Raquel Espinoza et al v. Compton Unified School District Police Department et al

Filing 99

STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY by Magistrate Judge Jay C. Gandhi re Joint REQUEST for Protective Order for Governing Discovery 90 . (twdb)

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Martin J. Kaufman, Esq. [CA SBN 155672]
[e-mail]
Eric C. Morris, Esq. [CA SBN 243425]
[e-mail]
THE KAUFMAN LAW FIRM, PC
2300 Westwood Boulevard, 2nd Floor
Los Angeles, California 90046
Tel: [phone]; Fax: [phone]

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Raymond P. Boucher, Esq. [CA SBN 115364]
[e-mail]
Hermez Moreno, Esq. [CA SBN 72009]
[e-mail]
Brian M. Bush [CA SBN 294713]
[e-mail]
KHORRAMI BOUCHER, LLP
444 S. Flower St. – 33rd Floor
Los Angeles, California 90071
Tel: [phone]; Fax: [phone]

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Attorneys for Plaintiffs

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Thomas M. Madruga [CA SBN 160421]
[e-mail]
Matthew P. Kelly [CA SBN 224297]
[e-mail]
Christine Hsu [CA SBN 256408]
[e-mail]
Johnny McNulty [CA SBN 290834]
[e-mail]
OLIVAREZ MADRUGA, P.C.
1100 South Flower Street, Suite 2200
Los Angeles, CA 90015
Tel: [phone]; Fax: [phone]

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Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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RAQUEL ESPINOZA et al.,

)
)
Plaintiffs,
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v.
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COMPTON UNIFIED SCHOOL
)
DISTRICT POLICE DEPARTMENT, )
et al.,
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Defendants.
)
)

Case No.: CV 13-3519 GW (JCGx)
DISCOVERY MATTER
STIPULATED PROTECTIVE
ORDER GOVERNING
DISCOVERY
Complaint Filed: August 14, 2013
Trial Date: March 3, 2015

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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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Plaintiffs Raquel Espinoza, Victor Lopez, J.A., a Minor, by and through his

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Guardian Ad Litem, Jose Alvarado, Catarino Garcia a.k.a. Rufino Garcia a.k.a.

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Candelario Garcia, and Maria Delgado a.k.a. Maria Calleros (collectively

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“Plaintiffs”) and defendants Compton Unified School District (“CUSD”),

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Compton Unified School District Board Of Trustees (“Board”), Compton Unified

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School District Police Department (“School Police”), Board President Micah Ali,

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Superintendent Darin Brawley, Police Chief Hourie Taylor, Officer Porch

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#30126, Officer Guillet #30194, Officer Keith Donahue #30106, Officer Timothy

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Wilson, Officer M. Venegas #30183, Officer T. Wilson, Officer E. Robinson

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#30107, Officer R. Garcia, Officer L. Gray #31149, Officer J. Ford #30182, CSA

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Timothy Pernell Bowdry, CSA Larry Ventress, and CSA Lamar Grady Walker

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(collectively “Defendants”), by and through their respective undersigned counsel

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of record, hereby stipulate and agree to the following terms for “Confidential”

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and “Highly Confidential – Attorneys’ Eyes Only” treatment of certain

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information and materials to be disclosed in discovery in this Litigation, subject

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to the Court’s approval, pursuant to Rule 26 of the Federal Rules of Civil

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Procedure.

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I.

INTRODUCTION AND SCOPE

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This Stipulated Protective Order (“Order”) shall govern the production,

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use, and disclosure of information and material in this Action constituting,

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containing, or disclosing, in whole or in part, “Protected Material” as defined

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herein. This Order shall also apply to all other parties who appear in this Action

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and whose counsel of record have received a copy of this Order and agree in

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writing to be bound by its terms.

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Disclosure and discovery activity in this Action may involve production of

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highly confidential, confidential, private, or personal information for which

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

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prosecuting this Litigation would be warranted. This Order does not confer
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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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

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protection it affords extends only to the limited information or items that are

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entitled under the applicable legal principles to treatment as confidential. This

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Order, as forth in Section 11, below, creates no entitlement to file confidential

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information under seal; Central District of California Civil Local Rule 79-5.1 sets

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

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

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II.

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DEFINITIONS
A.

“Action” or “Litigation”: The above-captioned proceeding entitled

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Raquel Espinoza, et. al. v. Compton Unified School District, et al., Civil

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Action No. CV 13-3519 GW (JCGx), which is pending in the United States

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District Court for the Central District of California, and any action that is

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deemed related or is consolidated or coordinated with it.

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B.

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under standards developed under Federal Rule of Civil Procedure 26(c) or

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other applicable federal or state laws. Counsel shall not designate Discovery

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Material as “Confidential” without first making a good faith determination

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that protection is warranted.

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C.

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party, as well as their support staff.

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D.

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Discovery Material that it produces in disclosures or responses to any

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discovery in this Litigation as “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”

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E.

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medium or manner generated, stored or maintained (including, among other

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things, testimony, transcripts, or tangible things) that are produced or

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generated in disclosures or responses to discovery in this matter.

“Confidential”: Any Discovery Material that qualifies for protection

Counsel: Outside counsel and/or in-house counsel of record for any
Designating Party: A Party or non-party to this Action that designates

Discovery Material: All items or information, regardless of the

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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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F.

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matter pertinent to the claims and defenses raised in this Action who has

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been retained by a Party to this Action or by a Party’s Counsel to serve as an

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expert witness or as a consultant in this Action. This definition includes a

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professional jury or trial consultant retained in connection with this

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Litigation.

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G.

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“Confidential” Discovery Material whose disclosure to another Party or non-

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party would create a substantial risk of serious injury that could not be

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avoided by less restrictive means. The parties agree that the following

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Discovery Material is “Highly Confidential—Attorneys’ Eyes Only” and

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shall receive treatment as such under the terms of this Order: (a) any

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Discovery Material containing any information that identifies the current

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addresses of any of the Plaintiffs or their Guardians Ad Litem; (b) any

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Discovery Material containing any information related to the immigration

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status of, or involvement in any immigration proceedings of, any of the

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Plaintiffs’ or their Guardians Ad Litem, whether past or present; (c) any

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Discovery Material containing any information related to any criminal

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proceedings, past or present, brought against any of the Plaintiffs or their

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Guardians Ad Litem; and (d) any Discovery Material containing any

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information identifying Minor Plaintiff J.A., other than by J.A.’s initials,

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year of birth, or last four digits of his social security number (ref., Fed. R.

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Civ. P. 5.2(a)). Counsel shall not designate Discovery Materials as “Highly

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Confidential – Attorney’s Eyes Only” without first making a good faith

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determination that protection is warranted.

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H.

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employees, consultants, retained experts, and outside counsel (and their

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support staff.

Expert: A person with specialized knowledge or experience of a

“Highly Confidential–Attorney’s Eyes Only”: Extremely sensitive

Party: Any party to this Action, including any officers, directors,

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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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I.

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Discovery Material in this Action.

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J.

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(including, but not limited to, communications and recordings contained in

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testimony, documents, discovery responses, e-mail, and all other media of

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expression) that has been designated “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” The parties will use

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reasonable care to avoid designating as “Protected Material” any document

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or information that is in the public domain or does not fall into any of the

Producing Party: A Party or non-party to this Action that produced
Protected Material: Non-public information or material of any type

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items listed in this subparagraph.

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K.

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support services (e.g., photocopying, videotaping, translating, preparation of

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exhibits or demonstrations, organizing, storing, or retrieving data in any

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form or medium, etc.) and their employees or subcontractors).

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L.

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Producing Party.

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III.

Professional Vendors: Any persons or entities that provide litigation

Receiving Party: A Party that receives Discovery Material from a

SCOPE

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The protections conferred by this Order cover not only Protected Material

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but also any information copied or extracted therefrom, as well as all copies,

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excerpts, summaries, or compilations thereof, plus pre-trial testimony,

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conversations, or presentations by parties or counsel to or in court or in other

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settings that might reveal Protected Material. The Parties shall meet and confer

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regarding the procedures for use of Protected Material at trial and shall move for

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entry of an appropriate protective order governing use at trial.

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IV.

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DURATION
Even after the termination of this Action, the confidentiality obligations

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imposed by this Order shall remain in effect until a Designating Party agrees

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otherwise in writing or a court otherwise directs. The Court shall have jurisdiction
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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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to enforce the terms of this Order for a period of six months after final termination

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of the Action.

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V.

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STATEMENT OF GOOD CAUSE
The Parties agree that good cause exists to enter into this Order in order to

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facilitate the exchange of information and material through discovery.

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Plaintiffs contend that the claims and defenses raised in this Litigation will likely

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require discovery related to pending and past criminal actions, pending and past

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immigration proceedings, and potentially other confidential, private or personal

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information of, or relating to, the Parties. The Plaintiffs further contend that they

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have a privacy interest in such information that outweighs the interest in public

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disclosure and thereby warrants certain protections from such public disclosure as

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set forth herein. While the Defendants do not necessarily agree with the

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Plaintiffs’ contention, and expressly reserve their right to object to any

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designations they contend are improper in the manner set forth below, the Parties

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have stipulated to terms that will allow for designation of information and

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materials as “Confidential” or, where appropriate and necessary only, “Highly

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Confidential–Attorneys’ Eyes Only” in order to facilitate the exchange of

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information and items through discovery in this Action.

The

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On July 2, 2014, the parties met and conferred pursuant to Central District

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of California Local Rule 37-1 prior to the filing of this Order, and agreed that the

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use of the designation “Highly Confidential – Attorneys’ Eyes Only” shall be

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limited to the following: (a) discovery material containing any information which

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identifies the current address of Plaintiffs; (b) any discovery material containing

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any information related to Plaintiffs’ immigration status or proceedings, whether

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past or present; (c) discovery material containing any information related to any

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criminal proceedings, past or present, brought against Plaintiffs; and (d) any

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discovery material containing any information identifying Minor J.A., other than

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by J.A.’s initials, year of birth, or last four digits of his social security number
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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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(ref., Fed. R. Civ. P. 5.2(a)). The Parties expressly reserve the right to amend the

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list of Protected Material designated as “Highly Confidential – Attorneys’ Eyes

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Only” in order to add categories of Protected Material that the Parties may be

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obligated to produce during the course of discovery and that meet the definition

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of “Highly Confidential–Attorney’s Eyes Only” as set forth above. The right to

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make such amendments shall be subject to the meet and confer requirements set

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forth in Central District of California Local Rule 37-1.

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VI.

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DESIGNATING PROTECTED MATERIAL
A.

Exercise of Restraint and Care in Designating Material for Protection:

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Each Designating Party must take care to limit any designation to specific

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Discovery Material that qualifies under the appropriate standards. A Designating

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Party must take care to designate for protection only those parts of Discovery

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Material so that other portions of the same for which protection is not warranted

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are not swept unjustifiably within the ambit of this Order. Mass, indiscriminate,

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or routine designations are prohibited. Designations that are shown to be clearly

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unjustified, or that have been made for any improper purpose (e.g., to

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unnecessarily encumber or retard the case development process, or to impose

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unnecessary expenses and burdens on other Parties) may expose the Designating

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Party to potential sanctions.

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If it comes to a Designating Party’s attention that Discovery Material it

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designated for protection does not qualify for protection under the terms of this

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Order, or do not qualify for the level of protection initially asserted under the

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terms of this Order, that Designating Party must promptly notify all other Parties

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that it is withdrawing the mistaken designation.

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B.

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Except as otherwise provided in this Order, or as otherwise stipulated or

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ordered, Discovery Material that qualifies for protection under this Order must be

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clearly designated before the Discovery Material is disclosed or produced.

Manner and Timing of Designations:

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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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C.

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For Discovery Material that is in documentary form (apart from transcripts

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of depositions or of other pre-trial proceedings), the Producing Party must affix

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the legend “Confidential” or “Highly Confidential –Attorneys’ Eyes Only” at the

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bottom of each page that contains Protected Material. If only a portion or portions

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of the Discovery Material on a page qualifies for protection, the Producing Party

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

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markings in the margins) and must specify, for each portion, the level of

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protection being asserted (either “Confidential” or “Highly Confidential—

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Requirements for Designations in Conformity With this Order:

Attorneys’ Eyes Only”).

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For Discovery Material that is testimony given in deposition or in any other

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pre-trial proceedings, the Party or non-party offering or sponsoring the testimony

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identify on the record, before the close of the deposition, hearing, or other pre-

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trial proceeding, all protected testimony, and further specify any portions of the

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testimony that qualify as “Highly Confidential—Attorneys’ Eyes Only.” When it

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is impractical to identify separately each portion of the testimony that is entitled

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to protection, and when it appears that substantial portions of the testimony may

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qualify for protection, the Party or non-party that sponsors, offers, or gives the

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testimony may invoke on the record before the deposition or proceeding is

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concluded a right to have up to 20 days from the date of receipt of the transcript

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to identify the specific portions of the testimony as to which protection is sought

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and to specify that level of protection being asserted (“Confidential” or “Highly

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Confidential—Attorneys’ Eyes Only”). Only those portions of the testimony that

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are appropriately designated for protection within the 20 days shall be covered by

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the provisions of this Order. Transcript pages containing Protected Material must

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be separately bound by the court reporter, who must affix to the top of each such

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page the legend “Confidential” or “Highly Confidential—Attorneys’ Eyes Only”

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as instructed by the Party or non-party offering or sponsoring the witness or
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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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presenting the testimony.

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For Discovery Material that is information produced in some form other

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than documentary or testimony form, and for any other tangible Discovery

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Material, the Producing Party must affix in a prominent place on the exterior of

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the container or containers in which the information or items is stored the legend

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“Confidential” or “Highly Confidential—Attorneys’ Eyes Only.” If only portions

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of the information or item warrant protection, the Producing Party, to the extent

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practicable, shall identify the protected portions, specifying whether they qualify

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as “Confidential” or “Highly Confidential—Attorneys’ Eyes Only.”

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D.

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If timely corrected, an inadvertent failure to designate Discovery Material

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as “Confidential” or “Highly Confidential—Attorneys’ Eyes Only” does not,

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

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Order for such material. If Discovery Material is appropriately designated as

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“Confidential” or “Highly Confidential—Attorneys’ Eyes Only” only after such

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material was initially produced, the Receiving Party, on timely notification of the

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designation, must make reasonable efforts to assure that such designated material

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is treated in accordance with the provisions of this Order.

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VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS

Inadvertent Failures to Designate:

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A.

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Unless a prompt challenge to a Designating Party’s designation is

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necessary to avoid foreseeable substantial unfairness, unnecessary economic

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burdens, or a later significant disruption or delay of the Litigation, a Receiving

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Party does not waive its right to challenge a designation by electing not to mount

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a challenge promptly after the original designation is disclosed.

Timing of Challenges:

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B.

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A Receiving Party that elects to initiate a challenge to a Designating

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Party’s designation of any Discovery Material as “Confidential” or “Highly

Meet and Confer:

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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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Confidential—Attorneys’ Eyes Only” must do so in good faith and must begin

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the process by conferring directly or in writing with counsel for the Designating

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Party. In conferring, the challenging Party must explain the basis for its belief

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that the designation was not proper and must give the Designating Party a

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reasonable opportunity to review the challenged designation of Discovery

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Material, to reconsider the designation, and, if no change in designation is

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offered, to explain the basis for the chosen designation. A challenging Party may

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proceed to the next stage of the challenge process only if it has engaged in this

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meet and confer process first.

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C.

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If a Designating Party elects not to change a designation after considering

Judicial Intervention:

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the basis offered by the challenging Party, the Designating Party must file and

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serve a motion seeking to preserve the designation within 20 days of the

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completion of the meet and confer process. Each such motion must be

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accompanied by a competent declaration that affirms that the movant has complied

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with the meet and confer requirements imposed in the preceding paragraph and

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under the Local Rules. The burden of persuasion on any such motion shall be on

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the Designating Party. Until the Court rules on the motion, all parties shall

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continue to afford the designated Discovery Material in question the level of

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protection to which it is entitled under the Designating Party’s designation.

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VIII. ACCESS TO AND USE OF PROTECTED MATERIAL

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A.

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A Receiving Party may use Protected Material that is disclosed or produced

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by another Party or by a non-party in connection with this Litigation only for

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

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

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conditions described in this Order. When the Action has terminated, a Receiving

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Party must comply with the provisions of the section below setting forth terms for

Basic Principles:

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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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final disposition.

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

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

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authorized under this Order.

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Nothing in this Order restricts the right of the Designating Party to make

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such use or disclosure of its own Discovery Material that has been designated

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“Confidential” or “Highly Confidential—Attorneys’ Eyes Only” in this Action as

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it otherwise is entitled to make. In addition, a Designating Party does not waive

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the classification of its own material and/or information as “Confidential” or

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“Highly Confidential—Attorneys’ Eyes Only” if such Designating Party

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discloses such information to non-parties for any reason. However, if the

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Disclosing Party discloses any documents or materials that are otherwise found in

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the public domain, the classification is waived by the Designating Party.

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B.

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Unless otherwise ordered by a Court or permitted in writing by the

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

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designated “Confidential” only to:

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Disclosure of Discovery Material Designated as “Confidential”:

1. A Receiving Party’s Counsel in this Action, as well as any

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employees of said Counsel to whom it is reasonably necessary

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to disclose the information for this Litigation;

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2. A Receiving Party and any of the Receiving Party’s officers,

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directors, and employees to whom disclosure is reasonably

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necessary for this Litigation and who signed Exhibit A;

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3. Experts of the Receiving Party to whom disclosure is

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reasonably necessary for this Litigation and who signed Exhibit

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A;

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4. The Court and its staff;

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5. Court reporters and their staff, and any Professional Vendors to
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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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whom disclosure is reasonably necessary for this Litigation and

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who have signed Exhibit A;

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6. Any witnesses in the Action during their deposition to whom

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disclosure is reasonably necessary and have signed Exhibit A.

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7. The author or the original source of the Discovery Material that

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is designated “Confidential.”

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C.

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Confidential—Attorneys’ Eyes Only”:

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Unless otherwise ordered by a Court or permitted in writing by the

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Designating Party, a Receiving Party may disclose any Discovery Material

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designated as “Highly Confidential—Attorneys’ Eyes Only” only to:

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Disclosure of Discovery Material that is Designated “Highly

1. A Receiving Party’s Counsel in this Action, as well as any

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employees of said Counsel to whom it is reasonably necessary

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to disclose the information for this Litigation;

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2. Experts of the Receiving Party to whom disclosure is

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reasonably necessary for this Litigation and who signed Exhibit

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A;

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3. The Court and its staff;

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4. Court reporters and their staff, and any Professional Vendors to

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whom disclosure is reasonably necessary for this Litigation and

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who have signed Exhibit A;

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5. The author or the original source of the Discovery Material that

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is designated “Highly Confidential—Attorneys’ Eyes Only.”

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IX.

PROTECTED MATERIAL SUBPOENAED OR ORDERED

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PRODUCED IN OTHER LITIGATION

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If a Receiving Party is served with a subpoena or an order issued in any

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other litigation or matter that would compel disclosure of any information or

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items designated in this Action as “Confidential” or “Highly Confidential—
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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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Attorneys’ Eyes Only,” the Receiving Party must promptly notify the Designating

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Party upon receipt, and in no event any later than five (5) business days of

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receipt, in writing (by fax or e-mail, if possible), of the receipt of the subpoena or

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order and enclose a copy of the same for the Designating Party’s review. It shall

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be the responsibility of the Designating Party to contact the subpoenaing party or

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court, where an order is issued, to alert them of the existence of this Order. The

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Designating Party shall bear the burdens and expenses of seeking protection in

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the court from which the subpoena or order issued of its right to protection of the

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Protected Material from disclosure under the terms of this Order. Nothing in this

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provision shall be construed as authorizing or encouraging a Receiving Party to

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disobey a lawful directive from another court. Until a Designating Party seeks a

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protective order from the appropriate court from which the subpoena or order

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issued and serves timely notice of the same to the Receiving Party prior to the

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production date specified in the subpoena or order, the Receiving Party may, in

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its own discretion, comply with the subpoena or order.

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X.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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disclosed Protected Material to any person or in any circumstance not authorized

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under this Protective Order, the Receiving Party must immediately: (a) notify in

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writing the Designating Party of the unauthorized disclosures; (b) use best efforts

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to retrieve all copies of the Protected Material; (c) inform any person or entity to

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whom unauthorized disclosure of Protected Material was made of the existence of

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this Order and provide a copy of the same; and (d) request that such person or

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entity execute Exhibit A, as appropriate.

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XI.

SUBMISSION OF PROTECTED MATERIAL TO THE COURT

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Without written permission from the Designating Party or a court order

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secured after appropriate notice to all interested Parties or non-parties, a Party

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may not file in the public record in this Action any Protected Material. The
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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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Parties agree to follow the procedures set forth under Central District Local Rule

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79-5 and any other applicable Local Rules or Court Orders or procedures for

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lodging and/or other submission of Protected Material in any pre-trial proceeding.

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The Designating Party maintains the burden of justifying any request to seal

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Protected Material from the public record, regardless of the party that submits the

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Protected Material under the applicable rules, orders or procedures.

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XII. FINAL DISPOSITION

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Unless a Designating Party agrees in writing or the Parties are ordered

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otherwise by the Court, each Receiving Party must return all Protected Material

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to the Producing Party, or destroy the same, within sixty (60) days of the final

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termination of this Action and provide written certification of such return or

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destruction to the Designating Party. As used in this section, “all Protected

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Material” includes all copies, abstracts, compilations, summaries or any other

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form of reproducing or capturing any of the Protected Material. Notwithstanding

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the sixty (60) day return or destruction requirement, all Counsel are entitled to

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retain any archival copy of all pleadings, motion papers, transcripts, including

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deposition

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correspondence, attorney client privileged communications or attorney work

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product, even if such material includes or references Protected Material. Any

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such archival copies that contain or constitute Protected Material under the terms

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of this Order remain subject to this Protective Order as set forth above in the

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section discussing duration.

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XIII. MISCELLANEOUS PROVISIONS

transcripts

and

any

exhibits

thereto,

legal

memoranda,

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A.

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electronic mail to Counsel. The date by which a party to this Action

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receiving the notice shall respond, or otherwise take Action, shall be

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computed from the date indicating that the facsimile was received. Any of

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the notice requirements herein may be waived in whole or in part, but only

Notice: All notices required by this Order are to be served via

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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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in writing signed by an attorney for the party designating Discovery Material

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under this Order.

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B.

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

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C.

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Party’s right to object to disclosure or production of any Discovery Material

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on any ground not addressed in this Order. Similarly, no Party or non-party

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waives any right to object on any ground to the proposed introduction into

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evidence of any of the Protected Material covered by this Order.

Right to Further Relief: Nothing in this Order abridges the right of any
Right to Assert Objections: The entry of this Order does not affect any

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D.

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public policy and other considerations. The Court may modify this Order

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sua sponte in the interests of justice.

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FOR GOOD CAUSE, IT IS SO STIPULATED.

Modification: This Order is subject to further court orders based upon

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Dated: August 5, 2014

KHORRAMI BOUCHER, LLP

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By: /s/ Brian M. Bush
Brian M. Bush

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THE KAUFMAN LAW FIRM, P.C.
Martin J. Kaufman
Eric C. Morris

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Attorneys for Plaintiffs

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Dated: August 5, 2014

OLIVAREZ MADRUGA, P.C.

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By: /s/ Matthew P. Kelly
Thomas M. Madruga
Matthew P. Kelly
Christine Hsu
Johnny McNulty
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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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Attorneys for Defendants

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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Dated: August 05, 2014
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_____________________________
U.S. MAGISTRATE JUDGE
JAY C. GANDHI

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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY

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EXHIBIT A

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WRITTEN ACKNOWLEDGEMENT TO ABIDE BY THE TERMS OF THE

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STIPULATION AND ORDER REGARDING CONFIDENTIALITY

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I, __________________________________, do solemnly swear that I have

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received a copy of the Stipulated Protective Order Governing Discovery that the

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Court entered as an Order in Raquel Espinoza, et. al. v. Compton Unified School

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District, et al., Civil Action No. CV 13-3519 GW (JCGx), in the United States

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District Court for the Central District of California, and I hereby agree to be

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bound by its terms and conditions. I recognize that during my participation in the

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Litigation, I may have occasion to read or hear Discovery Material that is

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designated either “Confidential” or possibly “Highly Confidential—Attorneys’

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Eyes Only” and thus subject to protection under the terms of this Order. I agree

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to use any such Protected Material solely in connection with my participation in

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this Litigation and for no other purpose. I hereby submit to the jurisdiction of the

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United States District Court for the Central District of California for the limited

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purpose of enforcing said Stipulated Protective Order Governing Discovery by

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contempt proceedings or other appropriate judicial remedies.

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I am employed by _________________________ and my title is
_______________________ [fill out only if appropriate].
I declare under penalty of perjury under the laws of the United States that
the foregoing is true and correct.
Executed on _____________, 20___, in __________________, State of
____________________.

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DECLARANT

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STIPULATED PROTECTIVE ORDER GOVERNING DISCOVERY