or Discovery Material on the record, before the

13

close of the deposition all protected testimony.

14

(c) for information produced in some form other than documentary

15

and for any other tangible items, that the Producing Party affix in a

16

prominent place on the exterior of the container or containers in which the

17

information is stored the legend

18

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

19

warrants protection, the Producing Party, to the extent practicable, shall

20

identify the protected portion(s).

21

5.3 Inadvertent Failures to Designate. If timely corrected, an

22

inadvertent failure to designate qualified information or items does not,

23

standing alone, waive the Designating Party’s right to secure protection

24

under this Order for such material. Upon timely correction of an inadvertent

25

failure to designate, the Receiving Party must make reasonable efforts to

26

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

27

Order.

28

1

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

2

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

3

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

4

Scheduling Order.

5

6.2 Meet and Confer. The Challenging Party shall initiate the

6

dispute resolution process under Local Rule 37.1 et seq.

7

6.3 The burden of persuasion in any such challenge proceeding

8

shall be on the Designating Party. Frivolous challenges, and those made for

9

an improper purpose (e.g., to harass or impose unnecessary expenses and

10

burdens on other parties) may expose the Challenging Party to sanctions.

11

Unless the Designating Party has waived or withdrawn the confidentiality

12

designation, all parties shall continue to afford the material in question the

13

level of protection to which it is entitled under the Producing Party’s

14

designation until the Court rules on the challenge.

15

7. ACCESS TO AND USE OF PROTECTED MATERIAL

16

7.1 Basic Principles. A Receiving Party may use Protected

17

Material that is disclosed or produced by another Party or by a Non-Party in

18

connection with this Action only for prosecuting, defending or attempting to

19

settle this Action. Such Protected Material may be disclosed only to the

20

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

21

the Action has been terminated, a Receiving Party must comply with the

22

provisions of section 13 below (FINAL DISPOSITION).

23

Protected Material must be stored and maintained by a Receiving

24

Party at a location and in a secure manner that ensures that access is limited

25

to the persons authorized under this Order.

26

7.2 Disclosure of “CONFIDENTIAL” Information or Items.

27

Unless otherwise ordered by the court or permitted in writing by the

28

1

Designating Party, a Receiving Party may disclose any information or item

2

designated “CONFIDENTIAL” only to:

3

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

4

employees of said Counsel of Record to whom it is reasonably necessary to

5

disclose the information for this Action;

6

(b) Experts (as defined in this Order) of the Receiving Party to whom

7

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

8

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

9

(c) the court and its personnel;

10

(d) court reporters and their staff;

11

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

12

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

13

have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

14

A);

15

(f) the author or recipient of a document containing the information or

16

a custodian or other person who otherwise possessed or knew the

17

information;

18

(g) during their depositions, witnesses, and attorneys for witnesses, in

19

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

20

deposing party requests that the witness sign the form attached as Exhibit

21

“A” hereto; and (2) they will not be permitted to keep any confidential

22

information unless they sign the “Acknowledgment and Agreement to Be

23

Bound” (Exhibit “A”), unless otherwise agreed by the Designating Party or

24

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

25

depositions that reveal Protected Material may be separately bound by the

26

court reporter and may not be disclosed to anyone except as permitted under

27

this Stipulated Protective Order;

28

1

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

2

mutually agreed upon by any of the parties engaged in settlement

3

discussions and who have signed the “Acknowledgment and Agreement to

4

Be Bound” (Exhibit A); and

5

(i) the officers, directors, and employees (including House Counsel)

6

of the Receiving Party to whom disclosure is reasonably necessary for this

7

Action.

8

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

9

PRODUCED IN OTHER LITIGATION

10

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

11

litigation that compels disclosure of any information or items designated in

12

this Action as “CONFIDENTIAL,” that Party must:

13

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

14

shall include a copy of the subpoena or court order unless prohibited by law;

15

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

16

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

17

by the subpoena or order is subject to this Protective Order. Such

18

notification shall include a copy of this Stipulated Protective Order; and

19

(c) cooperate with respect to all reasonable procedures sought to be

20

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

21

If the Designating Party timely seeks a protective order in the action

22

in which the subpoena or order was issued, the Party served with the

23

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

24

action as “CONFIDENTIAL” before a determination by the court from

25

which the subpoena or order issued, unless the Party has obtained the

26

Designating Party’s permission. The Designating Party shall bear the burden

27

and expense of seeking protection in that court of its confidential material –

28

1

and nothing in these provisions should be construed as authorizing or

2

encouraging a Receiving Party in this action to disobey a lawful directive

3

from another court.

4

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

5

PRODUCED IN THIS LITIGATION

6

(a) The terms of this Order are applicable to information produced by

7

a Non- Party in this Action and designated as “CONFIDENTIAL.” Such

8

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

9

protected by the remedies and relief provided by this Order. Nothing in these

10

provisions should be construed as prohibiting a Non-Party from seeking

11

additional protections.

12

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

13

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

14

Party is subject to an agreement with the Non-Party not to produce the Non-

15

Party’s confidential information, then the Party shall:

16

(1) promptly notify in writing the Requesting Party and the

17

Non-Party that some or all of the information requested is

18

subject to a confidentiality agreement with a Non-Party;

19

(2) promptly provide the Non-Party with a copy of the

20

Stipulated Protective Order in this Action, the relevant

21

discovery request(s), and a reasonably specific description of

22

the information requested; and

23

(3) make the information requested available for inspection by

24

the Non-Party, if requested.

25

(c) If the Non-Party fails to seek a protective order from this court

26

within 14 days of receiving the notice and accompanying information, the

27

28

1

Receiving Party may produce the Non-Party’s confidential information

2

responsive to the discovery request.

3

If the Non-Party timely seeks a protective order, the Receiving Party

4

shall not produce any information in its possession or control that is subject

5

to the confidentiality agreement with the Non-Party before a determination

6

by the court. Absent a court order to the contrary, the Non-Party shall bear

7

the burden and expense of seeking protection in this court of its Protected

8

Material.

9

10. UNAUTHORIZED DISCLOSURE OF PROTECTED

10

MATERIAL

11

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

12

disclosed Protected Material to any person or in any circumstance not

13

authorized under this Stipulated Protective Order, the Receiving Party must

14

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

15

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

16

Protected Material, (c) inform the person or persons to whom unauthorized

17

disclosures were made of all the terms of this Order, and (d) request such

18

person or persons to execute the “Acknowledgment and Agreement to Be

19

Bound” that is attached hereto as Exhibit A.

20

11. INADVERTENT PRODUCTION OF PRIVILEGED OR

21

OTHERWISE PROTECTED MATERIAL

22

When a Producing Party gives notice to Receiving Parties that certain

23

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

24

protection, the obligations of the Receiving Parties are those set forth in

25

Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended

26

to modify whatever procedure may be established in an e-discovery order

27

that provides for production without prior privilege review. Pursuant to

28

1

Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an

2

agreement on the effect of disclosure of a communication or information

3

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

4

parties may incorporate their agreement in the stipulated protective order

5

submitted to the court provided the Court so allows.

6

12. MISCELLANEOUS

7

12.1 Right to Further Relief. Nothing in this Order abridges the

8

right of any person to seek its modification by the Court in the future.

9

12.2 Right to Assert Other Objections. By stipulating to the entry

10

of this Protective Order, no Party waives any right it otherwise would have

11

to object to disclosing or producing any information or item on any ground

12

not addressed in this Stipulated Protective Order. Similarly, no Party waives

13

any right to object on any ground to use in evidence of any of the material

14

covered by this Protective Order.

15

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

16

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

17

Material may only be filed under seal pursuant to a court order authorizing

18

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

19

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

20

Party may file the information in the public record unless otherwise

21

instructed by the court.

22

13. FINAL DISPOSITION

23

After the final disposition of this Action, as defined in paragraphs 2.8

24

and 4, within 60 days of a written request by the Designating Party, each

25

Receiving Party must return all Protected Material to the Producing Party or

26

destroy such material. As used in this subdivision, “all Protected Material”

27

includes all copies, abstracts, compilations, summaries, and any other format

28

1

reproducing or capturing any of the Protected Material. Whether the

2

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

3

a written certification to the Producing Party (and, if not the same person or

4

entity, to the Designating Party) by the 60 day deadline that (1) identifies (by

5

category, where appropriate) all the Protected Material that was returned or

6

destroyed and (2) affirms that the Receiving Party has not retained any

7

copies, abstracts, compilations, summaries or any other format reproducing

8

or capturing any of the Protected Material. Notwithstanding this provision,

9

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

10

papers, trial, deposition, and hearing transcripts, legal memoranda,

11

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

12

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

13

contain Protected Material. Any such archival copies that contain or

14

constitute Protected Material remain subject to this Protective Order as set

15

forth in Section 4 (DURATION).

16

14. VIOLATION

17

Any willful violation of this Order may be punished by appropriate

18

measures including, without limitation, contempt proceedings and/or

19

monetary sanctions.

20

21

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

22

DATED: March 29, 2024 SEKI, NISHIMURA & WATASE, PLC

23

24

By /s/ JANET L. KEUPER

25

JANET L. KEUPER

26 JOSEPH P. ESPOSITO

Attorneys for Defendant

27

COUNTY OF LOS ANGELES

28

1

2

3 || DATED: March 29, 2024 PLC LAW GROUP, APC

A

5

By: __/s/ NA’SHAUN L. NEAL

6 PETER L. CARR, IV

7 NA’SHAUN L. NEAL

LAUREN K. McRAE

8 Attorneys for Plaintiff

9 SEBASTIAN PALMA

10

11

b FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

13

4 DATED: 4/2/2024

15 ft hrehlotln

16 || HON. JEAN P. ROSENBLUTH

7 United States Magistrate Judge

18

19

20

21

22

23

24

25

26

27

28

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I, _____________________________ [full name], of

4

_________________ [full address], declare under penalty of perjury that I

5

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

6

was issued by the U.S. District Court for the Central District of California on

7

[date] in the case of Sebastian Palma v. County of Los Angeles, et al., 2:23-

8

cv-06829-AB-JPR. I agree to comply with and to be bound by all terms of

9

this Stipulated Protective Order, and I understand and acknowledge that

10

failure to so comply could expose me to sanctions and punishment,

11

including contempt. I solemnly promise that I will not disclose in any

12

manner any information or item that is subject to this Stipulated Protective

13

Order to any person or entity except in strict compliance with the provisions

14

of this Order. I further agree to submit to the jurisdiction of the U.S. District

15

Court for the Central District of California for the purpose of enforcing the

16

terms of this Stipulated Protective Order, even if such enforcement

17

proceedings occur after termination of this action. I hereby appoint

18

__________________________ [full name] of

19

_______________________________________ [full address and telephone

20

number] as my California agent for service of process in connection with

21

this action or any proceedings related to enforcement of this Stipulated

22

Protective Order.

23

Date: ______________________________________

24

City and State where signed: _________________________________

25

Printed name: _______________________________

26

Signature: _________________________________

27

28

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

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.