Case □□□□□□□□□□□□□□□□□□□□□□ Document 32 Filed 05/12/22 Page1of17 Page ID#:177 46 8 UNITED STATES DISTRICT COURT 3 ze 9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION qESs z g5e 11 || SARAH JAFARI, Case No. 2:22-cv-00305-DSF (GJSx) [888 12 Plaintiff, PROPOSED) STIPULATED a pad ‘6 ROTECTIVE ORDER Soe Assigned to Hon. Dale S. Fischer, = unicipal entity: RONRAD THIEME, | “ou” "7 15 an Individual, DOES 1-10, inclusive, 16 Defendants. WW 18 19. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary or private information for which special protection from public 22 disclosure and from use for any purpose other than prosecuting this litigation may 23 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 24 enter the following Stipulated Protective Order. The parties acknowledge that this 25 ae This Stipulated Protective Order is substantially based on the model protective 27 order provided under Magistrate Judge Gail J. Standish’s Procedures. 28
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1 Order does not confer blanket protections on all disclosures or responses to 2 discovery and that the protection it affords from public disclosure and use extends 3 only to the limited information or items that are entitled to confidential treatment 4 under the applicable legal principles. 6 This action is likely to involve confidential information pertaining to 7 personnel records and institutional procedures within the institution and other 8 materials subject to privacy protections for which special protection from public g 9 || disclosure and from use for any purpose other than prosecution of this action is 4 bee 10 || warranted. Defendants contend that limiting disclosure of these documents to the : 5: 11 || context of this litigation as provided herein will, accordingly, further important law G ecu 12 || enforcement objectives and interests, including the safety of law enforcement 3 ou 13 || personnel, institutional safety as a whole, and the public, as well as individual 14 privacy rights of Plaintiff, Defendants, and third parties. Defendants further contend 15 that such confidential materials and information consist of, among other things, 16 materials entitled to privileges and/or protections under the following: the United 17 States Constitution, First Amendment; the California Constitution, Article I, Section 18 1; California Penal Code §§ 832.5, 832.7, and 832.8; California Evidence Code §8§ 19 1040 and 1043 et seq.; the Privacy Act of 1974, 5 U.S.C. § 552a; the right to 20 privacy; decisional law relating to such provisions; and information otherwise 21 generally unavailable to the public, or which may be privileged or otherwise 22 protected from disclosure under state or federal statutes, court rules, case decisions, 23 or common law. Defendants also maintain that such confidential materials and 24 information consist of materials entitled to the Official Information Privilege. 25 Confidential information with respect to the Defendants may include: 26 personnel files; internal institutional procedures and policy, investigative files and 27 documents; email and written correspondence records; and policies and procedures 28 that are kept from the public in the ordinary course of business, as well as other
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items subject to the Official Information Privilege and other privileges. The Parties 2 reserve the right to challenge a designation of confidentiality pursuant to the terms 3 set forth under Paragraph 6 of this Stipulated Protective Order. 4 Accordingly, to expedite the flow of information, to facilitate the prompt 5 resolution of disputes over confidentiality of discovery materials, to adequately 6 protect information the parties are entitled to keep confidential, to ensure that the 7 parties are permitted to reasonable necessary uses of such material in preparation for 8 and in conduct of trial, to address their handling at the end of the litigation, and 4 2 9 || serve the ends of justice, a protective order for such information is justified in this a He 10 || matter. It is the intent of the parties that information will not be designated as est 11 || confidential for tactical reasons and that nothing be so designated without a good 5 12 || faith belief that it has been maintained in a confidential, non-public manner, and 3 oa 13 || there is good cause why it should not be part of the public record of this case. = 14 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 15 The parties further acknowledge, as set forth in Section 12.3, below, that this 16 Stipulated Protective Order does not entitle them to file confidential information 17 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 18 and the standards that will be applied when a party seeks permission from the court 19 to file material under seal. 20 There is a strong presumption that the public has a right of access to judicial 21 proceedings and records in civil cases. In connection with non-dispositive motions, 22 good cause must be shown to support a filing under seal. See Kamakana v. City and 23 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 24 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 25 Jnc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 26 require good cause showing), and a specific showing of good cause or compelling 27 reasons with proper evidentiary support and legal justification, must be made with 28 respect to Protected Material that a party seeks to file under seal. The parties’ mere
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1 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 2 without the submission of competent evidence by declaration, establishing that the 3 material sought to be filed under seal qualifies as confidential, privileged, or 4 otherwise protectable—constitute good cause. 5 Further, if a party requests sealing related to a dispositive motion or trial, then 6 compelling reasons, not only good cause, for the sealing must be shown, and the 7 relief sought shall be narrowly tailored to serve the specific interest to be protected. 8 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 2 9 || each item or type of information, document, or thing sought to be filed or introduced 4 BBs 10 || under seal in connection with a dispositive motion or trial, the party seeking : 3: 11 || protection must articulate compelling reasons, supported by specific facts and legal 5 203 12 || justification, for the requested sealing order. Again, competent evidence supporting zh 13 || the application to file documents under seal must be provided by declaration. = 14 Any document that is not confidential, privileged, or otherwise protectable in 15 its entirety will not be filed under seal if the confidential portions can be redacted. 16 If documents can be redacted, then a redacted version for public viewing, omitting 17 only the confidential, privileged, or otherwise protectable portions of the document, 18 shall be filed. Any application that seeks to file documents under seal in their 19 entirety should include an explanation of why redaction is not feasible. 20 } 2. DEFINITIONS 21 2.1 Action: this pending federal lawsuit in the United States District Court 22 for the Central District of California titled Sarah Jafari v. County of Los Angeles, et 23 al., Case No.:2:22-cv-00305-DSF (GJSx). 24 2.2 Challenging Party: a Party or Non-Party that challenges the designation 25 of information or items under this Order. 26 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 27 how it is generated, stored or maintained) or tangible things that qualify for 28 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
ws
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1 the Good Cause Statement. 2 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 3 their support staff). 4 2.5 Designating Party: a Party or Non-Party that designates information or 5 items that it produces in disclosures or in responses to discovery as 6 “CONFIDENTIAL.” 7 2.6 Disclosure or Discovery Material: all items or information, regardless 8 of the medium or manner in which it is generated, stored, or maintained (including, 9 among other things, testimony, transcripts, and tangible things), that are produced or a ie 10 || generated in disclosures or responses to discovery in this matter. 56 11 2.7 Expert: a person with specialized knowledge or experience in a matter S oy 12 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 5 ou 13 || an expert witness or as a consultant in this Action. se 14 2.8 House Counsel: attorneys who are employees of a party to this Action. 7 15 || House Counsel does not include Outside Counsel of Record or any other outside 16 counsel. 17 2.9 Non-Party: any natural person, partnership, corporation, association or 18 other legal entity not named as a Party to this action. 19 2.10 Qutside Counsel of Record: attorneys who are not employees of a party 20 to this Action but are retained to represent or advise a party to this Action and have 21 appeared in this Action on behalf of that party or are affiliated with a law firm that 22 has appeared on behalf of that party, and includes support staff. 23 2.11 Party: any party to this Action, including all of its officers, directors, 24 employees, consultants, retained experts, and Outside Counsel of Record (and their 25 support staffs). 26 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 27 Discovery Material in this Action. 28 2.13 Professional Vendors: persons or entities that provide litigation support
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1 ) services (e.g., photocopying, videotaping, translating, preparing exhibits or 2 demonstrations, and organizing, storing, or retrieving data in any form or medium) 3 and their employees and subcontractors. 4 2.14 Protected Material: any Disclosure or Discovery Material that is 5 designated as “CONFIDENTIAL.” 6 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 7 from a Producing Party. 8]/3. SCOPE g 9 The protections conferred by this Stipulation and Order cover not only 4 EBs 10 || Protected Material (as defined above), but also (1) any information copied or sf 11 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 ne 12 || compilations of Protected Material; and (3) any testimony, conversations, or a zou 13 || presentations by Parties or their Counsel that might reveal Protected Material. a 14 Any use of Protected Material at trial shall be governed by the orders of the 15 trial judge. This Order does not govern the use of Protected Material at trial. 16) 4.. DURATION 17 FINAL DISPOSITION of the action is defined as the conclusion of any 18 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal i9 ||has run. Except as set forth below, the terms of this protective order apply through 20 FINAL DISPOSITION of the action. The parties may stipulate that they will be 21 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 22 but will have to file a separate action for enforcement of the agreement once all 23 proceedings in this case are complete. 24 Once a case proceeds to trial, information that was designated as 25 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 26 as an exhibit at trial becomes public and will be presumptively available to all 27} members of the public, including the press, unless compelling reasons supported by 28 specific factual findings to proceed otherwise are made to the trial judge in advance
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1 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” □
2 showing for sealing documents produced in discovery from “compelling reasons” 3 standard when merits-related documents are part of court record). Accordingly, for 4 such materials, the terms of this protective order do not extend beyond the 5 commencement of the trial. 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 4 ei 10 || qualifies under the appropriate standards. The Designating Party must designate for set 11 || protection only those parts of material, documents, items or oral or written SG 12 || communications that qualify so that other portions of the material, documents, items a oa 13 || or communications for which protection is not warranted are not swept unjustifiably = 82° 14|| within the ambit of this Order. 15 Mass, indiscriminate or routinized designations are prohibited. Designations 16 that are shown to be clearly unjustified or that have been made for an improper 17 purpose (e.g., to unnecessarily encumber the case development process or to impose 18 unnecessary expenses and burdens on other parties) may expose the Designating 19 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. 28 Designation in conformity with this Order requires:
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1 (a) for information in documentary form (e.g., paper or electronic documents, 2 but excluding transcripts of depositions or other pretrial or trial proceedings), that 3 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 4 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 5 portion of the material on a page qualifies for protection, the Producing Party also 6 must clearly identify the protected portion(s) (e.g., by making appropriate markings 7 the margins). 8 A Party or Non-Party that makes original documents available for inspection 4 8 9 ||need not designate them for protection until after the inspecting Party has indicated 4 bag 10 || which documents it would like copied and produced. During the inspection and ag! 11 || before the designation, all of the material made available for inspection shall be 5 aoe 12 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 3 ou 13 || documents it wants copied and produced, the Producing Party must determine which 14 documents, or portions thereof, qualify for protection under this Order. Then, 15 before producing the specified documents, the Producing Party must affix the 16 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 17 portion of the material on a page qualifies for protection, the Producing Party also 18 must clearly identify the protected portion(s) (e.g., by making appropriate markings 19 in the margins). 20 (b) for testimony given in depositions that the Designating Party identifies 21 the Disclosure or Discovery Material on the record, before the close of the 22 deposition all protected testimony. 23 (c) for information produced in some form other than documentary and for 24 any other tangible items, that the Producing Party affix in a prominent place on the 25 exterior of the container or containers in which the information is stored the legend 26 “CONFIDENTIAL.” If only a portion or portions of the information warrants 27 protection, the Producing Party, to the extent practicable, shall identify the protected 28 portion(s).
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1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive 3 the Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7\;}6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 2 9 || designation of confidentiality at any time that is consistent with the Court’s #8g 10]| Scheduling Order. =! 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute S acy 12 || resolution process under Local Rule 37.1 et seq. 3 a 13 6.3. The burden of persuasion in any such challenge proceeding shall be on = 37 14 || the Designating Party. Frivolous challenges, and those made for an improper = 15 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 16 parties) may expose the Challenging Party to sanctions. Unless the Designating 17 Party has waived or withdrawn the confidentiality designation, all parties shall 18 continue to afford the material in question the level of protection to which it is 19 entitled under the Producing Party’s designation until the Court rules on the 20 challenge. 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a Non-Party in connection with this 24 Action only for prosecuting, defending or attempting to settle this Action. Such 25 Protected Material may be disclosed only to the categories of persons and under the 26 conditions described in this Order. When the Action has been terminated, a 27 Receiving Party must comply with the provisions of section 13 below (FINAL 28 DISPOSITION).
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1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 otherwise ordered by the court or permitted in writing by the Designating Party, a 6 Receiving Party may disclose any information or item designated 7 \|“CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 3 9 || as employees of said Outside Counsel of Record to whom it is reasonably necessary 4 vee 10 || to disclose the information for this Action; ae 11 (b) the officers, directors, and employees (including House Counsel) of the S 12 || Receiving Party to whom disclosure is reasonably necessary for this Action; 3 13 (c) Experts (as defined in this Order) of the Receiving Party to whom Ss a7 14 || disclosure is reasonably necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) the court and its personnel; 17 (e) court reporters and their staff; 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 Vendors to whoin disclosure is reasonably necessary for this Action and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the information or a 22 custodian or other person who otherwise possessed or knew the information; 23 (h) during their depositions, witnesses, and attorneys for witnesses, in the 24 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 25 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 26 not be permitted to keep any confidential information unless they sign the 27 ““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 28 agreed by the Designating Party or ordered by the court. Pages of transcribed
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1 testimony or exhibits to depositions that reveal Protected Material may 2 be separately bound by the court reporter and may not be disclosed to anyone except 3 as permitted under this Stipulated Protective Order; and 4 (i) any mediator or settlement officer, and their supporting personnel, 5 mutually agreed upon by any of the parties engaged in settlement discussions. 6 /8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 8 If a Party is served with a subpoena or a court order issued in other litigation g 9 || that compels disclosure of any information or items designated in this Action as 328s ||“CONFIDENTIAL,” that Party must: : sg: 11 (a) promptly notify in writing the Designating Party. Such notification shall 5 12 || include a copy of the subpoena or court order; 3 13 (b) promptly notify in writing the party who caused the subpoena or order to 2" 14 || issue in the other litigation that some or all of the material covered by the subpoena 15 or order is subject to this Protective Order. Such notification shall include a copy of 16 this Stipulated Protective Order; and 17 (c) cooperate with respect to all reasonable procedures sought to be pursued 18 by the Designating Party whose Protected Material may be affected. 19 If the Designating Party timely seeks a protective order, the Party served with 20 the subpoena or court order shall not produce any information designated in this 21 action as “CONFIDENTIAL” before a determination by the court from which the 22 subpoena or order issued, unless the Party has obtained the Designating Party’s 23 permission. The Designating Party shall bear the burden and expense of seeking 24 protection in that court of its confidential material and nothing in these provisions 25 should be construed as authorizing or encouraging a Receiving Party in this Action 26 to disobey a lawful directive from another court. 27 \|/// 28 ///
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1)/9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE ! 3 (a) The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the 6 remedies and relief provided by this Order. Nothing in these provisions should be 7 construed as prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to A g 9 || produce a Non-Party’s confidential information in its possession, and the Party is 4 Be 10 || subject to an agreement with the Non-Party not to produce the Non-Party’s □ se: 11 || confidential information, then the Party shall: 5 12 (1) promptly notify in writing the Requesting Party and the Non-Party rou 13 || that some or all of the information requested is subject to a confidentiality fs ee" 14 || agreement with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated 16 Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 specific description of the information requested; and 18 (3) make the information requested available for inspection by the 19 Non-Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party 22 may produce the Non-Party’s confidential information responsive to the discovery 23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 not produce any information in its possession or control that is subject to the 25 confidentiality agreement with the Non-Party before a determination by the court. 26 Absent a court order to the contrary, the Non-Party shall bear the burden and 27 expense of seeking protection in this court of its Protected Material. 28 ///
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1)/}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 Ifa Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 7 persons to whom unauthorized disclosures were made of all the terms of this Order, 8 and (d) request such person or persons to execute the “Acknowledgment and A g 9 || Agreement to Be Bound” that is attached hereto as Exhibit A. a BB g 10\|}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE : af: 11 PROTECTED MATERIAL 5 acy 12 When a Producing Party gives notice to Receiving Parties that certain 5 He 13 || inadvertently produced material is subject to a claim of privilege or other protection, a7 14 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil = 15 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever 16 procedure may be established in an e-discovery order that provides for production 17 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 18 (e), insofar as the parties reach an agreement on the effect of disclosure of a 19 ) communication or information covered by the attorney-client privilege or work 20 product protection, the parties may incorporate their agreement in the stipulated 21 protective order submitted to the court. 22 }12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order, no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in this 28 Stipulated Protective Order. Similarly, no Party waives any right to object on any
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1 ground to use in evidence of any of the material covered by this Protective Order. 2 12.3 Filing Protected Material. A Party that seeks to file under seal any 3 Protected Material must comply with Local Civil Rule 79-5. Protected Material 4 may only be filed under seal pursuant to a court order authorizing the sealing of the 5 specific Protected Material at issue. Ifa Party’s request to file Protected Material 6 under seal is denied by the court, then the Receiving Party may file the information 7 in the public record unless otherwise instructed by the court. 8 \13. FINAL DISPOSITION 4 8 9 After the final disposition of this Action, as defined in paragraph 4, within 60 4 eee 10 || days of a written request by the Designating Party, each Receiving Party must return : sp! 11 || all Protected Material to the Producing Party or destroy such material. As used in 5 Sy 12 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 5 He 13 ||summaries, and any other format reproducing or capturing any of the Protected BS 27 14 || Material. Whether the Protected Material is returned or destroyed, the Receiving = 15 || Party must submit a written certification to the Producing Party (and, if not the same 16 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 17 (by category, where appropriate) all the Protected Material that was returned or 18 destroyed and (2) affirms that the Receiving Party has not retained any copies, 19 abstracts, compilations, summaries or any other format reproducing or capturing any 20 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 21 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 22 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 23 reports, attorney work product, and consultant and expert work product, even if such 24 materials contain Protected Material. Any such archival copies that contain or 25 constitute Protected Material remain subject to this Protective Order as set forth in 26 Section 4 (DURATION). 27:14. VIOLATION 28 Any violation of this Order may be punished by appropriate measures
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1 including, without limitation, contempt proceedings and/or monetary sanctions. 4 DATED: May 9, 2022 5 THE LAW OFFICES OF VINCENT MILLER 6 /s/ Vincent Miller 8 NICK SAGE 9 Attorneys for Plaintiff Sarah Jafari els ml 5 Ese 10 a oss eB 11 □ ese DATED: May 9, 2022 0 $22 |? THURRELL CANTRALL LLP oh ose /s/ Anahit Isaghulyan 14 ~ s a FARID A. SHARABY 16 ANAHIT ISAGHULYAN 17 Attorneys for Defendant County of Los Angeles 18 20 3 DATE May 12, 2022
23 ——— HON. (GAIL J. STANDISH 24 United’States Magistrate Judge 25 26 ad 28
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2 Pursuant to L.R. 5-4.3.4, I hereby certify that all other signatories listed, on 3 whose behalf the filing is submitted, concur in the filing’s content and have 4 authorized the filing. 6 DATED: May 9, 2022 HURRELL CANTRALL LLP -
py By: ag 9 THOMAS C. HURRELL Ese 10 FARID A. SHARABY Ruee ay ANAHIT ISAGHULYAN Z ake Attorneys for Defendant, COUNTY OF
5g 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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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 Sarah Jafari v. County of Los Angeles, et g 9 || al., Case No.:2:22-cv-00305-DSF (GJSx). I agree to comply with and to be bound 4 EBs 10||by all the terms of this Stipulated Protective Order and I understand and se: 11 || acknowledge that failure to so comply could expose me to sanctions and punishment 5 a8 12 || in the nature of contempt. I solemnly promise that I will not disclose in any manner a 13 ||any information or item that is subject to this Stipulated Protective Order to any ag 14 || person or entity except in strict compliance with the provisions of this Order. = 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of 18 /this action. I hereby appoint [print or type full 19 name] of [print or type full address 20 and telephone number] as my California agent for service of process in connection 21 with this action or any proceedings related to enforcement of this Stipulated 22 Protective Order. 23 24 Date: 25 City and State where sworn and signed: 26 Printed name: 27 Signature: □ 28
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