Priscilla Anderson v. County of Los Angeles et al

Filing 30

PROTECTIVE ORDER by Magistrate Judge Alexander F. MacKinnon. re Stipulation for Protective Order 29 (vm)

1 Thomas C. Hurrell, State Bar No. 119876
E-Mail: [e-mail]
2 Jennifer J. Moon, State Bar No. 186201
E-Mail: [e-mail]
3 HURRELL CANTRALL LLP
300 South Grand Avenue, Suite 1300
4 Los Angeles, California 90071
Telephone: [phone]
5 Facsimile: [phone]
6 Attorneys for Defendant, COUNTY OF LOS ANGELES
7
8
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

11
300 SOUTH GRAND AVENUE, SUITE 1300
LOS ANGELES, CAL FORNIA 90071
TELEPHONE [phone]

HURRELL CANTRALL

UNITED STATES DISTRICT COURT

10
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9

12 PRISCILLA ANDERSON, an
individual,
13
Plaintiff,
14
v.
15
COUNTY OF LOS ANGELES;
16 JEREMY FENNELL; and DOES 1
through 50, inclusive,
17
Defendants.
18

CASE NO. 2:18-cv-2753 AB (AFMx)
[Assigned to Hon. Andre Birotte, Jr.
Courtroom "7B"]
(PROPOSED) STIPULATED
PROTECTIVE ORDER

19
20
21 1.

A.

PURPOSES AND LIMITATIONS

22

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

23 proprietary or private information for which special protection from public disclosure
24 and from use for any purpose other than prosecuting this litigation may be warranted.
25 Accordingly, the parties hereby stipulate to and petition the Court to enter the
26 following Stipulated Protective Order. The parties acknowledge that this Order does
27 not confer blanket protections on all disclosures or responses to discovery and that
28 the protection it affords from public disclosure and use extends only to the limited

1 information or items that are entitled to confidential treatment under the applicable
2 legal principles.
3

B.

GOOD CAUSE STATEMENT

4

This action is likely to involve confidential information pertaining to personnel

5 records and other materials subject to privacy protections for which special protection
6 from public disclosure and from use for any purpose other than prosecution of this
7 action is warranted. Limiting disclosure of these documents to the context of this
8 litigation as provided herein will, accordingly, further important law enforcement
9 objections and interests, including the safety of personnel and the public, as well as
10 individual privacy rights of plaintiff, the individual defendants, and third parties. Such
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11 confidential materials and information consist of, among other things, materials
12 entitled to privileges and/or protections under the following: United States
13 Constitution, First Amendment; the California Constitution, Article I, Section 1;
14 California Penal Code sections 832.5, 832.7 and 832.8; California Evidence Code
15 sections 1040 and 1043 et. seq; the Privacy Act of 1974, 5 U.S.C. § 552a; Health
16 Insurance Portability and Accountability Act of 1996 (HIPPA); the right to privacy;
17 decisional law relating to such provisions; and information otherwise generally
18 unavailable to the public, or which may be privileged or otherwise protected from
19 disclosure under state or federal statutes, court rules, case decisions, or common law.
20 Defendants also contend that such confidential materials and information consist of
21 materials entitled to the Official Information Privilege.
22

Confidential information with respect to the Defendants may include but is not

23 limited to: personnel files; internal investigative files and documents; email and
24 written correspondence records; and policies and procedures that are kept from the
25 public in the ordinary course of business, as well as other items subject to the Official
26 Information Privilege and other privileges. Confidential information with financial
27 records; email and written correspondence records; video footage and/or photographs
28 of the incident; and psychological and medical notes, evaluations, reports, and
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1 treatment plans.
2

The parties reserve the right to challenge a designation of confidentiality

3 pursuant to the terms set forth under Paragraph 8 of this Order.
4

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

5 resolution of disputes over confidentiality of discovery materials, to adequately
6 protect information the parties are entitled to keep confidential, to ensure that the
7 parties are permitted to reasonably use such material in preparation for and in conduct
8 of trial, to address their handling at the end of the litigation, and serve the ends of
9 justice, a protective order for such information is justified in this matter. It is the intent
10 of the parties that information will not be designated as confidential for tactical
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11 reasons and that nothing be so designated without a good faith belief that it has been
12 maintained in a confidential, non-public manner, and there is good cause why it
13 should not be part of the public record of this case.
14
15
16

C.

ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER
SEAL

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

17 Stipulated Protective Order does not entitle them to file confidential information
18 under seal: Local Civil Rule 79-5 sets forth the procedures that must be followed and
19 the standards that will be applied when a party seeks permission from the court to file
20 material under seal.
21

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

22 proceedings and records in civil cases. In connection with non-dispositive motions,
23 good cause must be shown to support a filing under seal. See Kamakana v. City and
24 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
25 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,
26 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good
27 cause showing), and a specific showing of good cause or compelling reasons with
28 proper evidentiary support and legal justification, must be made with respect to
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1 Protected Material that a party seeks to file under seal. The parties' mere designatino
2 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the
3 submission of competent evidence by declaration, establishing that the material
4 sought to be filed under seal qualifies as confidential, privileged, or otherwise
5 protectable—constitute good cause.
6

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

7 compelling reasons, not only good cause, for the sealing must be shown, and the relief
8 sought shall be narrowly tailored to serve the specific interest to be protected. See
9 Pintos v. Pacific Creditors Ass'n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
10 or type of information, document, or thing sought to be filed or introduced under seal
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11 in connection with a dispositive motion or trial, the party seeking protection must
12 articulate compelling reasons, supported by specific facts and legal justification, for
13 the requested sealing order. Again, competent evidence supporting the application to
14 file documents under seal must be provided by declaration.
15

Any document that is not confidential, privileged, or otherwise protectable in

16 its entirety will not be filed under seal if the confidential portions can be redacted. IF
17 documents can be redacted, then a redacted version for public viewing, omitting only
18 the confidential, privileged, or otherwise protectable portions of the document, shall
19 be filed. Any application that seeks to file documents under seal in their entirety
20 should include an explanation of why redaction is not feasible.
21 2.

DEFINITIONS

22

2.1

Action: Priscilla Anderson v. County of Los Angeles, et al., Case No.

23 2:18-cv-2753 AB (AFMx).
24

2.2

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

25 designation of information or items under this Order.
26

2.3

"CONFIDENTIAL" Information or Items: information (regardless of

27 how it is generated, stored or maintained) or tangible things that qualify for
28 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
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1 the Good Cause Statement.
2

2.4

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

3 their support staff)
4

2.5

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

5 items that it produces in disclosures or in responses to discovery and
6 "CONFIDENTIAL."
7

2.6

Disclosure or Discovery Material: all items or information, regardless

8 of the medium or manner in which it is generated, stored, or maintained (including,
9 among other things, testimony, transcripts, and tangible things), that are produced or
10 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

12 pertinent to the litigation who has been retained by a Party or its counsel to serve as
13 an expert witness or as a consultant in this Action.
14

2.8

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

15 House Counsel does not include Outside Counsel of Record or any other outside
16 counsel.
17

2.9

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

18 other legal entity not named as a Party to this action.
19

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

20 party to this Action but are retained to represent or advise a party to this Action and
21 have appeared in this Action on behalf of that party or are affiliated with a law firm
22 that has appeared on behalf of that party, and includes support staff.
23

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

24 employees, consultants, retained experts, and Outside Counsel of Record (and their
25 support staffs).
26

2.12

Producing Party: a Party or Non-Party that produces Disclosure or

27 Discovery Material in this Action.
28

2.13 Professional Vendors: persons or entities that provide litigation
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1 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
2 demonstrations, and organizing, storing, or retrieving data in any form or medium)
3 and their employees and subcontractors.
4

2.14 Protected Material: any Disclosure or Discovery Material that is

5 designated as “CONFIDENTIAL.”
6

2.15 Receiving Party: a Party that receives Disclosure or Discovery

7 Material from a Producing Party.
8 3.

SCOPE

9 The protections conferred by this Stipulation and Order cover not only Protected
10 Material (as defined above), but also (1) any information copied or extracted from
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11 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
12 Material; and (3) any testimony, conversations, or presentations by Parties or their
13 Counsel that might reveal Protected Material. Any use of Protected Material at trial
14 shall be governed by the orders of the trial judge. This Order does not govern the use
15 of Protected Material at trial.
16 4.

DURATION

17 Once a case proceeds to trial, information that was designated as CONFIDENTIAL
18 or maintained pursuant to this protective order used or introduced as an exhibit at trial
19 becomes public and will be presumptively available to all members of the public,
20 including the press, unless compelling reasons supported by specific factual findings
21 to proceed otherwise are made to the trial judge in advance of the trial. See Kamakana,
22 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing documents
23 produced in discovery from “compelling reasons” standard when merits-related
24 documents are part of court record). Accordingly, the terms of this protective order
25 do not extend beyond the commencement of the trial.
26 5.

DESIGNATING PROTECTED MATERIAL

27

5.1

28

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

Exercise of Restraint and Care in Designating Material for Protection.

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1 under this Order must take care to limit any such designation to specific material
2 that qualifies under the appropriate standards. The Designating Party must designate
3 for protection only those parts of material, documents, items or oral or written
4 communications that qualify so that other portions of the material, documents, items
5 or communications for which protection is not warranted are not swept unjustifiably
6 within the ambit of this Order.
7

Mass, indiscriminate or routinized designations are prohibited. Designations

8 that are shown to be clearly unjustified or that have been made for an improper
9 purpose (e.g., to unnecessarily encumber the case development process or to impose
10 unnecessary expenses and burdens on other parties) may expose the Designating
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11 Party to sanctions. If it comes to a Designating Party’s attention that information or
12 items that it designated for protection do not qualify for protection, that Designating
13 Party must promptly notify all other Parties that it is withdrawing the inapplicable
14 designation.
15

5.2

Manner and Timing of Designations.

16

Except as otherwise provided in this Order (see, e.g., second paragraph of

17 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery
18 Material that qualifies for protection under this Order must be clearly so designated
19 before the material is disclosed or produced.
20

Designation in conformity with this Order requires:

21

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

22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
24 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
25 portion of the material on a page qualifies for protection, the Producing Party also
26 must clearly identify the protected portion(s) (e.g., by making appropriate markings
27 in the margins).
28

A Party or Non-Party that makes original documents available for inspection
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1 need not designate them for protection until after the inspecting Party has indicated
2 which documents it would like copied and produced. During the inspection and before
3 the designation, all of the material made available for inspection shall be deemed
4 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
5 copied and produced, the Producing Party must determine which documents, or
6 portions thereof, qualify for protection under this Order. Then, before producing the
7 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
8 to each page that contains Protected Material. If only a portion of the material on a
9 page qualifies for protection, the Producing Party also must clearly identify the
10 protected portion(s) (e.g., by making appropriate markings in the margins).
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(b) for testimony given in depositions that the Designating Party identifies the

12 Disclosure or Discovery Material on the record, before the close of the deposition all
13 protected testimony.
14

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

15 other tangible items, that the Producing Party affix in a prominent place on the exterior
16 of the container or containers in which the information is stored the legend
17 “CONFIDENTIAL.” If only a portion or portions of the information warrants
18 protection, the Producing Party, to the extent practicable, shall identify the protected
19 portion(s).
20

5.3

Inadvertent Failures to Designate.

21

If timely corrected, an inadvertent failure to designate qualified information

22 or items does not, standing alone, waive the Designating Party’s right to secure
23 protection under this Order for such material. Upon timely correction of a
24 designation, the Receiving Party must make reasonable efforts to assure that the
25 material is treated in accordance with the provisions of this Order.
26 6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

27

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

28 of confidentiality at any time that is consistent with the Court’s Scheduling Order.
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1

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

2 resolution process under Local Rule 37-1 et seq.
3

6.3

Joint Stipulation. Any challenge submitted to the Court shall be via a

4 joint stipulation pursuant to Local Rule 37-2.
5

6.4

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

6 the Designating Party. Frivolous challenges, and those made for an improper purpose
7 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
8 expose the Challenging Party to sanctions. Unless the Designating Party has waived
9 or withdrawn the confidentiality designation, all parties shall continue to afford the
10 material in question the level of protection to which it is entitled under the Producing
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11 Party’s designation until the Court rules on the challenge.
12 7.

ACCESS TO AND USE OF PROTECTED MATERIAL

13

7.1

14

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

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

15 this 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 the
17 conditions described in this Order. When the Action has been terminated, a Receiving
18 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
19 Protected Material must be stored and maintained by a Receiving Party at a location
20 and in a secure manner that ensures that access is limited to the persons authorized
21 under this Order.
22

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

Party

may

disclose

any

information

or

item

designated

25 “CONFIDENTIAL” only to:
26

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

27 employees of said Outside Counsel of Record to whom it is reasonably necessary to
28 disclose the information for this Action;
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1

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

2 Receiving Party to whom disclosure is reasonably necessary for this Action;
3

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

4 is reasonably necessary for this Action and who have signed the “Acknowledgment
5 and Agreement to Be Bound” (Exhibit A);
6

(d) the court and its personnel;

7

(e) court reporters and their staff;

8

(f) professional jury or trial consultants, mock jurors, and Professional Vendors

9 to whom disclosure is reasonably necessary for this Action and who have signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(g) the author or recipient of a document containing the information or a

12 custodian or other person who otherwise possessed or knew the information;
13

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

14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
15 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
16 not be permitted to keep any confidential information unless they sign the
17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
18 agreed by the Designating Party or ordered by the court. Pages of transcribed
19 deposition testimony or exhibits to depositions that reveal Protected Material may be
20 separately bound by the court reporter and may not be disclosed to anyone except as
21 permitted under this Stipulated Protective Order; and
22

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

23 agreed upon by any of the parties engaged in settlement discussions.
24 8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

25

IN OTHER LITIGATION

26

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

27 that compels disclosure of any information or items designated in this Action as
28 "CONFIDENTIAL" that Party must:
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1

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

2 include a copy of the subpoena or court order;
3

(b) promptly notify in writing the party who caused the subpoena or order to

4 issue in the other litigation that some or all of the material covered by the subpoena
5 or order is subject to this Protective Order. Such notification shall include a copy of
6 this Stipulated Protective Order; and
7

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

8 by the Designating Party whose Protected Material may be affected.
9

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

10 the subpoena or court order shall not produce any information designated in this
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11 action as “CONFIDENTIAL” before a determination by the court from which the
12 subpoena or order issued, unless the Party has obtained the Designating Party’s
13 permission. The Designating Party shall bear the burden and expense of seeking
14 protection in that court of its confidential material and nothing in these provisions
15 should be construed as authorizing or encouraging a Receiving Party in this Action
16 to disobey a lawful directive from another court.
17 9.

A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE

18

PRODUCED IN THIS LITIGATION

19

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

20 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
21 produced by Non-Parties in connection with this litigation is protected by the
22 remedies and relief provided by this Order. Nothing in these provisions should be
23 construed as prohibiting a Non-Party from seeking additional protections.
24

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

25 produce a Non-Party’s confidential information in its possession, and the Party is
26 subject to an agreement with the Non-Party not to produce the Non-Party’s
27 confidential information, then the Party shall:
28

(1) promptly notify in writing the Requesting Party and the Non-Party
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1 that some or all of the information requested is subject to a confidentiality
2 agreement with a Non-Party;
3

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

4 Protective Order in this Action, the relevant discovery request(s), and a reasonably
5 specific description of the information requested; and
6

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

7 Non-Party, if requested.
8

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

9 14 days of receiving the notice and accompanying information, the Receiving Party
10 may produce the Non-Party’s confidential information responsive to the discovery
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11 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
12 not produce any information in its possession or control that is subject to the
13 confidentiality agreement with the Non-Party before a determination by the court.
14 Absent a court order to the contrary, the Non-Party shall bear the burden and
15 expense of seeking protection in this court of its Protected Material.
16 10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

17

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

18 Protected Material to any person or in any circumstance not authorized under this
19 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
20 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
21 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
22 persons to whom unauthorized disclosures were made of all the terms of this Order,
23 and (d) request such person or persons to execute the “Acknowledgment and
24 Agreement to Be Bound” that is attached hereto as Exhibit A.
25 / / /
26 11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

27

PROTECTED MATERIAL

28

When a Producing Party gives notice to Receiving Parties that certain
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1 inadvertently produced material is subject to a claim of privilege or other protection,
2 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
3 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
4 procedure may be established in an e-discovery order that provides for production
5 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
6 (e), insofar as the parties reach an agreement on the effect of disclosure of a
7 communication or information covered by the attorney-client privilege or work
8 product protection, the parties may incorporate their agreement in the stipulated
9 protective order submitted to the court.

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MISCELLANEOUS

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10 12.

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

12 person to seek its modification by the Court in the future.
13

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

14 Protective Order, no Party waives any right it otherwise would have to object to
15 disclosing or producing any information or item on any ground not addressed in this
16 Stipulated Protective Order. Similarly, no Party waives any right to object on any
17 ground to use in evidence of any of the material covered by this Protective Order.
18

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

19 Protected Material must comply with Local Civil Rule 79-5. Protected Material
20 may only be filed under seal pursuant to a court order authorizing the sealing of the
21 specific Protected Material at issue. If a Party’s request to file Protected Material
22 under seal is denied by the court, then the Receiving Party may file the information
23 in the public record unless otherwise instructed by the court.
24 13.

FINAL DISPOSITION

25

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

26 days of a written request by the Designating Party, each Receiving Party must return
27 all Protected Material to the Producing Party or destroy such material. As used in
28 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
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1 summaries, and any other format reproducing or capturing any of the Protected
2 Material. Whether the Protected Material is returned or destroyed, the Receiving
3 Party must submit a written certification to the Producing Party (and, if not the same
4 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
5 (by category, where appropriate) all the Protected Material that was returned or
6 destroyed and (2) affirms that the Receiving Party has not retained any copies,
7 abstracts, compilations, summaries or any other format reproducing or capturing any
8 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
9 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
10 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
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11 reports, attorney work product, and consultant and expert work product, even if such
12 materials contain Protected Material. Any such archival copies that contain or
13 constitute Protected Material remain subject to this Protective Order as set forth in
14 Section 4 (DURATION).
15 / / /
16 / / /
17 / / /
18 / / /
19 / / /
20 / / /
21 / / /
22 / / /
23 / / /
24 / / /
25 / / /
26 14.

VIOLATION

27 Any violation of this Order may be punished by appropriate measures including,
28 without limitation, contempt proceedings and/or monetary sanctions.
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1
2 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
3
4 DATED: __________
5 _____________________________________
6 Mallory Whitelaw
7 Attorneys for Plaintiff Priscilla Anderson
8
9 DATED: ___________
10 _____________________________________
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11 Faryar Barzin
12 Attorneys for Defendant County of Los Angeles
13
14 DATED: __________
15 _____________________________________
16 Andrew Pongracz
17 Attorneys for Defendant Jeremy Fennell
18
19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
20 DATED: 12/26/2018
21
22 _____________________________________
23 ALEXANDER F. MacKINNON
24 United States Magistrate Judge
25
26

EXHIBIT A

27

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

28 I, _____________________________ [print or type full name], of
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1 _________________ [print or type full address], declare under penalty of perjury
2 that I have read in its entirety and understand the Stipulated Protective Order that
3 was issued by the United States District Court for the Central District of California
4 on [date] in the case of Priscilla Anderson v. County of Los Angeles, et al., Case No.
5 2:18-cv-2753 AB (AFMx). I agree to comply with and to be bound by all the terms
6 of this Stipulated Protective Order and I understand and acknowledge that failure to
7 so comply could expose me to sanctions and punishment in the nature of contempt. I
8 solemnly promise that I will not disclose in any manner any information or item that
9 is subject to this Stipulated Protective Order to any person or entity except in strict
10 compliance with the provisions of this Order. I further agree to submit to the
LLP

HURRELL CANTRALL

300 SOUTH GRAND AVENUE, SUITE 1300
LOS ANGELES, CAL FORNIA 90071
TELEPHONE [phone]

11 jurisdiction of the United States District Court for the Central District of California
12 for enforcing the terms of this Stipulated Protective Order, even if such enforcement
13 proceedings occur after termination of this action.
14 I hereby appoint __________________________ [print or type full name] of
15 _______________________________________ [print or type full address and
16 telephone number] as my California agent for service of process in connection with
17 this action or any proceedings related to enforcement of this Stipulated Protective
18 Order.
19 Date: ______________________________________
20
21 City and State where sworn and signed: _________________________________
22
23 Printed name: _______________________________
24
25 Signature: __________________________________
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