Miguel Marin v. AT and T Mobility Services LLC et al

Filing 26

STIPULATED PROTECTIVE ORDER by Magistrate Judge Patricia Donahue re Stipulation for Protective Order #24 . See document for details. (es)

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 1 of 16 Page ID #:227

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16

MICHAEL J. JAURIGUE (SB# 208123)
LIANA M. KHACHATOURIAN (SB# 337126)
[e-mail]
[e-mail]
JAURIGUE LAW GROUP
300 W. Glenoaks Blvd. Suite 300
Glendale, California 91202
Telephone: [phone]
Facsimile: 888-879-1697
Attorneys for Plaintiff
MIGUEL MARIN
ELIZABETH A. BROWN (SB# 235429)
JENNIFER SVANFELDT (SB# 233248)
CHRISTINA C.K. SEMMER (SB# 270909)
[e-mail]
[e-mail]
[e-mail]
GBG LLP
633 West 5th Street, Suite 1500
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
AT&T MOBILITY SERVICES LLC

17

UNITED STATES DISTRICT COURT

18

CENTRAL DISTRICT OF CALIFORNIA

19
20
21

MIGUEL MARIN,
Plaintiff,

22
23
24
25
26

vs.

Case No. 2:23-cv-03747-MWF-MAA
[PROPOSED]
 STIPULATED
PROTECTIVE ORDER

AT&T MOBILITY SERVICES LLC and Judge:
Dept.:
Does 1 through 50, inclusive,

Hon. Michael W. Fitzgerald
5A, First Street Courthouse

Defendants.

27
28
Case No. 2:23-cv-03747-MWF-MAA

 STIPULATED
[PROPOSED]
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 2 of 16 Page ID #:228

1

1.

PURPOSES AND LIMITATIONS

2

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 be

5

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

6

the following Stipulated Protective Order.

7

Stipulated Protective Order does not confer blanket protections on all disclosures or

8

responses to discovery and that the protection it affords from public disclosure and

9

use extends only to the limited information or items that are entitled to confidential

10

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

11

set forth in Section 13.3 below, that this Stipulated Protective Order does not entitle

12

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

13

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

14

seeks permission from the Court to file material under seal.

15

2.

The parties acknowledge that this

GOOD CAUSE STATEMENT

16

This action is likely to involve the exchange of records and information

17

referencing or otherwise reflecting certain business practices, internal procedures,

18

sensitive internal investigations, customer and employee information, and other

19

valuable research, development, commercial, financial, technical and/or proprietary

20

information for which special protection from public disclosure and from use for any

21

purpose other than prosecution of this action is warranted. Such confidential and

22

proprietary materials and information consist of, among other things, confidential

23

business or financial information, information regarding confidential business

24

practices, or other confidential research, development, or commercial information

25

(including information implicating privacy rights of third parties), information

26

otherwise generally unavailable to the public, or which may be privileged or

27

otherwise protected from disclosure under state or federal statutes, court rules, case

28

decisions, or common law. Accordingly, to expedite the flow of information, to
Case No. 2:23-cv-03747-MWF-MAA

-1-


[PROPOSED] STIPULATED
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 3 of 16 Page ID #:229

1

facilitate the prompt resolution of disputes over confidentiality of discovery

2

materials, to adequately protect information the parties are entitled to keep

3

confidential, to ensure that the parties are permitted reasonable necessary uses of such

4

material in preparation for and in the conduct of trial, to address their handling at the

5

end of the litigation, and to serve the ends of justice, a protective order for such

6

information is justified in this matter. It is the intent of the parties that information

7

will not be designated as confidential for tactical reasons and that nothing be so

8

designated without a good faith belief that it has been maintained in a confidential,

9

non-public manner, and there is good cause why it should not be part of the public

10

record of this case.

11

3.

12

DEFINITIONS
3.1.

Action: Miguel Marin v. AT&T Mobility Services LLC and Does 1

13

through 50, inclusive (C.D. Cal. Case No. 2:23-cv-03747-MWF-

14

MAA).

15

3.2.

16
17

Challenging Party: A Party or Nonparty that challenges the designation
of information or items under this Stipulated Protective Order.

3.3.

“CONFIDENTIAL” Information or Items: Information (regardless of

18

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

19

qualify for protection under Federal Rule of Civil Procedure 26(c), and

20

as specified above in the Good Cause Statement.

21

3.4.

22
23

Counsel: Outside Counsel of Record and In-House Counsel (as well as
their support staff).

3.5.

Designating Party: A Party or Nonparty that designates information or

24

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

25

“CONFIDENTIAL.”

26

3.6.

Disclosure or Discovery Material: All items or information, regardless

27

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

28

maintained (including, among other things, testimony, transcripts, and
Case No. 2:23-cv-03747-MWF-MAA

-2-

 STIPULATED
[PROPOSED]
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 4 of 16 Page ID #:230

1

tangible things), that is produced or generated in disclosures or

2

responses to discovery in this matter.

3

3.7.

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

4

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

5

counsel to serve as an expert witness or as a consultant in this Action.

6

3.8.

In-House Counsel: Attorneys who are employees of a party to this

7

Action. In-House Counsel does not include Outside Counsel of Record

8

or any other outside counsel.

9
10
11

3.9.

Nonparty: Any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.

3.10. Outside Counsel of Record: Attorneys who are not employees of a

12

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

13

this Action and have appeared in this Action on behalf of that party or

14

are affiliated with a law firm which has appeared on behalf of that

15

party, and includes support staff.

16

3.11. Party: Any party to this Action, including all of its officers, directors,

17

employees, consultants, retained experts, In-House Counsel, and

18

Outside Counsel of Record (and their support staffs).

19
20
21

3.12. Producing Party: A Party or Nonparty that produces Disclosure or
Discovery Material in this Action.
3.13. Professional Vendors: Persons or entities that provide litigation

22

support services (e.g., photocopying, videotaping, translating,

23

preparing exhibits or demonstrations, and organizing, storing, or

24

retrieving data in any form or medium) and their employees and

25

subcontractors.

26
27
28

3.14. Protected Material: Any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”
3.15. Receiving Party: A Party that receives Disclosure or Discovery
Case No. 2:23-cv-03747-MWF-MAA

-3-

 STIPULATED
[PROPOSED]
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 5 of 16 Page ID #:231

1
2

Material from a Producing Party.
4.

SCOPE

3

The protections conferred by this Stipulated Protective Order cover not only

4

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

5

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

6

and (3) any testimony, conversations, or presentations by Parties or their Counsel that

7

might reveal Protected Material.

8

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

9

trial judge. This Stipulated Protective Order does not govern the use of Protected

10

Material at trial.

11

5.

DURATION

12

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

13

confidential or maintained pursuant to this Stipulated Protective Order becomes

14

public and presumptively will be available to all members of the public, including

15

the press, unless compelling reasons supported by specific factual findings to proceed

16

otherwise are made to the trial judge in advance of the trial. See Kamakana v. City

17

and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing

18

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

19

“compelling reasons” standard when merits-related documents are part of court

20

record). Accordingly, the terms of this Stipulated Protective Order do not extend

21

beyond the commencement of the trial.

22
23

6.

DESIGNATING PROTECTED MATERIAL
6.1.

Exercise of Restraint and Care in Designating Material for Protection.

24

Each Party or Nonparty that designates information or items for

25

protection under this Stipulated Protective Order must take care to limit

26

any such designation to specific material that qualifies under the

27

appropriate standards.

The Designating Party must designate for

28
Case No. 2:23-cv-03747-MWF-MAA

-4-

 STIPULATED
[PROPOSED]
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 6 of 16 Page ID #:232

1

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

2

written communications that qualify so that other portions of the

3

material, documents, items, or communications for which protection is

4

not warranted are not swept unjustifiably within the ambit of this

5

Stipulated Protective Order.

6

Mass, indiscriminate, or routinized designations are prohibited.

7

Designations that are shown to be clearly unjustified or that have been

8

made for an improper purpose (e.g., to unnecessarily encumber the case

9

development process or to impose unnecessary expenses and burdens

10
11

on other parties) may expose the Designating Party to sanctions.
6.2.

Manner and Timing of Designations.

12

Except as otherwise provided in this Stipulated Protective Order

13

(see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered,

14

Disclosure or Discovery Material that qualifies for protection under this

15

Stipulated Protective Order must be clearly so designated before the

16

material is disclosed or produced.

17

Designation in conformity with this Stipulated Protective Order

18

requires the following:

19

(a)

For information in documentary form (e.g., paper or electronic

20

documents, but excluding transcripts of depositions or other

21

pretrial or trial proceedings), that the Producing Party affix at a

22

minimum, the legend “CONFIDENTIAL” to each page that

23

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

24

material on a page qualifies for protection, the Producing Party

25

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

26

making appropriate markings in the margins).

27

A Party or Nonparty that makes original documents

28

available for inspection need not designate them for protection
Case No. 2:23-cv-03747-MWF-MAA

-5-


[PROPOSED] STIPULATED
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 7 of 16 Page ID #:233

1

until after the inspecting Party has indicated which documents it

2

would like copied and produced. During the inspection and

3

before the designation, all of the material made available for

4

inspection shall be deemed “CONFIDENTIAL.”

5

inspecting Party has identified the documents it wants copied and

6

produced, the Producing Party must determine which documents,

7

or portions thereof, qualify for protection under this Stipulated

8

Protective Order.

9

documents, the Producing Party must affix the legend

10

“CONFIDENTIAL” to each page that contains Protected

11

Material. If only a portion or portions of the material on a page

12

qualifies for protection, the Producing Party also must clearly

13

identify the protected portion(s) (e.g., by making appropriate

14

markings in the margins).

15

(b)

After the

Then, before producing the specified

For testimony given in depositions, that the Designating Party

16

identify the Disclosure or Discovery Material on the record,

17

before the close of the deposition, all protected testimony.

18

(c)

For information produced in nondocumentary form, and for any

19

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

20

place on the exterior of the container or containers in which the

21

information is stored the legend “CONFIDENTIAL.” If only a

22

portion or portions of the information warrants protection, the

23

Producing Party, to the extent practicable, shall identify the

24

protected portion(s).

25

6.3.

Inadvertent Failure to Designate.

26

If timely corrected, an inadvertent failure to designate qualified

27

information or items does not, standing alone, waive the Designating

28

Party’s right to secure protection under this Stipulated Protective Order
Case No. 2:23-cv-03747-MWF-MAA

-6-


[PROPOSED] STIPULATED
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 8 of 16 Page ID #:234

1

for such material.

2

Receiving Party must make reasonable efforts to assure that the material

3

is treated in accordance with the provisions of this Stipulated Protective

4

Order.

5

7.

6

Upon timely correction of a designation, the

CHALLENGING CONFIDENTIALITY DESIGNATIONS
7.1.

7

Timing of Challenges.
Any Party or Nonparty may challenge a designation of confidentiality

8

at any time that is consistent with the Court’s Scheduling Order.

9

7.2.

Meet and Confer.

10

The Challenging Party shall initiate the dispute resolution process,

11

which shall comply with Local Rule 37.1 et seq., and with Section 4 of Judge

12

Audero’s Procedures (“Mandatory Telephonic Conference for Discovery

13

Disputes”).1

14

7.3.

Burden of Persuasion.

15

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

16

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

17

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

18

parties) may expose the Challenging Party to sanctions.

19

Designating Party has waived or withdrawn the confidentiality designation, all

20

parties shall continue to afford the material in question the level of protection

21

to which it is entitled under the Producing Party’s designation until the Court

22

rules on the challenge.

23
24

8.

Unless the

ACCESS TO AND USE OF PROTECTED MATERIALS
8.1.

Basic Principles.

25

A Receiving Party may use Protected Material that is disclosed or

26

produced by another Party or by a Nonparty in connection with this Action

27

1

28

Judge Audero’s Procedures are available at
https://www.cacd.uscourts.gov/honorable-maria-audero.
Case No. 2:23-cv-03747-MWF-MAA

-7-

STIPULATED
[PROPOSED]
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 9 of 16 Page ID #:235

1

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

2

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

3

under the conditions described in this Stipulated Protective Order. When the

4

Action reaches a final disposition, a Receiving Party must comply with the

5

provisions of Section 14 below.

6

Protected Material must be stored and maintained by a Receiving Party

7

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

8

persons authorized under this Stipulated Protective Order.

9

8.2.

Disclosure of “CONFIDENTIAL” Information or Items.

10

Unless otherwise ordered by the Court or permitted in writing by the

11

Designating Party, a Receiving Party may disclose any information or item

12

designated “CONFIDENTIAL” only to:

13

(a)

The Receiving Party’s Outside Counsel of Record, as well as

14

employees of said Outside Counsel of Record to whom it is

15

reasonably necessary to disclose the information for this Action;

16

(b)

The officers, directors, and employees (including In-House

17

Counsel) of the Receiving Party to whom disclosure is

18

reasonably necessary for this Action;

19

(c)

Experts of the Receiving Party to whom disclosure is reasonably

20

necessary for this Action and who have signed the

21

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

22

(d)

The Court and its personnel;

23

(e)

Court reporters and their staff;

24

(f)

Professional jury or trial consultants, mock jurors, and

25

Professional Vendors to whom disclosure is reasonably

26

necessary or this Action and who have signed the

27

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

28

(g)

The author or recipient of a document containing the

Case No. 2:23-cv-03747-MWF-MAA

-8-

STIPULATED
[PROPOSED]
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 10 of 16 Page ID #:236

1

information or a custodian or other person who otherwise

2

possessed or knew the information;

3

(h)

During their depositions, witnesses, and attorneys for witnesses,

4

in the Action to whom disclosure is reasonably necessary

5

provided: (i) the deposing party requests that the witness sign

6

the “Acknowledgment and Agreement to Be Bound” (Exhibit

7

A); and (ii) the witness will not be permitted to keep any

8

confidential information unless they sign the “Acknowledgment

9

and Agreement to Be Bound,” unless otherwise agreed by the

10

Designating Party or ordered by the Court. Pages of transcribed

11

deposition testimony or exhibits to depositions that reveal

12

Protected Material may be separately bound by the court

13

reporter and may not be disclosed to anyone except as permitted

14

under this Stipulated Protective Order; and

15

(i)

Any mediator or settlement officer, and their supporting

16

personnel, mutually agreed upon by any of the parties engaged

17

in settlement discussions.

18
19
20
21
22
23

9.

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

that compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL,” that Party must:
(a)

shall include a copy of the subpoena or court order;

24
25
26
27
28

Promptly notify in writing the Designating Party. Such notification

(b)

Promptly notify in writing the party who caused the subpoena or order
to issue in the other litigation that some or all of the material covered
by the subpoena or order is subject to this Stipulated Protective Order.
Such notification shall include a copy of this Stipulated Protective

Case No. 2:23-cv-03747-MWF-MAA

-9-


[PROPOSED] STIPULATED
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 11 of 16 Page ID #:237

1

Order; and

2

(c)

Cooperate with respect to all reasonable procedures sought to be

3

pursued by the Designating Party whose Protected Material may be

4

affected.

5

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

6

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

7

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

8

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

9

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

10

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

11

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

12

to disobey a lawful directive from another court.

13

10.

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
10.1. Application.
The terms of this Stipulated Protective Order are applicable to
information produced by a Nonparty in this Action and designated as
“CONFIDENTIAL.” Such information produced by Nonparties in connection
with this litigation is protected by the remedies and relief provided by this
Stipulated Protective Order. Nothing in these provisions should be construed
as prohibiting a Nonparty from seeking additional protections.
10.2. Notification.
In the event that a Party is required, by a valid discovery request, to
produce a Nonparty’s confidential information in its possession, and the Party
is subject to an agreement with the Nonparty not to produce the Nonparty’s
confidential information, then the Party shall:
(a)

Promptly notify in writing the Requesting Party and the
Nonparty that some or all of the information requested is subject

Case No. 2:23-cv-03747-MWF-MAA

-10-


[PROPOSED] STIPULATED
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 12 of 16 Page ID #:238

1

to a confidentiality agreement with a Nonparty;

2

(b)

Promptly provide the Nonparty with a copy of the Stipulated

3

Protective Order in this Action, the relevant discovery

4

request(s), and a reasonably specific description of the

5

information requested; and

6

(c)

7

Make the information requested available for inspection by the
Nonparty, if requested.

8

10.3. Conditions of Production.

9

If the Nonparty fails to seek a protective order from this Court within

10

fourteen (14) days after receiving the notice and accompanying information,

11

the Receiving Party may produce the Nonparty’s confidential information

12

responsive to the discovery request. If the Nonparty timely seeks a protective

13

order, the Receiving Party shall not produce any information in its possession

14

or control that is subject to the confidentiality agreement with the Nonparty

15

before a determination by the Court. Absent a court order to the contrary, the

16

Nonparty shall bear the burden and expense of seeking protection in this Court

17

of its Protected Material.

18

11.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

19

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

20

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

21

Stipulated Protective Order, the Receiving Party immediately must (1) notify in

22

writing the Designating Party of the unauthorized disclosures, (2) use its best efforts

23

to retrieve all unauthorized copies of the Protected Material, (3) inform the person or

24

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

25

Stipulated Protective Order, and (4) request such person or persons to execute the

26

“Acknowledgment and Agreement to be Bound” (Exhibit A).

27
28
Case No. 2:23-cv-03747-MWF-MAA

-11-


[PROPOSED] STIPULATED
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 13 of 16 Page ID #:239

1

12.

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain

inadvertently produced material is subject to a claim of privilege or other protection,
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
may be established in an e-discovery order that provides for production without prior
privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
parties reach an agreement on the effect of disclosure of a communication or
information covered by the attorney-client privilege or work product protection, the
parties may incorporate their agreement in the Stipulated Protective Order submitted
to the Court.
13.

MISCELLANEOUS
13.1. Right to Further Relief.
Nothing in this Stipulated Protective Order abridges the right of any
person to seek its modification by the Court in the future.
13.2. Right to Assert Other Objections.
By stipulating to the entry of this Stipulated Protective Order, no Party
waives any right it otherwise would have to object to disclosing or producing
any information or item on any ground not addressed in this Stipulated
Protective Order. Similarly, no Party waives any right to object on any ground
to use in evidence of any of the material covered by this Stipulated Protective
Order.
13.3. Filing Protected Material.
A Party that seeks to file under seal any Protected Material must comply
with Local Rule 79-5. Protected Material may only be filed under seal pursuant
to a court order authorizing the sealing of the specific Protected Material at
issue. If a Party’s request to file Protected Material under seal is denied by the

Case No. 2:23-cv-03747-MWF-MAA

-12-

 STIPULATED
[PROPOSED]
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 14 of 16 Page ID #:240

1

Court, then the Receiving Party may file the information in the public record

2

unless otherwise instructed by the Court.

3

14.

FINAL DISPOSITION

4

After the final disposition of this Action, within sixty (60) days of a written

5

request by the Designating Party, each Receiving Party must return all Protected

6

Material to the Producing Party or destroy such material. As used in this subdivision,

7

“all Protected Material” includes all copies, abstracts, compilations, summaries, and

8

any other format reproducing or capturing any of the Protected Material. Whether

9

the Protected Material is returned or destroyed, the Receiving Party must submit a

10

written certification to the Producing Party (and, if not the same person or entity, to

11

the Designating Party) by the 60-day deadline that (1) identifies (by category, where

12

appropriate) all the Protected Material that was returned or destroyed and (2) affirms

13

that the Receiving Party has not retained any copies, abstracts, compilations,

14

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

15

Material. Notwithstanding this provision, Counsel is entitled to retain an archival

16

copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; legal

17

memoranda; correspondence; deposition and trial exhibits; expert reports; attorney

18

work product; and consultant and expert work product, even if such materials contain

19

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

20

Material remain subject to this Stipulated Protective Order as set forth in Section 5.

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28
Case No. 2:23-cv-03747-MWF-MAA

-13-


[PROPOSED] STIPULATED
PROTECTIVE ORDER

Case 2:23-cv-03747-MWF-PD Document 24 Filed 08/18/23 Page 16 of 16 Page ID #:242

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I, __________________________ [full name], of

4

_____________________________ [address], declare under penalty of perjury that

5

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

6

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

7

__________________ [date] in the case of Miguel Marin v. AT&T Mobility

8

Services LLC et al., C.D. Cal. Case No. 2:23-cv-03747-MWF-MAA. I agree to

9

comply with and to be bound by all the terms of this Stipulated Protective Order,

10

and I understand and acknowledge that failure to so comply could expose me to

11

sanctions and punishment in the nature of contempt. I solemnly promise that I will

12

not disclose in any manner any information or item that is subject to this Stipulated

13

Protective Order to any person or entity except in strict compliance with the

14

provisions of this Stipulated Protective Order.

15

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

16

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

17

Stipulated Protective Order, even if such enforcement proceedings occur after

18

termination of this action. I hereby appoint _______________________[full name]

19

of _______________________________________[address and telephone number]

20

as my California agent for service of process in connection with this action or any

21

proceedings related to enforcement of this Stipulated Protective Order.

22

Signature:

_____________________________

23

Printed Name:

_____________________________

24

Date:

_____________________________

25

City and State Where Sworn and Signed:

_____________________________

26
27
28
Case No. 2:23-cv-03747-MWF-MAA

-15-

[PROPOSED] STIPULATED

PROTECTIVE ORDER