Jane D.M. Doe v. County of Los Angeles

• Court: District Court, C.D. California
• Decided: February 4, 2022
• Docket: 2:20-cv-03218
• Status: Unknown

Opinion

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1 LUIS A. CARRILLO, State Bar Number 70398 MICHAEL S. CARRILLO, State Bar Number 258878 2 CARRILLO LAW FIRM, LLP 3 1499 Huntington Drive, Suite 402 South Pasadena, California 91030 4 Telephone: (626) 799-9375 5 Facsimile: (626) 799-9380 NOTE: CHANGES MADE BY THE COURT

6 Attorneys for Plaintiff 7

8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 JANE D.M. DOE, a minor, by and through CASE NO.: 2:20-CV-03218-DDP-JPRx her Gaurdian ad Litem, Ivette Rodriguez, Hon. Dean D. Pregerson, Crtm. 9C, 9th Flr. 12 Hon. Mag. Jean P. Rosenbluth, Crtm. 690, 6th Flr. Plaintiff, 13

14 v. STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER 15 COUNTY OF LOS ANGELES; and DOES 1 THROUGH 10, inclusive, 16 Defendants. 17

18 19 20 1. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary, or private information for which special protection from public disclosure 23 and from use for any purpose other than prosecuting this litigation may be warranted. 24 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 25 Stipulated Protective Order. The parties acknowledge that this Stipulated Protective 26 Order does not confer blanket protections on all disclosures or responses to discovery 27 and that the protection it affords from public disclosure and use extends only to the 28 limited information or items that are entitled to confidential treatment under the

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1 applicable legal principles. The parties further acknowledge, as set forth in Section 13.3 2 below, that this Stipulated Protective Order does not entitle them to file confidential 3 information under seal; Local Rule 79-5 sets forth the procedures that must be followed 4 and the standards that will be applied when a party seeks permission from the Court to 5 file material under seal. Discovery in this action is likely to involve production of 6 confidential, proprietary, or private information for which special protection from 7 public disclosure and from use for any purpose other than prosecuting this litigation 8 may be warranted. 9 2. GOOD CAUSE STATEMENT 10 This action involves the County of Los Angeles and members of the Los Angeles 11 County Sheriff’s Department. Plaintiff is seeking materials and information that 12 Defendant, the County of Los Angeles, (“County”) maintains as confidential, such as 13 information that may be within the personnel files of the deputy sheriffs involved in this 14 incident, Internal Affairs materials and information, video recordings, audio recordings, 15 photographs, Force Investigation materials and information and other administrative 16 materials and information currently in the possession of the County and which the 17 County believes need special protection from public disclosure and from use for any 18 purpose other than prosecuting this litigation. Plaintiff is also seeking official 19 information contained in the personnel files of the deputy sheriffs involved in the 20 subject incident, which the County maintains as strictly confidential and which the 21 County believes need special protection from public disclosure and from use for any 22 purpose other than prosecuting this litigation. 23 The County asserts that the confidentiality of the materials and information 24 sought by Plaintiff is recognized by California and federal law, as evidenced inter alia 25 by California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. 26 Cal., 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The County has 27 not publicly released certain information referenced above except under protective 28 order, as required by law, or pursuant to a court order, if at all.

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1 The County contends that absent a protective order delineating the 2 responsibilities of nondisclosure on the part of the parties hereto, there is a specific risk 3 of unnecessary and undue disclosure by one or more of the many attorneys, secretaries, 4 law clerks, paralegals and expert witnesses involved in this case, as well as the corollary 5 risk of embarrassment, harassment and professional and legal harm on the part of the 6 LASD deputies referenced in the materials and information. 7 The County also contends that the unfettered disclosure of the materials and 8 information, absent a protective order, would allow the media to share this information 9 with potential jurors in the area, impacting the rights of the County herein to receive a 10 fair trial. 11 Accordingly, to expedite the flow of information, to facilitate the prompt 12 resolution of disputes over confidentiality of discovery materials, to adequately protect 13 information the parties are entitled to keep confidential, to ensure that the parties are 14 permitted reasonable necessary uses of such material in preparation for and in the 15 conduct of trial, to address their handling at the end of the litigation, and serve the ends 16 of justice, a protective order for such information is justified in this matter. It is the 17 intent of the parties that information will not be designated as confidential for tactical 18 reasons and that nothing be so designated without a good faith belief that it has been 19 maintained in a confidential, non-public manner, and there is good cause why it should 20 not be part of the public record of this case. 21 Plaintiff does not agree with and does not stipulate to the County’s contentions 22 stated herein, and nothing in this Stipulation or its associated Order shall resolve the 23 parties’ disagreement, or bind them, concerning the legal statements and claimed 24 privileges set forth above. However, Plaintiff agrees that there is Good Cause for a 25 Protective Order so as to preserve the respective interests of the parties while 26 streamlining the process of resolving any disagreements. 27 The parties jointly contend that there is typically a particularized need for 28 protection as to any medical or psychotherapeutic records and autopsy photographs,

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1 because of the privacy interests at stake therein. Because of these sensitive interests, a 2 Court Order should address these documents rather than a private agreement between 3 the parties. 4 The parties therefore stipulate that there is Good Cause for, and hereby jointly 5 request that the honorable Court issue a Protective Order regarding confidential 6 documents consistent with the terms and provisions of this Stipulation. However, the 7 entry of a Protective Order by the Court pursuant to this Stipulation shall not be 8 construed as any ruling by the Court on the aforementioned legal statements or privilege 9 claims in this section, nor shall this section be construed as part of any such Court Order. 10 3. DEFINITIONS 11 3.1 Action: Jane D.M. Doe v. County of Los Angeles, et al, Case No. 2:20- 12 CV-03218-DDP-JPRx 13 3.2 Challenging Party: A Party or Nonparty that challenges the designation 14 of information or items under this Stipulated Protective Order. 15 3.3 “CONFIDENTIAL” Information or Items: Information (regardless of 16 how it is generated, stored or maintained) or tangible things that qualify for protection 17 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 18 Statement. This also includes (1) any information copied or extracted from the 19 Confidential information; (2) all copies, excerpts, summaries, abstracts or compilations 20 of Confidential information; and (3) any testimony, conversations, or presentations that 21 might reveal Confidential information. 22 3.4 Counsel: Outside Counsel of Record and In-House Counsel (as well as 23 their support staff). 24 3.5 Designating Party: A Party or Nonparty that designates information or 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 3.6 Disclosure or Discovery Material: All items or information, regardless 28 of the medium or manner in which it is generated, stored, or maintained (including,

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1 among other things, testimony, transcripts, and tangible things), that are produced or 2 generated in disclosures or 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 counsel to serve as an 5 expert witness or as a consultant in this Action. 6 3.8 Final Disposition: when this Action has been fully and completely 7 terminated by way of settlement, dismissal, trial, appeal and/or remand to state court. 8 3.9 In-House Counsel: Attorneys who are employees of a party to this 9 Action. In-House Counsel does not include Outside Counsel of Record or any other 10 outside counsel. 11 3.10 Nonparty: Any natural person, partnership, corporation, association or 12 other legal entity not named as a Party to this action. 13 3.11 Outside Counsel of Record: Attorneys who are not employees of a party 14 to this Action but are retained to represent or advise a party to this Action and have 15 appeared in this Action on behalf of that party or are affiliated with a law firm that has 16 appeared on behalf of that party, and includes support staff. 17 3.12 Party: Any party to this Action, including all of its officers, directors, 18 boards, departments, divisions, employees, consultants, retained experts, In-House 19 Counsel, and Outside Counsel of Record (and their support staffs). 20 3.13 Producing Party: A Party or Nonparty that produces Disclosure or 21 Discovery Material in this Action. 22 3.14 Professional Vendors: Persons or entities that provide litigation support 23 services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 25 their employees and subcontractors. 26 3.15 Protected Material: Any Disclosure or Discovery Material that is 27 designated as “CONFIDENTIAL.” 28

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1 3.16 Receiving Party: A Party that receives Disclosure or Discovery Material 2 from a Producing Party. 3 4. SCOPE 4 The protections conferred by this Stipulated Protective Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or extracted 6 from Protected Material; (2) all copies, excerpts, abstracts, summaries, or compilations 7 of Protected Material; and (3) any testimony, conversations, or presentations by Parties 8 or their Counsel that might reveal Protected Material. 9 Any use of Protected Material at trial shall be governed by the orders of the trial 10 judge. This Stipulated Protective Order does not govern the use of Protected Material 11 at trial. 12 5. DURATION 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and that is 15 introduced or admitted as an exhibit at trial becomes public and will be presumptively 16 available to all members of the public, including the press, unless compelling reasons 17 supported by specific factual findings to proceed otherwise are made to the trial judge 18 in advance of the trial. See Kamakana v. County and County of Honolulu, 447 F.3d 19 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing 20 documents produced in discovery from “compelling reasons” standard when merits- 21 related documents are part of court record). Accordingly, the terms of this protective 22 order do not extend beyond the commencement of the trial as to the CONFIDENTIAL 23 information and materials introduced or admitted as an exhibit at trial. 24 /// 25 /// 26 6. DESIGNATING PROTECTED MATERIAL 27 6.1 Exercise of Restraint and Care in Designating Material for Protection. 28 Each Party or Nonparty that designates information or items for protection under this

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1 Stipulated Protective Order must take care to limit any such designation to specific 2 material that qualifies under the appropriate standards. The Designating Party must 3 designate for protection only those parts of material, documents, items or oral or 4 written communications that qualify so that other portions of the material, documents, 5 items or communications for which protection is not warranted are not swept 6 unjustifiably within the ambit of this Stipulated Protective Order. 7 Mass, indiscriminate or routinized designations are prohibited. Designations that 8 are shown to be clearly unjustified or that have been made for an improper purpose 9 (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating Party 11 to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 6.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Stipulated Protective Order(see, e.g., second paragraph of section 6.2(a) below), or 17 as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 18 protection under this Stipulated Protective Order must be clearly so designated before 19 the material is disclosed or produced. 20 Designation in conformity with this Stipulated Protective Order requires: 21 (a) for information in documentary form (e.g., paper or electronic documents, 22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” or words of a 24 similar effect, and that includes the case name and case number (hereinafter 25 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 26 portion of the material on a page qualifies for protection, the Producing Party also must 27 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 28 margins).

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1 A Party or Nonparty that makes original documents available for inspection need 2 not designate them for protection until after the inspecting Party has indicated which 3 documents it would like copied and produced. During the inspection and before the 4 designation, all of the material made available for inspection shall be deemed 5 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 6 copied and produced, the Producing Party must determine which documents, or portions 7 thereof, qualify for protection under this Stipulated Protective Order. Then, before 8 producing the specified documents, the Producing Party must affix the 9 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 10 portion of the material on a page qualifies for protection, the Producing Party also must 11 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 12 margins). 13 (b) for testimony given in depositions that the Designating Party identifies the 14 Disclosure or Discovery Material on the record, before the close of the deposition all 15 protected testimony. 16 (c) for information produced in some form other than documentary and for any 17 other tangible items, that the Producing Party affix in a prominent place on the exterior 18 of the container or containers in which the information is stored the legend 19 “CONFIDENTIAL.” If only a portion or portions of the information warrants 20 protection, the Producing Party, to the extent practicable, shall identify the protected 21 portion(s). 22 6.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive the 24 Designating Party’s right to secure protection under this Stipulated Protective Order for 25 such material. Upon timely correction of a designation, the Receiving Party must make 26 reasonable efforts to assure that the material is treated in accordance with the provisions 27 of this Stipulated Protective Order. 28 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS

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1 7.1 Timing of Challenges. Any Party or Nonparty may challenge a 2 designation of confidentiality at any time that is consistent with the Court’s Scheduling 3 Order. 4 7.2 Meet and Confer. The Challenging Party shall initiate the dispute 5 resolution process under Local Rule 37.1 et seq. 6 7.3 Burden of Persuasion. The burden of persuasion in any such challenge 7 proceeding shall be on the Designating Party. Frivolous challenges, and those made for 8 an improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 9 other parties) may expose the Challenging Party to sanctions. Unless the Designating 10 Party has waived or withdrawn the confidentiality designation, all parties shall continue 11 to afford the material in question the level of protection to which it is entitled under the 12 Producing Party’s designation until the Court rules on the challenge. 13 8. ACCESS TO AND USE OF PROTECTED MATERIAL 14 8.1 Basic Principles. A Receiving Party may use Protected Material that is 15 disclosed or produced by another Party or by a Nonparty in connection with this Action 16 only for prosecuting, defending or attempting to settle this Action. Such Protected 17 Material may be disclosed only to the categories of persons and under the conditions 18 described in this Stipulated Protective Order. When the Action reaches a final 19 disposition, a Receiving Party must comply with the provisions of section 14 below 20 (FINAL DISPOSITION). 21 Protected Material must be stored and maintained by a Receiving Party at a 22 location and in a secure manner that ensures that access is limited to the persons 23 authorized under this Stipulated Protective Order. 24 8.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 25 otherwise ordered by the court or permitted in writing by the Designating Party, a 26 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 27 only to: 28

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1 (a) The Receiving Party’s Counsel of Record in this Action, as well as employees 2 of said Counsel of Record to whom it is reasonably necessary to disclose the 3 information for this Action; 4 (b) The officers, directors, and employees (including In-House Counsel) of the 5 Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) Experts of the Receiving Party to whom disclosure is reasonably necessary 7 for this Action and who have signed the “Acknowledgment and Agreement to Be 8 Bound” (Exhibit A); 9 (d) The Court and its personnel; 10 (e) Court reporters and their staff; 11 (f) Professional jury or trial consultants, mock jurors, and Professional Vendors 12 to whom disclosure is reasonably necessary for this Action and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (g) The author or recipient of a document containing the information or a 15 custodian or other person who otherwise possessed or knew the information; 16 (h) During their depositions, witnesses, and attorneys for witnesses, in the Action 17 to whom disclosure is reasonably necessary provided: (i) the deposing party requests 18 that the witness sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 and (ii) the witness will not be permitted to keep any confidential information unless 20 they sign the “Acknowledgment and Agreement to Be Bound,” unless otherwise agreed 21 by the Designating Party or ordered by the Court. Pages of transcribed deposition 22 testimony or exhibits to depositions that reveal Protected Material may be separately 23 bound by the court reporter and may not be disclosed to anyone except as permitted 24 under this Stipulated Protective Order; and 25 (i) Any mediator or settlement officer, and their supporting personnel, mutually 26 agreed upon by any of the parties engaged in settlement discussions or appointed by the 27 Court and, for nonjudicial officers, who have signed the “Acknowledgment and 28 Agreement to Be Bound” (Exhibit A).

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1 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation that 4 compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) Promptly notify in writing the Designating Party. Such notification shall 7 include a copy of the subpoena or court order unless prohibited by law; 8 (b) Promptly notify in writing the party who caused the subpoena or order to 9 issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Stipulated Protective Order. Such notification 11 shall include a copy of this Stipulated Protective Order; and 12 (c) Cooperate with respect to all reasonable procedures sought to be pursued by 13 the Designating Party whose Protected Material may be affected. 14 The Party served with the subpoena or court order shall not produce any 15 information designated in this action as “CONFIDENTIAL”, unless the Party has 16 obtained the Designating Party’s permission or an order from the court from which the 17 subpoena or order issued. Nothing in these provisions should be construed as 18 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 19 from another court. 20 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 21 PRODUCED IN THIS LITIGATION 22 10.1 Application. The terms of this Stipulated Protective Order are applicable 23 to information produced by a NonParty in this Action and designated as 24 “CONFIDENTIAL.” Such information produced by Nonparties in connection with this 25 litigation is protected by the remedies and relief provided by this Stipulated Protective 26 Order. Nothing in these provisions should be construed as prohibiting a Nonparty from 27 seeking additional protections. 28

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1 10.2 Notification. In the event that a Party is required, by a valid discovery 2 request, to produce a Nonparty’s confidential information in its possession, and the 3 Party is subject to an agreement with the Nonparty not to produce the Nonparty’s 4 confidential information, then the Party shall: 5 (a) Promptly notify in writing the Requesting Party and the Nonparty that 6 some or all of the information requested is subject to a confidentiality agreement 7 with a Nonparty; 8 (b) Promptly provide the Nonparty with a copy of the Stipulated Protective 9 Order in this Action, the relevant discovery request(s), and a reasonably specific 10 description of the information requested; and 11 (c) Make the information requested available for inspection by the 12 Nonparty, if requested. 13 10.3 Conditions of Production. If the Nonparty fails to seek a protective order 14 from this Court within fourteen (14) days of receiving the notice and accompanying 15 information, the Receiving Party may produce the Nonparty’s confidential information 16 responsive to the discovery request. If the Nonparty timely seeks a protective order, the 17 Receiving Party shall not produce any information in its possession or control that is 18 subject to the confidentiality agreement with the Nonparty before a determination by 19 the Court. Absent a court order to the contrary, the Nonparty shall bear the burden and 20 expense of seeking protection in this court of its Protected Material. 21 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 25 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 26 all unauthorized copies of the Protected Material, (c) inform the person or persons to 27 whom unauthorized disclosures were made of all the terms of this Stipulated Protective 28

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1 Order, and (d) request such person or persons to execute the “Acknowledgment and 2 Agreement to Be Bound” (Exhibit A). 3 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other protection, 7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 9 may be established in an e-discovery order that provides for production without prior 10 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 11 parties reach an agreement on the effect of disclosure of a communication or 12 information covered by the attorney-client privilege or work product protection, the 13 parties may incorporate their agreement in the Stipulated Protective Order submitted to 14 the Court provided the Court so allows. 15 13. MISCELLANEOUS 16 13.1 Right to Further Relief. Nothing in this Stipulated Protective Order 17 abridges the right of any person to seek its modification by the Court in the future. 18 13.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Stipulated Protective Order, no Party waives any right it otherwise would have to object 20 to disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use in evidence of any of the material covered by this Stipulated Protective 23 Order. 24 13.3 Filing Protected Material. A Party that seeks to file under seal any 25 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 26 only be filed under seal pursuant to a court order authorizing the sealing of the specific 27 Protected Material at issue. If a Party’s request to file Protected Material under seal is 28

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1 denied by the court, then the Receiving Party may file the information in the public 2 record unless otherwise instructed by the Court. 3 4 14. FINAL DISPOSITION 5 After the FINAL DISPOSITION of this Action, as defined in paragraph 3.8, 6 within sixty (60) days of a written request by the Designating Party, each Receiving 7 Party must return all Protected Material to the Producing Party. As used in this 8 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 9 summaries, and any other format reproducing or capturing any of the Protected 10 Material. The Receiving Party must submit a written certification to the Producing 11 Party (and, if not the same person or entity, to the Designating Party) by the 60-day 12 deadline that (1) identifies (by category, where appropriate) all the Protected Material 13 that was returned and (2) affirms that the Receiving Party has not retained any copies, 14 abstracts, compilations, summaries or any other format reproducing or capturing any of 15 the Protected Material. Notwithstanding this provision, Counsel is entitled to retain an 16 archival copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; 17 legal 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 15. VIOLATION 23 Any violation of this Stipulated Protective Order may be punished by appropriate 24 measures including, without limitation, contempt proceedings and/or monetary 25 sanctions. 26 27 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD: 28

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1 || Dated: February 2, 2022 CARRILLO LAW FIRM LLP 3 By: __/s/ Luis A. Carrillo 4 LUIS A. CARRILLO, Attorneys for Plaintiff, JAN D.M. DOE 6 || Dated: January 31, 2022 CARPENTER, ROTHANS & DUMONT 8 By: _/s/ Jill Williams 9 JILL WILLIAMS, Attorneys for Defendant 10 COUNTY OF LOS ANGELES

11 12 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 13

15 || DATED: February 4, 2022 16 HONORABLE JEAN P. ROSENBLUTH U.S. DISTRICT COURT MAGISTRATE JUDGE 17 18 19 20 21 22 23 24 25 26 ATTACHMENT “A” ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 28

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1 2 I, [full name], of 3 [address], declare under penalty of perjury that I have read in its 4 entirety and understand the Stipulated Protective Order that was issued by the United 5 States District Court for the Central District of California on [date] in 6 the case of Jane D.M. Doe v. County of Los Angeles, et al, United States District Court 7 for the Central District of California, Central Division, Case No. 2:20-CV-03218-DDP- 8 JPRx. I agree to comply with and to be bound by all the terms of this Stipulated 9 Protective Order, and I understand and acknowledge that failure to so comply could 10 expose me to sanctions and punishment in the nature of contempt. I solemnly promise 11 that I will not disclose in any manner any information or item that is subject to this 12 Stipulated Protective Order to any person or entity except in strict compliance with the 13 provisions of this Stipulated Protective Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of this 17 action. I hereby appoint [full name] of 18 [address and telephone number] as my California 19 agent for service of process in connection with this action or any proceedings related to 20 enforcement of this Stipulated Protective Order. 21 22 Signature: 23 Printed Name: 24 Date: 25 County and State Where Sworn and Signed: 26 27 28