Robert G. Lindsey et al v. Paul Tanaka et al

Filing 57

PROTECTIVE ORDER by Magistrate Judge Rozella A. Oliver re Stipulation for Protective Order 56 (sbu)

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ANDREW BAUM - State Bar No. 190397
[e-mail]
GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
THE COUNTY OF LOS ANGELES

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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ROBERT G. LINDSEY and CHARLES
G. RODRIGUEZ,
Plaintiff,

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v.

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THE COUNTY OF LOS ANGELES;
PAUL TANAKA; KEVIN STENNIS;
and DOES 1 – 10, INCLUSIVE,

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Defendants.

CASE NO.: 2:17-CV-03886-FMO
(RAOX)
[Hon. Fernando M. Olguin
Courtroom “6D”]
[Discovery Document: Referred To
Magistrate Judge Rozella A. Oliver]
STIPULATION FOR
PROTECTIVE ORDER RE:
CONFIDENTIAL DISCOVERY
MATERIALS

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TRIAL DATE:

January 22, 2019

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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS
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1.

A. PURPOSES AND LIMITATIONS

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Discovery in this action is likely to involve production of confidential,

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proprietary, or private information for which special protection from public disclosure

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and from use for any purpose other than prosecuting this litigation may be warranted.

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Accordingly, the parties hereby stipulate to and petition the Court to enter the

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following Stipulated Protective Order. The parties acknowledge that this Order does

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not confer blanket protections on all disclosures or responses to discovery and that the

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protection it affords from public disclosure and use extends only to the limited

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information or items that are entitled to confidential treatment under the applicable

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legal principles.

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B. GOOD CAUSE STATEMENT

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In this case, plaintiffs are making claims of deprivation of civil rights under 42

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U.S.C. section 1983, Fourth Amendment, Due Process, Brady, Monell, selective

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prosecution, and equal protection violations against the defendants. In discovery,

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Plaintiffs have requested, inter alia, internal investigation reports from the County of

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Los Angeles Sheriff’s Department Internal Criminal Investigation Bureau and

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Internal Affairs Bureau; County of Los Angeles District Attorney files; the District

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Attorney’s Office Justice System Integrity Division files; personnel files of former

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Undersheriff Paul Tanaka and former Deputy District Attorney (now Judge) Kevin

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Stennis; arrest reports; written policies, procedures, and training materials of the Los

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Angeles Sheriff’s Department; and disciplinary information. These documents are

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confidential and/or are not available to the general public, and also contain sensitive

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personal/private information about third parties. Plaintiffs have also requested other

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County of Los Angeles communications concerning the events underlying this case,

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including emails among and between Sheriff’s Department and District Attorney’s

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Office representatives, audio files of interviews and video files. These recordings and

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communications contain information about unrelated matters and third parties.

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Likewise, Plaintiffs may be producing personal and private information regarding
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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS

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Plaintiffs, including, inter alia, medical and/or psychological records, that is not

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otherwise available to the public and are kept confidential.

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The United States Supreme Court has recognized the importance of protective

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orders to safeguard the privacy of individuals. See Seattle Times Co. v. Rhinehart, 467

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U.S. 20, 34-37 (1984). In addition, the public disclosure of confidential and sensitive

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information regarding the workings of the County of Los Angeles Sheriff’s

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Department and the County of Los Angeles District Attorney’s office would

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potentially harm County operations and prevent the County from effectively

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performing the duties to the public. Such public disclosure could endanger the

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security of Sheriff’s Department personnel who perform their duties, as criminals,

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detainees, and arrestees could anticipate Department tactics, thus nullifying their

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effectiveness and threatening the safety of law enforcement personnel. See Kelly v.

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City of San Jose (N.D. Cal. 1987) 114 F.R.D. 653, 666. (“A police department’s

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interest in not permitting the general public to have access to such materials [manuals

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and memoranda on law enforcement policies] must be weighty. Legitimate law

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enforcement efforts could be frustrated, and the lives of officers could be endangered,

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if anyone who wanted to could learn details about how officers are trained to

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accomplish their missions in specific situations.”)

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

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resolution of disputes over confidentiality of discovery materials, to adequately

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protect information the parties are entitled to keep confidential, to ensure that the

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parties are permitted reasonably necessary uses of such material in preparation for and

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in the conduct of trial, to address their handling at the end of the litigation, and serve

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the ends of justice, a protective order for such information is justified in this matter. It

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is the intent of the parties that information will not be designated as confidential for

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tactical reasons, and that nothing be so designated without a good faith belief that it

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has been maintained in a confidential, non-public manner, and there is good cause

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why it should not be part of the public record of this case.
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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS

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C. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER SEAL

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The parties further acknowledge, as set forth in section 12.3, below, that this

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Stipulated Protective Order does not entitle them to file confidential information

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under seal; Local Rule 79-5 sets forth the procedures that must be followed and the

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standards that will be applied when a party seeks permission from the court to file

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material under seal.

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

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

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good cause must be shown to support a filing under seal. See Kamakana v. City and

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County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

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

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187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require a

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good cause showing), and a specific showing of good cause or compelling reasons

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with proper evidentiary support and legal justification, must be made with respect to

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Protected Material that a party seeks to file under seal. The parties’ mere designation

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of Disclosure or Discovery Material as CONFIDENTIAL does not – without the

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submission of competent evidence by declaration, establishing that the material

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sought to be filed under seal qualifies as confidential, privileged, or otherwise

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protectable – constitute good cause.

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Further, if a party requests sealing related to a dispositive motion or trial, then

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compelling reasons, not only good cause, for the sealing must be shown, and the relief

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sought shall be narrowly tailored to serve the specific interest to be protected. See

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Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item

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or type of information, document, or thing sought to be filed or introduced under seal

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in connection with a dispositive motion or trial, the party seeking protection must

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articulate compelling reasons, supported by specific facts and legal justification, for

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the requested sealing order. Again, competent evidence supporting the application to

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file documents under seal must be provided by declaration.
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Any document that is not confidential, privileged, or otherwise protectable in

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its entirety will not be filed under seal if the confidential portions can be redacted. If

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documents can be redacted, then a redacted version for public viewing, omitting only

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the confidential, privileged, or otherwise protectable portions of the document, shall

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be filed. Any application that seeks to file documents under seal in their entirety

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should include an explanation of why redaction is not feasible.

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2.

DEFINITIONS

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2.1

Action: the above-captioned federal lawsuit

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2.2

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

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of information or items under this Order.
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“CONFIDENTIAL” Information or Items: information (regardless of

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

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

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Good Cause Statement.

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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

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

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“CONFIDENTIAL.”

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2.6

Disclosure or Discovery Material: all items or information, regardless of

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

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

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generated in disclosures or responses to discovery in this matter.

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2.7

Expert: a person with specialized knowledge or experience in a matter

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

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an expert witness or as a consultant in this Action.

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2.8

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

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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS
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House Counsel does not include Outside Counsel of Record or any other outside

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counsel.
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Non-Party: any natural person, partnership, corporation, association, or

other legal entity not named as a Party to this Action.

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

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

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

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has appeared on behalf of that party, and includes support staff.

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2.11 Party: any party to this Action, including all of its officers, directors,

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employees, consultants, retained experts, and Outside Counsel of Record (and their

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support staffs).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or

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Discovery Material in this Action.

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2.13 Professional Vendors: persons or entities that provide litigation support

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

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demonstrations, and organizing, storing, or retrieving data in any form or medium)

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and their employees and subcontractors.
2.14 Protected Material: any Disclosure or Discovery Material that is

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designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

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from a Producing Party.

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3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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

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

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Protected Material; and (3) any testimony, conversations, or presentations by Parties

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or their Counsel that might reveal Protected Material.
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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS

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The protections conferred by this Stipulation and Order do not cover the

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following information: (a) any information that is in the public domain at the time of

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disclosure to a Receiving Party or becomes part of the public domain after its

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disclosure to a Receiving Party as a result of publication not involving a violation of

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this Order, including becoming part of the public record through trial or otherwise;

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and (b) any information known to the Receiving Party prior to the disclosure or

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obtained by the Receiving Party after the disclosure from a source who obtained the

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information lawfully and under no obligation of confidentiality to the Designating

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Party.
Any use of Protected Material at trial shall be governed by the orders of the

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trial judge. This Order does not govern the use of Protected Material at trial.

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4.

DURATION

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

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“CONFIDENTIAL” or maintained pursuant to this protective order and that is used or

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

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all members of the public, including the press, unless compelling reasons supported

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by specific factual findings to proceed otherwise are made to the trial judge in

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advance of the trial. See Kamakana, 447 F.2d at 1080-81 (distinguishing “good

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cause” showing for sealing documents produced in discovery from “compelling

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reasons” standard when merits-related documents are part of court record).

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Accordingly, the terms of this protective order do not extend beyond the

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commencement of trial.

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Final disposition shall be deemed to be the later of (1) dismissal of all claims

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and defenses in this action, with or without prejudice; and (2) final judgment herein

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after the completion and exhaustion of all appeals, rehearings, remands, trials, or

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reviews of this action, including the time limits for filing any motions or applications

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for extension of time pursuant to applicable law.
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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS

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5.

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or Non-Party that designates information or items for protection under this

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Order must take care to limit any such designation to specific material that qualifies

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under the appropriate standards. The Designating Party must designate for protection

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only those parts of material, documents, items, or oral or written communications that

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qualify so that other portions of the material, documents, items, or communications

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for which protection is not warranted are not swept unjustifiably within the ambit of

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this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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

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

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

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Party to sanctions.

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

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designated for protection do not qualify for protection, that Designating Party must

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promptly notify all other Parties that it is withdrawing the inapplicable designation.

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5.2

Manner and Timing of Designations. Except as otherwise provided in

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

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

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

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produced.

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Designation in conformity with this Order requires:

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

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

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

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

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contains protected material. If only a portion of the material on a page qualifies for
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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS

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

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

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A Party or Non-Party that makes original documents available for inspection

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need not designate them for protection until after the inspecting Party has indicated

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which documents it would like copied and produced. During the inspection and

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before the designation, all of the material made available for inspection shall be

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deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

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it wants copied and produced, the Producing Party must determine which documents,

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or portions thereof, qualify for protection under this Order. Then, before producing

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the specified documents, the Producing Party must affix the “CONFIDENTIAL”

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legend to each page that contains Protected Material. If only a portion of the material

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on a page qualifies for protection, the Producing Party also must clearly identify the

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protected portion(s) (e.g., by making appropriate markings in the margins).
(b)

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for testimony given in depositions: that the Designating Party

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identifies the Disclosure or Discovery Material and any protected testimony on the

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record, before the close of the deposition.
(c)

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for information produced in some form other than documentary

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form and for any other tangible items: that the Producing Party affix in a prominent

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place on the exterior of any container or containers in which the information is stored

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

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

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protected portion(s).

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5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

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Upon timely correction of a designation, the Receiving Party must make reasonable

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efforts to assure that the material is treated in accordance with the provisions of this

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Order.
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6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

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Timing of Challenges.

Any Party or Non-Party may challenge a

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

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Scheduling Order.
6.2

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Meet and Confer.

The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.
6.3

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The burden of persuasion in any such challenge proceeding shall be on

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

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(e.g., to harass or impose unnecessary expenses and burdens on the other parties) may

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expose the Challenging Party to sanctions. Unless the Designating Party has waived

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or withdrawn the confidentiality designation, all parties shall continue to afford the

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material in question the level of protection to which it is entitled under the Producing

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Party’s designation until the Court rules on the challenge.

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7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is

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

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Action only for prosecuting, defending, or attempting to settle this Action. Such

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

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

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Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

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

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

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authorized under this Order.

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7.2

Disclosure of “CONFIDENTIAL” Information or Items.

Unless

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

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Receiving

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“CONFIDENTIAL” only to:

Party

may

disclose

any

information

or

item

designated

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(a)

the Receiving Party’s Outside Counsel of Record in this Action, as

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

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necessary to disclose the information for this Action;

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(b)

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

of the Receiving Party to whom disclosure is reasonably necessary for this Action;
(c)

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

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

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“Acknowledgement and Agreement to Be Bound” (Exhibit A);

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(d)

the court and its personnel;

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(e)

court reporters and their staff;

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(f)

professional jury or trial consultants, mock jurors, and

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Professional Vendors to whom disclosure is reasonably necessary for this Action and

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who have signed the “Acknowledgement and Agreement to Be Bound” (Exhibit A);

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(g)

the author or recipient of a document containing the information or

a custodian or other person who otherwise possessed or knew the information;
(h)

during depositions in the Action: witnesses, and attorneys for

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witnesses to whom disclosure is reasonably necessary provided: (1) the deposing

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party requests that the witness sign the form attached as Exhibit A hereto; and (2)

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

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

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

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deposition testimony or exhibits to depositions that reveal Protected Material may be

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separately bound by the court reporter based on a designation made during the

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deposition and may not be disclosed to anyone except as permitted under this

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Stipulated Protective Order; and

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(i)

any mediator or settlement officer, and their supporting personnel,

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

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8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

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OTHER LITIGATION

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

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litigation that compels disclosure of any information or items designated in this

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Action as “CONFIDENTIAL,” that Receiving Party must:
(a)

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promptly notify in writing the Designating Party. Such notification

shall include a copy of the subpoena or court order;
(b)

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promptly notify in writing the party who caused the subpoena or

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order to issue in other litigation that some or all of the material covered by the

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

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copy of this Stipulated Protective Order; and
(c)

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cooperate with respect to all reasonable procedures sought to be

pursued by the Designating Party whose Protected Material may be affected.

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If the Designating Party timely seeks a protective order, the Party served with

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the subpoena or court order shall not produce any information designated in this

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

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

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

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

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

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disobey a lawful directive from another court.

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9.

A

NON-PARTY’S

PROTECTED

MATERIAL

SOUGHT

TO

BE

PRODUCED IN THIS LITIGATION

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

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

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

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remedies and relief provided by this Order. Nothing in these provisions should be
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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS

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construed as prohibiting a Non-Party from seeking additional protections.

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(b) In the event that a Party is required, by a valid discovery request, to

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produce a Non-Party’s confidential information in its possession, and the Party is

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subject to an agreement with the Non-Party not to produce the Non-Party’s

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confidential information, then the Party shall:

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

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

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agreement with a Non-Party;

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

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

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specific description of the information requested; and
(3)

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make the information requested available for inspection by the

Non-Party, if requested.

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(c) If the Non-Party fails to seek a protective order from this court

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within 14 days of receiving the notice and accompanying information, the Receiving

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Party may produce the Non-Party’s confidential information responsive to the

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discovery request. If the Non-Party timely seeks a protective order, the Receiving

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

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

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

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of seeking protection in this court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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Protected Material to any person or in any circumstance not authorized under this

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Stipulated Protective Order, the Receiving Party must immediately (a) notify in

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

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to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS

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persons to whom the unauthorized disclosures were made of all the terms of this

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Order, and (d) request such person or persons to execute the “Acknowledgement and

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Agreement to Be Bound” that is attached hereto as Exhibit A.

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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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

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the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

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Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

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may be established in an e-discovery order that provides for production without prior

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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

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parties reach an agreement on the effect of disclosure of a communication or

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information covered by the attorney-client privilege or work product protection, the

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parties may incorporate their agreement in the stipulated protective order submitted to

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the court.

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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.

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

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

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

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

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

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

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

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only be filed under seal pursuant to a court order authorizing the sealing of the
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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS

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

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

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the public record unless otherwise instructed by the court.

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13.

FINAL DISPOSITION

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After the final disposition of this Action, as defined in paragraph 4, within 60

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days of a written request by the Designating Party, each Receiving Party must return

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all Protected Material to the Producing Party or destroy such material. As used in this

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subdivision, “all Protected Material” includes all copies, abstracts, compilations,

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summaries, and any other format reproducing or capturing any of the Protected

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

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Party must submit a written certification to the Producing Party (and, if not the same

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person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

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(by category, where appropriate) all the Protected Material that was returned or

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destroyed and (2) affirms that the Receiving Party has not retained any copies,

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

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of the Protected Material. Notwithstanding this provision, Counsel are entitled to

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retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

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transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

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reports, attorney work product, and consultant and expert work product, even if such

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materials contain Protected Material. Any such archival copies that contain or

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constitute Protected Material remain subject to this Protective Order as set forth in

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Section 4 (DURATION).

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14.

VIOLATION
Any violation of this Order may be punished by appropriate measures

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

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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS
1403653

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD:
DATED: October 18, 2017

GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP

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By: /s/

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ANDREW BAUM
Attorneys for Defendant
The County of Los Angeles

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DATED: October 19, 2017
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KAYE, McLANE, BEDNARSKI & LITT, LLP

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By: /s/Ronald O. Kaye

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RONALD O. KAYE
Attorneys for Plaintiffs
Robert G. Lindsey and Charles G.
Rodriguez

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DATED: October __, 2017

NEWMAN & HORTON, LLP

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By:

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PETER J. HORTON
Attorneys for Defendant
Paul Tanaka

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DATED: October 19, 2017

LAW OFFICE OF ROBERT M. SILVERMAN
and ALLEGUEZ & NEWMAN, LLP

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By: /s/ Carol L. Newman
ROBERT SILVERMAN
CAROL L. NEWMAN
Attorneys for Defendant
Kevin Stennis

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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS
1403653

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: October 24, 2017

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________________________
HON. ROZELLA A. OLIVER
United States Magistrate Judge

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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS
1403653

EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

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_________________ [print or type full address], declare under penalty of perjury that

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

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

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[date] in the case of Lindsey et al. v. County of Los Angeles et al. (CASE NO. 2:17-

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CV-03886-FMO (RAOX)), I agree to comply with and to be bound by all the terms of

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this Stipulated Protective Order and I understand and acknowledge that failure to so

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comply could expose me to sanctions and punishment in the nature of contempt. I

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solemnly promise that I will not disclose in any manner any information or item that

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is subject to this Stipulated Protective Order to any person or entity except in strict

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compliance with the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court

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for the Central District of California for the purpose of enforcing the terms of this

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action. I hereby appoint __________________________ [print or

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type full name] of _______________________________________ [print or type full

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address and telephone number] as my California agent for service of process in

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connection with this action or any proceedings related to enforcement of this

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Stipulated Protective Order.

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Date: ______________________________________

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City and State where sworn and signed: _________________________________

_____________________________

[print

or

type

full

name],

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Printed name: _______________________________

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Signature: __________________________________

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STIPULATION FOR PROTECTIVE ORDER RE: CONFIDENTIAL DISCOVERY MATERIALS
1403653

of