distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record
- even stipulated 17 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 WBEILNLEKDIIEC TF AYR. RH U&R G (ASBLNLA #G 2H24E0R1 8L)L P
2 bhur@willkie.com
JAYVAN E. MITCHELL (SBN # 322007)
3 jmitchell@willkie.com
One Front Street, 34th Floor
4 San Francisco, CA 94111
Telephone: (415) 858-7400
5 Facsimile: (415) 848-7599
6 Attorneys for Plaintiff Longwell Textiles Ltd.
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
11 LONGWELL TEXTILES LTD., a Case No.: 2:19-cv-09904-SVW-AGR
Chinese company
12
Plaintiff, STIPULATION AND PROTECTIVE
13 ORDER
v.
14
MATRIX INTERNATIONAL Judge: Hon Stephen V. Wilson
15 TEXTILE INC., a California Courtroom: 10
corporation, NEMAN PROPERTIES
16 LLC, a California limited liability Magistrate Judge: Hon. Alicia G.
company, and DOES 1 through 10, Rosenberg
17 Courtroom: 550
Defendants.
18 Complaint Filed: November 11, 2019
19 Trial Date: September 8, 2020
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24
25
26
27
28
1 1. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public disclosure
4 and from use for any purpose other than pursuing this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 following Stipulated Protective Order. The parties acknowledge that this Order does
7 not confer blanket protections on all disclosures or responses to discovery and that
8 the protection it affords from public disclosure and use extends only to the limited
9 information or items that are entitled to confidential treatment under the applicable
10 legal principles.
11 2. GOOD CAUSE STATEMENT
12 This action is likely to involve customer and pricing lists and other valuable
13 research, development, commercial, financial, technical and/or proprietary
14 information for which special protection from public disclosure and from use for any
15 purpose other than prosecution of this action is warranted. Such confidential and
16 proprietary materials and information consist of, among other things, confidential
17 business or financial information, information regarding confidential business
18 practices, or other confidential research, development, or commercial information
19 (including information implicating privacy rights of third parties), information
20 otherwise generally unavailable to the public, or which may be privileged or
21 otherwise protected from disclosure under state or federal statutes, court rules, case
22 decisions, or common law. Accordingly, to expedite the flow of information, to
23 facilitate the prompt resolution of disputes over confidentiality of discovery
24 materials, to adequately protect information the parties are entitled to keep
25 confidential, to ensure that the parties are permitted reasonable necessary uses of such
26 material in preparation for and in the conduct of trial, to address their handling at the
27 end of the litigation, and serve the ends of justice, a protective order for such
28 information is justified in this matter. It is the intent of the parties that information
1 will not be designated as confidential for tactical reasons and that nothing be so
2 designated without a good faith belief that it has been maintained in a confidential,
3 non-public manner, and there is good cause why it should not be part of the public
4 record of this case.
5 3. ACKNOWLEDGMENT OF UNDER SEAL FILING
PROCEDURE
6
7 The parties further acknowledge, as set forth in Section 14.3, below, that this
8 Stipulated Protective Order does not entitle them to file confidential information
9 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
10 the standards that will be applied when a party seeks permission from the court to
11 file material under seal. There is a strong presumption that the public has a right of
12 access to judicial proceedings and records in civil cases. In connection with non-
13 dispositive motions, good cause must be shown to support a filing under seal. See
14 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
15 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
16 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
17 protective orders require good cause showing), and a specific showing of good cause
18 or compelling reasons with proper evidentiary support and legal justification, must
19 be made with respect to Protected Material that a party seeks to file under seal. The
20 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL
21 does not—without the submission of competent evidence by declaration, establishing
22 that the material sought to be filed under seal qualifies as confidential, privileged, or
23 otherwise protectable—constitute good cause.
24 Further, if a party requests sealing related to a dispositive motion or trial, then
25 compelling reasons, not only good cause, for the sealing must be shown, and the
26 relief sought shall be narrowly tailored to serve the specific interest to be protected.
27 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each
28 item or type of information, document, or thing sought to be filed or introduced under
1 seal, the party seeking protection must articulate compelling reasons, supported by
2 specific facts and legal justification, for the requested sealing order. Again,
3 competent evidence supporting the application to file documents under seal must be
4 provided by declaration.
5 Any document that is not confidential, privileged, or otherwise protectable in
6 its entirety will not be filed under seal if the confidential portions can be redacted. If
7 documents can be redacted, then a redacted version for public viewing, omitting only
8 the confidential, privileged, or otherwise protectable portions of the document, shall
9 be filed. Any application that seeks to file documents under seal in their entirety
10 should include an explanation of why redaction is not feasible.
11 4. DEFINITIONS
12 4.1 Action: this pending federal lawsuit.
13 4.2 Challenging Party: a Party or Non-Party that challenges the designation
14 of information or items under this Order.
15 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
16 how it is generated, stored or maintained) or tangible things that qualify for protection
17 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
18 Cause Statement.
19 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
20 their support staff).
21 4.5 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 “CONFIDENTIAL.”
24 4.6 Disclosure or Discovery Material: all items or information, regardless
25 of the medium or manner in which it is generated, stored, or maintained (including,
26 among other things, testimony, transcripts, and tangible things), that are produced or
27 generated in disclosures or responses to discovery.
28 4.7 Expert: a person with specialized knowledge or experience in a matter
1 pertinent to the litigation who has been retained by a Party or its counsel to serve as
2 an expert witness or as a consultant in this Action.
3 4.8 House Counsel: attorneys who are employees of a party to this Action.
4 House Counsel does not include Outside Counsel of Record or any other outside
5 counsel.
6 4.9 Non-Party: any natural person, partnership, corporation, association or
7 other legal entity not named as a Party to this action.
8 4.10 Outside Counsel of Record: attorneys who are not employees of a party
9 to this Action but are retained to represent a party to this Action and have appeared
10 in this Action on behalf of that party or are affiliated with a law firm that has appeared
11 on behalf of that party, and includes support staff.
12 4.11 Party: any party to this Action, including all of its officers, directors,
13 employees, consultants, retained experts, and Outside Counsel of Record (and their
14 support staffs).
15 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
16 Discovery Material in this Action.
17 4.13 Professional Vendors: persons or entities that provide litigation support
18 services (e.g., photocopying, videotaping, translating, preparing exhibits or
19 demonstrations, and organizing, storing, or retrieving data in any form or medium)
20 and their employees and subcontractors.
21 4.14 Protected Material: any Disclosure or Discovery Material that is
22 designated as “CONFIDENTIAL.”
23 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material
24 from a Producing Party.
25 5. SCOPE
26 The protections conferred by this Stipulation and Order cover not only
27 Protected Material (as defined above), but also (1) any information copied or
28 extracted from Protected Material; (2) all copies, excerpts, summaries, or
1 compilations of Protected Material; and (3) any testimony, conversations, or
2 presentations by Parties or their Counsel that might reveal Protected Material.
3 Any use of Protected Material at trial shall be governed by the orders of the
4 trial judge and other applicable authorities. This Order does not govern the use of
5 Protected Material at trial.
6 6. DURATION
7 Once a case proceeds to trial, information that was designated as
8 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
9 as an exhibit at trial becomes public and will be presumptively available to all
10 members of the public, including the press, unless compelling reasons supported by
11 specific factual findings to proceed otherwise are made to the trial judge in advance
12 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
13 showing for sealing documents produced in discovery from “compelling reasons”
14 standard when merits-related documents are part of court record). Accordingly, the
15 terms of this protective order do not extend beyond the commencement of the trial.
16 7. DESIGNATING PROTECTED MATERIAL
17 7.1 Exercise of Restraint and Care in Designating Material for Protection.
18 Each Party or Non-Party that designates information or items for protection under
19 this Order must take care to limit any such designation to specific material that
20 qualifies under the appropriate standards. The Designating Party must designate for
21 protection only those parts of material, documents, items or oral or written
22 communications that qualify so that other portions of the material, documents, items
23 or communications for which protection is not warranted are not swept unjustifiably
24 within the ambit of this Order.
25 Mass, indiscriminate or routinized designations are prohibited. Designations
26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber the case development process or to impose
28 unnecessary expenses and burdens on other parties) may expose the Designating
1 Party to sanctions.
2 If it comes to a Designating Party’s attention that information or items that it
3 designated for protection do not qualify for protection, that Designating Party must
4 promptly notify all other Parties that it is withdrawing the inapplicable designation.
5 7.2 Manner and Timing of Designations. Except as otherwise provided in
6 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
7 that qualifies for protection under this Order must be clearly so designated before the
8 material is disclosed or produced.
9 Designation in conformity with this Order requires:
10 (a) for information in documentary form (e.g., paper or electronic
11 documents, but excluding transcripts of depositions or other pretrial or trial
12 proceedings), that the Producing Party affix at a minimum, the legend
13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
14 contains protected material. If only a portion of the material on a page qualifies for
15 protection, the Producing Party also must clearly identify the protected portion(s)
16 (e.g., by making appropriate markings in the margins).
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 which documents it would like copied and produced. During the inspection and
20 before the designation, all of the material made available for inspection shall be
21 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
22 it wants copied and produced, the Producing Party must determine which documents,
23 or portions thereof, qualify for protection under this Order. Then, before producing
24 the specified documents, the Producing Party must affix the “CONFIDENTIAL
25 legend” to each page that contains Protected Material. If only a portion of the material
26 on a page qualifies for protection, the Producing Party also must clearly identify the
27 protected portion(s) (e.g., by making appropriate markings in the margins).
28 (b) for testimony given in depositions that the Designating Party identifies
1 the Disclosure or Discovery Material on the record, before the close of the deposition
2 all protected testimony.
3 (c) for information produced in some form other than documentary and for
4 any other tangible items, that the Producing Party affix in a prominent place on the
5 exterior of the container or containers in which the information is stored the legend
6 “CONFIDENTIAL.” If only a portion or portions of the information warrants
7 protection, the Producing Party, to the extent practicable, shall identify the protected
8 portion(s).
9 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
10 failure to designate qualified information or items does not, standing alone, waive
11 the Designating Party’s right to secure protection under this Order for such material.
12 Upon timely correction of a designation, the Receiving Party must make reasonable
13 efforts to assure that the material is treated in accordance with the provisions of this
14 Order.
15 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
16 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
17 designation of confidentiality at any time that is consistent with the Court’s
18 Scheduling Order.
19 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
20 resolution process under Local Rule 37-1 et seq.
21 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
22 joint stipulation pursuant to Local Rule 37-2.
23 8.4 The burden of persuasion in any such challenge proceeding shall be on
24 the Designating Party. Frivolous challenges, and those made for an improper purpose
25 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
26 expose the Challenging Party to sanctions. Unless the Designating Party has waived
27 or withdrawn the confidentiality designation, all parties shall continue to afford the
28 material in question the level of protection to which it is entitled under the Producing
1 Party’s designation until the Court rules on the challenge.
2 9. ACCESS TO AND USE OF PROTECTED MATERIAL
3 9.1 Basic Principles. A Receiving Party may use Protected Material that is
4 disclosed or produced by another Party or by a Non-Party in connection with this
5 Action only for prosecuting, defending or attempting to settle this Action. Such
6 Protected Material may be disclosed only to the categories of persons and under the
7 conditions described in this Order. When the Action has been terminated, a Receiving
8 Party must comply with the provisions of section 15 below (FINAL DISPOSITION).
9 Protected Material must be stored and maintained by a Receiving Party at a
10 location and in a secure manner that ensures that access is limited to the persons
11 authorized under this Order.
12 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
13 otherwise ordered by the court or permitted in writing by the Designating Party, a
14 Receiving Party may disclose any information or item designated
15 “CONFIDENTIAL” only to:
16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
17 as employees of said Outside Counsel of Record to whom it is reasonably necessary
18 to disclose the information for this Action;
19 (b) the officers, directors, and employees (including House Counsel) of the
20 Receiving Party to whom disclosure is reasonably necessary for this Action;
21 (c) Experts (as defined in this Order) of the Receiving Party to whom
22 disclosure is reasonably necessary for this Action and who have signed the
23 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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 Vendors to whom disclosure is reasonably necessary for this Action and who have
28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
1 (g) the author or recipient of a document containing the information or a
2 custodian or other person who otherwise possessed or knew the information;
3 (h) during their depositions, witnesses, and attorneys for witnesses, in the
4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
5 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
6 not be permitted to keep any confidential information unless they sign the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
8 agreed by the Designating Party or ordered by the court. Pages of transcribed
9 deposition testimony or exhibits to depositions that reveal Protected Material may be
10 separately bound by the court reporter and may not be disclosed to anyone except as
11 permitted under this Stipulated Protective Order; and
12 (i) any mediators or settlement officers and their supporting personnel,
13 mutually agreed upon by any of the parties engaged in settlement discussions.
14 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION
15
If a Party is served with a subpoena or a court order issued in other litigation
16
that compels disclosure of any information or items designated in this Action as
17
“CONFIDENTIAL,” that Party must:
18
(a) promptly notify in writing the Designating Party. Such notification shall
19
include a copy of the subpoena or court order;
20
(b) promptly notify in writing the party who caused the subpoena or order
21
to issue in the other litigation that some or all of the material covered by the subpoena
22
or order is subject to this Protective Order. Such notification shall include a copy of
23
this Stipulated Protective Order; and
24
(c) cooperate with respect to all reasonable procedures sought to be pursued
25
by the Designating Party whose Protected Material may be affected. If the
26
Designating Party timely seeks a protective order, the Party served with the subpoena
27
or court order shall not produce any information designated in this action as
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1 “CONFIDENTIAL” before a determination by the court from which the subpoena or
2 order issued, unless the Party has obtained the Designating Party’s permission. The
3 Designating Party shall bear the burden and expense of seeking protection in that
4 court of its confidential material and nothing in these provisions should be construed
5 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful
6 directive from another court.
7 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
8
(a) The terms of this Order are applicable to information produced by a
9
Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
10
produced by Non-Parties in connection with this litigation is protected by the
11
remedies and relief provided by this Order. Nothing in these provisions should be
12
construed as prohibiting a Non-Party from seeking additional protections.
13
(b) In the event that a Party is required, by a valid discovery request, to
14
produce a Non-Party’s confidential information in its possession, and the Party is
15
subject to an agreement with the Non-Party not to produce the Non-Party’s
16
confidential information, then the Party shall:
17
(1) promptly notify in writing the Requesting Party and the Non-Party that
18
some or all of the information requested is subject to a confidentiality agreement with
19
a Non-Party;
20
(2) promptly provide the Non-Party with a copy of the Stipulated Protective
21
Order in this Action, the relevant discovery request(s), and a reasonably specific
22
description of the information requested; and
23
(3) make the information requested available for inspection by the
24
Non-Party, if requested.
25
(c) If the Non-Party fails to seek a protective order from this court within
26
14 days of receiving the notice and accompanying information, the Receiving Party
27
may produce the Non-Party’s confidential information responsive to the discovery
28
1 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
2 not produce any information in its possession or control that is subject to the
3 confidentiality agreement with the Non-Party before a determination by the court.
4 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
5 of seeking protection in this court of its Protected Material.
6 12. UNAUTHORIZED DISCLOSURE OF PROTECTED
MATERIAL
7
8 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
9 Protected Material to any person or in any circumstance not authorized under this
10 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
11 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
12 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
13 persons to whom unauthorized disclosures were made of all the terms of this Order,
14 and (d) request such person or persons to execute the “Acknowledgment an
15 Agreement to Be Bound” attached hereto as Exhibit A.
16 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL
17
18 When a Producing Party gives notice to Receiving Parties that certain
19 inadvertently produced material is subject to a claim of privilege or other protection,
20 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil\
21 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
22 may be established in an e-discovery order that provides for production without prior
23 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), the privilege
24 or protection is not waived by disclosure connected with the litigation pending before
25 the Court.
26 14. MISCELLANEOUS
27 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
28 person to seek its modification by the Court in the future.
1 14.2 Right to Assert Other Objections. By stipulating to the entry of this
2 Protective Order, no Party waives any right it otherwise would have to object to
3 disclosing or producing any information or item on any ground not addressed in this
4 Stipulated Protective Order. Similarly, no Party waives any right to object on any
5 ground to use in evidence of any of the material covered by this Protective Order.
6 14.3 Filing Protected Material. A Party that seeks to file under seal any
7 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
8 only be filed under seal pursuant to a court order authorizing the sealing of the
9 specific Protected Material. If a Party’s request to file Protected Material under seal
10 is denied by the court, then the Receiving Party may file the information in the public
11 record unless otherwise instructed by the court.
12 15. FINAL DISPOSITION
13 After the final disposition of this Action, as defined in paragraph 6, within 60
14 days of a written request by the Designating Party, each Receiving Party must return
15 all Protected Material to the Producing Party or destroy such material. As used in this
16 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
17 summaries, and any other format reproducing or capturing any of the Protected
18 Material. Whether the Protected Material is returned or destroyed, the Receiving
19 Party must submit a written certification to the Producing Party (and, if not the same
20 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies
21 (by category, where appropriate) all the Protected Material that was returned or
22 destroyed and (2) affirms that the Receiving Party has not retained any copies,
23 abstracts, compilations, summaries or any other format reproducing or capturing any
24 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
25 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
26 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
27 reports, attorney work product, and consultant and expert work product, even if such
28 materials contain Protected Material. Any such archival copies that contain or
1 constitute Protected Material remain subject to this Protective Order as set forth in
2 Section 6 (DURATION).
3 16. VIOLATION
4 Any violation of this Order may be punished by appropriate measures
5 including, without limitation, contempt proceedings and/or monetary sanctions.
6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8 Dated: June 2, 2020 WILLKIE FARR & GALLAGHER LLP
9
By: /s/ Benedict Y. Hur
10
BENEDICT Y. HUR
11 JAYVAN E. MITCHELL
12 Attorneys for Plaintiff,
Longwell Textiles, Ltd.
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Dated: June 2, 2020 FOLEY BEZEK BEHLE AND CURTIS LLP
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15 By: /s/ Roger N Behle
KEVIN D GAMARNIK
16 ROGER N BEHLE , JR
17 Attorneys for Defendants
Matrix International Textile, Inc. and Neman
18 Properties, LLC
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1 ATTESTATION
2 Pursuant to Civil Local Rule 5-4.3.4, I attest that all other signatories listed
|| and on whose behalf this filing is submitted, concur in the filing’s content and hav
4|| authorized the filing.
Dated: June 2, 2020 WILLKIE FARR & GALLAGHER LLP
7 By: _/s/ Benedict Y. Hur
° Longwell Textiles, Ld
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'? |! FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: June 3, 2020
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16 United States Masistrate badge
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STIPULATION AND PROTECTIVE ORDER
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 Longwell Textiles Ltd. v. Matrix
8 International Textile Inc., et al., Case No. 2:19-cv-09904-SVW-AGR. I agree to
9 comply with and to be bound by all the terms of this Stipulated Protective Order
10 and I 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
12 not disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the
14 provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action.
19 I hereby appoint __________________________ [print or type full name] of
20 _______________________________________ [print or type full address and
21 telephone number] as my California agent for service of process in connection with
22 this action or any proceedings related to enforcement of this Stipulated Protective
23 Order.
24 Date: ______________________________________
25 City and State where sworn and signed: _________________________________
26 Printed name: _______________________________
27
28 Signature: __________________________________