The opinion
1 |} HAHN LOESER & PARKS LLP
> Samuel C. Sneed (SBN 289205)
One America Plaza
3 ||600 W. Broadway, Suite 1500
4 San Diego, CA 92101
Telephone: 619.810.4300
5 || Facsimile: 619.810.4301
6 ssneed@hahnlaw.com
7 || Attorneys for Plaintiff, DAN’S DEALS LLC
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
= 12|]{DAN’S DEALS LLC, a limited liability | Case No. 8:19-cv-01248-CJC-PLA
2 13 company,
Assigned to Hon. Cormac J. Carney
14
os Plaintiff, |DISCOVERY MATTER
16 PROTECTIVE ORDER
© v.
2 17
18 || SUNSPOTWEB, INC., a corporation,
ATTILA BORKA, an individual, and | Courtroom: 7C
19 || DOES | through 10, Complaint Filed: June 20, 2019
20
71 Defendants.
22
23
24
25
26
27
28
1 8:19-cv-01248-CJC-PLA
1 |} 1. PURPOSES, LIMITATIONS, AND GOOD CAUSE STATEMENT
2 A. PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential,
4||proprietary, or private information for which special protection from public
5 ||disclosure and from use for any purpose other than prosecuting this litigation may
6 |{be warranted. This Order does not confer blanket protections on all disclosures or
7 ||responses to discovery and that the protection it affords from public disclosure and
8 }juse extends only to the limited information or items that are entitled to
9 ||confidential treatment under the applicable legal principles..
10 |]2. GOOD CAUSE STATEMENT
11 This action is likely to involve confidential and private consumer
5 12 ||information, confidential agreements, confidential and proprietary methods and
g 13 ||practices, trade secrets, and other valuable research, development, commercial,
14 || financial, technical and/or proprietary information for which special protection
He 15 ||from public disclosure and from use for any purpose other than prosecution of this
16 ||action is warranted.
17 Such confidential and proprietary materials and information consist of,
18 |}among other things, confidential and private information regarding consumers’
19 ||personal information, confidential agreements between businesses, confidential
20 ||business information, information regarding confidential business methods and
21 ||practices, or other confidential research, development, or commercial information
22 ||(including information implicating privacy rights of third parties), information
23 |}otherwise generally unavailable to the public, or which may be privileged or
24 |/otherwise protected from disclosure under state or federal statutes, court rules,
25 ||case decisions, or common law. Accordingly, to expedite the flow of information,
26 ||to facilitate the prompt resolution of disputes over confidentiality of discovery
27 ||materials, to adequately protect information the parties are entitled to keep
28 ||confidential, to ensure that the parties are permitted reasonable necessary uses of
2 8:19-cv-01248-CJC-PLA
1 |/such material in preparation for and in the conduct of trial, to address their
2 ||handling at the end of the litigation, and serve the ends of justice, a protective
3 |jorder for such information is justified in this matter. It is the intent of the parties
4 ||that information will not be designated as confidential for tactical reasons and that
5 |{nothing be so designated without a good faith belief that it has been maintained in
6 confidential, non-public manner, and there is good cause why it should not be
7 || part of the public record of this case.
8 }}3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
9 This Protective Order does not entitle the parties to file confidential
10 ||information under seal; Local Civil Rule 79-5 sets forth the procedures that must
11 ||be followed and the standards that will be applied when a party seeks permission
5 12 ||from the court to file material under seal. There is a strong presumption that the
g 13 ||public has a right of access to judicial proceedings and records in civil cases. In
14 ||connection with non-dispositive motions, good cause must be shown to support a
He 15 || filing under seal. See Kamakana v. City and County of Honolulu, 447 F.3d 1172,
16 ||1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th
17 || Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis.
18 ||1999) (even stipulated protective orders require good cause showing), and a
19 ||specific showing of good cause or compelling reasons with proper evidentiary
20 |/support and legal justification, must be made with respect to Protected Material
21 ||that a party seeks to file under seal. The parties’ mere designation of Disclosure or
22 ||Discovery Material as CONFIDENTIAL does not— without the submission of
23 ||competent evidence by declaration, establishing that the material sought to be
24 || filed under seal qualifies as confidential, privileged, or otherwise protectable—
25 ||constitute good cause.
26 Further, if a party requests sealing related to a dispositive motion or trial,
27 ||then compelling reasons, not only good cause, for the sealing must be shown, and
28 ||the relief sought shall be narrowly tailored to serve the specific interest to be
3 8:19-cv-01248-CJC-PLA
1 ||protected. See Pintos vy. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9" Cir.
2 ||2010). For each item or type of information, document, or thing sought to be filed
3 |Jor introduced under seal, the party seeking protection must articulate compelling
4||reasons, supported by specific facts and legal justification, for the requested
5 ||sealing order. Again, competent evidence supporting the application to file
6 |documents under seal must be provided by declaration.
7 Any document that is not confidential, privileged, or otherwise protectable
8 |}in its entirety will not be filed under seal if the confidential portions can be
9 ||redacted. If documents can be redacted, then a redacted version for public
10 ||viewing, omitting only the confidential, privileged, or otherwise protectable
11 ||portions of the document, shall be filed. Any application that seeks to file
5 12 ||documents under seal in their entirety should include an explanation of why
g 13 ||redaction is not feasible
14/4. DEFINITIONS
He 15 4.1 Action: This pending federal law suit.
16 4.2 Challenging Party: a Party or Non-Party that challenges the
17 ||designation of information or items under this Order.
18 43 “CONFIDENTIAL” Information or Items: information (regardless of
19 ||how it is generated, stored or maintained) or tangible things that qualify for
20 ||protection under Federal Rule of Civil Procedure 26(c), and as specified above in
21 ||the Good Cause Statement.
22 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
23 ||their support staff).
24 4.5 Designating Party: a Party or Non-Party that designates information
25 |jor items that it produces in disclosures or in responses to discovery as
26 ||“CONFIDENTIAL.”
27 4.6 Disclosure or Discovery Material: all items or information,
28 ||regardless of the medium or manner in which it is generated, stored, or maintained
1 |/Gncluding, among other things, testimony, transcripts, and tangible things), that
2 ||are produced or generated in disclosures or responses to discovery in this matter.
3 4.7 Expert: a person with specialized knowledge or experience in a
4 |)matter pertinent to the litigation who has been retained by a Party or its counsel to
5 ||Sserve as an expert witness or as a consultant in this Action.
6 4.8 House Counsel: attorneys who are employees of a party to this
7 || Action. House Counsel does not include Outside Counsel of Record or any other
8 |}outside counsel.
9 4.9 Non-Party: any natural person, partnership, corporation, association,
10 |}or other legal entity not named as a Party to this action.
11 4.10 Outside Counsel of Record: attorneys who are not employees of a
5 12 ||party to this Action but are retained to represent or advise a party to this Action
g 13 |}and have appeared in this Action on behalf of that party or are affiliated with a law
14 || firm which has appeared on behalf of that party, and includes support staff.
He 15 4.11 Party: any party to this Action, including all of its officers, directors,
16 ||employees, consultants, retained experts, and Outside Counsel of Record (and
17 ||their support staffs).
18 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 || Discovery Material in this Action.
20 4.13 Professional Vendors: persons or entities that provide litigation
21 ||support services (e.g., photocopying, videotaping, translating, preparing exhibits
22 |}or demonstrations, and organizing, storing, or retrieving data in any form or
23 ||medium) and their employees and subcontractors.
24 4.14 Protected Material: any Disclosure or Discovery Material that is
25 designated as “CONFIDENTIAL.”
26 4.15 Receiving Party: a Party that receives Disclosure or Discovery
27 || Material from a Producing Party.
28 1/5. SCOPE
5 8:19-cv-01248-CJC-PLA
1 The protections conferred by this Order cover not only Protected Material
2||(as defined above), but also (1) any information copied or extracted from
3 ||Protected Material; (2) all copies, excerpts, summaries, or compilations of
4||Protected Material; and (3) any testimony, conversations, or presentations by
5 ||Parties or their Counsel that might reveal Protected Material.
6 Any use of Protected Material at trial shall be governed by the orders of the
7 ||trial judge and other applicable authorities. This Order does not govern the use of
8 || Protected Material at trial.
9 || 6. DURATION
10 Once a case proceeds to trial, information that was designated as
11 }|}CONFIDENTIAL or maintained pursuant to this protective order used or
5 12 |}introduced as an exhibit at trial becomes public and will be presumptively
g 13 |Javailable to all members of the public, including the press, unless compelling
14 ||reasons supported by specific factual findings to proceed otherwise are made to
He 15 ||the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-8]
16 ||(distinguishing “good cause” showing for sealing documents produced in
17 ||discovery from “compelling reasons” standard when merits-related documents are
18 || part of court record). Accordingly, the terms of this protective order do not extend
19 ||beyond the commencement of the trial.
20 || 7. DESIGNATING PROTECTED MATERIAL
21 7.1 Exercise of Restraint and Care in Designating Material for Protection.
22 ||Each Party or Non-Party that designates information or items for protection under
23 ||this Order must take care to limit any such designation to specific material that
24 || qualifies under the appropriate standards. The Designating Party must designate
25 ||for protection only those parts of material, documents, items, or oral or written
26 ||communications that qualify so that other portions of the material, documents,
27 ||items, or communications for which protection is not warranted are not swept
28 |/unjustifiably within the ambit of this Order.
6 8:19-cv-01248-CJC-PLA
1 Mass, indiscriminate, or routinized designations are prohibited.
2 ||Designations that are shown to be clearly unjustified or that have been made for
3 |/an improper purpose (e.g., to unnecessarily encumber the case development
4||process or to impose unnecessary expenses and burdens on other parties) may
5 |}expose the Designating Party to sanctions.
6 If it comes to a Designating Party’s attention that information or items that
7 ||it designated for protection do not qualify for protection, that Designating Party
8 |;|must promptly notify all other Parties that it is withdrawing the inapplicable
9 || designation.
10 7.2 Manner and Timing of Designations. Except as otherwise provided in
11 ||this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material
5 12 ||that qualifies for protection under this Order must be clearly so designated before
g 13 ||the material is disclosed or produced.
14 Designation in conformity with this Order requires:
He 15 (a) for information in documentary form (e.g., paper or electronic
16 ||documents, but excluding transcripts of depositions or other pretrial or trial
17 ||proceedings), that the Producing Party affix at a minimum, the legend
18 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
19 ||contains protected material. If only a portion or portions of the material on a page
20 ||qualifies for protection, the Producing Party also must clearly identify the
21 ||protected portion(s) (e.g., by making appropriate markings in the margins).
22 A Party or Non-Party that makes original documents available for
23 ||inspection need not designate them for protection until after the inspecting Party
24 ||has indicated which documents it would like copied and produced. During the
25 ||inspection and before the designation, all of the material made available for
26 ||inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
27 ||identified the documents it wants copied and produced, the Producing Party must
28 ||determine which documents, or portions thereof, qualify for protection under this
7 8:19-cv-01248-CJC-PLA
1 |/Order. Then, before producing the specified documents, the Producing Party must
2 ||affix the “CONFIDENTIAL legend” to each page that contains Protected
3 ||Material. If only a portion or portions of the material on a page qualifies for
4 ||protection, the Producing Party also must clearly identify the protected portion(s)
5 ||(e.g., by making appropriate markings in the margins).
6 (b) for testimony given in depositions that the Designating Party identify
7||the Disclosure or Discovery Material on the record, before the close of the
8 || deposition all protected testimony.
9 (c) for information produced in some form other than documentary and for
10 ||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/]|legend “CONFIDENTIAL.” If only a portion or portions of the information
13 || warrants protection, the Producing Party, to the extent practicable, shall identify
14 ||the protected portion(s).
He 15 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
16 || failure to designate qualified information or items does not, standing alone, waive
17 ||the Designating Party’s right to secure protection under this Order for such
18 ||material. Upon timely correction of a designation, the Receiving Party must make
19 ||reasonable efforts to assure that the material is treated in accordance with the
20 || provisions of this Order.
1/8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
22 8.1 Timing of Challenges. Any Party or Non-Party may challenge a
23 ||designation of confidentiality at any time that is consistent with the Court’s
24 Scheduling Order.
25 8.2 Meet_and Confer. The Challenging Party shall initiate the dispute
26 ||resolution process under Local Rule 37-1 et seq.
27 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
28 ||joint stipulation pursuant to Local Rule 37-2.
8 8:19-cv-01248-CJC-PLA
1 8.4 The burden of persuasion in any such challenge proceeding shall be on
2 ||the Designating Party. Frivolous challenges, and those made for an improper
3 ||purpose (e.g., to harass or impose unnecessary expenses and burdens on other
4 ||parties) may expose the Challenging Party to sanctions. Unless the Designating
5 ||Party has waived or withdrawn the confidentiality designation, all parties shall
6 |{continue to afford the material in question the level of protection to which it is
7 \|entitled under the Producing Party’s designation until the Court rules on the
8 challenge.
9 1/9. ACCESS TO AND USE OF PROTECTED MATERIAL
10 9.1 Basic Principles. A Receiving Party may use Protected Material that is
11 ||disclosed or produced by another Party or by a Non-Party in connection with this
5 12 ||Action only for prosecuting, defending, or attempting to settle this Action. Such
g 13 ||Protected Material may be disclosed only to the categories of persons and under
14 ||the conditions described in this Order. When the Action has been terminated, a
He 15 ||Receiving Party must comply with the provisions of section 13 below (FINAL
“242 16 || DISPOSITION).
17 Protected Material must be stored and maintained by a Receiving Party at a
18 ||location and in a secure manner that ensures that access is limited to the persons
19 □□ authorized under this Order.
20 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
21 |}otherwise ordered by the court or permitted in writing by the Designating Party, a
22||Receiving Party may disclose any information or item designated
23 ||““CONFIDENTIAL” only to:
24 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
25 |/as employees of said Outside Counsel of Record to whom it is reasonably
26 ||necessary to disclose the information for this Action;
27 (b) the officers, directors, and employees (including House Counsel) of the
28 ||Receiving Party to whom disclosure is reasonably necessary for this Action;
9 8:19-cv-01248-CJC-PLA
1 (c) Experts (as defined in this Order) of the Receiving Party to whom
2 ||disclosure is reasonably necessary for this Action and who have signed the
3 ||‘“Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (d) the Court and its personnel;
5 (e) court reporters and their staff;
6 (f) professional jury or trial consultants, mock jurors, and Professional
7 || Vendors to whom disclosure is reasonably necessary for this Action and who have
8 ||signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (g) the author or recipient of a document containing the information or a
10 }}custodian or other person who otherwise possessed or knew the information;
11 (h) during their depositions, witnesses, and attorneys for witnesses, in the
5 12 }|Action to whom disclosure is reasonably necessary provided: (1) the deposing
g 13 ||party requests that the witness sign the form attached as Exhibit A hereto; and (2)
14 ||they will not be permitted to keep any confidential information unless they sign
He 15 ||the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
16 ||otherwise agreed by the Designating Party or ordered by the court. Pages of
17 ||transcribed deposition testimony or exhibits to depositions that reveal Protected
18 ||Material may be separately bound by the court reporter and may not be disclosed
19 ||to anyone except as permitted under this Protective Order; and
20 (i) any mediator or settlement officer, and their supporting personnel,
21 |}mutually agreed upon by any of the parties engaged in settlement discussions.
||10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
23 || IN OTHER LITIGATION
24 If a Party is served with a subpoena or a court order issued in other
25 || litigation that compels disclosure of any information or items designated in this
26 || Action as “CONFIDENTIAL,” that Party must:
27 (a) promptly notify in writing the Designating Party. Such notification shall
28 ||include a copy of the subpoena or court order;
10 8:19-cv-01248-CJC-PLA
1 (b) promptly notify in writing the party who caused the subpoena or order
2 ||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 ||include a copy of this Protective Order; and
5 (c) cooperate with respect to all reasonable procedures sought to be pursued
6 ||by the Designating Party whose Protected Material may be affected. If the
7||Designating Party timely seeks a protective order, the Party served with the
8 ||subpoena or court order shall not produce any information designated in this
9 ||action as “CONFIDENTIAL” before a determination by the court from which the
10 ||subpoena or order issued, unless the Party has obtained the Designating Party’s
11 ||}permission. The Designating Party shall bear the burden and expense of seeking
5 12 protection in that court of its confidential material and nothing in these provisions
g 13 ||should be construed as authorizing or encouraging a Receiving Party in this
14 || Action to disobey a lawful directive from another court.
He 15}}11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
16 PRODUCED IN THIS LITIGATION
17 (a) The terms of this Order are applicable to information produced by a
18 ||Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
19 ||produced by Non-Parties in connection with this litigation is protected by the
20 ||remedies and relief provided by this Order. Nothing in these provisions should be
21 |/construed as prohibiting a Non-Party from seeking additional protections.
22 (b) In the event that a Party is required, by a valid discovery request, to
23 ||produce a Non-Party’s confidential information in its possession, and the Party is
24 ||subject to an agreement with the Non-Party not to produce the Non-Party’s
25 ||confidential information, then the Party shall:
26 (1) promptly notify in writing the Requesting Party and the Non-Party that
27 |{some or all of the information requested is subject to a confidentiality agreement
28 || with a Non-Party;
ll 8:19-cv-01248-CJC-PLA
1 (2) promptly provide the Non-Party with a copy of the Protective Order in
2||this Action, the relevant discovery request(s), and a reasonably specific
3 || description of the information requested; and
4 (3) make the information requested available for inspection by the Non-
5 || Party, if requested.
6 (c) If the Non-Party fails to seek a protective order from this court within 14
7 ||days of receiving the notice and accompanying information, the Receiving Party
8 ||may produce the Non-Party’s confidential information responsive to the discovery
9 ||request. If the Non-Party timely secks a protective order, the Receiving Party shall
10 ||not produce any information in its possession or control that is subject to the
11 ||}confidentiality agreement with the Non-Party before a determination by the court.
5 12 }|Absent a court order to the contrary, the Non-Party shall bear the burden and
g 13 ||expense of seeking protection in this court of its Protected Material.
14}}12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
He 15 If a Receiving Party learns that, by inadvertence or otherwise, it has
16 ||disclosed Protected Material to any person or in any circumstance not authorized
17 |}under this Protective Order, the Receiving Party must immediately (a) notify in
18 || writing the Designating Party of the unauthorized disclosures, (b) use its best
19 ||efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
20 ||person or persons to whom unauthorized disclosures were made of all the terms of
21||this Order, and (d) request such person or persons to execute the
22 ||““Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
23 ||A.
24}/13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
25 ||, PROTECTED MATERIAL
26 When a Producing Party gives notice to Receiving Parties that certain
27 ||inadvertently produced material is subject to a claim of privilege or other
28 ||protection, the obligations of the Receiving Parties are those set forth in Federal
12 8:19-cv-01248-CJC-PLA
1 |/Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
2 ||whatever procedure may be established in an e-discovery order that provides for
3 || production without prior privilege review. Pursuant to Federal Rule of Evidence
4||502(d) and (e), insofar as the parties reach an agreement on the effect of
5 ||disclosure of a communication or information covered by the attorney-client
6 ||privilege or work product protection, the parties may incorporate their agreement
7 ||1in the stipulated protective order submitted to the court.
8{114. MISCELLANEOUS
9 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
10 person to seek its modification by the Court in the future.
11 14.2 Right to Assert Other Objections. By entry of this Protective Order no
5 ||Party waives any right it otherwise would have to object to disclosing or
g 13 ||}producing any information or item on any ground not addressed in this Protective
14 }|Order. Similarly, no Party waives any right to object on any ground to use in
He 15 ||evidence of any of the material covered by this Protective Order.
16 14.3 Filing Protected Material. A Party that seeks to file under seal any
17 ||Protected Material must comply with Civil Local Rule 79-5. Protected Material
18 ||may only be filed under seal pursuant to a court order authorizing the sealing of
19 ||the specific Protected Material at issue. If a Party's request to file Protected
20 || Material under seal is denied by the court, then the Receiving Party may file the
21 |/information in the public record unless otherwise instructed by the court.
22|/15. FINAL DISPOSITION
23 After the final disposition of this Action, as defined in paragraph 4, within
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 |jused in this subdivision, “all Protected Material” includes all copies, abstracts,
27 ||compilations, summaries, and any other format reproducing or capturing any of
28 ||the Protected Material. Whether the Protected Material is returned or destroyed,
13 8:19-cv-01248-CJC-PLA
1 |/the Receiving Party must submit a written certification to the Producing Party
2 ||(and, if not the same person or entity, to the Designating Party) by the 60 day
3 ||deadline that (1) identifies (by category, where appropriate) all the Protected
4 ||Material that was returned or destroyed and (2) affirms that the Receiving Party
5 ||has not retained any copies, abstracts, compilations, summaries or any other
6 ||format reproducing or capturing any of the Protected Material. Notwithstanding
7 ||this provision, Counsel are entitled to retain an archival copy of all pleadings,
8 |;}motion papers, trial, deposition, and hearing transcripts, legal memoranda,
9 ||correspondence, deposition and trial exhibits, expert reports, attorney work
10 ||product, and consultant and expert work product, even if such materials contain
11 ||Protected Material. Any such archival copies that contain or constitute Protected
5 12 ||Material remain subject to this Protective Order as set forth in Section 4
= 2 13||(URATION).
2255 14|[16. VIOLATION
He 15 Any violation of this Order may be punished by any and all appropriate
16 |}measures including, without limitation, contempt proceedings and/or monetary
2 17 || sanctions.
18
19
20 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21 Jae Mamet
22 ||Dated: March 16, 2020
23 HON. PAUL L. ABRAMS
UNITED STATES MAGISTRATE JUDGE
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26
27
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14 8:19-cv-01248-CJC-PLA
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 [print or type full name],
4 |lof [print or type full address],
5 ||declare under penalty of perjury that I have read in its entirety and understand the
6 ||Protective Order that was issued by the United States District Court for the
7||Central District of California on [date] in the case of Dan’s Deals
8 v. Sunspotweb, Inc., et al., Case No. 8:19-cv-01248-CJC-PLA. I agree to
9||comply with and to be bound by all the terms of this Protective Order and I
10 |}understand and acknowledge that failure to so comply could expose me to
11 }|sanctions and punishment in the nature of contempt. I solemnly promise that I will
5 12 ||not disclose in any manner any information or item that is subject to this
g 13 ||Protective Order to any person or entity except in strict compliance with the
14 || provisions of this Order. I further agree to submit to the jurisdiction of the United
He 15 ||States District Court for the Central District of California for the purpose of
16 ||enforcing the terms of this Protective Order, even if such enforcement proceedings
17}}occur after termination oof this action. I hereby appoint
18 [print or type full name] of
19 [print or type full address
20 ||and telephone number] as my California agent for service of process in connection
21 ||with this action or any proceedings related to enforcement of this Protective
22 || Order.
23
24 || Date:
25 ||City and State where sworn and signed:
26 || Printed name:
27 || Signature:
28 1 8:19-cv-01248-CJC-PLA
EXHIBIT A