Michael Epifanio Armijo v. CBS Studios Inc. et al

Filing 60

PROTECTIVE ORDER by Magistrate Judge Michael R. Wilner re Stipulation for Protective Order 57 . (see document for details) (hr)

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Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 1 of 16 Page ID #:678 1 ADAM LEVIN (SBN 156773) axl@msk.com 2 EMILY F. EVITT (SBN 261491) efe@msk.com 3 MITCHELL SILBERBERG & KNUPP LLP 2049 Century Park East, 18th Floor 4 Los Angeles, CA 90067-3120 Telephone: (310) 312-2000 5 Facsimile: (310) 312-3100 6 Attorneys for CBS Studios Inc. CBS/CTS, Inc. and CBS Broadcasting Inc. 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 13 14 WESTERN DISTRICT MICHAEL EPIFANIO ARMIJO, CASE NO. 2:23-cv-08426-GW-MRW District Judge George H. Wu Magistrate Judge Michael R. Wilner Plaintiff, v. STIPULATED PROTECTIVE ORDER CBS STUDIOS, INC., a Delaware 15 corporation; and DOES 1 through 100, inclusive, 16 Defendants. 17 ‫ ܆‬CHECK IF SUBMITTED WITHOUT MATERIAL MODIFICATIONS TO MRW FORM Filing Date: Trial Date: 18 19 20 21 22 23 24 25 26 27 Mitchell Silberberg & Knupp LLP 28 1 STIPULATED PROTECTIVE ORDER 20017549.1 October 5, 2023 October 29, 2024 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 2 of 16 Page ID #:679 1 1. INTRODUCTION 2 1.1 3 Discovery in this action is likely to involve production of confidential, PURPOSES AND LIMITATIONS 4 proprietary, or private information for which special protection from public 5 disclosure and from use for any purpose other than prosecuting this litigation may 6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 7 enter the following Stipulated Protective Order. The parties acknowledge that this 8 Order does not confer blanket protections on all disclosures or responses to 9 discovery and that the protection it affords from public disclosure and use extends 10 only to the limited information or items that are entitled to confidential treatment 11 under the applicable legal principles. The parties further acknowledge, as set forth 12 in Section 12.3, below, that this Stipulated Protective Order does not entitle them 13 to file confidential information under seal; Civil Local Rule 79-5 sets forth the 14 procedures that must be followed and the standards that will be applied when a 15 party seeks permission from the court to file material under seal. 16 1.2 GOOD CAUSE STATEMENT 17 This lawsuit arises from the alleged wrongful termination of Plaintiff 18 Michael Epifanio Armijo’s employment, and related claims. Therefore, documents 19 produced in this matter will include Plaintiff’s personnel file, W-2 forms, earnings 20 statements, and medical records and information. These documents are likely to 21 contain personal and confidential information including, but not limited to, 22 Plaintiff’s social security number, address, and earning information and medical 23 history. A protective order is necessary to protect this confidential information. 24 Additionally, a protective order is necessary to protect Plaintiff’s medical 25 information. A protective order may also be necessary to protect confidential 26 business information produced by Defendants, including documents that contain 27 personal information of employees not involved in this matter, documents Mitchell Silberberg & Knupp LLP 28 2 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 3 of 16 Page ID #:680 1 discussing internal human resource matters and internal policies and procedures, 2 and corporate organizational charts. 3 2. DEFINITIONS 4 2.1 Action: this pending federal law suit.Challenging Party: a Party or 5 Non-Party that challenges the designation of information or items under this Order. 6 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for 8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 9 the Good Cause Statement. 10 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 11 their support staff). 12 2.5 Designating Party: a Party or Non-Party that designates information 13 or items that it produces in disclosures or in responses to discovery as 14 “CONFIDENTIAL.” 15 2.6 Disclosure or Discovery Material: all items or information, regardless 16 of the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced 18 or generated in disclosures or responses to discovery in this matter. 19 2.7 Expert: a person with specialized knowledge or experience in a 20 matter pertinent to the litigation who has been retained by a Party or its counsel to 21 serve as an expert witness or as a consultant in this Action. 22 2.8 House Counsel: attorneys who are employees of a party to this 23 Action. House Counsel does not include Outside Counsel of Record or any other 24 outside counsel. 25 2.9 Non-Party: any natural person, partnership, corporation, association, 26 or other legal entity not named as a Party to this action. 27 Mitchell Silberberg & Knupp LLP 2.10 Outside Counsel of Record: attorneys who are not employees of a 28 party to this Action but are retained to represent or advise a party to this Action 3 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 4 of 16 Page ID #:681 1 and have appeared in this Action on behalf of that party or are affiliated with a law 2 firm which has appeared on behalf of that party, and includes support staff. 2.11 Party: any party to this Action, including all of its officers, directors, 3 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 6 7 Discovery Material in this Action. 2.13 Professional Vendors: persons or entities that provide litigation 8 9 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 and their employees and subcontractors. 2.14 Protected Material: any Disclosure or Discovery Material that is 12 13 designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery 14 15 Material from a Producing Party. 16 3. SCOPE 17 The protections conferred by this Stipulation and Order cover not only 18 Protected Material (as defined above), but also (1) any information copied or 19 extracted from Protected Material; (2) all copies, excerpts, summaries, or 20 compilations of Protected Material; and (3) any testimony, conversations, or 21 presentations by Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at trial will be governed by the orders of the 22 23 trial judge. This Order does not govern the use of Protected Material at trial. 24 4. DURATION 25 Even after final disposition of this litigation, the confidentiality obligations 26 imposed by this Order will remain in effect until a Designating Party agrees 27 otherwise in writing or a court order otherwise directs. Final disposition will be Mitchell Silberberg & Knupp LLP 28 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 4 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 5 of 16 Page ID #:682 1 with or without prejudice; and (2) final judgment herein after the completion and 2 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 3 including the time limits for filing any motions or applications for extension of 4 time pursuant to applicable law. 5 6 5. DESIGNATING PROTECTED MATERIAL 7 5.1 Exercise of Restraint and Care in Designating Material for Protection. 8 Each Party or Non-Party that designates information or items for protection under 9 this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. The Designating Party must designate 11 for protection only those parts of material, documents, items, or oral or written 12 communications that qualify so that other portions of the material, documents, 13 items, or communications for which protection is not warranted are not swept 14 unjustifiably within the ambit of this Order. 15 Mass, indiscriminate, or routinized designations are prohibited. 16 Designations that are shown to be clearly unjustified or that have been made for an 17 improper purpose (e.g., to unnecessarily encumber the case development process 18 or to impose unnecessary expenses and burdens on other parties) may expose the 19 Designating Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2 Manner and Timing of Designations. Except as otherwise provided in 24 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. Mitchell Silberberg & Knupp LLP 28 Designation in conformity with this Order requires: 5 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 6 of 16 Page ID #:683 (a) 1 for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains Protected Material. If only a portion or portions of the material on a page 6 qualifies for protection, the Producing Party also must clearly identify the 7 protected portion(s) (e.g., by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and 11 before the designation, all of the material made available for inspection will be 12 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 13 documents it wants copied and produced, the Producing Party must determine 14 which documents, or portions thereof, qualify for protection under this Order. 15 Then, before producing the specified documents, the Producing Party must affix 16 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 17 only a portion or portions of the material on a page qualifies for protection, the 18 Producing Party also must clearly identify the protected portion(s) (e.g., by making 19 appropriate markings in the margins). (b) 20 for testimony given in depositions that the Designating Party 21 identify the Disclosure or Discovery Material on the record, before the close of the 22 deposition all protected testimony. Alternatively, any Party may designate 23 deposition testimony as Protected Material by notifying all Parties in writing not 24 later than 30 days after receipt of the transcript of the specific pages and lines of 25 the transcript that should be treated as Protected Material. All deposition 26 transcripts shall be treated as “CONFIDENTIAL” for a period of 30 days after 27 initial receipt of the transcript. Mitchell Silberberg & Knupp LLP 28 6 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 7 of 16 Page ID #:684 (c) 1 for information produced in some form other than documentary 2 and for any other tangible items, that the Producing Party affix in a prominent 3 place on the exterior of the container or containers in which the information is 4 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 5 information warrants protection, the Producing Party, to the extent practicable, will 6 identify the protected portion(s). 5.3 7 Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 failure to designate qualified information or items does not, standing alone, waive 9 the Designating Party’s right to secure protection under this Order for such 10 material. Upon timely correction of a designation, the Receiving Party must make 11 reasonable efforts to assure that the material is treated in accordance with the 12 provisions of this Order. 13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 15 designation of confidentiality at any time that is consistent with the Court’s 16 Scheduling Order. 17 6.2 Meet and Confer. The Challenging Party will initiate the dispute 18 resolution process (and, if necessary, file a discovery motion) under Local Rule 19 37.1 et seq. 20 6.3 The burden of persuasion in any such challenge proceeding will be on 21 the Designating Party. Frivolous challenges, and those made for an improper 22 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 23 parties) may expose the Challenging Party to sanctions. Unless the Designating 24 Party has waived or withdrawn the confidentiality designation, all parties will 25 continue to afford the material in question the level of protection to which it is 26 entitled under the Producing Party’s designation until the Court rules on the 27 challenge. Mitchell Silberberg & Knupp LLP 28 7 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 8 of 16 Page ID #:685 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 Action only for prosecuting, defending, or attempting to settle this Action. Such 5 Protected Material may be disclosed only to the categories of persons and under 6 the conditions described in this Order. When the Action has been terminated, a 7 Receiving Party must comply with the provisions of section 13 below (FINAL 8 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 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 otherwise ordered by the court or permitted in writing by the Designating Party, a 14 Receiving Party may disclose any information or item designated 15 “CONFIDENTIAL” only to: (a) 16 the Receiving Party’s Outside Counsel of Record in this Action, 17 as well as employees of said Outside Counsel of Record to whom it is reasonably 18 necessary to disclose the information for this Action; (b) 19 the officers, directors, and employees (including House 20 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for 21 this Action; (c) 22 Experts (as defined in this Order) of the Receiving Party to 23 whom disclosure is reasonably necessary for this Action and who have signed the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (d) the Court and its personnel; 26 (e) court reporters and their staff; 27 Mitchell Silberberg & Knupp LLP 28 8 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 9 of 16 Page ID #:686 (f) 1 professional jury or trial consultants and mock jurors to whom 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) Professional Vendors; 5 (h) the author or recipient of a document containing the 6 information or a custodian or other person who otherwise possessed or knew the 7 information; (i) 8 during their depositions, witnesses, and attorneys for witnesses, 9 in the Action to whom disclosure is reasonably necessary provided: (1) the 10 deposing party requests that the witness sign the form attached as Exhibit A hereto; 11 and (2) they will not be permitted to keep any CONFIDENTIAL information 12 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 13 unless otherwise agreed by the Designating Party or ordered by the court. Pages of 14 transcribed deposition testimony or exhibits to depositions that reveal Protected 15 Material may be separately bound by the court reporter and may not be disclosed 16 to anyone except as permitted under this Stipulated Protective Order; and (j) 17 any mediator or settlement officer, and their supporting 18 personnel, mutually agreed upon by any of the parties engaged in settlement 19 discussions. 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 21 PRODUCED IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 23 that compels disclosure of any information or items designated in this Action as 24 “CONFIDENTIAL,” that Party must: (a) 25 promptly notify in writing the Designating Party. Such 26 notification will include a copy of the subpoena or court order; (b) 27 Mitchell Silberberg & Knupp LLP promptly notify in writing the party who caused the subpoena 28 or order to issue in the other litigation that some or all of the material covered by 9 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 10 of 16 Page ID #:687 1 the subpoena or order is subject to this Protective Order. Such notification will 2 include a copy of this Stipulated Protective Order; and (c) 3 cooperate with respect to all reasonable procedures sought to be 4 pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served 5 6 with the subpoena or court order will not produce any information designated in 7 this action as “CONFIDENTIAL” before a determination by the court from which 8 the subpoena or order issued, unless the Party has obtained the Designating Party’s 9 permission. The Designating Party will 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 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 14 PRODUCED IN THIS LITIGATION (a) 15 The terms of this Order are applicable to information produced 16 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 17 information produced by Non-Parties in connection with this litigation is protected 18 by the remedies and relief provided by this Order. Nothing in these provisions 19 should be construed as prohibiting a Non-Party from seeking additional 20 protections. (b) 21 In the event that a Party is required, by a valid discovery 22 request, to produce a Non-Party’s confidential information in its possession, and 23 the Party is subject to an agreement with the Non-Party not to produce the Non24 Party’s confidential information, then the Party will: (1) 25 promptly notify in writing the Requesting Party and the 26 Non-Party that some or all of the information requested is subject to a 27 confidentiality agreement with a Non-Party; Mitchell Silberberg & Knupp LLP 28 10 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 11 of 16 Page ID #:688 (2) 1 promptly provide the Non-Party with a copy of the 2 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 3 reasonably specific description of the information requested; and (3) 4 make the information requested available for inspection 5 by the Non-Party, if requested. (c) 6 If the Non-Party fails to seek a protective order from this court 7 within 14 days of receiving the notice and accompanying information, the 8 Receiving Party may produce the Non-Party’s confidential information responsive 9 to the discovery request. If the Non-Party timely seeks a protective order, the 10 Receiving Party will not produce any information in its possession or control that 11 is subject to the confidentiality agreement with the Non-Party before a 12 determination by the court. Absent a court order to the contrary, the Non-Party 13 will bear the burden and expense of seeking protection in this court of its Protected 14 Material. 15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 If a Receiving Party learns that, by inadvertence or otherwise, it has 17 disclosed Protected Material to any person or in any circumstance not authorized 18 under this Stipulated Protective Order, the Receiving Party must immediately (a) 19 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 20 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 21 the person or persons to whom unauthorized disclosures were made of all the terms 22 of this Order, and (d) request such person or persons to execute the 23 “Acknowledgment and Agreement to Be Bound” that is attached hereto as 24 Exhibit A. 25 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 26 OTHERWISE PROTECTED MATERIAL (a) 27 Mitchell Silberberg & Knupp LLP When a Producing Party gives notice to Receiving Parties that 28 certain inadvertently produced material is subject to a claim of privilege or other 11 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 12 of 16 Page ID #:689 1 protection, the obligations of the Receiving Parties are those set forth in Federal 2 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 3 whatever procedure may be established in an e-discovery order that provides for 4 production without prior privilege review. (b) 5 Pursuant to Federal Rule of Evidence 502(d) and (e), if a Party 6 inadvertently produces information subject to a claim of attorney-client privilege, 7 work-product protection, or any other legal privilege protecting information from 8 discovery, or subject to HIPAA or other privacy laws, such inadvertent disclosure 9 shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or 10 work-product protection with respect to the inadvertently produced information or 11 its related subject matter, either in this case or in any court or legal proceeding. (c) 12 If the Producing Party discovers that it has inadvertently 13 produced such privileged information, the Producing Party may, in good faith, 14 claw back such information by: (a) notifying all parties in writing of the 15 inadvertent disclosure; and (b) identifying any such inadvertently produced 16 information, by Bates Number or unique character string. The Receiving Parties 17 shall promptly: (a) return, destroy, sequester, or delete all copies of the 18 inadvertently disclosed information; (b) take reasonable steps to retrieve such 19 inadvertently disclosed information if it was disseminated by the Receiving Party 20 prior to such notification; and (c) provide a certification of counsel that all such 21 information has been returned, destroyed, sequestered, or deleted. (d) 22 If a Receiving Party has reason to believe that privileged 23 material has been inadvertently produced by the Producing Party, the Receiving 24 Party shall have an obligation to notify the Producing Party, sequester the material 25 in question, and not review, copy, distribute, or otherwise utilize the material until 26 the Producing Party confirms whether or not the material in question is in fact 27 subject to a claim of privilege. Mitchell Silberberg & Knupp LLP 28 12 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 13 of 16 Page ID #:690 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of 3 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 4 5 Protective Order no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in 7 this Stipulated Protective Order. Similarly, no Party waives any right to object on 8 any ground to use in evidence of any of the material covered by this Protective 9 Order. 12.3 Prior or Public Knowledge. This Protective Order shall not apply to 10 11 information that, prior to disclosure, is public knowledge, and the restrictions 12 contained in this Protective Order shall not apply to information that is, or after 13 disclosure becomes, public; was in the possession of the Party to whom disclosure 14 is made prior to disclosure other than documents and information that was already 15 protected by applicable labor or HIPAA laws and provisions; or is public 16 knowledge other than by an act or omission of the party to whom such disclosure is 17 made; or that is legitimately and independently acquired from a source not subject 18 to this Protective Order. 12.4 Filing Protected Material. A Party that seeks to file under seal any 19 20 Protected Material must comply with Civil Local Rule 79-5. Protected Material 21 may only be filed under seal pursuant to a court order authorizing the sealing of the 22 specific Protected Material at issue. If a Party’s request to file Protected Material 23 under seal is denied by the court, then the Receiving Party may file the information 24 in the public record unless otherwise instructed by the court. 25 13. FINAL DISPOSITION 26 After the final disposition of this Action, as defined in paragraph 4, within 27 60 days of a written request by the Designating Party, each Receiving Party must Mitchell Silberberg & Knupp LLP 28 return all Protected Material to the Producing Party or destroy such material. As 13 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 14 of 16 Page ID #:691 1 used in this subdivision, “all Protected Material” includes all copies, abstracts, 2 compilations, summaries, and any other format reproducing or capturing any of the 3 Protected Material. Whether the Protected Material is returned or destroyed, the 4 Receiving Party must submit a written certification to the Producing Party (and, if 5 not the same person or entity, to the Designating Party) by the 60 day deadline that 6 (1) identifies (by category, where appropriate) all the Protected Material that was 7 returned or destroyed and (2) affirms that the Receiving Party has not retained any 8 copies, abstracts, compilations, summaries or any other format reproducing or 9 capturing any of the Protected Material. Notwithstanding this provision, Counsel 10 are entitled to retain an archival copy of all pleadings, motion papers, trial, 11 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 12 and trial exhibits, expert reports, attorney work product, and consultant and expert 13 work product, even if such materials contain Protected Material. Any such 14 archival copies that contain or constitute Protected Material remain subject to this 15 Protective Order as set forth in Section 4 (DURATION). 16 14. Any willful violation of this Order may be punished by civil or criminal 17 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 18 authorities, or other appropriate action at the discretion of the Court. 19 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 20 Dated: July 8, 2024 21 CRISTAL CABRERA CRISTAL LAW OFFICES 22 By: 23 24 25 Dated: July 8, 2024 Cristal Cabrera Attorney for Michael Epifanio Armijo ADAM LEVIN EMILY F. EVITT 26 27 Mitchell Silberberg & Knupp LLP 28 14 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 15 of 16 Page ID #:692 MITCHELL SILBERBERG & KNUPP LLP 1 2 3 By: 4 5 Emily F. Evitt Attorneys for CBS Studios Inc., CBS/CTS, Inc. and CBS Broadcasting Inc. 6 OR RDERED. 7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 8 9 07/09/2024 DATED:_______________ 10 __________________________________ _________________________________ HON. MICHAEL WILNER N M ICHAEL R. R W ILNER United States Magistrate Judge 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Mitchell Silberberg & Knupp LLP 28 15 STIPULATED PROTECTIVE ORDER 20017549.1 Case 2:23-cv-08426-GW-MRW Document 57 Filed 07/08/24 Page 16 of 16 Page ID #:693 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [full name], of _________________ 4 [full address], declare under penalty of perjury that I have read in its entirety and 5 understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on [date] in the case of Michael 7 Epifanio Armijo v. CBS Studios, Inc. et al., No. 2:23-cv-08426-GW-MRW. I agree 8 to comply with and to be bound by all the terms of this Stipulated Protective Order 9 and I understand and acknowledge that failure to so comply could expose me to 10 sanctions and punishment in the nature of contempt. I solemnly promise that I will 11 not disclose in any manner any information or item that is subject to this Stipulated 12 Protective Order to any person or entity except in strict compliance with the 13 provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District 15 Court for the Central District of California for the purpose of enforcing the terms 16 of this Stipulated Protective Order, even if such enforcement proceedings occur 17 after termination of this action. I hereby appoint __________________________ 18 [full name] of _______________________________________ [full address and 19 telephone number] as my California agent for service of process in connection 20 with this action or any proceedings related to enforcement of this Stipulated 21 Protective Order. 22 Date: ______________________________________ 23 City and State where signed: _________________________________ 24 Printed name: _______________________________ 25 Signature: __________________________________ 26 27 Mitchell Silberberg & Knupp LLP 28 16 STIPULATED PROTECTIVE ORDER 20017549.1

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