even stipulated protective 3 orders require good cause showing
How later courts described this case
- even stipulated protective 3 orders require good cause showing
Written by the judges who cited it.
The opinion
1 JEULNISEE T O. ’MBORINERNO, EC,A CSAta Steta Btea Br Naro N. 2o4. 5298647763
2
RYNN & JANOWSKY, LLP
3 4100 Newport Place Drive, Suite 700
Newport Beach, CA 92660
4 T: 949.752.2911
F: 949.752.0953
5
elise@rjlaw.com
6 june@rjlaw.com
7
PHILLIP RAY, NJ State Bar No. 039692002
8 KLUGER HEALEY, LLC
106 Apple Street, Suite 302
9 Tinton Falls, NJ 07724
T: 732.852.7500
10
F: 888.635.1653
11 pray@klugherhealey.com
12
Attorneys for Defendant MAGNET MEDIA, INC.
13
UNITED STATES DISTRICT COURT
14
FOR THE CENTRAL DISTRICT OF CALIFORNIA
15
16 DAVID BRASHEAR, individually, and CASE NO. 2:17-CV-06026-AB-AFM
on behalf of all others similarly situated,
17
STIPULATED
18 Plaintiff, CONFIDENTIALITY
AGREEMENT AND [PROPOSED]
19 v. PROTECTIVE ORDER
20
MAGNET MEDIA, INC., a New York
21 corporation, COMPLEX MEDIA, INC., a
Delaware Corporation,
22
23 Defendants.
24
25
26
27
28
1 1. A. PURPOSES AND LIMITATIONS
2
Discovery in this action are likely to involve production of confidential,
3
proprietary, or private information for which special protection from public
4
5 disclosure and from use for any purpose other than prosecuting this litigation may
6
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
7
enter the following Stipulated Protective Order. The parties acknowledge that this
8
9 Order does not confer blanket protections on all disclosures or responses to
10
discovery and that the protection it affords from public disclosure and use extends
11
only to the limited information or items that are entitled to confidential treatment
12
13 under the applicable legal principles.
14
B. GOOD CAUSE STATEMENT
15
This action is likely to involve customer and pricing lists and other valuable
16
17 research, development, commercial, financial, technical and/or proprietary
18
information for which special protection from public disclosure and from use for
19
20 any purpose other than prosecution of this action is warranted. Such confidential
21 and proprietary materials and information consist of, among other things,
22
confidential business or financial information, information regarding confidential
23
24 business practices, or other confidential research, development, or commercial
25 information (including information implicating privacy rights of third parties),
26
information otherwise generally unavailable to the public, or which may be
27
28 privileged or otherwise protected from disclosure under state or federal statutes,
1 court rules, case decisions, or common law. Accordingly, to expedite the flow of
2
information, to facilitate the prompt resolution of disputes over confidentiality of
3
discovery materials, to adequately protect information the parties are entitled to
4
5 keep confidential, to ensure that the parties are permitted reasonable necessary uses
6
of such material in preparation for and in the conduct of trial, to address their
7
handling at the end of the litigation, and serve the ends of justice, a protective order
8
9 for such information is justified in this matter. It is the intent of the parties that
10
information will not be designated as confidential for tactical reasons and that
11
nothing be so designated without a good faith belief that it has been maintained in
12
13 a confidential, non-public manner, and there is good cause why it should not be
14
part of the public record of this case.
15
C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
16
17 The parties further acknowledge, as set forth in Section 12.3, below, that this
18
Stipulated Protective Order does not entitle them to file confidential information
19
20 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
21 and the standards that will be applied when a party seeks permission from the court
22
to file material under seal.
23
24 There is a strong presumption that the public has a right of access to judicial
25 proceedings and records in civil cases. In connection with non-dispositive motions,
26
good cause must be shown to support a filing under seal. See Kamakana v. City
27
28 and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.
1 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony
2
Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective
3
orders require good cause showing), and a specific showing of good cause or
4
5 compelling reasons with proper evidentiary support and legal justification, must be
6
made with respect to Protected Material that a party seeks to file under seal. The
7
parties’ mere designation of Disclosure or Discovery Material as
8
9 CONFIDENTIAL does not—without the submission of competent evidence by
10
declaration, establishing that the material sought to be filed under seal qualifies as
11
confidential, privileged, or otherwise protectable—constitute good cause.
12
13 Further, if a party requests sealing related to a dispositive motion or trial,
14
then compelling reasons, not only good cause, for the sealing must be shown, and
15
the relief sought shall be narrowly tailored to serve the specific interest to be
16
17 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.
18
2010). For each item or type of information, document, or thing sought to be filed
19
20 or introduced under seal in connection with a dispositive motion or trial, the party
21 seeking protection must articulate compelling reasons, supported by specific facts
22
and legal justification, for the requested sealing order. Again, competent evidence
23
24 supporting the application to file documents under seal must be provided by
25 declaration.
26
Any document that is not confidential, privileged, or otherwise protectable
27
28 in its entirety will not be filed under seal if the confidential portions can be
1 redacted. If documents can be redacted, then a redacted version for public viewing,
2
omitting only the confidential, privileged, or otherwise protectable portions of the
3
document, shall be filed. Any application that seeks to file documents under seal in
4
5 their entirety should include an explanation of why redaction is not feasible.
6
2. DEFINITIONS
7
2.1 Action: The instant pending action, entitled: Brashear, et al. v. Magnet
8
9 Media, Inc., et al., bearing case no. 2:17-CV-06026-AB-AFM.
10
2.2 Challenging Party: a Party or Non-Party that challenges the designation
11
of information or items under this Order.
12
13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
14
how it is generated, stored or maintained) or tangible things that qualify for
15
protection under Federal Rule of Civil Procedure 26(c), and as specified above in
16
17 the Good Cause Statement.
18
2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
19
20 support staff).
21 2.5 Designating Party: a Party or Non-Party that designates information or
22
items that it produces in disclosures or in responses to discovery as
23
24 “CONFIDENTIAL.”
25 2.6 Disclosure or Discovery Material: all items or information, regardless of
26
the medium or manner in which it is generated, stored, or maintained (including,
27
28 among other things, testimony, transcripts, and tangible things), that are produced
1 or generated in disclosures or responses to discovery in this matter.
2
2.7 Expert: a person with specialized knowledge or experience in a matter
3
pertinent to the litigation who has been retained by a Party or its counsel to serve
4
5 as an expert witness or as a consultant in this Action.
6
2.8 House Counsel: attorneys who are employees of a party to this Action.
7
House Counsel does not include Outside Counsel of Record or any other outside
8
9 counsel.
10
2.9 Non-Party: any natural person, partnership, corporation, association or
11
other legal entity not named as a Party to this action.
12
13 2.10 Outside Counsel of Record: attorneys who are not employees of a party
14
to this Action but are retained to represent or advise a party to this Action and have
15
appeared in this Action on behalf of that party or are affiliated with a law firm that
16
17 has appeared on behalf of that party, and includes support staff.
18
2.11 Party: any party to this Action, including all of its officers, directors,
19
20 employees, consultants, retained experts, and Outside Counsel of Record (and their
21 support staffs).
22
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
23
24 Discovery Material in this Action.
25 2.13 Professional Vendors: persons or entities that provide litigation support
26
services (e.g., photocopying, videotaping, translating, preparing exhibits or
27
28 demonstrations, and organizing, storing, or retrieving data in any form or medium)
1 and their employees and subcontractors.
2
2.14 Protected Material: any Disclosure or Discovery Material that is
3
designated as “CONFIDENTIAL.”
4
5 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
6
from a Producing Party.
7
3. SCOPE
8
9 The protections conferred by this Stipulation and Order cover not only
10
Protected Material (as defined above), but also (1) any information copied or
11
extracted from Protected Material; (2) all copies, excerpts, summaries, or
12
13 compilations of Protected Material; and (3) any testimony, conversations, or
14
presentations by Parties or their Counsel that might reveal Protected Material.
15
Any use of Protected Material at trial shall be governed by the orders of the
16
17 trial judge. This Order does not govern the use of Protected Material at trial.
18
4. DURATION
19
20 Once a case proceeds to trial, information that was designated as
21 CONFIDENTIAL or maintained pursuant to this protective order used or
22
introduced as an exhibit at trial becomes public and will be presumptively
23
24 available to all members of the public, including the press, unless compelling
25 reasons supported by specific factual findings to proceed otherwise are made to the
26
trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
27
28 (distinguishing “good cause” showing for sealing documents produced in
1 discovery from “compelling reasons” standard when merits-related documents are
2
part of court record). Accordingly, the terms of this protective order do not extend
3
beyond the commencement of the trial.
4
5 5. DESIGNATING PROTECTED MATERIAL
6
5.1 Exercise of Restraint and Care in Designating Material for Protection.
7
Each Party or Non-Party that designates information or items for protection under
8
9 this Order must take care to limit any such designation to specific material that
10
qualifies under the appropriate standards. The Designating Party must designate for
11
protection only those parts of material, documents, items, or oral or written
12
13 communications that qualify so that other portions of the material, documents,
14
items, or communications for which protection is not warranted are not swept
15
unjustifiably within the ambit of this Order.
16
17 Mass, indiscriminate, or routinized designations are prohibited. Designations
18
that are shown to be clearly unjustified or that have been made for an improper
19
20 purpose (e.g., to unnecessarily encumber or retard the case development process or
21 to impose unnecessary expenses and burdens on other parties) expose the
22
Designating Party to sanctions.
23
24 If it comes to a Designating Party’s attention that information or items that it
25 designated for protection do not qualify for protection, that Designating Party must
26
promptly notify all other Parties that it is withdrawing the mistaken designation.
27
28 5.2 Manner and Timing of Designations. Except as otherwise provided in
1 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
2
stipulated or ordered, Disclosure or Discovery Material that qualifies for
3
protection under this Order must be clearly so designated before the material is
4
5 disclosed or produced.
6
Designation in conformity with this Order requires:
7
(a) for information in documentary form (e.g., paper or electronic
8
9 documents, but excluding transcripts of depositions or other pretrial or trial
10
proceedings), that the Producing Party affix at a minimum, the legend
11
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
12
13 contains protected material. If only a portion of the material on a page qualifies for
14
protection, the Producing Party also must clearly identify the protected portion(s)
15
(e.g., by making appropriate markings in the margins).
16
17 A Party or Non-Party that makes original documents available for inspection
18
need not designate them for protection until after the inspecting Party has indicated
19
20 which material it would like copied and produced. During the inspection and
21 before the designation, all of the material made available for inspection shall be
22
deemed “CONFIDENTIAL.” After the inspecting Party has identified the
23
24 documents it wants copied and produced, the Producing Party must determine
25 which documents, or portions thereof, qualify for protection under this Order.
26
Then, before producing the specified documents, the Producing Party must affix
27
28 the “CONFIDENTIAL legend” to each page that contains Protected Material. If
1 only a portion of the material on a page qualifies for protection, the Producing
2
Party also must clearly identify the protected portion(s) (e.g., by making
3
appropriate markings in the margins).
4
5 (b) for testimony given in depositions that the Designating Party
6
identifies the Disclosure or Discovery Material on the record, before the close of
7
the deposition all protected testimony.
8
9 (c) for information produced in some form other than documentary and
10
for any other tangible items, that the Producing Party affix in a prominent place on
11
the exterior of the container or containers in which the information is stored the
12
13 legend “CONFIDENTIAL.” If only a portion or portions of the information
14
warrants protection, the Producing Party, to the extent practicable, shall identify
15
the protected portion(s).
16
17 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
18
failure to designate qualified information or items does not, standing alone, waive
19
20 the Designating Party’s right to secure protection under this Order for such
21 material. Upon timely correction of a designation, the Receiving Party must make
22
reasonable efforts to assure that the material is treated in accordance with the
23
24 provisions of this Order.
25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
26
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
27
28 designation of confidentiality at any time that is consistent with the Court’s
1 Scheduling Order.
2
6.2 Meet and Confer. The Challenging Party shall initiate the dispute
3
resolution process under Local Rule 37-1 et seq.
4
5 6.3 Joint Stipulation. Any challenge submitted to the court shall be via
6
joint stipulation pursuant to Local Rule 37-2.
7
6.4 The burden of persuasion in any such challenge proceeding shall be
8
9 on the Designating Party. Frivolous challenges, and those made for an improper
10
purpose (e.g., to harass or impose unnecessary expenses and burdens on other
11
parties) may expose the Challenging Party to sanctions. Unless the Designating
12
13 Party has waived ow withdrawn the confidentiality designation, all parties shall
14
continue to afford the material in question the level of protection to which it is
15
entitled under the Producing Party’s designation until the Court rules on the
16
17 challenge.
18
7. ACCESS TO AND USE OF PROTECTED MATERIAL
19
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
case only for prosecuting, defending, or attempting to settle this litigation. Such
23
24 Protected Material may be disclosed only to the categories of persons and under
25 the conditions described in this Order. When the Action has been terminated, a
26
Receiving Party must comply with the provisions of section 13 below (FINAL
27
28 DISPOSITION).
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
5 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
6
otherwise ordered by the court or permitted in writing by the Designating Party, a
7
Receiving Party may disclose any information or item designated
8
9 “CONFIDENTIAL” only to:
10
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well
11
as employees of said Outside Counsel of Record to whom it is reasonably
12
13 necessary to disclose the information for this Action;
14
(b) the officers, directors, and employees (including House Counsel) of
15
the Receiving Party to whom disclosure is reasonably necessary for this litigation
16
17 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
18
A);
19
20 (c) Experts (as defined in this Order) of the Receiving Party to whom
21 disclosure is reasonably necessary for this litigation and who have signed the
22
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
23
24 (d) the court and its personnel;
25 (e) court reporters and their staff;
26
(f) professional jury or trial consultants, mock jurors, and Professional
27
28 Vendors to whom disclosure is reasonably necessary for this litigation and who
1 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
2
(g) the author or recipient of a document containing the information or a
3
custodian or other person who otherwise possessed or knew the information;
4
5 (h) during their depositions, witnesses, and attorneys for witnesses, in
6
the Action to whom disclosure is reasonably necessary provided: (1) the deposing
7
party requests that the witness sign the form attached as Exhibit A hereto; and (2)
8
9 they will not be permitted to keep any confidential information unless they sign the
10
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
11
agreed by the Designating Party or ordered by the court. Pages of transcribed
12
13 deposition testimony or exhibits to depositions that reveal Protected Material must
14
be separately bound by the court reporter and may not be disclosed to anyone
15
except as permitted under this Stipulated Protective Order; and
16
17 (i) any mediator or settlement officer, and their supporting personnel,
18
mutually agreed upon by any of the parties engaged in settlement discussions.
19
20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
21 OTHER LITIGATION
22
If a Party is served with a subpoena or a court order issued in other litigation
23
24 that compels disclosure of any information or items designated in this Action as
25 “CONFIDENTIAL,” that Party must:
26
(a) promptly notify in writing the Designating Party. Such notification
27
28 shall include a copy of the subpoena or court order;
1 (b) promptly notify in writing the party who caused the subpoena or
2
order to issue in the other litigation that some or all of the material covered by the
3
subpoena or order is subject to this Protective Order. Such notification shall
4
5 include a copy of this Stipulated Protective Order; and
6
(c) cooperate with respect to all reasonable procedures sought to be
7
pursued by the Designating Party whose Protected Material may be affected.
8
9 If the Designating Party timely seeks a protective order, the Party served with
10
the subpoena or court order shall not produce any information designated in this
11
action as “CONFIDENTIAL” before a determination by the court from which the
12
13 subpoena or order issued, unless the Party has obtained the Designating Party’s
14
permission. The Designating Party shall bear the burden and expense of seeking
15
protection in that court of its confidential material and nothing in these provisions
16
17 should be construed as authorizing or encouraging a Receiving Party in this Action
18
to disobey a lawful directive from another court.
19
20 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
21 PRODUCED IN THIS LITIGATION
22
(a) The terms of this Order are applicable to information produced by a
23
24 Non-Party in this action and designated as “CONFIDENTIAL.” Such information
25 produced by Non-Parties in connection with this litigation is protected by the
26
remedies and relief provided by this Order. Nothing in these provisions should be
27
28 construed as prohibiting a Non-Party from seeking additional protections.
1 (b) In the event that a Party is required, by a valid discovery request, to
2
produce a Non-Party’s confidential information in its possession, and the Party is
3
subject to an agreement with the Non-Party not to produce the Non-Party’s
4
5 confidential information, then the Party shall:
6
(1) promptly notify in writing the Requesting Party and the Non-Party
7
that some or all of the information requested is subject to a confidentiality
8
9 agreement with a Non-Party;
10
(2) 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
13 specific description of the information requested; and
14
(3) make the information requested available for inspection by the
15
Non-Party, if requested.
16
17 (c) If the Non-Party fails to seek a protective order from this court within
18
14 days of receiving the notice and accompanying information, the Receiving
19
20 Party may produce the Non-Party’s confidential information responsive to the
21 discovery request. If the Non-Party timely seeks a protective order, the Receiving
22
Party shall not produce any information in its possession or control that is subject
23
24 to the confidentiality agreement with the Non-Party before a determination by the
25 court. Absent a court order to the contrary, the Non-Party shall bear the burden
26
and expense of seeking protection in this court of its Protected Material.
27
28 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
1 If a Receiving Party learns that, by inadvertence or otherwise, it has
2
disclosed Protected Material to any person or in any circumstance not authorized
3
under this Stipulated Protective Order, the Receiving Party must immediately (a)
4
5 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
6
best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
7
the person or persons to whom unauthorized disclosures were made of all the terms
8
9 of this Order, and (d) request such person or persons to execute the
10
“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
11
A.
12
13 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
14
PROTECTED MATERIAL
15
When a Producing Party gives notice to Receiving Parties that certain
16
17 inadvertently produced material is subject to a claim of privilege or other
18
protection, the obligations of the Receiving Parties are those set forth in Federal
19
20 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
21 whatever procedure may be established in an e-discovery order that provides for
22
production without prior privilege review. Pursuant to Federal Rule of Evidence
23
24 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
25 of a communication or information covered by the attorney-client privilege or
26
work product protection, the parties may incorporate their agreement in the
27
28 stipulated protective order submitted to the court.
1 12. MISCELLANEOUS
2
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
3
person to seek its modification by the court in the future.
4
5 12.2 Right to Assert Other Objections. By stipulating to the entry of this
6
Protective Order no Party waives any right it otherwise would have to object to
7
disclosing or producing any information or item on any ground not addressed in
8
9 this Stipulated Protective Order. Similarly, no Party waives any right to object on
10
any ground to use in evidence of any of the material covered by this Protective
11
Order.
12
13 12.3 Filing Protected Material. A Party that seeks to file under seal any
14
Protected Material must comply with Civil Local Rule 79-5. Protected Material
15
may only be filed under seal pursuant to a court order authorizing the sealing of the
16
17 specific Protected Material at issue. If a Party's request to file Protected Material
18
under seal is denied by the court, then the Receiving Party may file the information
19
20 in the public record unless otherwise instructed by the court.
21 13. FINAL DISPOSITION
22
After the final disposition of this Action, as defined in paragraph 4, within
23
24 60 days of a written request by the Designating Party, each Receiving Party must
25 return all Protected Material to the Producing Party or destroy such material. As
26
used in this subdivision, “all Protected Material” includes all copies, abstracts,
27
28 compilations, summaries, and any other format reproducing or capturing any of the
1 Protected Material. Whether the Protected Material is returned or destroyed, the
2
Receiving Party must submit a written certification to the Producing Party (and, if
3
not the same person or entity, to the Designating Party) by the 60 day deadline that
4
5 (1) identifies (by category, where appropriate) all the Protected Material that was
6
returned or destroyed and (2) affirms that the Receiving Party has not retained any
7
copies, abstracts, compilations, summaries or any other format reproducing or
8
9 capturing any of the Protected Material. Notwithstanding this provision, Counsel
10
are entitled to retain an archival copy of all pleadings, motion papers, trial,
11
deposition, and hearing transcripts, legal memoranda, correspondence, deposition
12
13 and trial exhibits, expert reports, attorney work product, and consultant and expert
14
work product, even if such materials contain Protected Material. Any such archival
15
copies that contain or constitute Protected Material remain subject to this
16
17 Protective Order as set forth in Section 4 (DURATION).
18
14. VIOLATION
19
20 Any violation of this Order may be punished by appropriate measures
21 including, without limitation, contempt proceedings and/or monetary sanctions.
22
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
23
24
DATED: _____10/30/2019___________ ______/s Alan Harris_______________________
25
Attorneys for Plaintiff
26
27 DATED: _____10/30/2019___________ ________/s Phillip G. Ray____________________
Attorneys for Defendant Magnet Media, Inc.
28
1
2 || DATED: ___ 10/30/2019 /s Jeffrey Weston
3 Attorneys for Defendant Complex Media, Inc.
4
5
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
6
7 || DATED: 11/1/2019
8 .
9
10 || ALEXANDER F. MacKINNON
11 United States Magistrate Judge
12
2
a
LL
17
Zz 18
19
20
21
22
23
24
25
26
27
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 that I have read in its entirety and
5
understand the Stipulated Protective Order that was issued by the United States District Court for
6
the Central District of California on [date] in the case of Brashear, et al. v. Magnet Media, Inc., et
7
al.Case No. 2:17-cv-06026-AB-AFM. I agree to comply with and to be bound by all the terms of
8
this Stipulated Protective Order and I understand and acknowledge that failure to so comply could
9
expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will
10
not disclose in any manner any information or item that is subject to this Stipulated Protective
11
Order to any person or entity except in strict compliance with the provisions of this Order.
12
I further agree to submit to the jurisdiction of the United States District Court for the Central
13 District of California for the purpose of enforcing the terms of this Stipulated Protective Order,
14 even if such enforcement proceedings occur after termination of this action.
15 I hereby appoint __________________________ [print or type full name] of
16 _______________________________________ [print or type full address and telephone number]
17 as my California agent for service of process in connection with this action or any proceedings
18 related to enforcement of this Stipulated Protective Order.
19
20 Date: ______________________________________
21 City and State where sworn and signed: _________________________________
22
23 Printed name: _______________________________
24
25 Signature: __________________________________
26
27
28