Samuel C. Cudjoe v. G2 Secure Staff, LLC et al

Filing 24

STIPULATED PROTECTIVE ORDER [CHANGES MADE BY COURT TO PARAGRAPHS 1C, 3, 5B, 8, 9C, 13] by Magistrate Judge Jacqueline Chooljian re: Stipulation for Protective Order 23 . See order for details. (hr)

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Kevin A. Lipeles (Bar No. 244275) Thomas H. Schelly (Bar No. 217285) 2 Julian Bellenghi (Bar No. 129942) LIPELES LAW GROUP, APC 3 880 Apollo Street, Suite 336 El Segundo, CA 90245 4 Telephone: (310) 322-2211 Fax: (310) 322-2252 1 5 Attorneys for Plaintiff Samuel C. Cudjoe 6 7 8 9 10 11 Rafael G. Nendel-Flores, CA Bar No. 223358 Christopher J. Archibald, CA Bar No. 253075 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Park Tower, Suite 1500 695 Town Center Drive Costa Mesa, CA 92626 Telephone: 714.800.7900 Facsimile: 714.754.1298 12 Attorneys for Defendant G2 Secure Staff, LLC 13 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION 16 17 SAMUEL C. CUDJOE, an individual, Plaintiff, 18 19 vs. G2 SECURE STAFF, LLC, a Texas limited liability company; and DOES 1 21 through 100, inclusive, 20 22 23 24 25 26 Defendant. Case No. 2:16-cv-06581 BRO (JCx) [DISCOVERY DOCUMENT: REFERRED TO MAGISTRATE JUDGE JACQUELINE CHOOLJIAN] STIPULATED PROTECTIVE ORDER [CHANGES MADE BY COURT TO PARAGRAPHS 1C, 3, 5B, 8, 9C, 13] Complaint Filed: July 29, 2016 Trial Date: September 19, 2017 District Judge: Hon. Beverly Reid O’Connell Magistrate Judge: Hon. Jacqueline Chooljian 27 CudjoeJCProtOrd.d ocx 28 STIPULATED PROTECTIVE ORDER 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 12 This action is likely to involve trade secrets, development, commercial, 13 financial, technical and/or proprietary information for which special protection from 14 public disclosure and from use for any purpose other than prosecution of this action 15 is warranted. Such confidential and proprietary materials and information consist of, 16 among other things, confidential business or financial information, information 17 regarding 18 development, or commercial information (including information implicating privacy 19 rights of third parties), information otherwise generally unavailable to the public, or 20 which may be privileged or otherwise protected from disclosure under state or 21 federal statutes, court rules, case decisions, or common law. 22 expedite the flow of information, to facilitate the prompt resolution of disputes over 23 confidentiality of discovery materials, to adequately protect information the parties 24 are entitled to keep confidential, to ensure that the parties are permitted reasonable 25 necessary uses of such material in preparation for and in the conduct of trial, to 26 address their handling at the end of the litigation, and serve the ends of justice, a 27 CudjoeJCProtOrd.d ocx B. protective order for such information is justified in this matter. It is the intent of the 28 parties that information will not be designated as confidential for tactical reasons and GOOD CAUSE STATEMENT confidential business practices, or other 1 STIPULATED PROTECTIVE ORDER confidential research, Accordingly, to 1 that nothing be so designated without a good faith belief that it has been maintained 2 in a confidential, non-public manner, and there is good cause why it should not be 3 part of the public record of this case. 4 5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL The parties further acknowledge, as set forth in Section 12C, below, that this 6 Stipulated Protective Order does not entitle them to file confidential information 7 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 8 the standards that will be applied when a party seeks permission from the court to 9 file material under seal. 10 There is a strong presumption that the public has a right of access to judicial 11 proceedings and records in civil cases. In connection with non-dispositive motions, 12 good cause must be shown to support a filing under seal. See Kamakana v. City and 13 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 14 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Wellbon v. Sony Electronics, 15 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 16 good cause showing), and a specific showing of good cause or compelling reasons 17 with proper evidentiary support and legal justification, must be made with respect to 18 Protected Material that a party seeks to file under seal. The parties’ mere designation 19 of Disclosure or Discovery Material as CONFIDENTIAL does not — without the 20 submission of competent evidence by declaration, establishing that the material 21 sought to be filed under seal qualifies as confidential, privileged, or otherwise 22 protectable-constitute good cause. 23 Further, if a party requests sealing related to a dispositive motion or trial, then 24 compelling reasons, not only good cause, for the sealing must be shown, and the 25 relief sought shall be narrowly tailored to serve the specific interest to be protected. 26 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010), cert. 27 CudjoeJCProtOrd.d ocx denied, 562 U.S. 1134 (2011). For each item or type of information, document, or 28 thing sought to be filed or introduced under seal in connection with a dispositive 2 STIPULATED PROTECTIVE ORDER 1 motion or trial, the party seeking protection must articulate compelling reasons, 2 supported by specific facts and legal justification, for the requested sealing order. 3 Again, competent evidence supporting the application to file documents under seal 4 must be provided by declaration. 5 Any document that is not confidential, privileged, or otherwise protectable in 6 its entirety will not be filed under seal if the confidential portions can be redacted. If 7 documents can be redacted, then a redacted version for public viewing, omitting only 8 the confidential, privileged, or otherwise protectable portions of the document, shall 9 be filed. Any application that seeks to file documents under seal in their entirety 10 should include an explanation of why redaction is not feasible. 11 12 13 14 15 16 17 2. DEFINITIONS A. Action: Samuel C. Cudjoe v. G2 Secure Staff, LLC, Case No. 2:16-cv- 06581 BRO (JCx) B. Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. C. “CONFIDENTIAL” Information or Items: information (regardless of 18 how it is generated, stored or maintained) or tangible things that qualify for 19 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 20 Good Cause Statement. 21 22 23 D. Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). E. Designating Party: a Party or Non-Party that designates information or 24 items that it produces in disclosures or in responses to discovery as 25 “CONFIDENTIAL.” 26 27 CudjoeJCProtOrd.d ocx F. Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, 28 3 STIPULATED PROTECTIVE ORDER 1 among other things, testimony, transcripts, and tangible things), that are produced or 2 generated in disclosures or responses to discovery in this matter. G. 3 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to serve as 5 an expert witness or as a consultant in this Action. H. 6 House Counsel: attorneys who are employees of a party to this Action. 7 House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 I. 10 Non-Party: any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. J. 11 Outside Counsel of Record: attorneys who are not employees of a party 12 to this Action but are retained to represent or advise a party to this Action and have 13 appeared in this Action on behalf of that party or are affiliated with a law firm that 14 has appeared on behalf of that party, and includes support staff. K. 15 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 L. 19 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. M. 20 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. N. 24 25 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” O. 26 Receiving Party: a Party that receives Disclosure or Discovery Material 27 CudjoeJCProtOrd.d ocx from a Producing Party. 28 /// 4 STIPULATED PROTECTIVE ORDER 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any deposition testimony, conversations, 6 or presentations by Parties or their Counsel that might reveal Protected Material, 7 other than during a court hearing or at trial. 8 Any use of Protected Material during a court hearing or at trial shall be 9 governed by the orders of the presiding judge. This Order does not govern the use of 10 Protected Material during a court hearing or at trial. 11 12 4. DURATION 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 15 as an exhibit at trial becomes public and will be presumptively available to all 16 members of the public, including the press, unless compelling reasons supported by 17 specific factual findings to proceed otherwise are made to the trial judge in advance 18 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 19 showing for sealing documents produced in discovery from “compelling reasons” 20 standard when merits-related documents are part of court record). Accordingly, the 21 terms of this protective order do not extend beyond the commencement of the trial. 22 23 24 5. DESIGNATING PROTECTED MATERIAL A. Exercise of Restraint and Care in Designating Material for Protection. 25 26 this Order must take care to limit any such designation to specific material that 27 CudjoeJCProtOrd.d ocx Each Party or Non-Party that designates information or items for protection under qualifies under the appropriate standards. The Designating Party must designate for 28 protection only those parts of material, documents, items or oral or written 5 STIPULATED PROTECTIVE ORDER 1 communications that qualify so that other portions of the material, documents, items 2 or communications for which protection is not warranted are not swept unjustifiably 3 within the ambit of this Order. 4 Mass, indiscriminate or routinized designations are prohibited. Designations 5 that are shown to be clearly unjustified or that have been made for an improper 6 purpose (e.g., to unnecessarily encumber the case development process or to impose 7 unnecessary expenses and burdens on other parties) may expose the Designating 8 Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items that it 10 designated for protection do not qualify for protection, that Designating Party must 11 promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 13 B. Manner and Timing of Designations. Except as otherwise provided in this Order (see, e.g., second paragraph of section 5B(i) below), or as otherwise 14 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 15 under this Order must be clearly so designated before the material is disclosed or 16 produced. 17 Designation in conformity with this Order requires: 18 (i) for information in documentary form (e.g., paper or electronic documents, 19 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 20 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 21 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 22 portion of the material on a page qualifies for protection, the Producing Party also 23 must clearly identify the protected portion(s) (e.g., by making appropriate markings 24 in the margins). 25 A Party or Non-Party that makes original documents available for inspection 26 need not designate them for protection until after the inspecting Party has indicated 27 which documents it would like copied and produced. During the inspection and CudjoeJCProtOrd.d ocx 28 before the designation, all of the material made available for inspection shall be 6 STIPULATED PROTECTIVE ORDER 1 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 2 it wants copied and produced, the Producing Party must determine which documents, 3 or portions thereof, qualify for protection under this Order. Then, before producing 4 the specified documents, the Producing Party must affix the “CONFIDENTIAL 5 legend” to each page that contains Protected Material. If only a portion of the 6 material on a page qualifies for protection, the Producing Party also must clearly 7 identify the protected portion(s) (e.g., by making appropriate markings in the 8 margins). (ii) 9 for testimony given in depositions that the Designating Party identifies 10 the Disclosure or Discovery Material on the record, before the close of the deposition 11 all protected testimony. (iii) 12 for information produced in some form other than documentary and for 13 any other tangible items, that the Producing Party affix in a prominent place on the 14 exterior of the container or containers in which the information is stored the legend 15 “CONFIDENTIAL.” If only a portion or portions of the information warrants 16 protection, the Producing Party, to the extent practicable, shall identify the protected 17 portion(s). C. 18 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 failure to designate qualified information or items does not, standing alone, waive 20 the Designating Party’s right to secure protection under this Order for such material. 21 Upon timely correction of a designation, the Receiving Party must make reasonable 22 efforts to assure that the material is treated in accordance with the provisions of this 23 Order. 24 25 26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS A. Timing of Challenges. Any Party or Non-Party may challenge a 27 CudjoeJCProtOrd.d ocx designation of confidentiality at any time that is consistent with the Court’s 28 Scheduling Order. 7 STIPULATED PROTECTIVE ORDER B. 1 2 The Challenging Party shall initiate the dispute resolution process under Local Rule 37-1 et seq. C. 3 4 Meet and Confer. Joint Stipulation. Any challenge submitted to the Court shall be via a joint stipulation pursuant to Local Rule 37-2. D. 5 The burden of persuasion in any such challenge proceeding shall be on 6 the Designating Party. Frivolous challenges, and those made for an improper 7 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 8 parties) may expose the Challenging Party to sanctions. Unless the Designating 9 Party has waived or withdrawn the confidentiality designation, all parties shall 10 continue to afford the material in question the level of protection to which it is 11 entitled under the Producing Party’s designation until the Court rules on the 12 challenge. 13 14 15 7. ACCESS TO AND USE OF PROTECTED MATERIAL A. Basic Principles. A Receiving Party may use Protected Material that is 16 disclosed or produced by another Party or by a Non-Party in connection with this 17 Action only for prosecuting, defending or attempting to settle this Action. Such 18 Protected Material may be disclosed only to the categories of persons and under the 19 conditions described in this Order. 20 Receiving Party must comply with the provisions of section 13 below (FINAL 21 DISPOSITION). When the Action has been terminated, a 22 Protected Material must be stored and maintained by a Receiving Party at a 23 location and in a secure manner that ensures that access is limited to the persons 24 authorized under this Order. 25 B. Disclosure of “CONFIDENTIAL” Information or Items. Unless 26 27 CudjoeJCProtOrd.d ocx otherwise ordered by the court or permitted in writing by the Designating Party, a Receiving 28 “CONFIDENTIAL” only to: Party may disclose any information 8 STIPULATED PROTECTIVE ORDER or item designated 1 (i) the Receiving Party’s Outside Counsel of Record in this Action, as well 2 as employees of said Outside Counsel of Record to whom it is reasonably necessary 3 to disclose the information for this Action; 4 5 6 (ii) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; (iii) Experts (as defined in this Order) of the Receiving Party to whom 7 disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (iv) the court and its personnel; 10 (v) court reporters and their staff; 11 (vi) professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 15 (vii) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 16 (viii) during their depositions, witnesses, and attorneys for witnesses, in the 17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 18 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 19 not be permitted to keep any confidential information unless they sign the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 21 agreed by the Designating Party or ordered by the court. Pages of transcribed 22 deposition testimony or exhibits to depositions that reveal Protected Material may be 23 separately bound by the court reporter and may not be disclosed to anyone except as 24 permitted under this Stipulated Protective Order; and 25 26 (ix) any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 27 CudjoeJCProtOrd.d ocx 28 9 STIPULATED PROTECTIVE ORDER 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: A. 6 7 promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; B. 8 promptly notify in writing the party who caused the subpoena or order 9 to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall include 11 a copy of this Stipulated Protective Order; and C. 12 13 cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with 15 the subpoena or court order shall not produce any information designated in this 16 action as “CONFIDENTIAL” before a determination by the court from which the 17 subpoena or order issued, unless the Party has obtained the Designating Party’s 18 permission, or unless otherwise required by law or court order. The Designating 19 Party shall bear the burden and expense of seeking protection in that court of its 20 confidential material and nothing in these provisions should be construed as 21 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 22 directive from another court. 23 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25 PRODUCED IN THIS LITIGATION 26 A. The terms of this Order are applicable to information produced by a 27 CudjoeJCProtOrd.d ocx Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 28 produced by Non-Parties in connection with this litigation is protected by the 10 STIPULATED PROTECTIVE ORDER 1 remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. 3 B. In the event that a Party is required, by a valid discovery request, to 4 produce a Non-Party’s confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Party’s 6 confidential information, then the Party shall: (i) 7 Promptly notify in writing the Requesting Party and the Non- 8 Party that some or all of the information requested is subject to a confidentiality 9 agreement with a Non-Party. 10 (ii) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and (iii) 13 14 15 make the information requested available for inspection by the Non-Party, if requested. C. If a Non-Party represented by counsel fails to commence the process 16 17 notice and accompanying information or fails contemporaneously to notify the 18 Receiving Party that it has done so, the Receiving Party may produce the Non- 19 Party’s confidential information responsive to the discovery request. 20 unrepresented Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party may 22 produce the Non-Party’s confidential information responsive to the discovery 23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 not produce any information in its possession or control that is subject to the 25 confidentiality agreement with the Non-Party before a determination by the court 26 unless otherwise required by the law or court order. Absent a court order to the 27 CudjoeJCProtOrd.d ocx called for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving the contrary, the Non-Party shall bear the burden and expense of seeking protection in 28 this court of its Protected Material. 11 STIPULATED PROTECTIVE ORDER If an 1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 7 persons to whom unauthorized disclosures were made of all the terms of this Order, 8 and (d) request such person or persons to execute the “Acknowledgment and 9 Agreement to Be Bound” that is attached hereto as Exhibit A. 10 11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 12 PROTECTED MATERIAL 13 When a Producing Party gives notice to Receiving Parties that certain 14 inadvertently produced material is subject to a claim of privilege or other protection, 15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 17 may be established in an e-discovery order that provides for production without prior 18 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 19 parties reach an agreement on the effect of disclosure of a communication or 20 information covered by the attorney-client privilege or work product protection, the 21 parties may incorporate their agreement in the stipulated protective order submitted 22 to the court. 23 24 25 26 27 CudjoeJCProtOrd.d ocx 28 12. MISCELLANEOUS A. Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. B. Right to Assert Other Objections. By stipulating to the entry of this Protective Order, no Party waives any right it otherwise would have to object to 12 STIPULATED PROTECTIVE ORDER 1 disclosing or producing any information or item on any ground not addressed in this 2 Stipulated Protective Order. Similarly, no Party waives any right to object on any 3 ground to use in evidence of any of the material covered by this Protective Order. C. 4 Filing Protected Material. A Party that seeks to file under seal any 5 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 6 only be filed under seal pursuant to a court order authorizing the sealing of the 7 specific Protected Material at issue. If a Party’s request to file Protected Material 8 under seal is denied by the court, then the Receiving Party may file the information 9 in the public record unless otherwise instructed by the court. 10 11 13. FINAL DISPOSITION 12 13 days of a written request by the Designating Party, each Receiving Party must return 14 all Protected Material to the Producing Party or destroy such material. As used in 15 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 16 summaries, and any other format reproducing or capturing any of the Protected 17 Material. Whether the Protected Material is returned or destroyed, the Receiving 18 Party must submit a written certification to the Producing Party (and, if not the same 19 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 20 (by category, where appropriate) all the Protected Material that was returned or 21 destroyed and (2) affirms that the Receiving Party has not retained any copies, 22 abstracts, compilations, summaries or any other format reproducing or capturing any 23 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 24 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 25 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 26 reports, attorney work product, and consultant and expert work product, even if such 27 CudjoeJCProtOrd.d ocx After the final disposition of this Action, as defined in paragraph 4, within 60 materials contain Protected Material. Any such archival copies that contain or 28 constitute Protected Material remain subject to this Protective Order. 13 STIPULATED PROTECTIVE ORDER 1 2 3 14. VIOLATION Any violation of this Order may be punished by appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 8 DATED: January 23, 2017 LIPELES LAW GROUP, APC 9 10 By: /s/ Julian B. Bellenghi Kevin A. Lipeles Thomas H. Schelly Julian Bellenghi 11 12 13 Attorneys for Plaintiff Samuel C. Cudjoe 14 15 DATED: January 23, 2017 16 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 17 18 By: /s/Christopher J. Archibald Rafael G. Nendel-Flores Christopher J. Archibald 19 20 Attorneys for Defendant G2 Secure Staff, LLC 21 22 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED AS MODIFIED. 23 DATED: January 26, 2017 24 25 26 __________/s/__________________________ HON. JACQUELINE CHOOLJIAN United States Magistrate Judge 27 CudjoeJCProtOrd.d ocx 28 14 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, __________________________________ [print or type full name], of 4 ____________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on January 26, 2017 in the case of Samuel C. Cudjoe v. G2 Secure Staff, LLC, Case 8 No. 2:16-cv-06581 BRO (JCx). I agree to comply with and to be bound by all the 9 terms of this Stipulated Protective Order and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information 12 or item that is subject to this Stipulated Protective Order to any person or entity 13 except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of 17 this action. I hereby appoint ______________________________ [print or type full 18 name] of ____________________________________________ [print or type full 19 address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this 21 Stipulated Protective Order. 22 Date: _________________________ 23 City and State where sworn and signed: ____________________________________ 24 25 Printed name: ____________________________ 26 27 Signature: _______________________________ CudjoeJCProtOrd.d ocx 28 28378572.1 15 STIPULATED PROTECTIVE ORDER

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