Mary Swan Lewis et al v. City of Manhattan Beach et al

Filing 37

STIPULATED PROTECTIVE ORDER by Magistrate Judge Rozella A. Oliver re Corrected Stipulation for Protective Order 36 (dml)

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MARY SWAN LEWIS DAVID EUGENE LEWIS 3200 Pacific Ave Manhattan Beach, CA 90266 (310) 600 - 1533 1 2 3 4 5 Plaintiffs in PRO SE 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 MARY SWAN LEWIS Case No. 2:2023-cv-03319-WLH-RAO 13 STIPULATED PROTECTIVE ORDER DAVID EUGENE LEWIS 14 v. 15 CITY OF MANHATTAN BEACH, SHAWN THOMPSON, STEVE 16 KITSIOS, DANIEL BRANDT, JENNIFER LEACH, DONOVAN TORRES, IAN MIKELSON, and DOES 18 1 through 20, inclusive, 17 19 Defendants. 20 21 I. 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 24 disclosure and from use for any purpose other than prosecuting this litigation may 25 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 26 enter the following Stipulated Protective Order. The parties acknowledge that this 27 Order does not confer blanket protections on all disclosures or responses to 28 discovery and that the protection it affords from public disclosure and use extends 1 STIPULATED PROTECTIVE ORDER 1 only to the limited information or items that are entitled to confidential treatment 2 under the applicable legal principles. 3 II. 4 GOOD CAUSE STATEMENT On October 12, 2023, Plaintiffs ’son was granted a diversion pursuant to 5 California Penal Code § 1001.36, also known as “mental health diversion.” The 6 benefits to such a granting are substantial to the grantee, specifically the notable 7 guarantee that all records pertaining to the arrest and the criminal case, no matter 8 whether they are in the custody of a private individual, private entity, court, or 9 criminal justice agency (as defined by California Penal Code § 851.92, subdivision 10 are sealed and not subject to disclosure to any person or entity. There are only two 11 authorized exceptions regarding disclosure: the person to whom the diversion was 12 granted and a criminal justice agency. A criminal justice agency may only disclose 13 sealed records amongst themselves for the purposes of prosecution, but may not be 14 shared to any other person or entity. 15 The presiding Los Angeles County Superior Court judge used her inherent 16 authority to seal the records used in the diversion hearing to prevent their 17 disclosure. The records sealed included all police reports related to that particular 18 case. The judge’s decision to seal is consistent with subdivision (k) of California 19 Penal Code § 1001.36, which prevents the disclosure of any document used in the 20 consideration of diversion. 21 The parties acknowledge that several documents relevant to the instant case, 22 including police reports and search warrant affidavits, fall under the protective 23 umbrella of California Penal Code § 1001.36 and the relevant record sealing statues 24 (i.e. California Penal Code §§ 851.87, 851.90, 851.91, 851.92, and 1001 et seq.). As 25 Plaintiffs ’son has a statutory right to privacy, his rights should not be violated 26 through public disclosure of information and records. This Protective Order shall 27 apply to all of the following: 28 (a) Any and all police files relating to Plaintiffs’ son (pertaining to case 2 STIPULATED PROTECTIVE ORDER 1 DR-22-0000362) 2 (b) Any and all reports pertaining to case DR-22-0000362 3 (c) Any and all documents that reveal the identity of Plaintiffs’ son 4 This action is likely to involve trade secrets, customer and pricing lists and 5 other valuable research, development, commercial, financial, technical and/or 6 proprietary information for which special protection from public disclosure and 7 from use for any purpose other than prosecution of this action is warranted. Such 8 confidential and proprietary materials and information consist of, among other 9 things, confidential business or financial information, information regarding 10 confidential business practices, or other confidential research, development, or 11 commercial information (including information implicating privacy rights of third 12 parties), information otherwise generally unavailable to the public, or which may be 13 privileged or otherwise protected from disclosure under state or federal statutes, 14 court rules, case decisions, or common law. Accordingly, to expedite the flow of 15 information, to facilitate the prompt resolution of disputes over confidentiality of 16 discovery materials, to adequately protect information the parties are entitled to 17 keep confidential, to ensure that the parties are permitted reasonable necessary uses 18 of such material in preparation for and in the conduct of trial, to address their 19 handling at the end of the litigation, and serve the ends of justice, a protective order 20 for such information is justified in this matter. It is the intent of the parties that 21 information will not be designated as confidential for tactical reasons and that 22 nothing be so designated without a good faith belief that it has been maintained in a 23 confidential, non-public manner, and there is good cause why it should not be part 24 of the public record of this case. 25 III. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER 26 SEAL 27 The parties further acknowledge, as set forth in Section 12.3, below, that this 28 Stipulated Protective Order does not entitle them to file confidential information 3 STIPULATED PROTECTIVE ORDER 1 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 2 and the standards that will be applied when a party seeks permission from the court 3 to file material under seal. 4 There is a strong presumption that the public has a right of access to judicial 5 proceedings and records in civil cases. In connection with non-dispositive motions, 6 good cause must be shown to support a filing under seal. See Kamakana v. City and 7 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 8 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 9 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 10 require good cause showing), and a specific showing of good cause or compelling 11 reasons with proper evidentiary support and legal justification, must be made with 12 respect to Protected Material that a party seeks to file under seal. The parties ’mere 13 designation of Disclosure or Discovery Material as CONFIDENTIAL does not — 14 without the submission of competent evidence by declaration, establishing that the 15 material sought to be filed under seal qualifies as confidential, privileged, or 16 otherwise protectable — constitute good cause. 17 Further, if a party requests sealing related to a dispositive motion or trial, then 18 compelling reasons, not only good cause, for the sealing must be shown, and the 19 relief sought shall be narrowly tailored to serve the specific interest to be protected. 20 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 21 each item or type of information, document, or thing sought to be filed or 22 introduced under seal in connection with a dispositive motion or trial, the party 23 seeking protection must articulate compelling reasons, supported by specific facts 24 and legal justification, for the requested sealing order. Again, competent evidence 25 supporting the application to file documents under seal must be provided by 26 declaration. 27 28 Any document that is not confidential, privileged, or otherwise protectable in its entirety will not be filed under seal if the confidential portions can be redacted. If 4 STIPULATED PROTECTIVE ORDER 1 documents can be redacted, then a redacted version for public viewing, omitting 2 only the confidential, privileged, or otherwise protectable portions of the document 3 shall be filed. Any application that seeks to file documents under seal in their 4 entirety should include an explanation of why redaction is not feasible. 5 IV. DEFINITIONS 6 (a) ACTION refers to Civil Case 2:2023-cv-03319-WLH-RAO 7 (b) CHALLENGING PARTY refers to a Party or Non-Party that challenges 8 9 the designation of information or items under this Order. (c) “CONFIDENTIAL” INFORMATION OR ITEMS refers to information 10 (regardless of how it is generated, stored or maintained) or tangible things that 11 qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified 12 above in the Good Cause Statement. 13 14 15 (d) COUNSEL refers to outside Counsel of Record and House Counsel (as well as their support staff). (e) DESIGNATING PARTY refers to a Party or Non-Party that designates 16 information or items that it produces in disclosures or in responses to discovery as 17 “CONFIDENTIAL.” 18 (f) DISCLOSURE OR DISCOVERY MATERIAL refers to all items or 19 information, regardless of the medium or manner in which it is generated, stored, or 20 maintained (including, among other things, testimony, transcripts, and tangible 21 things) that are produced or generated in disclosures or responses to discovery in 22 this matter. 23 (g) EXPERT refers to a person with specialized knowledge or experience 24 in a matter pertinent to the litigation who has been retained by a Party or its counsel 25 to serve as an expert witness or as a consultant in this Action. 26 (h) HOUSE COUNSEL refers to attorneys who are employees of a party to 27 this Action. House Counsel does not include Outside Counsel of Record or any 28 other outside counsel. 5 STIPULATED PROTECTIVE ORDER (i) 1 2 NON-PARTY refers to any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. (l) 3 OUTSIDE COUNSEL OF RECORD refers to attorneys who are not 4 employees of a party to this Action but are retained to represent or advise a party to 5 this Action and have appeared in this Action on behalf of that party or are affiliated 6 with a law firm that has appeared on behalf of that party, and includes support staff. (m) 7 PARTY refers to any party to this Action, including all of its officers, 8 directors, employees, consultants, retained experts, and Outside Counsel of Record 9 (and their support staffs). (n) 10 11 PRODUCING PARTY refers to a Party or Non-Party that produces Disclosure or Discovery Material in this Action. (o) 12 PROFESSIONAL VENDORS refers to persons or entities that provide 13 litigation support services (e.g., photocopying, videotaping, translating, preparing 14 exhibits or demonstrations, and organizing, storing, or retrieving data in any form or 15 medium) and their employees and subcontractors. (p) 16 17 PROTECTED MATERIAL refers to any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” (q) 18 RECEIVING PARTY refers to a Party that receives Disclosure or 19 Discovery Material from a Producing Party. 20 V. SCOPE The protections conferred by this Stipulation and Order cover not only 21 22 Protected Material (as defined above), but also (1) any information copied or 23 extracted from Protected Material; (2) all copies, excerpts, summaries, or 24 compilations of Protected Material; and (3) any testimony, conversations, or 25 presentations by Parties or their Counsel that might reveal Protected Material. 26 Any use of Protected Material at trial shall be governed by the orders of the trial 27 judge. This Order does not govern the use of Protected Material at trial. 28 // 6 STIPULATED PROTECTIVE ORDER 1 VI. DURATION 2 Once a case proceeds to trial, information that was designated as 3 CONFIDENTIAL or maintained pursuant to this protective order used or 4 introduced as an exhibit at trial becomes public and will be presumptively available 5 to all members of the public, including the press, unless compelling reasons 6 supported by specific factual findings to proceed otherwise are made to the trial 7 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing 8 “good cause” showing for sealing documents produced in discovery from 9 “compelling reasons” standard when merits-related documents are part of court 10 record). Accordingly, the terms of this protective order do not extend beyond the 11 commencement of the trial. 12 VII. DESIGNATING PROTECTED MATERIAL 13 14 A. Exercise of Restraint and Care in Designating Material for Protection 15 Each Party or Non-Party that designates information or items for protection 16 under this Order must take care to limit any such designation to specific material 17 that qualifies under the appropriate standards. The Designating Party must designate 18 for protection only those parts of material, documents, items or oral or written 19 communications that qualify so that other portions of the material, documents, items 20 or communications for which protection is not warranted are not swept unjustifiably 21 within the ambit of this Order. 22 Mass, indiscriminate or routinized designations are prohibited. Designations 23 that are shown to be clearly unjustified or that have been made for an improper 24 purpose (e.g., to unnecessarily encumber the case development process or to impose 25 unnecessary expenses and burdens on other parties) may expose the Designating 26 Party to sanctions. 27 28 If it comes to a Designating Party’s attention that information or items that it designated for protection do not qualify for protection, that Designating Party must 7 STIPULATED PROTECTIVE ORDER 1 promptly notify all other Parties that it is withdrawing the inapplicable designation. 2 B. 3 Except as otherwise provided in this Order (see, e.g., second paragraph of 4 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery 5 Material that qualifies for protection under this Order must be clearly so designated 6 before the material is disclosed or produced. Designation in conformity with this 7 Order requires: 8 9 (a) Manner and Timing of Designations For information in documentary form (e.g., paper or electronic documents, but excluding transcripts of depositions or other pretrial or trial 10 proceedings), that the Producing Party affix at a minimum, the legend 11 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 12 contains protected material. If only a portion of the material on a page qualifies for 13 protection, the Producing Party also must clearly identify the protected portion(s) 14 (e.g., by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents available for inspection 16 need not designate them for protection until after the inspecting Party has indicated 17 which documents it would like copied and produced. During the inspection and 18 before the designation, all of the material made available for inspection shall be 19 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 20 documents it wants copied and produced, the Producing Party must determine 21 which documents, or portions thereof, qualify for protection under this Order. Then, 22 before producing the specified documents, the Producing Party must affix the 23 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 24 portion of the material on a page qualifies for protection, the Producing Party also 25 must clearly identify the protected portion(s) (e.g., by making appropriate markings 26 in the margins). 27 28 (b) For testimony given in depositions that the Designating Party identifies the Disclosure or Discovery Material on the record, before the close of the 8 STIPULATED PROTECTIVE ORDER 1 deposition all protected testimony. 2 (c) For information produced in some form other than documentary and 3 for any other tangible items, that the Producing Party affix in a prominent place 4 on the exterior of the container or containers in which the information is stored the 5 legend “CONFIDENTIAL.” If only a portion or portions of the information 6 warrants protection, the Producing Party, to the extent practicable, shall identify the 7 protected portion(s). 8 C. Inadvertent Failures to Designate 9 If timely corrected, an inadvertent failure to designate qualified information or 10 items does not, standing alone, waive the Designating Party’s right to secure 11 protection under this Order for such material. Upon timely correction of a 12 designation, the Receiving Party must make reasonable efforts to assure that the 13 material is treated in accordance with the provisions of this Order. 14 VIII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 15 A. 16 Any Party or Non-Party may challenge a designation of confidentiality at any 17 Timing of Challenges time that is consistent with the Court’s Scheduling Order. 18 B. 19 The Challenging Party shall initiate the dispute resolution process under Local 20 Meet and Confer Rule 37.1 et seq. 21 C. Burden of Persuasion 22 The burden of persuasion in any such challenge proceeding shall be on the 23 Designating Party. Frivolous challenges, and those made for an improper purpose 24 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 25 expose the Challenging Party to sanctions. Unless the Designating Party has waived 26 or withdrawn the confidentiality designation, all parties shall continue to afford the 27 material in question the level of protection to which it is entitled under the 28 Producing Party’s designation until the Court rules on the challenge. 9 STIPULATED PROTECTIVE ORDER 1 IX. ACCESS TO AND USE OF PROTECTED MATERIAL 2 A. Basic Principles 3 A Receiving Party may use Protected Material that is disclosed or produced by 4 another Party or by a Non-Party in connection with this Action only for prosecuting, 5 defending or attempting to settle this Action. Such Protected Material may be 6 disclosed only to the categories of persons and under the conditions described in 7 this Order. When the Action has been terminated, a Receiving Party must comply 8 with the provisions of section 13 below (FINAL DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 location and in a secure manner that ensures that access is limited to the persons 11 authorized under this Order. 12 B. Disclosure of “CONFIDENTIAL” Information or Items 13 Unless otherwise ordered by the court or permitted in writing by the 14 Designating Party, a Receiving Party may disclose any information or item 15 designated “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 17 as employees of said Outside Counsel of Record to whom it is reasonably necessary 18 to disclose the information for this Action; 19 20 21 (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 22 disclosure is reasonably necessary for this Action and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 Vendors to whom disclosure is reasonably necessary for this Action and who have 28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 STIPULATED PROTECTIVE ORDER 1 2 3 (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 4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 6 will not be permitted to keep any confidential information unless they sign the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 8 agreed by the Designating Party or ordered by the court. Pages of transcribed 9 deposition testimony or exhibits to depositions that reveal Protected Material may 10 be separately bound by the court reporter and may not be disclosed to anyone 11 except as permitted under this Stipulated Protective Order; and 12 (i) any mediator or settlement officer, and their supporting personnel, 13 mutually agreed upon by any of the parties engaged in settlement discussions. 14 X. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 15 16 If a Party is served with a subpoena or a court order issued in other litigation 17 that compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL,” that Party must: 19 20 21 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to 22 issue in the other litigation that some or all of the material covered by the subpoena 23 or order is subject to this Protective Order. Such notification shall include a copy of 24 this Stipulated Protective Order; and 25 26 27 28 (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 the subpoena or court order shall not produce any information designated in this 11 STIPULATED PROTECTIVE ORDER 1 action as “CONFIDENTIAL” before a determination by the court from which the 2 subpoena or order issued, unless the Party has obtained the Designating Party’s 3 permission. The Designating Party shall bear the burden and expense of seeking 4 protection in that court of its confidential material and nothing in these provisions 5 should be construed as authorizing or encouraging a Receiving Party in this Action 6 to disobey a lawful directive from another court. 7 XI. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 8 9 (a) The terms of this Order are applicable to information produced by a 10 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 11 produced by Non-Parties in connection with this litigation is protected by the 12 remedies and relief provided by this Order. Nothing in these provisions should be 13 construed as prohibiting a Non-Party from seeking additional protections. 14 (b) In the event that a Party is required, by a valid discovery request, to 15 produce a Non-Party’s confidential information in its possession, and the Party is 16 subject to an agreement with the Non-Party not to produce the Non-Party’s 17 confidential information, then the Party shall: (1) 18 19 20 Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; (2) 21 22 23 26 promptly provide the Non-Party with a copy of the Stipulated Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and (3) 24 25 promptly notify in writing the Requesting Party and the Non- make the information requested available for inspection by the Non-Party, if requested. (c) If the Non-Party fails to seek a protective order from this court within 14 27 days of receiving the notice and accompanying information, the Receiving Party 28 may produce the Non-Party’s confidential information responsive to the discovery 12 STIPULATED PROTECTIVE ORDER 1 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 2 not produce any information in its possession or control that is subject to the 3 confidentiality agreement with the Non-Party before a determination by the court. 4 Absent a court order to the contrary, the Non-Party shall bear the burden and 5 expense of seeking protection in this court of its Protected Material. 6 XII. 7 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 10 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 11 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 12 or persons to whom unauthorized disclosures were made of all the terms of this 13 Order, and (d) request such person or persons to execute the “Acknowledgment and 14 Agreement to Be Bound” that is attached hereto as “Exhibit A.” 15 XIII. OTHERWISE PROTECTED MATERIAL 16 17 INADVERTENT PRODUCTION OF PRIVILEGED OR When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 21 may be established in an e-discovery order that provides for production without 22 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 23 as the parties reach an agreement on the effect of disclosure of a communication or 24 information covered by the attorney-client privilege or work product protection, the 25 parties may incorporate their agreement in the stipulated protective order submitted 26 to the court. 27 XIV. 28 (a) MISCELLANEOUS Right to Further Relief. Nothing in this Order abridges the right of any 13 STIPULATED PROTECTIVE ORDER 1 2 person to seek its modification by the Court in the future. (b) Right to Assert Other Objections. By stipulating to the entry of this 3 Protective Order, no Party waives any right it otherwise would have to object to 4 disclosing or producing any information or item on any ground not addressed in this 5 Stipulated Protective Order. Similarly, no Party waives any right to object on any 6 ground to use in evidence of any of the material covered by this Protective Order. 7 (c) Filing Protected Material. A Party that seeks to file under seal any 8 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 9 only be filed under seal pursuant to a court order authorizing the sealing of the 10 specific Protected Material at issue. If a Party’s request to file Protected Material 11 under seal is denied by the court, then the Receiving Party may file the information 12 in the public record unless otherwise instructed by the court. 13 XV. FINAL DISPOSITION 14 After the final disposition of this Action, as defined in paragraph 4, within 60 15 days of a written request by the Designating Party, each Receiving Party must 16 return all Protected Material to the Producing Party or destroy such material. As 17 used in this subdivision, “all Protected Material” includes all copies, abstracts, 18 compilations, summaries, and any other format reproducing or capturing any of the 19 Protected Material. Whether the Protected Material is returned or destroyed, the 20 Receiving Party must submit a written certification to the Producing Party (and, if 21 not the same person or entity, to the Designating Party) by the 60 day deadline that 22 (1) identifies (by category, where appropriate) all the Protected Material that was 23 returned or destroyed and (2) affirms that the Receiving Party has not retained any 24 copies, abstracts, compilations, summaries or any other format reproducing or 25 capturing any of the Protected Material. Notwithstanding this provision, Counsel 26 are entitled to retain an archival copy of all pleadings, motion papers, trial, 27 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 28 and trial exhibits, expert reports, attorney work product, and consultant and expert 14 STIPULATED PROTECTIVE ORDER 1 work product, even if such materials contain Protected Material. Any such archival 2 copies that contain or constitute Protected Material remain subject to this Protective 3 Order as set forth in Section 4 (DURATION). 4 XVI. VIOLATION 5 Any violation of this Order may be punished by appropriate measures 6 including, without limitation, contempt proceedings and/or monetary sanctions. 7 8 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD 9 10 11 DATED: NOVEMBER 3, 2023 /s/ Mary Swan Lewis /s/ David Eugene Lewis 12 13 14 15 16 17 MARY SWAN LEWIS DAVID EUGENE LEWIS Plaintiffs In PRO SE /s/ Jonathan D. Redford 18 19 20 JONATHAN D. REDFORD CARPENTER, ROTHANS & DUMONT, LLP. Attorney for Defendants 21 22 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. DATED: November 13, 2023 24 25 26 27 HON. O ROZELLA O AA A. O OLIVER United States Magistrate Judge 28 15 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of ___________ [insert formal name of the case and the 9 number and initials assigned to it by the court]. I agree to comply with and to be 10 bound by all the terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions and 12 punishment in the nature of contempt. I solemnly promise that I will not disclose in 13 any manner any information or item that is subject to this Stipulated Protective 14 Order to any person or entity except in strict compliance with the provisions of this 15 Order. 16 I further agree to submit to the jurisdiction of the United States District Court for 17 the Central District of California for enforcing the terms of this Stipulated 18 Protective Order, even if such enforcement proceedings occur after termination of 19 this action. 20 I hereby appoint __________________________ [print or type full name] of 21 _______________________________________ [print or type full address and 22 telephone number] as my California agent for service of process in connection with 23 this action or any proceedings related to enforcement of this Stipulated Protective 24 Order. 25 Date: ______________________________________ 26 City and State where sworn and signed: _________________________________ 27 Printed name: _______________________________ 28 Signature: __________________________________ 16 STIPULATED PROTECTIVE ORDER

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