Jason Kirby v. Juan Navarro et al

Filing 117

ORDER ON STIPULATED PROTECTIVE ORDER by Magistrate Judge Gail J. Standish re Stipulation for Protective Order 116 . (ec)

1
2
3
4
5
6
7
8

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

9
10

CASE NO.: CV14-09161 PSG (GJS)

JASON KIRBY,

11

v.

13
14
15

(PROPOSED) ORDER ON
STIPULATED PROTECTIVE
ORDER

Plaintiff,

12

Action Filed: December 19, 2014
Trial Date: None Set

COUNTY OF LOS ANGELES AND
JUAN NAVARRO

16

Defendants.

17
18

PURSUANT TO THE STIPULATION of the parties and good cause

19
20

therefore, it is hereby ordered:

21
22
23
24

1.

A. PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve the production of confidential,

proprietary or private information for which special protection from public

25
26
27

disclosure and from use for any purpose other than prosecuting this litigation may
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

28
-1(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

enter the following Stipulated Protective Order. The parties acknowledge that this
Order does not confer blanket protections on all disclosures or responses to

3
4

discovery and that the protection it affords from public disclosure and use extends

5

only to the limited information or items that are entitled to confidential treatment

6

under the applicable legal principles.

7
8

B. GOOD CAUSE STATEMENT

9

This action is likely to involve the production of private, confidential and

10

proprietary information for which special protection from public disclosure and

11
12

from use for any purpose other than prosecution of this action is warranted. Such

13

confidential and proprietary materials and information consist of, among other

14

things, the medical and psychiatric records of plaintiff, as well as official

15
16

government information such as, among other things, internal administrative

17

investigations of officer-involved uses of force and internal complaints and

18

external citizen complaints of police misconduct (including information

19
20

implicating privacy rights of third parties), and information otherwise generally

21

unavailable to the public, or which may be privileged or otherwise protected from

22

disclosure under state or federal statutes, court rules, case decisions, or common
23
24

law. Accordingly, to expedite the flow of information, to facilitate the prompt

25

resolution of disputes over confidentiality of discovery materials, to adequately

26
27
28

protect information the parties are entitled to keep confidential, to ensure that the
parties are permitted reasonable necessary uses of such material in preparation for
-2(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

and in the conduct of trial, to address their handling at the end of the litigation, and
serve the ends of justice, a protective order for such information is justified in this

3
4

matter. It is the intent of the parties that information will not be designated as

5

confidential for tactical reasons and that nothing be so designated without a good

6

faith belief that it has been maintained in a confidential, non-public manner, and

7
8

there is good cause why it should not be part of the public record of this case.

9
10

C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
SEAL

11
12
13
14

The parties further acknowledge, as set forth in Section 12.3, below, that
this Stipulated Protective Order does not entitle them to file confidential
information under seal; Local Civil Rule 79-5 sets forth the procedures that must

15
16

be followed and the standards that will be applied when a party seeks permission

17

from the court to file material under seal.

18

There is a strong presumption that the public has a right of access to judicial

19
20

proceedings and records in civil cases. In connection with non-dispositive

21

motions, good cause must be shown to support a filing under seal. See, Kamakana

22

v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v.
23
24

Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v.

25

Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

26
27
28

protective orders require good cause showing), and a specific showing of good
cause or compelling reasons with proper evidentiary support and legal justification,
-3(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

must be made with respect to Protected Material that a party seeks to file under
seal. The parties’ mere designation of Disclosure or Discovery Material as

3
4

CONFIDENTIAL does not—without the submission of competent evidence by

5

declaration, establishing that the material sought to be filed under seal qualifies as

6

confidential, privileged, or otherwise protectable—constitute good cause.

7
8
9
10

Further, if a party requests sealing related to a dispositive motion or trial,
then compelling reasons, not only good cause, for the sealing must be shown, and
the relief sought shall be narrowly tailored to serve the specific interest to be

11
12

protected. See, Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.

13

2010). For each item or type of information, document, or thing sought to be filed

14

or introduced under seal in connection with a dispositive motion or trial, the party

15
16

seeking protection must articulate compelling reasons, supported by specific facts

17

and legal justification, for the requested sealing order. Again, competent evidence

18

supporting the application to file documents under seal must be provided by

19
20
21

declaration.
Any document that is not confidential, privileged, or otherwise protectable

22

in its entirety will not be filed under seal if the confidential portions can be
23
24

redacted. If documents can be redacted, then a redacted version for public

25

viewing, omitting only the confidential, privileged, or otherwise protectable

26
27

portions of the document, shall be filed. Any application that seeks to file

28
-4(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

documents under seal in their entirety should include an explanation of why
redaction is not feasible.

3
4
5
6

2.

DEFINITIONS
2.1

Action: this federal lawsuit, case number CV14-9161 PSG (GJS).

2.2

Challenging Party: a Party or Non-Party that challenges the

7
8
9
10

designation of information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless of

how it is generated, stored or maintained) or tangible things that qualify for

11
12

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

13

the Good Cause Statement.

14

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as

15
16
17
18

their support staff) and Plaintiff in Pro Per.
2.5

Designating Party: a Party or Non-Party that designates information

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

19
20
21

“CONFIDENTIAL.”
2.6

Disclosure or Discovery Material: all items or information, regardless

22

of the medium or manner in which it is generated, stored, or maintained (including,
23
24

among other things, testimony, transcripts, and tangible things), that are produced

25

or generated in disclosures or responses to discovery in this matter.

26
27
28
-5(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

2.7

Expert: a person with specialized knowledge or experience in a

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

3
4
5
6

serve as an expert witness or as a consultant in this Action.
2.8

House Counsel: attorneys who are employees of a party to this

Action. House Counsel does not include Outside Counsel of Record or any other

7
8

outside counsel.

9

2.9

10

Non-Party: any natural person, partnership, corporation,

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

11
12

2.10 Outside Counsel of Record: attorneys who are not employees of a

13

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

14

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

15
16
17
18

firm that has appeared on behalf of that party, and includes support staff.
2.11 Party: any party to this Action, including all of its officers, directors,
employees, consultants, retained experts, and Outside Counsel of Record (and their

19
20

support staffs).

21
22
23
24

2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
2.13

Professional Vendors: persons or entities that provide litigation

25
26

support services (e.g., photocopying, videotaping, translating, preparing exhibits or

27
28
-6(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

demonstrations, and organizing, storing, or retrieving data in any form or medium)
and their employees and subcontractors.

3

2.14 Protected Material: any Disclosure or Discovery Material that is

4
5

designated as “CONFIDENTIAL.”

6

2.15

Receiving Party: a Party that receives Disclosure or Discovery

7
8

Material from a Producing Party.

9

3.

10

SCOPE
The protections conferred by this Stipulation and Order cover not only

11
12

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

13

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

14

compilations of Protected Material; and (3) any testimony, conversations, or

15
16

presentations by Parties or their Counsel that might reveal Protected Material.

17
18

Any use of Protected Material at trial shall be governed by the orders of the
trial judge. This Order does not govern the use of Protected Material at trial.

19
20
21

4.

DURATION
Once a case proceeds to trial, information that was designated as

22

CONFIDENTIAL or maintained pursuant to this protective order used or
23
24

introduced as an exhibit at trial becomes public and will be presumptively

25

available to all members of the public, including the press, unless compelling

26
27
28

reasons supported by specific factual findings to proceed otherwise are made to the
trial judge in advance of the trial. See, Kamakana, 447 F.3d at 1180-81
-7(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

(distinguishing “good cause” showing for sealing documents produced in
discovery from “compelling reasons” standard when merits-related documents are

3
4

part of court record). Accordingly, the terms of this protective order do not extend

5

beyond the commencement of the trial.

6

5.

DESIGNATING PROTECTED MATERIAL

7
8
9
10

5.1

Exercise of Restraint and Care in Designating Material for

Protection. Each Party or Non-Party that designates information or items for
protection under this Order must take care to limit any such designation to specific

11
12

material that qualifies under the appropriate standards. The Designating Party

13

must designate for protection only those parts of material, documents, items or oral

14

or written communications that qualify so that other portions of the material,

15
16

documents, items or communications for which protection is not warranted are not

17

swept unjustifiably within the ambit of this Order.

18

Mass, indiscriminate or routinized designations are prohibited. Designations

19
20

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

21

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

22

impose unnecessary expenses and burdens on other parties) may expose the
23
24
25

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

26
27
28

designated for protection do not qualify for protection that Designating Party must
promptly notify all other Parties that it is withdrawing the inapplicable designation.
-8(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

5.2

Manner and Timing of Designations. Except as otherwise provided in

this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

3
4

stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

5

under this Order must be clearly so designated before the material is disclosed or

6

produced.

7
8
9

Designation in conformity with this Order requires:
(a)

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

10
11

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

12

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

13

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

14
15

contains protected material. If only a portion of the material on a page qualifies for

16

protection, the Producing Party also must clearly identify the protected portion(s)

17

(e.g., by making appropriate markings in the margins).

18
19
20
21

A Party or Non-Party that makes original documents available for inspection
need not designate them for protection until after the inspecting Party has indicated
which documents it would like copied and produced. During the inspection and

22
23
24
25

before the designation, all of the material made available for inspection shall be
deemed “CONFIDENTIAL.” After the inspecting Party has identified the
documents it wants copied and produced, the Producing Party must determine

26
27
28

which documents, or portions thereof, qualify for protection under this Order.
Then, before producing the specified documents, the Producing Party must affix
-9(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

the “CONFIDENTIAL legend” to each page that contains Protected Material. If
only a portion of the material on a page qualifies for protection, the Producing

3
4

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

5

appropriate markings in the margins).

6

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

7
8

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

9

deposition all protected testimony.

10

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

11
12

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

13

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

14

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

15
16

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

17

protected portion(s).

18

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

19
20

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

21

the Designating Party’s right to secure protection under this Order for such

22

material. Upon timely correction of a designation, the Receiving Party must make
23
24

reasonable efforts to assure that the material is treated in accordance with the

25

provisions of this Order.

26
27
28

//
//
-10(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1

6.

2

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

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

3
4

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

5

Scheduling Order.

6

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

7
8

resolution process under Local Rule 37.1 et seq.

9
10

6.3

The burden of persuasion in any such challenge proceeding shall be

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

11
12

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

13

parties) may expose the Challenging Party to sanctions. Unless the Designating

14

Party has waived or withdrawn the confidentiality designation, all parties shall

15
16

continue to afford the material in question the level of protection to which it is

17

entitled under the Producing Party’s designation until the Court rules on the

18

challenge.

19
20
21

7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that

22

is disclosed or produced by another Party or by a Non-Party in connection with this
23
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

26
27
28

the conditions described in this Order. When the Action has been terminated, a
Receiving Party must comply with the provisions of section 13 below (FINAL
-11(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

DISPOSITION). Protected Material must be stored and maintained by a Receiving
Party at a location and in a secure manner that ensures that access is limited to the

3
4
5
6

persons authorized under this Order.
7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

otherwise ordered by the court or permitted in writing by the Designating Party, a

7
8

Receiving Party may disclose any information or item designated

9

“CONFIDENTIAL” only to:

10

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

11
12

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

13

necessary to disclose the information for this Action;

14

(b) the officers, directors, and employees (including House Counsel) of the

15
16

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

17

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

18

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

19
20
21

“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(d) the court and its personnel;

22

(e) court reporters and their staff;
23
24
25

(f) professional jury or trial consultants, mock jurors, and Professional
Vendors to whom disclosure is reasonably necessary for this Action and who have

26
27

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

28
-12(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;

3

(h) during their depositions, witnesses, and attorneys for witnesses, in the

4
5
6

Action to whom disclosure is reasonably necessary provided: (1) the deposing
party requests that the witness sign the form attached as Exhibit 1 hereto; and (2)

7
8

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

9

“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

10

agreed by the Designating Party or ordered by the court. Pages of transcribed

11
12

deposition testimony or exhibits to depositions that reveal Protected Material may

13

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

14

except as permitted under this Stipulated Protective Order; and

15

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

16

17 mutually agreed upon by any of the parties engaged in settlement discussions.
18

8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

19
20

IN OTHER LITIGATION

21

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

22

that compels disclosure of any information or items designated in this Action as
23
24 “CONFIDENTIAL,” that Party must:
25

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

26
27

include a copy of the subpoena or court order;

28
-13(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

(b) promptly notify in writing the party who caused the subpoena or order to
issue in the other litigation that some or all of the material covered by the subpoena

3
4

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

5

of this Stipulated Protective Order; and

6

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

7
8

by the Designating Party whose Protected Material may be affected.

9
10

If the Designating Party timely seeks a protective order, the Party served
with the subpoena or court order shall not produce any information designated in

11
12

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

13

the subpoena or order issued, unless the Party has obtained the Designating Party’s

14

permission. The Designating Party shall bear the burden and expense of seeking

15
16

protection in that court of its confidential material and nothing in these provisions

17

should be construed as authorizing or encouraging a Receiving Party in this Action

18

to disobey a lawful directive from another court.

19
20
21

9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION

22

(a)

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

23
24

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

25

produced by Non-Parties in connection with this litigation is protected by the

26
27
28

remedies and relief provided by this Order. Nothing in these provisions should be
construed as prohibiting a Non-Party from seeking additional protections. (b) In
-14(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

the event that a Party is required, by a valid discovery request, to produce a NonParty’s confidential information in its possession, and the Party is subject to an

3
4

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

5

information, then the Party shall:

6

(1) promptly notify in writing the Requesting Party and the Non-Party that

7
8

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

9

agreement with a Non-Party;

10

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

11
12

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

13

specific description of the information requested; and

14

(3) make the information requested available for inspection by the Non-

15
16

Party, if requested.

17

If the Non-Party fails to seek a protective order from this court within 14

18

days of receiving the notice and accompanying information, the Receiving Party
19
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
23

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

24

confidentiality agreement with the Non-Party before a determination by the court.

25

Absent a court order to the contrary, the Non-Party shall bear the burden and

26
27

expense of seeking protection in this court of its Protected Material.

28
-15(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1

10.

2

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has

3
4

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

5

under this Stipulated Protective Order, the Receiving Party must immediately (a)

6

notify in writing the Designating Party of the unauthorized disclosures, (b) use its

7
8

best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform

9

the person or persons to whom unauthorized disclosures were made of all the terms

10

of this Order, and (d) request such person or persons to execute the

11
12

“Acknowledgment and Agreement to Be Bound,” that is attached hereto as Exhibit

13

A.

14

11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

15
16

PROTECTED MATERIAL

17

When a Producing Party gives notice to Receiving Parties that certain

18

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

19
20

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

21

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

22

whatever procedure may be established in an e-discovery order that provides for
23
24

production without prior privilege review. Pursuant to Federal Rule of Evidence

25

502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

26
27

of a communication or information covered by the attorney-client privilege or

28
-16(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

work product protection, the parties may incorporate their agreement in the
stipulated protective order submitted to the court.

3
4

12.

5
6

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

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

7
8

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

9

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

10

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

11
12

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

13

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

14

Order.

15
16

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

17

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

18

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

19
20

specific Protected Material at issue. If a Party’s request to file Protected Material

21

under seal is denied by the court, then the Receiving Party may file the information

22

in the public record unless otherwise instructed by the court.
23
24
25

13.

FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within

26
27
28

60 days of a written request by the Designating Party, each Receiving Party must
return all Protected Material to the Producing Party or destroy such material. As
-17(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

used in this subdivision, “all Protected Material” includes all copies, abstracts,
compilations, summaries, and any other format reproducing or capturing any of the

3
4

Protected Material. Whether the Protected Material is returned or destroyed, the

5

Receiving Party must submit a written certification to the Producing Party (and, if

6

not the same person or entity, to the Designating Party) by the 60 day deadline that

7
8

(1) identifies (by category, where appropriate) all the Protected Material that was

9

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

10

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

11
12

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

13

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

14

deposition, and hearing transcripts, legal memoranda, correspondence, deposition

15
16

and trial exhibits, expert reports, attorney work product, and consultant and expert

17

work product, even if such materials contain Protected Material. Any such

18

archival copies that contain or constitute Protected Material remain subject to this

19
20

Protective Order as set forth in Section 4 (DURATION).

21

14.

VIOLATION

22

Any violation of this Order may be punished by appropriate measures
23
24

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

25

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

26
27
28

DATED: August 16, 2017

___________________________________
GAIL J. STANDISH
UNITED STATES MAGISTRATE JUDGE
-18-

(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3
4
5
6

I, _____________________________ [print or type full name], of
_________________ [print or type full address], declare under penalty of perjury

7
8

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

9

was issued by the United States District Court for the Central District of California

10

on [date] in the case of Jason Kirby v. County of Los Angeles and Juan Navarro,

11
12

Case Number CV14-9161 PSG (GJS). I agree to comply with and to be bound by

13

all the terms of this Stipulated Protective Order and I understand and acknowledge

14

that failure to so comply could expose me to sanctions and punishment in the

15
16

nature of contempt. I solemnly promise that I will not disclose in any manner any

17

information or item that is subject to this Stipulated Protective Order to any person

18

or entity except in strict compliance with the provisions of this Order.

19
20
21

I further agree to submit to the jurisdiction of the United States District
Court for the Central District of California for enforcing the terms of this

22

Stipulated Protective Order, even if such enforcement proceedings occur after
23
24

termination of this action. I hereby appoint __________________________ [print

25

or type full name] of _______________________________________ [print or

26
27

type full address and telephone number] as my California agent for service of

28
-19(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER

1
2

process in connection with this action or any proceedings related to enforcement of
this Stipulated Protective Order.

3
4

Date: ______________________________________

5

City and State where sworn and signed: _________________________________

6

Printed name: _______________________________

7
8

Signature: __________________________________

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-20(PROPOSED) ORDER ON JOINT STIPULATION FOR PROTECTIVE ORDER