Sree Lakshmi Ramisetty v. Kaiser Foundation Hospitals ( 2024 )

1 Elliot A. Singer, Esq. (SBN 350334) CONDUIT LAW, LLC 2 1544 York St. Denver, CO 80206 3 Telephone: (720) 432-7032 4 Facsimile: (720) 554-8042 Email: elliot@conduit.law 5 Attorneys for Plaintiff 6 SEYFARTH SHAW LLP 7 Eric M. Steinert, Esq. (SBN 168384) 560 Mission Street, 31st Floor 8 San Francisco, CA 94105 9 Telephone: (415) 397-2823 Facsimile: (415) 397-8549 10 Email: esteinert@seyfarth.com 11 SEYFARTH SHAW LLP 12 D. Joshua Salinas, Esq. (SBN 282065) 2029 Century Park East, Suite 3500 13 Los Angeles, CA 90067-3021 14 Telephone: (310) 277-7200 Facsimile: (310) 201-5219 15 Email: jsalinas@seyfarth.com 16 Attorneys for Defendant 17 18 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA 20 SREE LAKSHMI RAMISETTY, Case No.: 2:24-cv-03030-FLA-SSC 21 Plaintiff, 22 STIPULATED PROTECTIVE ORDER1 23 v. 24 KAISER FOUNDATION HOSPITALS, Complaint Filed: April 15, 2024 Trial Date: Dec. 9, 2025 25 Defendant. 26 27 1 This Stipulated Protective Order is substantially based on the model protective 28 order provided under Magistrate Judge Stephanie S. Christensen’s Procedures as of 1 1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 production of confidential, proprietary or private information for which special 4 protection from public disclosure and from use for any purpose other than prosecuting 5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 6 petition the Court to enter the following Stipulated Protective Order. The parties 7 acknowledge that this Order does not confer blanket protections on all disclosures or 8 responses to discovery and that the protection it affords from public disclosure and use 9 extends only to the limited information or items that are entitled to confidential 10 treatment under the applicable legal principles. 11 1.2 Good Cause Statement. This action is likely to involve trade secrets, 12 commercial, financial, technical and/or proprietary information for which special 13 protection from public disclosure and from use for any purpose other than prosecution 14 of this action is warranted. Such confidential and proprietary materials and 15 information consist of, among other things, employee records, employment policies 16 and procedures, training materials, strategic human resources decisions, pay and 17 salary records, information protected by the Health Insurance Portability and 18 Accountability Act (“HIPAA”), other confidential business or financial information, 19 information regarding confidential business practices, or other confidential research, 20 development, or commercial information (including information implicating privacy 21 rights of third parties), information otherwise generally unavailable to the public, 22 information that would, if disclosed, cause competitive disadvantage to Defendant or 23 Defendant’s affiliates, or information which may be privileged or otherwise protected 24 from disclosure under state or federal statutes, court rules, case decisions, or common 25 law. Accordingly, to expedite the flow of information, to facilitate the prompt 26 resolution of disputes over confidentiality of discovery materials, to adequately 27 protect information the parties are entitled to keep confidential, to ensure that the 28 parties are permitted reasonable necessary uses of such material in preparation for and 1 in the conduct of trial, to address their handling at the end of the litigation, and serve 2 the ends of justice, a protective order for such information is justified in this matter. It 3 is the intent of the parties that information will not be designated as confidential for 4 tactical reasons and that nothing be so designated without a good faith belief that it 5 has been maintained in a confidential, non-public manner, and there is good cause 6 why it should not be part of the public record of this case. 7 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties further 8 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 9 does not entitle them to file confidential information under seal; Local Rule 79-5 sets 10 forth the procedures that must be followed and the standards that will be applied when 11 a party seeks permission from the court to file material under seal. 12 There is a strong presumption that the public has a right of access to judicial 13 proceedings and records in civil cases. In connection with non-dispositive motions, 14 good cause must be shown to support a filing under seal. See Kamakana v. City and 15 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd 16 v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. 17 Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective 18 orders require good cause showing), and a specific showing of good cause or 19 compelling reasons with proper evidentiary support and legal justification, must be 20 made with respect to Protected Material that a party seeks to file under seal. The 21 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL 22 does not—without the submission of competent evidence by declaration, establishing 23 that the material sought to be filed under seal qualifies as confidential, privileged, or 24 otherwise protectable—constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, then 26 compelling reasons, not only good cause, for the sealing must be shown, and the 27 relief sought shall be narrowly tailored to serve the specific interest to be protected. 28 See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each 1 item or type of information, document, or thing sought to be filed or introduced 2 under seal in connection with a dispositive motion or trial, the party seeking 3 protection must articulate compelling reasons, supported by specific facts and legal 4 justification, for the requested sealing order. Again, competent evidence supporting 5 the application to file documents under seal must be provided by declaration. 6 Any document that is not confidential, privileged, or otherwise protectable in 7 its entirety will not be filed under seal if the confidential portions can be redacted. If 8 documents can be redacted, then a redacted version for public viewing, omitting only 9 the confidential, privileged, or otherwise protectable portions of the document, shall 10 be filed. Any application that seeks to file documents under seal in their entirety 11 should include an explanation of why redaction is not feasible. 12 2. DEFINITIONS 13 2.1 Action: This pending lawsuit: Sree Lakshmi Ramisetty, Case No. 2:24- 14 cv-03030-FLA-SSC. 15 2.2 Challenging Party: a Party or Non-Party that challenges the designation 16 of information or items under this Order. 17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 18 how it is generated, stored or maintained) or tangible things that qualify for protection 19 under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in 20 the Good Cause Statement. 21 (a) Notwithstanding any other provision of this Stipulated Protective Order, 22 “CONFIDENTIAL” Information or Items is further defined to include any sensitive or 23 private personal information, such contact information (e.g., home addresses, phone 24 numbers) of current or former employees of Defendant. Such materials shall be 25 considered “CONFIDENTIAL,” whether or not the materials were so designated by 26 the producing Party. 27 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 28 support staff). 1 2.5 Designating Party: a Party or Non-Party that designates information or 2 items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 2.6 Disclosure or Discovery Material: all items or information, regardless of 5 the medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things), that are produced or 7 generated in disclosures or responses to discovery in this matter. 8 2.7 Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 10 expert witness or as a consultant in this Action. 11 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 12 this Action, with or without prejudice; and (2) final judgment herein after the 13 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 14 this Action, including the time limits for filing any motions or applications for 15 extension of time pursuant to applicable law. 16 2.9 In-House Counsel: attorneys who are employees of a party to this Action. 17 In-House Counsel does not include Outside Counsel of Record or any other outside 18 counsel. 19 2.10 Non-Party: any natural person, partnership, corporation, association, or 20 other legal entity not named as a Party to this action. 21 2.11 Outside Counsel of Record: attorneys who are not employees of a party 22 to this Action but are retained to represent or advise a party to this Action and have 23 appeared in this Action on behalf of that party or are affiliated with a law firm which 24 has appeared on behalf of that party, and includes support staff. 25 2.12 Party: any party to this Action, including all of its officers, directors, 26 employees, consultants, retained experts, and Outside Counsel of Record (and their 27 support staffs). 28 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 1 Discovery Material in this Action. 2 2.14 Professional Vendors: persons or entities that provide litigation- support 3 services (e.g., photocopying, videotaping, translating, preparing exhibits or 4 demonstrations, and organizing, storing, or retrieving data in any form or medium) 5 and their employees and subcontractors. 6 2.15 Protected Material: any Disclosure or Discovery Material that is 7 designated as “CONFIDENTIAL.” 8 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 9 from a Producing Party. 10 3. SCOPE 11 The protections conferred by this Stipulation and Order cover not only 12 Protected Material (as defined above), but also (1) any information copied or 13 extracted from Protected Material; (2) all copies, excerpts, summaries, or 14 compilations of Protected Material; and (3) any testimony, conversations, or 15 presentations by Parties or their Counsel that might reveal Protected Material. 16 Any use of Protected Material at trial shall be governed by the orders of the 17 trial judge. This Stipulated Protective Order does not govern the use of Protected 18 Material at trial. 19 4. TRIAL AND DURATION 20 The terms of this Stipulated Protective Order apply through Final Disposition 21 of the Action. 22 Once a case proceeds to trial, information that was designated as 23 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and 24 used or introduced as an exhibit at trial becomes public and will be presumptively 25 available to all members of the public, including the press, unless compelling reasons 26 supported by specific factual findings to proceed otherwise are made to the trial judge 27 in advance of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 28 cause” showing for sealing documents produced in discovery from “compelling 1 reasons” standard when merits-related documents are part of court record). 2 Accordingly, for such materials, the terms of this Stipulated Protective Order do not 3 extend beyond the commencement of the trial. 4 5. DESIGNATING PROTECTED MATERIAL 5 5.1 Exercise of Restraint and Care in Designating Material for Protection. 6 Each Party or Non-Party that designates information or items for protection under this 7 Order must take care to limit any such designation to specific material that qualifies 8 under the appropriate standards. The Designating Party must designate for protection 9 only those parts of material, documents, items, or oral or written communications that 10 qualify so that other portions of the material, documents, items, or communications 11 for which protection is not warranted are not swept unjustifiably within the ambit of 12 this Order. 13 Mass, indiscriminate, or routinized designations are prohibited. Designations 14 that are shown to be clearly unjustified or that have been made for an improper 15 purpose (e.g., to unnecessarily encumber the case development process or to impose 16 unnecessary expenses and burdens on other parties) may expose the Designating 17 Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 designated for protection do not qualify for protection, that Designating Party must 20 promptly notify all other Parties that it is withdrawing the inapplicable designation. 21 5.2 Manner and Timing of Designations. Except as otherwise provided in 22 this Stipulated Protective Order (see, e.g., section 2.3(a) and second paragraph of 23 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery 24 Material that qualifies for protection under this Stipulated Protective Order must be 25 clearly so designated before the material is disclosed or produced. 26 Designation in conformity with this Stipulated Protective Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 28 documents, but excluding transcripts of depositions or other pretrial or trial 1 proceedings), that the Producing Party affix at a minimum, the legend 2 “CONFIDENTIAL” to each page that contains protected material. If only a portion 3 or portions of the material on a page qualifies for protection, the Producing Party also 4 must clearly identify the protected portion(s) (e.g., by making appropriate markings 5 in the margins). 6 A Party or Non-Party that makes original documents available for inspection 7 need not designate them for protection until after the inspecting Party has indicated 8 which documents it would like copied and produced. During the inspection and 9 before the designation, all of the material made available for inspection shall be 10 deemed CONFIDENTIAL. After the inspecting Party has identified the documents it 11 wants copied and produced, the Producing Party must determine which documents, 12 or portions thereof, qualify for protection under this Stipulated Protective Order. 13 Then, before producing the specified documents, the Producing Party must affix the 14 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 15 portion or portions of the material on a page qualifies for protection, the Producing 16 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 17 markings in the margins). 18 (b) for testimony given in depositions that the Designating Party identify the 19 Disclosure or Discovery Material on the record, before the close of the deposition all 20 protected testimony. 21 (c) for information produced in some form other than documentary and for 22 any other tangible items, that the Producing Party affix in a prominent place on the 23 exterior of the container or containers in which the information is stored the 24 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants 25 protection, the Producing Party, to the extent practicable, shall identify the protected 26 portion(s). 27 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 28 failure to designate qualified information or items does not, standing alone, waive the 1 Designating Party’s right to secure protection under this Order for such material. 2 Upon timely correction of a designation, the Receiving Party must make reasonable 3 efforts to assure that the material is treated in accordance with the provisions of this 4 Stipulated Protective Order. 5 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 7 designation of confidentiality at any time that is consistent with the court’s 8 Scheduling Order. 9 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 10 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 11 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2 12 6.3 The burden of persuasion in any such challenge proceeding shall be on 13 the Designating Party. Frivolous challenges, and those made for an improper purpose 14 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 15 expose the Challenging Party to sanctions. Unless the Designating Party has waived 16 or withdrawn the confidentiality designation, all parties shall continue to afford the 17 material in question the level of protection to which it is entitled under the Producing 18 Party’s designation until the court rules on the challenge. 19 7. ACCESS TO AND USE OF PROTECTED MATERIAL 20 7.1 Basic Principles. A Receiving Party may use Protected Material that is 21 disclosed or produced by another Party or by a Non-Party in connection with this 22 Action only for prosecuting, defending, or attempting to settle this Action. Such 23 Protected Material may be disclosed only to the categories of persons and under the 24 conditions described in this Order. When the Action reaches a Final Disposition, a 25 Receiving Party must comply with the provisions of section 13 below. 26 27 28 2 Judge Christensen’s Procedures are available at 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 Stipulated Protective 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: 8 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as 9 well as employees of said Outside Counsel of Record to whom it is reasonably 10 necessary to disclose the information for this Action; 11 (b) to the officers, directors, and employees (including House Counsel) of 12 the Receiving Party to whom disclosure is reasonably necessary for this Action; 13 (c) to Experts (as defined in this Order) of the Receiving Party to whom 14 disclosure is reasonably necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) to the court and its personnel; 17 (e) to court reporters and their staff; 18 (f) to professional jury or trial consultants, mock jurors, and Professional 19 Vendors to whom disclosure is reasonably necessary for this Action and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) to 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, to 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 “Acknowledgment and Agreement to Be Bound” 26 (Exhibit A); and (2) the witness will not be permitted to keep any confidential 27 information unless they sign the “Acknowledgment and Agreement to Be Bound” 28 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the 1 court. Pages of transcribed deposition testimony or exhibits to depositions that reveal 2 Protected Material may be separately bound by the court reporter and may not be 3 disclosed to anyone except as permitted under this Stipulated Protective Order; and 4 (i) to 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 7 PRODUCED IN OTHER LITIGATION 8 If a Party is served with a subpoena or a court order issued in other litigation 9 that compels disclosure of any information or items designated in this Action as 10 “CONFIDENTIAL,” that Party must: 11 (a) promptly notify in writing the Designating Party. Such notification shall 12 include a copy of the subpoena or court order; 13 (b) promptly notify in writing the party who caused the subpoena or order to 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 20 with 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 to 26 disobey a lawful directive from another court. 27 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 28 PRODUCED IN THIS LITIGATION 1 9.1 Application. The terms of this Stipulated Protective Order are applicable 2 to information produced by a Non-Party in this Action and designated as 3 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with 4 this litigation is protected by the remedies and relief provided by this Order. Nothing 5 in these provisions should be construed as prohibiting a Non-Party from seeking 6 additional protections. 7 9.2 Notification. In the event that a Party is required, by a valid discovery 8 request, to produce a Non-Party’s confidential information in its possession, and the 9 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 10 confidential information, then the Party shall: 11 (a) promptly notify in writing the Requesting Party and the Non-Party that 12 some or all of the information requested is subject to a confidentiality agreement with 13 a Non-Party; 14 (b) make the information requested available for inspection by the Non- 15 Party, if requested. 16 9.3 Conditions of Production. If the Non-Party fails to seek a protective 17 order from this court within 14 days of receiving the notice and accompanying 18 information, the Receiving Party may produce the Non-Party’s confidential 19 information responsive to the discovery request. If the Non-Party timely seeks a 20 protective order, the Receiving Party shall not produce any information in its 21 possession or control that is subject to the confidentiality agreement with the Non- 22 Party before a determination by the court. Absent a court order to the contrary, the 23 Non-Party shall bear the burden and expense of seeking protection in this court of its 24 Protected Material. 25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 27 Protected Material to any person or in any circumstance not authorized under this 28 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 3 persons to whom unauthorized disclosures were made of all the terms of this Order, 4 and (d) request such person or persons to execute the “Acknowledgment and 5 Agreement to Be Bound” (Exhibit 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 protection, 10 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 11 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 12 procedure may be established in an e-discovery order that provides for production 13 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules 14 of Evidence, insofar as the parties reach an agreement on the effect of disclosure of a 15 communication or information covered by the attorney-client privilege or work 16 product protection, the parties may incorporate their agreement in the stipulated 17 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 to 25 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 28 Protected Material must comply with Local Rule 79-5. Protected Material may only 1 be filed under seal pursuant to a court order authorizing the sealing of the specific 2 Protected Material at issue. If a Party's request to file Protected Material under seal 3 is denied by the court, then the Receiving Party may file the information in the public 4 record unless otherwise instructed by the court. 5 12.4 After this Stipulated Protective Order has been signed by counsel for all 6 Parties, it shall be presented to the Court for entry. Counsel agree to be bound by the 7 terms set forth herein with regard to any Protected Materials that have been produced 8 before the Court signs this Stipulated Protective Order. 9 12.5 The Parties and all signatories to the “Acknowledgment and Agreement 10 to Be Bound” (Exhibit A) agree to be bound by this Stipulated Protective Order 11 pending its approval and entry by the Court. In the event that the Court modifies this 12 Stipulated Protective Order, or in the event that the Court enters a different Protective 13 Order, the Parties agree to be bound by this Stipulated Protective Order until such 14 time as the Court may enter such a different Order. It is the Parties’ intent to be 15 bound by the terms of this Stipulated Protective Order pending its entry so as to allow 16 for immediate production of Protected Materials under the terms herein. 17 13. FINAL DISPOSITION 18 After the Final Disposition of this Action, as defined in paragraph 4, within 30 19 days of a written request by the Designating Party, each Receiving Party must return 20 all Protected Material to the Producing Party or destroy such material. As used in 21 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected 23 Material. Whether the Protected Material is returned or destroyed, the Receiving 24 Party must submit a written certification to the Producing Party (and, if not the same 25 person or entity, to the Designating Party) by 30 day deadline that (1) identifies (by 26 category, where appropriate) all the Protected Material that was returned or destroyed 27 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 28 compilations, summaries or any other format reproducing or capturing any of the 1 Protected Material. Notwithstanding this provision, Counsel is entitled to retain an 2 archival copy of all pleadings, motion papers, trial, deposition, and hearing 3 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 4 reports, attorney work product, and consultant and expert work product, even if such 5 materials contain Protected Material. Any such archival copies that contain or 6 constitute Protected Material remain subject to this Protective Order as set forth in 7 Section 4. 8 14. VIOLATION 9 Any violation of this Stipulated Protective Order may be punished by any and 10 all appropriate measures including, without limitation, contempt proceedings and/or 11 monetary sanctions. 12 13 SIGNATURE ATTESTATION 14 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, D. Joshua Salinas, attest that all 15 signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. 16 17 By: /s/ D. Joshua Salinas 18 19 /// 20 /// 21 22 23 24 25 26 27 28 1||1T IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 4|| DATED: November 20, 2024 CONDUIT LAW, LLC 5 6 By:__/s/ Elliot A. Singer 4 Elliot A. Singer Attomneys for Plaintiff SREE LAKSHMI 8 RAMISETTY 9 10}| DATED: November 20, 2024 SEYFARTH SHAW LLP 11 12 By:__/s/D. Joshua Salinas Eric M. Steinert 13 D. Joshua Salinas 14 Attorneys for Defendant KAISER 15 FOUNDATION HOSPITALS 16 7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 DATED: November 20, 2024 50 HON. STEPHANIE S. CHRISTENSEN United States Magistrate Judge 22 23 24 25 26 27 28 QCTIDITIT ATLRIN DDAVICMTIV7CL COVDINLD 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 5 penalty of perjury that I have read in its entirety and understand the Stipulated 6 Protective Order that was issued by the United States District Court for the Central 7 District of California on [date] in the case of Sree Lakshmi Ramisetty, Case No. 2:24- 8 cv-03030-FLA-SSC. I agree to comply with and to be bound by all the terms of this 9 Stipulated Protective Order and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that is 12 subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the 15 Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. I 17 hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: __________________________________ 23 City and State where 24 sworn and signed: __________________________________ 25 Printed name: __________________________________ 26 Signature: __________________________________ 27 28