Leticia Solis et al v. City of Los Angeles et al

Filing 35

STIPULATED PROTECTIVE ORDER by Magistrate Judge Patrick J. Walsh. re Stipulation for Protective Order 34 . (sbou)

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1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 CASE NO: CV17-02352 AB (PJWx) LETICIA SOLIS AND MELDARDO SOLIS, as Special Administrators of the Estate of ADRIAN SOLIS, Assigned to Hon. Andre Briotte Jr.; Courtroom 7B Assigned to Magistrate Patrick J. Walsh 13 Plaintiff, 14 vs. 15 16 17 STIPULATED PROTECTIVE ORDER CITY OF LOS ANGELES; SHERWIN VIGILANTE; JUSTIN KOBY and DOE Police Officers 1 through 10, inclusive, 18 Defendants. 19 20 21 22 23 24 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 25 proprietary, or private information for which special protection from public 26 disclosure and from use for any purpose other than prosecuting this litigation may 27 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 28 enter the following Stipulated Protective Order. The parties acknowledge that this 1 1 Order does not confer blanket protections on all disclosures or responses to 2 discovery and that the protection it affords from public disclosure and use extends 3 only to the limited information or items that are entitled to confidential treatment 4 under the applicable legal principles. The parties further acknowledge, as set forth 5 in Section 12.3, below, that this Stipulated Protective Order does not entitle them 6 to file confidential information under seal; Civil Local Rule 79-5 sets forth the 7 procedures that must be followed and the standards that will be applied when a 8 party seeks permission from the court to file material under seal. 9 10 B. GOOD CAUSE STATEMENT 11 The Los Angeles Police Department (“Department”) conducts internal 12 administrative investigations of Officer Involved Uses of Force and Complaint 13 Investigations (hereinafter “Administrative Investigations”). Once an 14 Administrative Investigation is initiated, a formal investigation number is prepared. 15 Such investigations are reviewed by appropriate command officers in the 16 Department. This review has several purposes: (1) to determine whether the 17 involved officers violated any Department policies or procedures; (2) to determine 18 whether administrative discipline and/or retraining of the involved officers is 19 necessary; and (3) to ascertain if police policies and procedures in such areas as 20 supervision, training, tactics, policies, etc. should be modified. Administrative 21 Investigations are an essential aid to providing critical evaluation of Department 22 officers and policies, and to determine the most effective way to serve the citizens 23 of Los Angeles. 24 The Department strives to maintain the confidentiality of an officer's 25 Administrative Investigations, and the information contained therein, in 26 recognition of the protections granted pursuant to California Penal Code §§ 832.5, 27 832.7, and 832.8 and 1040 et al. of the California Evidence Code. Just as officer's 28 personnel package is maintained as confidential, so too are the Administrative 2 1 Investigations involving a particular officer(s). Administrative Investigations, like 2 an officer's personnel package, include information which is both personal in 3 nature and could potentially impact the liberty interests of the involved police 4 officers and/or civilians named within. The information obtained from personnel 5 packages and Administrative Investigations can, and have been used to initiate 6 disciplinary action against officers, as well as evidence in disciplinary proceedings 7 where the officer's conduct was considered to be contrary to Department policy. At 8 this time, the parties have agreed that certain Administrative Investigation 9 information will be provided pursuant to the terms set forth in this Protective 10 Order. As a result, the parties have agreed to this Proposed Protective Order 11 covering these records for the following Good Cause reasons: 12 Administrative Investigations are maintained as confidential reports and are 13 considered part of the individual officers' personnel record. Administrative 14 Investigations include information which is both personal in nature and could 15 potentially impact the liberty interests of the involved police officers and/or 16 civilians named within. The information obtained from Administrative 17 Investigations can and have been used to initiate disciplinary action against officers 18 and as evidence in disciplinary proceedings where the use of force or tactics used 19 were considered to be contrary to Department policy. 20 Unfettered release of Administrative Investigations have the potential for 21 untold negative results. In terms of societal interests, it would inhibit the 22 Department’s ability to frankly engage in critical self-analysis. Public exposure of 23 many Administrative Investigations could severely threaten the safety and well- 24 being of the individuals, their families and associates. Many Administrative 25 Investigations include embarrassing facts. At a minimum, disclosure of an entire 26 Administrative Investigation would cause needless intrusion of privacy rights and 27 have a negative effect on the Department’s effort to conduct these important 28 investigations. Indeed, for all of these reasons, persons interviewed by 3 1 Investigators are advised that their statements are being taken for the confidential 2 use of the Department. 3 The materials and interview statements of Administrative Investigations are 4 maintained in protected files in order to maintain their confidentiality. They are 5 not routinely shown to other city departments. Even then, information which is not 6 clearly relevant to the rationale governing the request is redacted to ensure the 7 utmost regard for the privacy rights of the mentioned within a given report. The 8 reports are not available to the general public except by court order. 9 In each case involving court-ordered disclosure of information from an 10 Administrative Investigation sought in state or federal court, it is Department 11 policy to seek a protective order limiting use of the information to the case at trial 12 and identifying those persons who may properly be granted access to the 13 information. Absent a protective order, it becomes unrealistic to conceive that the 14 large numbers of attorneys, secretaries, law clerks, paralegals and witnesses 15 involved in many cases will be able to maintain proper confidence of personal, 16 private material absent an order which clearly delineates their responsibilities. The 17 orders further request that said records be returned to the Department after the case 18 has terminated, either by final judgment or otherwise. This request serves to 19 ensure that intrusion into the privacy and employment rights of those involved is 20 limited to the particular case in which the facts are relevant. 21 The issuance of an appropriate protective order makes certain that these 22 privacy concerns are not compromised beyond that degree necessary to the issues 23 before the court. Accordingly, on behalf of the Los Angeles Police Department 24 and those persons identified within a given Administrative Investigation, the 25 Defendants respectfully request these procedural protections in the instant case. 26 Accordingly, the parties hereby stipulate that the above-referenced 27 Administrative Investigation documents and items are confidential in nature and is 28 appropriately produced pursuant to a protective order. 4 1 2 3 4 5 6 2. DEFINITIONS 2.1 Action: Leticia Solis, et al. v. City of Los Angeles, et al., United States District Court case no. CV17-02352 AB (PJWx). 2.2 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for 8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 9 the Good Cause Statement. 10 11 12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.5 Designating Party: a Party or Non-Party that designates information or 13 items that it produces in disclosures or in responses to discovery as 14 “CONFIDENTIAL.” 15 2.6 Disclosure or Discovery Material: all items or information, regardless 16 of the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced 18 or generated in disclosures or responses to discovery in this matter. 19 2.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve 21 as an expert witness or as a consultant in this Action. 22 2.8 House Counsel: attorneys who are employees of a party to this Action. 23 House Counsel does not include Outside Counsel of Record or any other outside 24 counsel. 25 26 27 28 2.9 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this Action but are retained to represent or advise a party to this Action 5 1 and have appeared in this Action on behalf of that party or are affiliated with a law 2 firm which has appeared on behalf of that party, and includes support staff. 3 2.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 8 2.13 Professional Vendors: persons or entities that provide litigation 9 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 and their employees and subcontractors. 12 13 2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 14 15 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 16 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 compilations of Protected Material; and (3) any testimony, conversations, or 22 presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the trial 24 judge. This Order does not govern the use of Protected Material at trial. 25 26 27 28 4. DURATION Upon final termination of this litigation in either the United States District Court (Central District of California) or exhaustion of all appeals, all Confidential 6 1 Information and all copies thereof shall be returned to the Los Angeles City 2 Attorney’s Office within thirty (30) calendar days along with written confirmation 3 from Plaintiff’s counsel that all materials are being returned pursuant to the terms 4 of this Stipulation and the District Court’s order on this Stipulation. Since Plaintiff 5 is alleging both federal and state claims, the City of Los Angeles and any 6 individual police officer defendants (including those who may be added as parties 7 to this litigation) object to Plaintiff’s retention, possession, custody and control of 8 the above-referenced Confidential Information in the event the federal claims are 9 dismissed and remaining state law claims are remanded to the Los Angeles County 10 Superior Court (“Superior Court”). These objections are made pursuant to 11 California law, including but not limited to, the Peace Officer’s Bill of Rights, 12 California Evidence Code Sections 1043 and 1045, as well as Haggerty v. Superior 13 Court (2004) 117 Cal.App.4th 1079. In the event that the federal claims in this 14 litigation are dismissed and the remaining state law claims are remanded to the 15 Superior Court, Defendant City and/or any individual police officer defendants 16 (including those who may be added as parties to this litigation) reserve the right to 17 file any and all necessary motions for an order from the Superior Court compelling 18 Plaintiff and/or his counsel to return all or specified portions of the Confidential 19 Information produced by the City of Los Angeles in this litigation. 20 21 22 5. DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 23 Each Party or Non-Party that designates information or items for protection under 24 this Order must take care to limit any such designation to specific material that 25 qualifies under the appropriate standards. The Designating Party must designate for 26 protection only those parts of material, documents, items, or oral or written 27 communications that qualify so that other portions of the material, documents, 28 7 1 items, or communications for which protection is not warranted are not swept 2 unjustifiably within the ambit of this Order. 3 Mass, indiscriminate, or routinized designations are prohibited. Designations 4 that are shown to be clearly unjustified or that have been made for an improper 5 purpose (e.g., to unnecessarily encumber the case development process or to 6 impose unnecessary expenses and burdens on other parties) may expose the 7 Designating Party to sanctions. 8 If it comes to a Designating Party’s attention that information or items that it 9 designated for protection do not qualify for protection, that Designating Party must 10 promptly notify all other Parties that it is withdrawing the inapplicable designation. 11 5.2 Manner and Timing of Designations. Except as otherwise provided in 12 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 14 under this Order must be clearly so designated before the material is disclosed or 15 produced. 16 Designation in conformity with this Order requires: 17 (a) for information in documentary form (e.g., paper or electronic 18 documents, but excluding transcripts of depositions or other pretrial or trial 19 proceedings), that the Producing Party affix at a minimum, the legend 20 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 21 contains protected material. If only a portion or portions of the material on a page 22 qualifies for protection, the Producing Party also must clearly identify the 23 protected portion(s) (e.g., by making appropriate markings in the margins). 24 A Party or Non-Party that makes original documents available for inspection 25 need not designate them for protection until after the inspecting Party has indicated 26 which documents it would like copied and produced. During the inspection and 27 before the designation, all of the material made available for inspection shall be 28 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 8 1 documents it wants copied and produced, the Producing Party must determine 2 which documents, or portions thereof, qualify for protection under this Order. 3 Then, before producing the specified documents, the Producing Party must affix 4 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 5 only a portion or portions of the material on a page qualifies for protection, the 6 Producing Party also must clearly identify the protected portion(s) (e.g., by making 7 appropriate markings in the margins). 8 9 10 (b) for testimony given in depositions that the Designating Party identify the Disclosure or Discovery Material on the record, before the close of the deposition all protected testimony. 11 (c) for information produced in some form other than documentary and for 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 protection, the Producing Party, to the extent practicable, shall identify the 16 protected portion(s). 17 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 18 failure to designate qualified information or items does not, standing alone, waive 19 the Designating Party’s right to secure protection under this Order for such 20 material. Upon timely correction of a designation, the Receiving Party must make 21 reasonable efforts to assure that the material is treated in accordance with the 22 provisions of this Order. 23 24 25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 26 designation of confidentiality at any time that is consistent with the Court’s 27 Scheduling Order. 28 9 1 2 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 3 6.3 The burden of persuasion in any such challenge proceeding shall be 4 on the Designating Party. Frivolous challenges, and those made for an improper 5 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 6 parties) may expose the Challenging Party to sanctions. Unless the Designating 7 Party has waived or withdrawn the confidentiality designation, all parties shall 8 continue to afford the material in question the level of protection to which it is 9 entitled under the Producing Party’s designation until the Court rules on the 10 challenge. 11 12 13 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this 15 Action only for prosecuting, defending, or attempting to settle this Action. Such 16 Protected Material may be disclosed only to the categories of persons and under 17 the conditions described in this Order. When the Action has been terminated, a 18 Receiving Party must comply with the provisions of section 13 below (FINAL 19 DISPOSITION). 20 Protected Material must be stored and maintained by a Receiving Party at a 21 location and in a secure manner that ensures that access is limited to the persons 22 authorized under this Order. 23 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 24 otherwise ordered by the court or permitted in writing by the Designating Party, a 25 Receiving Party may disclose any information or item designated 26 “CONFIDENTIAL” only to: 27 28 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as employees of said Outside Counsel of Record to whom it is reasonably 10 1 necessary to disclose the information for this Action; 2 3 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; 4 (c) Experts (as defined in this Order) of the Receiving Party to whom 5 disclosure is reasonably necessary for this Action and who have signed the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (d) the court and its personnel; 8 (e) court reporters and their staff; 9 (f) professional jury or trial consultants, mock jurors, and Professional 10 Vendors to whom disclosure is reasonably necessary for this Action and who have 11 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 13 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 14 (h) during their depositions, witnesses, and attorneys for witnesses, in the 15 Action to whom disclosure is reasonably necessary provided: (1) the deposing 16 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 17 they will not be permitted to keep any confidential information unless they sign the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 19 agreed by the Designating Party or ordered by the court. Pages of transcribed 20 deposition testimony or exhibits to depositions that reveal Protected Material may 21 be separately bound by the court reporter and may not be disclosed to anyone 22 except as permitted under this Stipulated Protective Order; and 23 (i) any mediator or settlement officer, and their supporting personnel, 24 mutually agreed upon by any of the parties engaged in settlement discussions. 25 /// 26 /// 27 28 11 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 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: 6 7 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 8 (b) 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 11 include a copy of this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be 13 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 the 15 subpoena or court order shall not produce any information designated in this action 16 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. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this Action 21 to disobey a lawful directive from another court. 22 23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 27 produced by Non-Parties in connection with this litigation is protected by the 28 12 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: 7 (1) promptly notify in writing the Requesting Party and the Non-Party 8 that 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 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and 13 14 (3) make the information requested available for inspection by the Non- Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 16 14 days of receiving the notice and accompanying information, the Receiving 17 Party may produce the Non-Party’s confidential information responsive to the 18 discovery request. If the Non-Party timely seeks a protective order, the Receiving 19 Party shall not produce any information in its possession or control that is subject 20 to the confidentiality agreement with the Non-Party before a determination by the 21 court. Absent a court order to the contrary, the Non-Party shall bear the burden and 22 expense of seeking protection in this court of its Protected Material. 23 24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has 26 disclosed Protected Material to any person or in any circumstance not authorized 27 under this Stipulated Protective Order, the Receiving Party must immediately (a) 28 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 13 1 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 2 the person or persons to whom unauthorized disclosures were made of all the terms 3 of this Order, and (d) request such person or persons to execute the 4 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 5 A. 6 7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 8 PROTECTED MATERIAL 9 When a Producing Party gives notice to Receiving Parties that certain 10 inadvertently produced material is subject to a claim of privilege or other 11 protection, the obligations of the Receiving Parties are those set forth in Federal 12 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 13 whatever procedure may be established in an e-discovery order that provides for 14 production without prior privilege review. Pursuant to Federal Rule of Evidence 15 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 16 of a communication or information covered by the attorney-client privilege or 17 work product protection, the parties may incorporate their agreement in the 18 stipulated protective order submitted to the court. 19 20 21 22 23 12. 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. 12.2 Right to Assert Other Objections. By stipulating to the entry of this 24 Protective Order no Party waives any right it otherwise would have to object to 25 disclosing or producing any information or item on any ground not addressed in 26 this Stipulated Protective Order. Similarly, no Party waives any right to object on 27 any ground to use in evidence of any of the material covered by this Protective 28 Order. 14 1 12.3 Filing Protected Material. A Party that seeks to file under seal any 2 Protected Material must comply with Civil Local Rule 79-5. Protected Material 3 may only be filed under seal pursuant to a court order authorizing the sealing of the 4 specific Protected Material at issue. If a Party's request to file Protected Material 5 under seal is denied by the court, then the Receiving Party may file the information 6 in the public record unless otherwise instructed by the court. 7 8 13. 9 FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 4, each 10 Receiving Party must return all Protected Material to the Producing Party or 11 destroy such material in accordance with paragraph 4. As used in this subdivision, 12 “all Protected Material” includes all copies, abstracts, compilations, summaries, 13 and any other format reproducing or capturing any of the Protected Material. 14 Whether the Protected Material is returned or destroyed, the Receiving Party must 15 submit a written certification to the Producing Party (and, if not the same person or 16 entity, to the Designating Party) by the 30 day deadline that (1) identifies (by 17 category, where appropriate) all the Protected Material that was returned or 18 destroyed and (2)affirms that the Receiving Party has not retained any copies, 19 abstracts, compilations, summaries or any other format reproducing or capturing 20 any of the Protected Material. Notwithstanding this provision, Counsel are entitled 21 to retain an archival copy of all pleadings, motion papers, trial, deposition, and 22 hearing transcripts, legal memoranda, correspondence, deposition and trial 23 exhibits, expert reports, attorney work product, and consultant and expert work 24 product, even if such materials contain Protected Material. Any such archival 25 copies that contain or constitute Protected Material remain subject to this 26 Protective Order as set forth in Section 4 (DURATION). 27 /// 28 /// 15 1 14. 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. Any violation of this Order may be punished by any and all appropriate 5 6 7 DATED: October 24, 2017 LAW OFFICE OF GREGORY PEACOCK By: ___________/S/___________________ Gregory Peacock, Esq. Attorney for Plaintiff LETICIA SOLIS, et al. 8 9 10 11 12 DATED: October 24, 2017 13 14 MICHAEL N. FEUER, City Attorney THOMAS H. PETERS, Chief Assist City Attorney CORY M. BRENTE, Supv. Assist. City Attorney By: ______________/S/________________ J. EDWIN RATHBUN, JR. Deputy City Attorney Attorneys for Defendants CITY OF LOS ANGELES, SHERWIN VIGILANTE and JUSTIN KOBY 15 16 17 18 19 20 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 22 23 24 DATED: October 26, 2017 ________________________________ HONORABLE PATRICK J. WALSH United States Chief Magistrate Judge 25 26 27 28 16 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 5 penalty of perjury that I have read in its entirety and understand the Stipulated 6 Protective Order that was issued by the United States District Court for the Central 7 District of California on _____________ in the case of Leticia Solis, et al. v. City 8 of Los Angeles, et al., United States District Court case no. CV17-02352 AB 9 (PJWx). I agree to comply with and to be bound by all the terms of this Stipulated 10 Protective Order and I understand and acknowledge that failure to so comply could 11 expose me to sanctions and punishment in the nature of contempt. I solemnly 12 promise that I will not disclose in any manner any information or item that is 13 subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms 17 of this Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. I hereby appoint __________________________ 19 [print or type full name] of _______________________________________ [print 20 or type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement of 22 this Stipulated Protective Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: _________________________________ 17

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