Kathy Jiron v. County of San Bernardino; Gabrielle Leos; Austin Decoud; Does 1 to 10, inclusive

1 Eugenia Bagdassarian, State Bar No. 334898 E-Mail: eugenia@triallit.com 2 E-Service: service@triallit.com TRIAL LIT ATTORNEYS, APC 3 600 West Broadway, Suite 235 Glendale, CA 91204 4 Telephone: (818) 584-3500 Facsimile: (877)565-0213 [5] Attorneys for Plaintiff, KATHY JIRON [7] UNITED STATES DISTRICT COURT [8] CENTRAL DISTRICT OF CALIFORNIA [10] KATHY JIRON, an Individual, Case No. 5:25-cv-00520-JGB(SSCx) [11] Plaintiff, STIPULATED PROTECTIVE 12 ORDER1 v. 13 [Assigned to Hon. Jesus G. Bernal] COUNTY OF SAN BERNARDINO; 14 GABRIELLE LEOS, an individual; [DISCOVERY MATTER] AUSTIN DECOUD, an individual; and 15 DOES 1 to 10, inclusive, 16 Defendants. [18] 19 1. INTRODUCTION 20 1.1 Purposes and Limitations. Discovery in this action is likely to involve 21 production of confidential, proprietary, or private information for which special 22 protection from public disclosure and from use for any purpose other than 23 prosecuting this litigation may be warranted. Accordingly, the parties hereby 24 stipulate to and petition the court to enter the following Stipulated Protective Order. [25] 26 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. Christensen’s Procedures. All [27] deviations or amendments to the model protective order have been red-lined in 1 The parties acknowledge that this Order does not confer blanket protections on all 2 disclosures or responses to discovery and that the protection it affords from public 3 disclosure and use extends only to the limited information or items that are entitled 4 to confidential treatment under the applicable legal principles. 5 1.2 Good Cause Statement 6 This action involves the County of San Bernardino and members of the San 7 Bernardino County Sheriff’s Department. This action is likely to involve the 8 exchange of protected health information (“PHI”), peace officer personnel 9 information, and materials from open investigations consisting of official 10 information for which special protection from public disclosure—and from use for 11 any purpose other than the prosecution of this action—is warranted. Such 12 confidential materials and information consist of, among other things, medical 13 records containing PHI, peace officer personnel records and investigations 14 containing official information, other administrative materials, as well as video 15 recordings, audio recordings, and photographs involving incidents to which law 16 enforcement responded. 17 Defendants contend that the disclosure of the confidential information 18 regarding the individuals may violate those individuals’ privacy rights. Defendants 19 also contend that the disclosure of the information may also jeopardize the security 20 of the County's operations and jeopardize the safety of its peace officers. 21 Defendants may seek information such as Plaintiff’s medical records that 22 Plaintiff believes are highly sensitive, confidential, and are legally protected from 23 disclosure. See Wooden v. Comprehensive Health Mgmt., No. 20-00053 LEK-WRP, [24] 2021 U.S. Dist. LEXIS 101889 , at *3 (D. Haw. May 28, 2021) (“[M]edical records 25 are confidential, as recognized under the Health Insurance Portability and 26 Accountability Act of 1996.”); Pratt v. Gamboa, No. 17-CV-04375-LHK, 2020 U.S. 27 Dist. LEXIS 90913, at *5 (N.D. Cal. May 22, 2020) (same). Plaintiff contends that 1 the undue disclosure of such information creates a specific risk of embarrassment, 2 emotional harm, and reputational harm. 3 Accordingly, to expedite the flow of information, to facilitate the prompt 4 resolution of disputes over confidentiality of discovery materials, to adequately 5 protect information the parties are entitled to keep confidential, to ensure that the 6 parties are permitted reasonable necessary uses of such material in preparation for 7 and in the conduct of trial, to address their handling at the end of the litigation, and 8 serve the ends of justice, a protective order for such information is justified in this 9 matter. It is the intent of the parties that information will not be designated as 10 confidential for tactical reasons and that nothing be so designated without a good 11 faith belief that it has been maintained in a confidential, non-public manner, and 12 there is good cause why it should not be part of the public record of this case. 13 The Parties agree that there is Good Cause for a Protective Order so as to 14 preserve the respective interests of the parties while streamlining the process of 15 resolving any disagreements. 16 The Parties therefore stipulate that there is Good Cause for, and hereby jointly 17 request that the honorable Court issue a Protective Order regarding confidential 18 documents consistent with the terms and provisions of this Stipulation. However, 19 the entry of a Protective Order by the Court pursuant to this Stipulation shall not be 20 construed as any ruling by the Court on the aforementioned legal statements or 21 privilege claims in this section, no shall this section be construed as part of any such 22 Court Order. 23 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties 24 further acknowledge, as set forth in Section 12.3, below, that this Stipulated 25 Protective Order does not entitle them to file confidential information under seal; 26 Local Rule 79-5 sets forth the procedures that must be followed and the standards 27 that will be applied when a party seeks permission from the court to file material 1 There is a strong presumption that the public has a right of access to judicial 2 proceedings and records in civil cases. In connection with non-dispositive motions, 3 good cause must be shown to support a filing under seal. See Kamakana v. City and 4 Cnty. of Honolulu, 447 F.3d 1172 , 1176 (9th Cir. 2006), Phillips ex rel. Ests. of 5 Byrd v. Gen. Motors Corp., 307 F.3d 1206 , 1210–11 (9th Cir. 2002), Makar-Welbon 6 v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 7 protective orders require good cause showing), and a specific showing of good 8 cause or compelling reasons with proper evidentiary support and legal justification, 9 must be made with respect to Protected Material that a party seeks to file under seal. 10 The parties’ mere designation of Disclosure or Discovery Material as 11 CONFIDENTIAL does not—without the submission of competent evidence by 12 declaration, establishing that the material sought to be filed under seal qualifies as 13 confidential, privileged, or otherwise protectable—constitute good cause. 14 Further, if a party requests sealing related to a dispositive motion or trial, then 15 compelling reasons, not only good cause, for the sealing must be shown, and the 16 relief sought shall be narrowly tailored to serve the specific interest to be protected. 17 See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665 , 677–79 (9th Cir. 2010). For each 18 item or type of information, document, or thing sought to be filed or introduced 19 under seal in connection with a dispositive motion or trial, the party seeking 20 protection must articulate compelling reasons, supported by specific facts and legal 21 justification, for the requested sealing order. Again, competent evidence supporting 22 the application to file documents under seal must be provided by declaration. 23 Any document that is not confidential, privileged, or otherwise protectable in its 24 entirety will not be filed under seal if the confidential portions can be redacted. If 25 documents can be redacted, then a redacted version for public viewing, omitting 26 only the confidential, privileged, or otherwise protectable portions of the document, 27 shall be filed. Any application that seeks to file documents under seal in their 1 2. DEFINITIONS 2 2.1 Action: This pending federal lawsuit,encaptioned Kathy Jiron v. 3 County of San Bernardino, et. al. 5:25-cv-00520-JGB(SSCx). 4 2.2 Challenging Party: A Party or Non-Party that challenges the 5 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 or 13 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 or 18 generated in disclosures or responses to discovery in this matter. 19 2.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as 21 an expert witness or as a consultant in this Action. 22 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses 23 in this Action, with or without prejudice; and (2) final judgment herein after the 24 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 25 this Action, including the time limits for filing any motions or applications for 26 extension of time pursuant to applicable law. [27] 1 2.9 In-House Counsel: attorneys who are employees of a party to this 2 Action. In-House Counsel does not include Outside Counsel of Record or any other 3 outside counsel. 4 2.10 Non-Party: any natural person, partnership, corporation, association, or 5 other legal entity not named as a Party to this action. 6 2.11 Outside Counsel of Record: attorneys who are not employees of a party 7 to this Action but are retained to represent or advise a party to this Action and have 8 appeared in this Action on behalf of that party or are affiliated with a law firm which 9 has appeared on behalf of that party, and includes support staff. 10 2.12 Party: any party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 2.14 Professional Vendors: persons or entities that provide litigation16 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 and their employees and subcontractors. 19 2.15 Protected Material: any Disclosure or Discovery Material that is 20 designated as “CONFIDENTIAL.” 21 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 22 from a Producing Party. 23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only 25 Protected Material (as defined above), but also (1) any information copied or 26 extracted from Protected Material; (2) all copies, excerpts, summaries, or 27 compilations of Protected Material; and (3) any testimony, conversations, or 1 Any use of Protected Material at trial shall be governed by the orders of the 2 trial judge. This Stipulated Protective Order does not govern the use of Protected 3 Material at trial. 4 4. TRIAL AND DURATION 5 Even after Final Disposition of this litigation, the confidentiality obligations 6 imposed by this Stipulated Protective Order shall remain in effect until a 7 Designating Party agrees otherwise in writing or a court order otherwise directs. 8 Final disposition shall be deemed to be the later of (1) dismissal of all claims and 9 defenses in this Action, with or without prejudice; and (2) final judgment herein 10 after the completion and exhaustion of all appeals, rehearings, remands, trials, or 11 reviews of this Action, including the time limits for filing any motions or 12 applications for extension of time pursuant to applicable law. 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and 15 used or introduced as an exhibit at trial becomes public and will be presumptively 16 available to all members of the public, including the press, unless compelling 17 reasons supported by specific factual findings to proceed otherwise are made to the 18 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81 19 (distinguishing “good cause” showing for sealing documents produced in discovery 20 from “compelling reasons” standard when merits-related documents are part of court 21 record). Accordingly, for such materials, the terms of this Stipulated Protective 22 Order do not extend beyond the commencement of the trial. A party may file a 23 motion for a protective order for any material, document, item, or communication 24 used as a trial exhibit during trial within thirty (30) days of the material, document, 25 item, or communication being admitted as a trial exhibit. 26 5. DESIGNATING PROTECTED MATERIAL [27] 5.1 Exercise of Restraint and Care in Designating Material for Protection. 1 Each Party or Non-Party that designates information or items for protection under 2 this Order must take care to limit any such designation to specific material that 3 qualifies under the appropriate standards. The Designating Party must designate for 4 protection only those parts of material, documents, items, or oral or written 5 communications that qualify so that other portions of the material, documents, 6 items, or communications for which protection is not warranted are not swept 7 unjustifiably within the ambit of this Order. 8 Mass, indiscriminate, or routinized designations are prohibited. Designations 9 that are shown to be clearly unjustified or that have been made for an improper 10 purpose (e.g., to unnecessarily encumber the case development process or to 11 impose unnecessary expenses and burdens on other parties) may expose the 12 Designating Party to sanctions. 13 If it comes to a Designating Party’s attention that information or items that it 14 designated for protection do not qualify for protection, that Designating Party must 15 promptly notify all other Parties that it is withdrawing the inapplicable designation. [16] 5.2 Manner and Timing of Designations. Except as otherwise provided in [17] this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) [18] below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that [19] qualifies for protection under this Stipulated Protective Order must be clearly so [20] designated before the material is disclosed or produced. [21] Designation in conformity with this Stipulated Protective Order requires: [22] (a) for information in documentary form (e.g., paper or electronic [23] documents, but excluding transcripts of depositions or other pretrial or trial [24] proceedings), that the Producing Party affix at a minimum, the legend [25] “CONFIDENTIAL” to each page that contains protected material. If only a [26] portion or portions of the material on a page qualifies for protection, the Producing [27] Party also must clearly identify the protected portion(s) (e.g., by making 1 A Party or Non-Party that makes original documents available for inspection 2 need not designate them for protection until after the inspecting Party has indicated 3 which documents it would like copied and produced. During the inspection and 4 before the designation, all of the material made available for inspection shall be 5 deemed CONFIDENTIAL. After the inspecting Party has identified the documents 6 it wants copied and produced, the Producing Party must determine which 7 documents, or portions thereof, qualify for protection under this Stipulated 8 Protective Order. Then, before producing the specified documents, the Producing 9 Party must affix the “CONFIDENTIAL” legend to each page that contains 10 Protected Material. If only a portion or portions of the material on a page qualifies 11 for protection, the Producing Party also must clearly identify the protected 12 portion(s) (e.g., by making appropriate markings in the margins). 13 (b) for testimony given in depositions that the Designating Party identify 14 the Disclosure or Discovery Material on the record, before the close of the 15 deposition all protected testimony. 16 (c) for information produced in some form other than documentary and 17 for any other tangible items, that the Producing Party affix in a prominent place on 18 the exterior of the container or containers in which the information is stored the 19 “CONFIDENTIAL” legend. If only a portion or portions of the information 20 warrants protection, the Producing Party, to the extent practicable, shall identify the 21 protected portion(s). [22] 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent [23] failure to designate qualified information or items does not, standing alone, waive [24] the Designating Party’s right to secure protection under this Order for such material. [25] Upon timely correction of a designation, the Receiving Party must make reasonable [26] efforts to assure that the material is treated in accordance with the provisions of this [27] Stipulated Protective Order. 1 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 2 designation of confidentiality at any time that is consistent with the court’s 3 Scheduling Order. 4 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 5 resolution process under Local Rule 37.1 et seq. 6 6.3 The burden of persuasion in any such challenge proceeding shall be on 7 the Designating Party. Frivolous challenges, and those made for an improper 8 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 9 parties) may expose the Challenging Party to sanctions. Unless the Designating 10 Party has waived or withdrawn the confidentiality designation, all parties shall 11 continue to afford the material in question the level of protection to which it is 12 entitled under the Producing Party’s designation until the court rules on the 13 challenge. 14 7. ACCESS TO AND USE OF PROTECTED MATERIAL 15 7.1 Basic Principles. A Receiving Party may use Protected Material that 16 is disclosed or produced by another Party or by a Non-Party in connection with this 17 Action only for prosecuting, defending, or attempting to settle this Action. Such 18 Protected Material may be disclosed only to the categories of persons and under the 19 conditions described in this Order. When the Action reaches a Final Disposition, a 20 Receiving Party must comply with the provisions of Section 13 below. 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 7.2 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 27 “CONFIDENTIAL” only: 1 well as employees of said Outside Counsel of Record to whom it is reasonably 2 necessary to disclose the information for this Action; 3 (b) to the officers, directors, and employees (including House Counsel) of 4 the Receiving Party to whom disclosure is reasonably necessary for this Action; 5 (c) to Experts (as defined in this Order) of the Receiving Party to whom 6 disclosure is reasonably necessary for this Action and who have signed the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) to the court and its personnel; 9 (e) to court reporters and their staff; 10 (f) to professional jury or trial consultants, mock jurors, and Professional 11 Vendors to whom disclosure is reasonably necessary for this Action and who have 12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (g) to the author or recipient of a document containing the information or 14 a custodian or other person who otherwise possessed or knew the information; [15] (h) during their depositions, to witnesses, and attorneys for witnesses, in [16] the Action to whom disclosure is reasonably necessary, provided: (1) the deposing [17] party requests that the witness sign the “Acknowledgment and Agreement to Be [18] Bound” (Exhibit A); and (2) the witness will not be permitted to keep any [19] confidential information unless they sign the “Acknowledgment and Agreement to [20] Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or [21] ordered by the court. Pages of transcribed deposition testimony or exhibits to [22] depositions that reveal Protected Material may be separately bound by the court [23] reporter and may not be disclosed to anyone except as permitted under this [24] Stipulated Protective Order; and [25] (i) to any mediator or settlement officer, and their supporting personnel, [26] mutually agreed upon by any of the parties engaged in settlement discussions. [27] // 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that 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 [7] shall include a copy of the subpoena or court order; [8] (b) promptly notify in writing the party who caused the subpoena or order [9] to issue in the other litigation that some or all of the material covered by the [10] subpoena or order is subject to this Protective Order. Such notification shall include [11] a copy of this Stipulated Protective Order; and [12] (c) cooperate with respect to all reasonable procedures sought to be [13] pursued by the Designating Party whose Protected Material may be affected. [14] If the Designating Party timely seeks a protective order, the Party served [15] with the subpoena or court order shall not produce any information designated in [16] this action as “CONFIDENTIAL” before a determination by the court from which [17] the subpoena or order issued, unless the Party has obtained the Designating Party’s [18] permission. The Designating Party shall bear the burden and expense of seeking [19] protection in that court of its confidential material and nothing in these provisions [20] should be construed as authorizing or encouraging a Receiving Party in this Action [21] to disobey a lawful directive from another court. [22] 9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE [23] PRODUCED IN THIS LITIGATION [24] 9.1 Application. The terms of this Stipulated Protective Order are [25] applicable to information produced by a Non-Party in this Action and designated as [26] “CONFIDENTIAL.” Such information produced by Non-Parties in connection with [27] this litigation is protected by the remedies and relief provided by this Order. 1 Nothing in these provisions should be construed as prohibiting a Non-Party from 2 seeking additional protections. 3 9.2 Notification. In the event that a Party is required, by a valid discovery 4 request, to produce a Non-Party’s confidential information in its possession, and the 5 Party is subject to an agreement with the Non-Party not to produce the Non6 Party’s confidential information, then the Party shall: 7 (a) promptly notify in writing the Requesting Party and the Non-Party 8 that some or all of the information requested is subject to a confidentiality 9 agreement with a Non-Party; 10 (b) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and 13 (c) make the information requested available for inspection by the Non14 Party, if requested. 15 9.3 Conditions of Production. If the Non-Party fails to seek a protective 16 order from this court within 14 days of receiving the notice and accompanying 17 information, the Receiving Party may produce the Non-Party’s confidential 18 information responsive to the discovery request. If the Non-Party timely seeks a 19 protective order, the Receiving Party shall not produce any information in its 20 possession or control that is subject to the confidentiality agreement with the Non21 Party before a determination by the court. Absent a court order to the contrary, the 22 Non-Party shall bear the burden and expense of seeking protection in this court of its 23 Protected Material. 24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL [25] If a Receiving Party learns that, by inadvertence or otherwise, it has [26] disclosed Protected Material to any person or in any circumstance not authorized [27] under this Stipulated Protective Order, the Receiving Party must immediately (a) 1 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 2 the person or persons to whom unauthorized disclosures were made of all the terms 3 of this Order, and (d) request such person or persons to execute the 4 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 5 A. 6 11 . INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL [8] When a Producing Party gives notice to Receiving Parties that certain [9] inadvertently produced material is subject to a claim of privilege or other [10] protection, the obligations of the Receiving Parties are those set forth in Rule [11] 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended [12] to modify whatever procedure may be established in an e-discovery order that [13] provides for production without prior privilege review. Pursuant to Rules 502(d) [14] and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement [15] on the effect of disclosure of a communication or information covered by the [16] attorney-client privilege or work product protection, the parties may incorporate [17] their agreement in the stipulated protective order submitted to the court. [18] 12. MISCELLANEOUS [19] 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order [20] abridges the right of any person to seek its modification by the court in the future. [21] 12.2 Right to Assert Other Objections. By stipulating to the entry of this [22] Stipulated Protective Order no Party waives any right it otherwise would have to [23] object to disclosing or producing any information or item on any ground not [24] addressed in this Stipulated Protective Order. Similarly, no Party waives any right [25] to object on any ground to use in evidence of any of the material covered by this [26] Stipulated Protective Order. [27] 12.3 Filing Protected Material. A Party that seeks to file under seal any 1 Protected Material must comply with Local Rule 79-5. Protected Material may 2 only be filed under seal pursuant to a court order authorizing the sealing of the 3 specific Protected Material at issue. If a Party's request to file Protected Material 4 under seal is denied by the court, then the Receiving Party may file the 5 information in the public record unless otherwise instructed by the court. 6 13. FINAL DISPOSITION [7] After the Final Disposition of this Action, as defined in paragraph 4, within [8] 60 days of a written request by the Designating Party, each Receiving Party must [9] return all Protected Material to the Producing Party or destroy such material. As [10] used in this subdivision, “all Protected Material” includes all copies, abstracts, [11] compilations, summaries, and any other format reproducing or capturing any of the [12] Protected Material. Whether the Protected Material is returned or destroyed, the [13] Receiving Party must submit a written certification to the Producing Party (and, if [14] not the same person or entity, to the Designating Party) by the 60 day deadline that [15] (1) identifies (by category, where appropriate) all the Protected Material that was [16] returned or destroyed and (2) affirms that the Receiving Party has not retained any [17] copies, abstracts, compilations, summaries or any other format reproducing or [18] capturing any of the Protected Material. Notwithstanding this provision, Counsel is [19] entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, [20] and hearing transcripts, legal memoranda, correspondence, deposition and trial [21] exhibits, expert reports, attorney work product, and consultant and expert work [22] product, even if such materials contain Protected Material. Any such archival [23] copies that contain or constitute Protected Material remain subject to this Protective [24] Order as set forth in Section 4. [27] 1)}14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished by any 3 || and all appropriate measures including, without limitation, contempt proceedings 4 || and/or monetary sanctions. [5] 6 || DATED: December 4, 2025 WESIERSKI & ZUREK LLP [8] 9 By: /s/ Kathryn J. Harvey KATHRYN J. HARVEY 10 Attorney for Defendant, COUNTY OF 11 SAN BERNARDINO 12 || DATED: December 4, 2025 TRIAL LIT ATTORNEYS APC [14] 15 By: /s/ Eugenia Bagdassarian EUGENIA BAGDASSARIAN 16 Attorney for Plaintiff, KATHY JIRON [17] 18 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. [19] 20|| DATED: December 5, 2025 Z-— 1 Stephanie S. Christensen United States Magistrate Judge [28] 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of ___________ [insert formal name of the case and the 8 number and initials assigned to it by the court]. I agree to comply with and to be 9 bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. I 14 further agree to submit to the jurisdiction of the United States District Court for the 15 Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [print or 18 type full name] of _______________________________________ [print or type 19 full address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this 21 Stipulated Protective Order. [22] 23 Date: ______________________________________ 24 City and State where sworn and signed: ____________________________ 25 Printed name: _______________________________ 26 Signature: __________________________________