Hugo Salazar v. Cedars-Sinai Medical Center

Filing 22

PROTECTIVE ORDER by Magistrate Judge Michael R. Wilner. re Stipulation for Protective Order 21 (vm)

1 EMILIO GONZALEZ (State Bar No. 197382)
[e-mail]
2 GIANCARLO UREY (State Bar No. 267069)
[e-mail]
3 MARIA ARAKELIAN (State Bar No. 327796)
[e-mail]
4 DAVIS WRIGHT TREMAINE LLP
865 South Figueroa Street, 24th Floor
5 Los Angeles, California 90017-2566
Telephone: [phone]
6 Fax: [phone]
7 Attorneys for Defendant
CEDARS-SINAI MEDICAL CENTER
8
9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA

11
12 HUGO SALAZAR, an Individual,
13
Plaintiff,
14

vs.

Case No. 2:20-cv-07447-SVW-MRWx
STIPULATED PROTECTIVE
ORDER

15 CEDARS-SINAI MEDICAL CENTER,
Assigned to the Hon. Stephen V. Wilson
a California corporation; and DOES 1Magistrate Judge: Michael R. Wilner
16 10, inclusive,
17

Defendants.

18
19
20
21
22
23
24
25
26
27
28
STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

1
2

1.

PURPOSES AND LIMITATIONS AND GOOD CAUSE STATEMENT
Discovery in this action is likely to involve production of confidential,

3

proprietary, or private information for which special protection from public

4

disclosure and from use for any purpose other than prosecuting this litigation may

5

be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

6

enter the following Stipulated Protective Order. The parties acknowledge that this

7

Order does not confer blanket protections on all disclosures or responses to

8

discovery and that the protection it affords from public disclosure and use extends

9

only to the limited information or items that are entitled to confidential treatment

10

under the applicable legal principles. The parties further acknowledge, as set forth

11

in Section 12.3, below, that this Stipulated Protective Order does not entitle them to

12

file confidential information under seal; Civil Local Rule 79-5 sets forth the

13

procedures that must be followed and the standards that will be applied when a

14

party seeks permission from the court to file material under seal.

15

The grounds for this Protective Order are that discovery in this action

16

involves the disclosure of confidential, proprietary, and/or private information that

17

warrants special protection from public disclosure, and from use for any purpose

18

other than prosecuting and defending this action and any subsequent appeal of this

19

action. The confidential, proprietary, and/or private material that may be produced

20

in this action includes, but is not limited to, (1) confidential medical records and

21

information of non-parties; (2) other “Protected Health Information” (“PHI”) as

22

defined in 45 Code of Federal Regulations (“CFR”) Section 160.103 of the Health

23

Insurance Portability and Accountability Act of 1996 (“HIPAA”); (3) “medical

24

information” as defined in California Civil Code Section 56.05(g); (4) private

25

information regarding Cedars-Sinai Medical Center’s (“Cedars-Sinai”) current and

26

former employees; (5) proprietary business information; and (6) other documents

27

and information that may be subject to confidentiality limitations on disclosure due

28

to federal laws, state laws, and privacy rights.
1

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

Cedars-Sinai is required by federal and state laws to protect the

1
2

confidentiality of certain documents and information, including private information

3

regarding its current and former employees, as well as PHI, including medical

4

records and other medical information relating to patients. Prejudice or harm to a

5

party or third party may result if no protective order is granted, as the privacy rights

6

of Cedars-Sinai’s past and present patients and employees could be violated if any

7

of the confidential information identified above is published or otherwise used or

8

disclosed for purposes outside those permitted in this Protective Order. Cedars-

9

Sinai may also be harmed and/or prejudiced if its proprietary or other confidential

10

information is made public.

11

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

12

resolution of disputes over confidentiality of discovery materials, to adequately

13

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

14

parties are permitted reasonable necessary uses of such material in preparation for

15

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

16

serve the ends of justice, a protective order for such information is justified in this

17

matter. It is the intent of the parties that information will not be designated as

18

confidential for tactical reasons and that nothing be so designated without a good

19

faith belief that it has been maintained in a confidential, non-public manner, and

20

there is good cause why it should not be part of the public record of this case.

21
22
23
24
25
26
27
28

2.

DEFINITIONS
2.1

Action: this pending federal law suit, Hugo Salazar v. Cedars-Sinai

Medical Center, Case No. 2:20-cv-07447-SVW-MRW.
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

how it is generated, stored or maintained) or tangible things that qualify for
2

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

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

2

the Good Cause Statement.

3
4
5

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

6

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

7

“CONFIDENTIAL.”

8
9

2.6

Disclosure or Discovery Material: all items or information, regardless

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

10

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

11

or generated in disclosures or responses to discovery in this matter.

12

2.7

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

13

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

14

an expert witness or as a consultant in this Action.

15

2.8

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

16

House Counsel does not include Outside Counsel of Record or any other outside

17

counsel.

18
19
20

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

21

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

22

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

23

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

24

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

25

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

26

support staffs).

27
28

2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
3

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

2.13 Professional Vendors: persons or entities that provide litigation

2

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

3

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

4

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

5
6

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

7
8

Material from a Producing Party.

9
10

3.

SCOPE

11

The protections conferred by this Stipulation and Order cover not only

12

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

13

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

14

compilations of Protected Material; and (3) any testimony, conversations, or

15

presentations by Parties or their Counsel that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders of the

16
17

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

18
19
20

4.

DURATION
Even after final disposition of this litigation, the confidentiality obligations

21

imposed by this Order shall remain in effect until a Designating Party agrees

22

otherwise in writing or a court order otherwise directs. Final disposition shall be

23

deemed to be the later of (1) dismissal of all claims and defenses in this Action,

24

with or without prejudice; and (2) final judgment herein after the completion and

25

exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

26

including the time limits for filing any motions or applications for extension of time

27

pursuant to applicable law.

28
4

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1
2

5.

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

3

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

4

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

5

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

6

protection only those parts of material, documents, items, or oral or written

7

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

8

items, or communications for which protection is not warranted are not swept

9

unjustifiably within the ambit of this Order.

10

Mass, indiscriminate, or routinized designations are prohibited. Designations

11

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

12

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

13

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

14

Party to sanctions.

15

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

16

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

17

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

18

5.2

Manner and Timing of Designations. Except as otherwise provided in

19

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

20

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

21

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

22

produced.

23

Designation in conformity with this Order requires:

24

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

25

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

26

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

27

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

28

contains protected material. If only a portion or portions of the material on a page
5

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

qualifies for protection, the Producing Party also must clearly identify the protected

2

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

3

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

4

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

5

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

6

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

7

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

8

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

9

which documents, or portions thereof, qualify for protection under this Order. Then,

10

before producing the specified documents, the Producing Party must affix the

11

“CONFIDENTIAL legend” to each page that contains Protected Material. If only a

12

portion or portions of the material on a page qualifies for protection, the Producing

13

Party also must clearly identify the protected portion(s) (e.g., by making appropriate

14

markings in the margins).

15

(b) for testimony given in depositions that the Designating Party identify the

16

Disclosure or Discovery Material on the record, before the close of the deposition

17

all protected testimony.

18

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

19

any other tangible items, that the Producing Party affix in a prominent place on the

20

exterior of the container or containers in which the information is stored the legend

21

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

22

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

23

portion(s).

24

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

25

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

26

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

27

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

28
6

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

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

2

Order.

3
4

6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

5

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

6

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

7

Scheduling Order.
6.2

8
9

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37-1, et seq.
6.3

10

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

11

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

12

purpose (e.g., to harass or impose unnecessary expenses and burdens on other

13

parties) may expose the Challenging Party to sanctions. Unless the Designating

14

Party has waived or withdrawn the confidentiality designation, all parties shall

15

continue to afford the material in question the level of protection to which it is

16

entitled under the Producing Party’s designation until the Court rules on the

17

challenge.

18
19
20

7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

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

21

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

22

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

23

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

24

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

25

Receiving Party must comply with the provisions of section 13 below (FINAL

26

DISPOSITION).

27
28
7

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

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

2

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

3

authorized under this Order.

4

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

5

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

6

Receiving Party may disclose any information or item designated

7

“CONFIDENTIAL” only to:

8
9
10
11

(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 necessary
to disclose the information for this Action;
(b) the officers, directors, and employees (including House Counsel) of the

12

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

13

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

14

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

15

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

16

(d) the court and its personnel;

17

(e) court reporters and their staff;

18

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

19

Vendors to whom disclosure is reasonably necessary for this Action and who have

20

signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

21
22
23

(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 their depositions, witnesses and attorneys for witnesses, in the

24

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

25

requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they

26

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

27

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

28

agreed by the Designating Party or ordered by the court. Pages of transcribed
8

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

deposition testimony or exhibits to depositions that reveal Protected Material may

2

be separately bound by the court reporter and may not be disclosed to anyone

3

except as permitted under this Stipulated Protective Order; and
(i) any mediator or settlement officer, and their supporting personnel,

4
5

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

6
7

8.

8

IN OTHER LITIGATION

9

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
If a Party is served with a subpoena or a court order issued in other litigation

10

that compels disclosure of any information or items designated in this Action as

11

“CONFIDENTIAL,” that Party must:

12
13

(a) promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order;

14

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

15

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

16

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

17

this Stipulated Protective Order; and

18
19
20

(c) cooperate with respect to all reasonable procedures sought to be pursued
by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with

21

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

22

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

23

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

24

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

25

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

26

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

27

to disobey a lawful directive from another court.

28
9

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

9.

2

PRODUCED IN THIS LITIGATION

3

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
(a) The terms of this Order are applicable to information produced by a Non-

4

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

5

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

6

remedies and relief provided by this Order. Nothing in these provisions should be

7

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

8
9

(b) In the event that a Party is required, by a valid discovery request, to
produce a Non-Party’s confidential information in its possession, and the Party is

10

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

11

confidential information, then the Party shall:

12

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

13

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

14

agreement with a Non-Party;

15

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

16

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

17

reasonably specific description of the information requested; and

18

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

19

Non-Party, if requested.

20

(c) If the Non-Party fails to seek a protective order from this court within 14

21

days of receiving the notice and accompanying information, the Receiving Party

22

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

23

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

24

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

25

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

26

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

27

expense of seeking protection in this court of its Protected Material.

28
10

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

2
3

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

4

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

5

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

6

to retrieve all unauthorized copies of the Protected Material, (c) inform the person

7

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

8

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

9

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

10
11

11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

12

PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain

13
14

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

15

protection, the obligations of the Receiving Parties are those set forth in Federal

16

Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

17

whatever procedure may be established in an e-discovery order that provides for

18

production without prior privilege review. Pursuant to Federal Rule of Evidence

19

502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

20

of a communication or information covered by the attorney-client privilege or work

21

product protection, the parties may incorporate their agreement in the stipulated

22

protective order submitted to the court.

23
24
25
26
27
28

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
Protective Order no Party waives any right it otherwise would have to object to
11

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

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

2

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

3

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

4

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

5

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

6

only be filed under seal pursuant to a court order authorizing the sealing of the

7

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

8

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

9

in the public record unless otherwise instructed by the court.

10
11
12

13.

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

13

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

14

return all Protected Material to the Producing Party or destroy such material. As

15

used in this subdivision, “all Protected Material” includes all copies, abstracts,

16

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

17

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

18

Receiving Party must submit a written certification to the Producing Party (and, if

19

not the same person or entity, to the Designating Party) by the 60 day deadline that

20

(1) identifies (by category, where appropriate) all the Protected Material that was

21

returned or destroyed and (2)affirms that the Receiving Party has not retained any

22

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

23

capturing any of the Protected Material. Notwithstanding this provision, Counsel

24

are entitled to retain an archival copy of all pleadings, motion papers, trial,

25

deposition, and hearing transcripts, legal memoranda, correspondence, deposition

26

and trial exhibits, expert reports, attorney work product, and consultant and expert

27

work product, even if such materials contain Protected Material. Any such archival

28
12

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

copies that contain or constitute Protected Material remain subject to this Protective

2

Order as set forth in Section 4 (DURATION).

3
4

14.

Any violation of this Order may be punished by any and all appropriate

5

measures including, without limitation, contempt proceedings and/or monetary

6

sanctions.

7
8

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

9
10
11
12
13
14
15
16
17
18
19
20
21
22

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

23
24

DATED:________________________

25

_____________________________________
HON. MICHAEL R. WILNER
27 United States Magistrate Judge
26

28
13

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]

1

EXHIBIT A: ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

2
3

I, _____________________________ [print or type full name], of

4

________________________ [print or type full address], declare under penalty of

5

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

6

Order that was issued by the United States District Court for the Central District of

7

California on [date] in the case of Hugo Salazar v. Cedars-Sinai Medical Center,

8

Case No. 2:20-cv-07447-SVW-MRW. I agree to comply with and to be bound by

9

all the terms of this Stipulated Protective Order and I understand and acknowledge

10

that failure to so comply could expose me to sanctions and punishment in the nature

11

of contempt. I solemnly promise that I will not disclose in any manner any

12

information or item that is subject to this Stipulated Protective Order to any person

13

or entity except in strict compliance with the provisions of this Order.

14

I further agree to submit to the jurisdiction of the United States District Court

15

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

16

Stipulated Protective Order, even if such enforcement proceedings occur after

17

termination of this action. I hereby appoint __________________________ [print

18

or type full name] of _______________________________________ [print or type

19

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

20

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

21

Stipulated Protective Order.

22
23
24
25
26
27
28

Date: ______________________________________
City and State where sworn and signed: _________________________________
Printed name: _______________________________
Signature: __________________________________
14

STIPULATED PROTECTIVE ORDER
4815-6225-4542v.2 0067789-001605

DAVIS WRIGHT TREMAINE LLP
865 S FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
[phone]
Fax: [phone]