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)

Download PDF
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

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?