Sophia Larios v. City of Long Beach

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Nicholas C. Calabia, Esq. (SBN 311665)

2 ncalabia@socaljusticelawgroup.com

SOCAL JUSTICE LAW GROUP, P.C.

3 5670 Wilshire Boulevard, 18th Floor

Los Angeles, California 90036

4 Telephone: (323) 723-3120

Facsimile: (310) 734-1710

5

6 Attorneys for Plaintiff, SOPHIA LARIOS

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10

11 SOPHIA LARIOS, an individual ) Case No.: 2:18−cv−10486 PSG (PJWx)

)

12 Plaintiff, ) [Assigned to the Hon. Philip S. Gutierrez,

) United States District Judge]

13 vs. )

)

14 CITY OF LONG BEACH; OFFICER B. )

)

PASION; OFFICER C. ROTH;

15 OFFICER J. MENDOZA; OFFICER ) JOINT STIPULATION REGARDING

16

A G. OD NO ZM ALIN EG ZU ; OE FZ F; IO CF EF RICER A. ) ) )

[ GPX ORX VOX EPX ROX NSXE INXD GX] P PR RO OT DE UC CT TI IV OE N O OR FD ER

ALVARADO; OFFICER ) CONFIDENTIAL INFORMATION

17 JOHNSON; OFFICER ORTEGA and )

DOES 6 through 20, inclusive, )

18 ) DISCOVERY MATTER

)

19 )

Defendants. )

20 )

)

21

TO THIS HONORABLE COURT:

22

This stipulation is entered into by and between the attorneys of record for the

23

current parties in the above-referenced action as follows:

24

1. A. PURPOSE AND LIMITATIONS

25

Discovery in this action is likely to involve production of confidential,

26

proprietary, or private information for which special protection from public disclosure

27

and from use for any purpose other than prosecuting this litigation may be warranted.

1 Accordingly, the parties hereby stipulate to and petition the Court to enter the following

2 Stipulated Protective Order. The parties acknowledge that this Order does not confer

3 blanket protections on all disclosures or responses to discovery and that the protection it

4 affords from public disclosure and use extends only to the limited information or items

5 that are entitled to confidential treatment under the applicable legal principles. The

6 parties further acknowledge, as set forth in Section 12.3 below, that this Stipulated

7 Protective Order does not entitle them to file confidential information under seal; Civil

8 Local Rule 79-5 sets forth the procedures that must be followed and the standards that

9 will be applied when a party seeks permission from the court to file material under seal.

10 There is a strong presumption that the public has a right of access to judicial

11 proceedings and records in civil cases. In connection with non-dispositive motions,

12 good cause must be shown to support a filing under seal. See Kamakana v. City and

13 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

14 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,

15 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

16 cause showing), and a specific showing of good cause or compelling reasons with

17 proper evidentiary support and legal justification, must be made with respect to material

18 that a party seeks to file under seal. The parties’ mere designation of material as

19 “CONFIDENTIAL” does not— without the submission of competent evidence by

20 declaration, establishing that the material sought to be filed under seal qualifies as

21 confidential, privileged, or otherwise protectable—constitute good cause. Further, if a

22 party requests sealing related to dispositive motion or trial, then compelling reasons, not

23 only good cause, for the sealing must be shown, and the relief sought shall be narrowly

24 tailored to serve the specific interest to be protected. See Pintos v. Pacific Creditors

25 Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010).

26 Any document that is not confidential, privileged, or otherwise protectable in its

27 entirety will not be filed under seal if the confidential portions can be redacted. If

1 the confidential, privileged, or otherwise protectable portions of the document, shall be

2 filed. Any application that seeks to file documents under seal in their entirety should

3 include an explanation of why redaction is not feasible.

4 B. GOOD CAUSE STATEMENT

5 This action is likely to involve confidential information pertaining to personnel

6 records and other materials subject to privacy protections for which special protection

7 from public disclosure and from use for any purpose other than prosecution of this

8 action is warranted. Limiting disclosure of these documents to the context of this

9 litigation as provided herein will, accordingly further important law enforcement

10 objectives and interests, including the safety of personnel and the public, as well as

11 individual privacy rights of Plaintiff, Defendants, individuals likely to be named in the

12 future, and third parties. Such confidential materials and information consist of, among

13 other things, materials entitled to privileges and/or protections under the following: the

14 United States Constitution, First Amendment; the California Constitution, Article I,

15 Section 1; California Penal Code §§ 832.5, 832.7, and 832.8; California Evidence Code

16 §§ 1040 and 1043 et seq.; the Privacy Act of 1974, 5 U.S.C. § 552a; Health Insurance

17 Portability and Accountability Act of 1996 (HIPAA), Public Law 104-191, decisional

18 law relating to such provisions; and information otherwise generally unavailable to the

19 public, or which may be privileged or otherwise protected from disclosure under state or

20 federal statutes, court rules, case decisions, or common law.

21 Confidential information with respect to the Defendants may include but is not

22 limited to: personnel files; internal investigative files and documents; email and written

23 correspondence records; and policies and procedures that are kept from the public in the

24 ordinary course of business, as well as other items subject to the Official Information

25 Privilege and other privileges.

26 Confidential information with respect to the Plaintiff may include but is not

27 limited to: employment and financial records; email and written correspondence

1 records; and psychological and medical records of any kind including, but not limited

2 to, notes, evaluations, reports, and treatment plans.

3 Accordingly, to expedite the flow of information, to facilitate the prompt

4 resolution of disputes over confidentiality of discovery materials, to adequately protect

5 information the parties are entitled to keep confidential, to ensure that the parties are

6 permitted to reasonably use such material in preparation for and in conduct of trial, to

7 address their handling at the end of the litigation, and serve the ends of justice, a

8 protective order for such information is justified in this matter. It is the intent of the

9 parties that information will not be designated as confidential for tactical reasons and

10 that nothing be so designated without a good faith belief that it has been maintained in a

11 confidential, non-public manner, and there is good cause why it should not be part of the

12 public record of this case.

13 2. DEFINITIONS

14 2.1 Action: Larios v. City of Long Beach, et al. (2:18−cv−10486 PSG

15 (PJWx)).

16 2.2 Challenging Party: a Party or Non-Party that challenges the designation

17 of information or items under this Order.

18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

19 how it is generated, stored or maintained) or tangible things that qualify for protection

20 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

21 Statement.

22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

23 their support staff).

24 2.5 Designating Party: a Party or Non-Party that designates information or

25 items that it produces in disclosures or in responses to discovery as

26 “CONFIDENTIAL.”

27 2.6 Disclosure or Discovery Material: all items or information, regardless

1 among other things, testimony, transcripts, and tangible things), that are produced or

2 generated in disclosures or responses to discovery in this matter.

3 2.7 Expert: a person with specialized knowledge or experience in a matter

4 pertinent to the litigation who has been retained by a Party or its counsel to serve as an

5 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 counsel.

9 2.9 Non-Party: any natural person, partnership, corporation, association, or

10 other legal entity not named as a Party to this action.

11 2.10 Outside Counsel of Record: attorneys who are not employees of a

12 party to this Action but are retained to represent or advise a party to this Action and

13 have appeared in this Action on behalf of that party or are affiliated with a law firm

14 which has appeared on behalf of that party, and includes support staff.

15 2.11 Party: any party to this Action, including all of its officers, directors,

16 employees, consultants, retained experts, and Outside Counsel of Record (and their

17 support staffs).

18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

19 Discovery Material in this Action.

20 2.13 Professional Vendors: persons or entities that provide litigation

21 support services (e.g., photocopying, videotaping, translating, preparing exhibits or

22 demonstrations, and organizing, storing, or retrieving data in any form or medium) and

23 their employees and subcontractors.

24 2.14 Protected Material: any Disclosure or Discovery Material that is

25 designated as “CONFIDENTIAL.”

26 2.15 Receiving Party: a Party that receives Disclosure or Discovery

27 Material from a Producing Party.

1 2.16 Producing Party: a Party that makes a Disclosure or produces

2 Discovery Material to the Receiving Party.

3 3. SCOPE

4 The protections conferred by this Order cover not only Protected Material (as

5 defined above), but also (1) any information copied or extracted from Protected

6 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and

7 (3) any testimony, conversations, or presentations by Parties or their Counsel (as

8 defined by Sections 4.8 and 4.10) that might reveal Protected Material.

9 Any use of Protected Material at trial shall be governed by the orders of the trial

10 judge. This Order does not govern the use of Protected Material at trial.

11 4. DURATION

12 Once a case proceeds to trial, information that was designated as

13 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as

14 an exhibit at trial becomes public and will be presumptively available to all members of

15 the public, including the press, unless compelling reasons supported by specific factual

16 findings to proceed otherwise are made to the trial judge in advance of the trial. See

17 Kamakana, 447 F. 3d at 1180-81 (distinguishing “good cause: showing for sealing

18 documents produced in discovery from “compelling reasons” standard when merits-

19 related documents are part of court record). Accordingly, the terms of this protective

20 order do not extend beyond the commencement of trial.

21 In the event that this case does not proceed to trial, the confidentiality obligations

22 imposed by this Order shall remain in effect until the dismissal of all claims and

23 defenses in this Action, with or without prejudice.

24 5. DESIGNATING PROTECTED MATERIAL

25 5.1 Exercise of Restraint and Care in Designating Material for

26 Protection. Each Party or Non-Party that designates information or items for protection

27 under this Order must take care to limit any such designation to specific material that

1 protection only those parts of material, documents, items, or oral or written

2 communications that qualify so that other portions of the material, documents, items, or

3 communications for which protection is not warranted are not swept unjustifiably within

4 the ambit of this Order.

5 Mass, indiscriminate, or routinized designations are prohibited. Designations that

6 are shown to be clearly unjustified or that have been made for an improper purpose

7 (e.g., to unnecessarily encumber the case development process or to impose unnecessary

8 expenses and burdens on other parties) may expose the Designating Party to sanctions.

9 If it comes to a Designating Party’s attention that information or items that it

10 designated for protection do not qualify for protection, that Designating Party must

11 promptly notify all other Parties that it is withdrawing the inapplicable designation.

12 5.2 Manner and Timing of Designations. Except as otherwise provided in this

13 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or

14 ordered, Disclosure or Discovery Material that qualifies for protection under this Order

15 must be clearly so designated before the material is disclosed or produced.

16 Designation in conformity with this Order requires:

17 (a) for information in documentary form (e.g., paper or electronic documents, but

18 excluding transcripts of depositions or other pretrial or trial proceedings), that the

19 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

20 “CONFIDENTIAL legend”), to each page that contains protected material. If only a

21 portion or portions of the material on a page qualifies for protection, the Producing

22 Party also must clearly identify the protected portion(s) (e.g., by making appropriate

23 markings in the margins).

24 A Party or Non-Party that makes original documents available for inspection need

25 not designate them for protection until after the inspecting Party has indicated which

26 documents it would like copied and produced. During the inspection and before the

27 designation, all of the material made available for inspection shall be deemed

1 copied and produced, the Producing Party must determine which documents, or portions

2 thereof, qualify for protection under this Order. Then, before producing the specified

3 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page

4 that contains Protected Material. If only a portion or portions of the material on a page

5 qualifies for protection, the Producing Party also must clearly identify the protected

6 portion(s) (e.g., by making appropriate markings in the margins).

7 (b) for testimony given in depositions that the Designating Party identify the

8 Disclosure or Discovery Material on the record, before the close of the deposition all

9 protected testimony.

10 (c) for information produced in some form other than documentary and for any

11 other tangible items, that the Producing Party affix in a prominent place on the exterior

12 of the container or containers in which the information is stored the legend

13 “CONFIDENTIAL.” If only a portion or portions of the information warrants

14 protection, the Producing Party, to the extent practicable, shall identify the protected

15 portion(s).

16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to

17 designate qualified information or items does not, standing alone, waive the Designating

18 Party’s right to secure protection under this Order for such material. Upon timely

19 correction of a designation, the Receiving Party must make reasonable efforts to assure

20 that the material is treated in accordance with the provisions of this Order.

21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation

23 of confidentiality at any time that is consistent with the Court’s Scheduling Order.

24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution

25 process under Local Rule 37.1 et seq.

26 6.3 The burden of persuasion in any such challenge proceeding shall be on the

27 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

1 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

2 the confidentiality designation, all parties shall continue to afford the material in

3 question the level of protection to which it is entitled under the Producing Party’s

4 designation until the Court rules on the challenge.

5 7. ACCESS TO AND USE OF PROTECTED MATERIAL

6 7.1 Basic Principles. A Receiving Party may use Protected Material that is

7 disclosed or produced by another Party or by a Non-Party in connection with this Action

8 only for prosecuting, defending, or attempting to settle this Action. Such Protected

9 Material may be disclosed only to the categories of persons and under the conditions

10 described in this Order. When the Action has been terminated, a Receiving Party must

11 comply with the provisions of section 13 below (FINAL DISPOSITION).

12 Protected Material must be stored and maintained by a Receiving Party at a

13 location and in a secure manner that ensures that access is limited to the persons

14 authorized under this Order.

15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

16 ordered by the court or permitted in writing by the Designating Party, a Receiving Party

17 may disclose any information or item designated “CONFIDENTIAL” only to:

18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

19 employees of said Outside Counsel of Record to whom it is reasonably necessary to

20 disclose the information for this Action;

21 (b) the officers, directors, and employees (including House Counsel) of the

22 Receiving Party to whom disclosure is reasonably necessary for this Action;

23 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure

24 is reasonably necessary for this Action and who have signed the “Acknowledgment and

25 Agreement to Be Bound” (Exhibit A);

26 (d) the court and its personnel;

27 (e) court reporters and their staff;

1 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to

2 whom disclosure is reasonably necessary for this Action and who have signed the

3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

4 (g) the author or recipient of a document containing the information or a

5 custodian or other person who otherwise possessed or knew the information;

6 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action

7 to whom disclosure is reasonably necessary provided: (1) the deposing party requests

8 that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be

9 permitted to keep any confidential information unless they sign the “Acknowledgment

10 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating

11 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to

12 depositions that reveal Protected Material may be separately bound by the court reporter

13 and may not be disclosed to anyone except as permitted under this Stipulated Protective

14 Order; and

15 (i) any mediator or settlement officer, and their supporting personnel, mutually

16 agreed upon by any of the parties engaged in settlement discussions.

17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

18 PRODUCED IN OTHER LITIGATION

19 If a Party is served with a subpoena or a court order issued in other litigation that

20 compels disclosure of any information or items designated in this Action as

21 “CONFIDENTIAL,” that Party must:

22 (a) promptly notify in writing the Designating Party. Such notification shall

23 include a copy of the subpoena or court order;

24 (b) promptly notify in writing the party who caused the subpoena or order to

25 issue in the other litigation that some or all of the material covered by the subpoena or

26 order is subject to this Stipulated Protective Order. Such notification shall include a

27 copy of this Stipulated Protective Order; and

1 (c) cooperate with respect to all reasonable procedures sought to be pursued by

2 the Designating Party whose Protected Material may be affected.

3 If the Designating Party timely seeks a protective order, the Party served with the

4 subpoena or court order shall not produce any information designated in this action as

5 “CONFIDENTIAL” before a determination by the court from which the subpoena or

6 order issued, unless the Party has obtained the Designating Party’s permission. The

7 Designating Party shall bear the burden and expense of seeking protection in that court

8 of its confidential material and nothing in these provisions should be construed as

9 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

10 directive from another court.

11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

12 PRODUCED IN THIS LITIGATION

13 (a) The terms of this Order are applicable to information produced by a Non-Party

14 in this Action and designated as “CONFIDENTIAL.” Such information produced by

15 Non-Parties in connection with this litigation is protected by the remedies and relief

16 provided by this Order. Nothing in these provisions should be construed as prohibiting a

17 Non-Party from seeking additional protections.

18 (b) In the event that a Party is required, by a valid discovery request, to produce a

19 Non-Party’s confidential information in its possession, and the Party is subject to an

20 agreement with the Non-Party not to produce the Non-Party’s confidential information,

21 then the Party shall:

22 (1) promptly notify in writing the Requesting Party and the Non-Party that

23 some or all of the information requested is subject to a confidentiality agreement with a

24 Non-Party;

25 (2) promptly provide the Non-Party with a copy of the Stipulated

26 Protective Order in this Action, the relevant discovery request(s), and a reasonably

27 specific description of the information requested; and

1 (3) make the information requested available for inspection by the Non-

2 Party, if requested.

3 (c) If the Non-Party fails to seek a protective order from this court within fourteen

4 (14) days of receiving the notice and accompanying information, the Receiving Party

5 may produce the Non-Party’s confidential information responsive to the discovery

6 request. If the Non-Party timely seeks a protective order, the Receiving Party shall not

7 produce any information in its possession or control that is subject to the confidentiality

8 agreement with the Non-Party before a determination by the court. Absent a court order

9 to the contrary, the Non-Party shall bear the burden and expense of seeking protection in

10 this court of its Protected Material.

11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

13 Protected Material to any person or in any circumstance not authorized under this

14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

15 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

16 all unauthorized copies of the Protected Material, (c) inform the person or persons to

17 whom unauthorized disclosures were made of all the terms of this Order, and (d) request

18 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

19 that is attached hereto as Exhibit A.

20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR

21 OTHERWISE PROTECTED MATERIAL

22 When a Producing Party gives notice to Receiving Parties that certain

23 inadvertently produced material is subject to a claim of privilege or other protection, the

24 obligations of the Receiving Parties are those set forth in Federal Rule of Civil

25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

26 may be established in an e-discovery order that provides for production without prior

27 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

1 information covered by the attorney-client privilege or work product protection, the

2 parties may incorporate their agreement in the stipulated protective order submitted to

3 the court.

4 12. MISCELLANEOUS

5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

6 person to seek its modification by the Court in the future.

7 12.2 Right to Assert Other Objections. By stipulating to the entry of this

8 Protective Order no Party waives any right it otherwise would have to object to

9 disclosing or producing any information or item on any ground not addressed in this

10 Stipulated Protective Order. Similarly, no Party waives any right to object on any

11 ground to use in evidence of any of the material covered by this Protective Order.

12 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected

13 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed

14 under seal pursuant to a court order authorizing the sealing of the specific Protected

15 Material at issue. If a Party's request to file Protected Material under seal is denied by

16 the court, then the Receiving Party may file the information in the public record unless

17 otherwise instructed by the court.

18 13. FINAL DISPOSITION

19 After the final disposition of this Action, as defined in paragraph 4, within 60

20 days of a written request by the Designating Party, each Receiving Party must

21 return all Protected Material to the Producing Party or destroy such material. As used in

22 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

23 summaries, and any other format reproducing or capturing any of the Protected

24 Material. Whether the Protected Material is returned or destroyed, the Receiving Party

25 must submit a written certification to the Producing Party (and, if not the same person or

26 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category,

27 where appropriate) all the Protected Material that was returned or destroyed and (2)

1 summaries or any other format reproducing or capturing any of the Protected Material.

2 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all

3 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

4 correspondence, deposition and trial exhibits, expert reports, attorney work product, and

5 consultant and expert work product, even if such materials contain Protected Material.

6 Any such archival copies that contain or constitute Protected Material remain subject to

7 this Protective Order as set forth in Section 4 (DURATION).

8 14. Any violation of this Order may be punished by any and all appropriate

9 measures including, without limitation, contempt proceedings and/or monetary

10 sanctions.

11

12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

13

14 DATED: May 21, 2020 Respectfully submitted,

15 SOCAL JUSTICE LAW GROUP, P.C.

16

/s/ Nicholas C. Calabia

17 Jennifer A. Bandlow, Esq.

18 Nicholas C. Calabia, Esq.

Attorneys for Plaintiff

19

20 DATED: May 21, 2020 Respectfully submitted,

21 HURRELL CANTRALL LLP

22

23 /s/ Shakira L. Johnson __________ _

Thomas C. Hurrell, Esq.

24

Shakira L. Johnson, Esq.

25 Attorneys for Defendants CITY OF LONG

26 BEACH, a municipal corporation,

OFFICER B. PASION, an individual,

27 OFFICER C. ROTH, an individual,

1 OFFICER ALVARADO, an individual,

OFFICER JOHNSON, an individual, and

2 OFFICER ORTEGA, an individual

3

4 ||DATED: May 21, 2020 Respectfully submitted,

5 BRADLEY & GMELICH LLP

6

7 /s/ Jonathan A. Ross

THOMAS P. GMELICH

8 JONATHAN A. ROSS

9 CAROL A. HUMISTON

Attorneys for Defendant, OFFICER A.

10 DOMINGUEZ

12 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

13

14 ||DATED: May 22, 2020

15 Patrick J. Walsh

United Stated Magistrate Judge

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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 in the case of Larios v. City of Long Beach, et al. (2:18−cv−10486

8 PSG (PJWx)). I agree to comply with and to be bound by all the terms of this Stipulated

9 Protective Order and I understand and acknowledge that failure to so comply could

10 expose me to sanctions and punishment in the nature of contempt. I solemnly promise

11 that I will not disclose in any manner any information or item that is subject to this

12 Stipulated Protective Order to any person or entity except in strict compliance with the

13 provisions of this Order. I further agree to submit to the jurisdiction of the United States

14 District Court for the Central District of California for enforcing the terms of this

15 Stipulated Protective Order, even if such enforcement proceedings occur after

16 termination of this action.

17

18 Date: _________________________________

19

20 City and State where sworn and signed: _________________________________

21

22 Printed name: _________________________________

23

24 Signature: _________________________________

25

26

27