Kimberly Scott v. Jaguar Land Rover North America, LLC

1 BOWMAN AND BROOKE LLP

Brian Takahashi (SBN: 146505)

2 E-mail: brian.takahashi@bowmanandbrooke.com

Richard L. Stuhlbarg (SBN: 180631)

3 E-mail: richard.stuhlbarg@bowmanandbrooke.com

Freddy I. Fonseca (SBN: 311311)

4 E-mail: freddy.fonseca@bowmanandbrooke.com

970 West 190th Street, Suite 700

5 Torrance, California 90502

Tel No.: 310/ 768-3068

6 Fax No.: 310/ 719-1019

7 Attorneys for Defendant

JAGUAR LAND ROVER NORTH AMERICA, LLC

8

9 UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA – EASTERN DIVISION

11 KIMBERLY SCOTT, ) CASE NO: 5:19-cv-1873 JGB (SPx)

)

12 Plaintiff, ) Assigned to District Judge Jesus G. Bernal

) Magistrate Judge Sheri Pym

13 vs. )

) (Removed from San Bernardino

14 JAGUAR LAND ROVER NORTH ) County Superior Court, Case No.

AMERICA, LLC, a Delaware ) CIVDS1925809)

15 Limited Liability Company, and )

DOES 1 through 10, inclusive, ) STIPULATED PROTECTIVE

16 ) ORDER; ORDER

Defendants. )

17 ) Action Filed: August 29, 2019

) Trial: March 23, 2021

18 )

)

19

20 1. A. PURPOSES AND LIMITATIONS

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

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

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

24 Accordingly, the parties hereby stipulate to and petition the Court to enter the

25 following Stipulated Protective Order. The parties acknowledge that this Order does

26 not confer blanket protections on all disclosures or responses to discovery and that

27 the protection it affords from public disclosure and use extends only to the limited

28 information or items that are entitled to confidential treatment under the applicable

1 legal principles.

2 B. GOOD CAUSE STATEMENT

3 This action is likely to involve trade secrets, customer information, and other

4 valuable research, development, commercial, financial, technical and/or proprietary

5 information for which special protection from public disclosure and from use for any

6 purpose other than prosecution of this action is warranted. Such confidential and

7 proprietary materials and information consist of, among other things, confidential

8 business or financial information, information regarding confidential business

9 practices, or other confidential research, development, or commercial information

10 (including information implicating privacy rights of third parties), information

11 otherwise generally unavailable to the public, or which may be privileged or

12 otherwise protected from disclosure under state or federal statutes, court rules, case

13 decisions, or common law. Accordingly, to expedite the flow of information, to

14 facilitate the prompt resolution of disputes over confidentiality of discovery

15 materials, to adequately protect information the parties are entitled to keep

16 confidential, to ensure that the parties are permitted reasonable necessary uses of such

17 material in preparation for and in the conduct of trial, to address their handling at the

18 end of the litigation, and serve the ends of justice, a protective order for such

19 information is justified in this matter. It is the intent of the parties that information

20 will not be designated as confidential for tactical reasons and that nothing be so

21 designated without a good faith belief that it has been maintained in a confidential,

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

23 record of this case.

24 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

25 SEAL

26 The parties further acknowledge, as set forth in Section 12.3, below, that this

27 Stipulated Protective Order does not entitle them to file confidential information

28 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and

1 the standards that will be applied when a party seeks permission from the court to file

2 material under seal.

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

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

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

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

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

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

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

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

11 Protected Material that a party seeks to file under seal. The parties' mere designation

12 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the

13 submission of competent evidence by declaration, establishing that the material

14 sought to be filed under seal qualifies as confidential, privileged, or otherwise

15 protectable—constitute good cause.

16 Further, if a party requests sealing related to a dispositive motion or trial, then

17 compelling reasons, not only good cause, for the sealing must be shown, and the relief

18 sought shall be narrowly tailored to serve the specific interest to be protected. See

19 Pintos v. Pacific Creditors Ass'n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each

20 item or type of information, document, or thing sought to be filed or introduced under

21 seal in connection with a dispositive motion or trial, the party seeking protection must

22 articulate compelling reasons, supported by specific facts and legal justification, for

23 the requested sealing order. Again, competent evidence supporting the application

24 to file documents under seal must be provided by declaration.

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

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

27 documents can be redacted, then a redacted version for public viewing, omitting only

28 the confidential, privileged, or otherwise protectable portions of the document, shall

1 be filed. Any application that seeks to file documents under seal in their entirety

2 should include an explanation of why redaction is not feasible.

3 2. DEFINITIONS

4 2.1 Action: Kimberly Scott v. Jaguar Land Rover North America, LLC, et.

5 al., United States District Court — Central District, Case No. 5:19-cv-1873 JGB

6 (SPx).

7 2.2 Challenging Party: a Party or Non-Party that challenges the designation

8 of information or items under this Order.

9 2.3 "CONFIDENTIAL" Information or Items: information (regardless of

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

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

12 Cause Statement.

13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

14 their support staff).

15 2.5 Designating Party: a Party or Non-Party that designates information or

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

17 "CONFIDENTIAL."

18 2.6 Disclosure or Discovery Material: all items or information, regardless

19 of the medium or manner in which it is generated, stored, or maintained (including,

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

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

22 2.7 Expert: a person with specialized knowledge or experience in a matter

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

24 an expert witness or as a consultant in this Action.

25 2.8 House Counsel: attorneys who are employees of a party to this Action.

26 House Counsel does not include Outside Counsel of Record or any other outside

27 counsel.

28 2.9 Non-Party: any natural person, partnership, corporation, association or

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

2 2.10 Outside Counsel of Record: attorneys who are not employees of a party

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

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

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

6 2.11 Party: any party to this Action, including all of its officers, directors,

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

8 support staffs).

9 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

10 Discovery Material in this Action.

11 2.13 Professional Vendors: persons or entities that provide litigation support

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

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

14 and their employees and subcontractors.

15 2.14 Protected Material: any Disclosure or Discovery Material that is

16 designated as "CONFIDENTIAL."

17 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

18 from a Producing Party.

19 3. SCOPE

20 The protections conferred by this Stipulation and Order cover not only

21 Protected Material (as defined above), but also (1) any information copied or

22 extracted from Protected Material; (2) all copies, excerpts, summaries, or

23 compilations of Protected Material; and (3) any testimony, conversations, or

24 presentations by Parties or their Counsel that might reveal Protected Material.

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

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

27 4. DURATION

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

1 CONFIDENTIAL or maintained pursuant to this protective order used or introduced

2 as an exhibit at trial becomes public and will be presumptively available to all

3 members of the public, including the press, unless compelling reasons supported by

4 specific factual findings to proceed otherwise are made to the trial judge in advance

5 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing "good cause"

6 showing for sealing documents produced in discovery from "compelling reasons"

7 standard when merits-related documents are part of court record). Accordingly, the

8 terms of this protective order do not extend beyond the commencement of the trial.

9 5. DESIGNATING PROTECTED MATERIAL

10 5.1 Exercise of Restraint and Care in Designating Material for Protection.

11 Each Party or Non-Party that designates information or items for protection under

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

13 qualifies under the appropriate standards. The Designating Party must designate for

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

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

16 or communications for which protection is not warranted are not swept unjustifiably

17 within the ambit of this Order.

18 Mass, indiscriminate or routinized designations are prohibited. Designations

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

20 purpose (e.g., to unnecessarily encumber the case development process or to impose

21 unnecessary expenses and burdens on other parties) may expose the Designating

22 Party to sanctions.

23 If it comes to a Designating Party's attention that information or items that it

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

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

26 5.2 Manner and Timing of Designations. Except as otherwise provided in this

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

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

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

2 Designation in conformity with this Order requires:

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

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

5 Producing Party affix at a minimum, the legend "CONFIDENTIAL" (hereinafter

6 "CONFIDENTIAL legend"), to each page that contains protected material. If only a

7 portion of the material on a page qualifies for protection, the Producing Party also

8 must clearly identify the protected portion(s) (e.g., by making appropriate markings

9 in the margins).

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

11 need not designate them for protection until after the inspecting Party has indicated

12 which documents it would like copied and produced. During the inspection and

13 before the designation, all of the material made available for inspection shall be

14 deemed "CONFIDENTIAL." After the inspecting Party has identified the documents

15 it wants copied and produced, the Producing Party must determine which documents,

16 or portions thereof, qualify for protection under this Order. Then, before producing

17 the specified documents, the Producing Party must affix the "CONFIDENTIAL

18 legend" to each page that contains Protected Material. If only a portion of the material

19 on a page qualifies for protection, the Producing Party also must clearly identify the

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

21 (b) for testimony given in depositions that the Designating Party identifies the

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

23 protected testimony.

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

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

26 exterior of the container or containers in which the information is stored the legend

27 "CONFIDENTIAL." If only a portion or portions of the information warrants

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

1 portion(s).

2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

3 failure to designate qualified information or items does not, standing alone, waive the

4 Designating Party's right to secure protection under this Order for such material.

5 Upon timely correction of a designation, the Receiving Party must make reasonable

6 efforts to assure that the material is treated in accordance with the provisions of this

7 Order.

8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

10 designation of confidentiality at any time that is consistent with the Court's

11 Scheduling Order.

12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

13 resolution process under Local Rule 37-1 et seq.

14 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

15 joint stipulation pursuant to Local Rule 37-2.

16 6.4 The burden of persuasion in any such challenge proceeding shall be on

17 the Designating Party. Frivolous challenges, and those made for an improper purpose

18 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may

19 expose the Challenging Party to sanctions. Unless the Designating Party has waived

20 or withdrawn the confidentiality designation, all parties shall continue to afford the

21 material in question the level of protection to which it is entitled under the Producing

22 Party's designation until the Court rules on the challenge.

23 7. ACCESS TO AND USE OF PROTECTED MATERIAL

24 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

27 Protected Material may be disclosed only to the categories of persons and under the

28 conditions described in this Order. When the Action has been terminated, a

1 Receiving Party must comply with the provisions of section 13 below (FINAL

2 DISPOSITION).

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

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

5 authorized under this Order.

6 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless

7 otherwise ordered by the court or permitted in writing by the Designating Party, a

8 Receiving Party may disclose any information or item designated

9 "CONFIDENTIAL" only to:

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

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

12 disclose the information for this Action;

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

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

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

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

17 "Acknowledgment and Agreement to Be Bound" (Exhibit A);

18 (d) the court and its personnel;

19 (e) court reporters and their staff;

20 (f) professional jury or trial consultants, mock jurors, and Professional

21 Vendors to whom disclosure is reasonably necessary for this Action and who have

22 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A);

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

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

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

26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

27 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will

28 not be permitted to keep any confidential information unless they sign the

1 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise

2 agreed by the Designating Party or ordered by the court. Pages of transcribed

3 deposition testimony or exhibits to depositions that reveal Protected Material may be

4 separately bound by the court reporter and may not be disclosed to anyone except as

5 permitted under this Stipulated Protective Order; and

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

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

8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

9 IN OTHER LITIGATION

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

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

12 "CONFIDENTIAL," that Party must:

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

14 include a copy of the subpoena or court order;

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

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

17 or order is subject to this Protective Order. Such notification shall include a copy of

18 this Stipulated Protective Order; and

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

20 the Designating Party whose Protected Material may be affected.

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

22 the subpoena or court order shall not produce any information designated in this

23 action as "CONFIDENTIAL" before a determination by the court from which the

24 subpoena or order issued, unless the Party has obtained the Designating Party's

25 permission. The Designating Party shall bear the burden and expense of seeking

26 protection in that court of its confidential material and nothing in these provisions

27 should be construed as authorizing or encouraging a Receiving Party in this Action

28 to disobey a lawful directive from another court.

1 9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE

2 PRODUCED IN THIS LITIGATION

3 (a) The terms of this Order are applicable to information produced by a

4 Non-Party in this Action and designated as "CONFIDENTIAL." Such information

5 produced by Non-Parties in connection with this litigation is protected by the

6 remedies and relief provided by this Order. Nothing in these provisions should be

7 construed as prohibiting a Non-Party from seeking additional protections.

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

9 produce a Non-Party's confidential information in its possession, and the Party is

10 subject to an agreement with the Non-Party not to produce the Non-Party's

11 confidential information, then the Party shall:

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

13 Party that some or all of the information requested is subject to a confidentiality

14 agreement with a Non-Party;

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

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

17 specific description of the information requested; and

18 (3) make the information requested available for inspection by the

19 Non-Party, if requested.

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

21 14 days of receiving the notice and accompanying information, the Receiving Party

22 may produce the Non-Party's confidential information responsive to the discovery

23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall

24 not produce any information in its possession or control that is subject to the

25 confidentiality agreement with the Non-Party before a determination by the court.

26 Absent a court order to the contrary, the Non-Party shall bear the burden and expense

27 of seeking protection in this court of its Protected Material.

28 / / /

1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

7 persons to whom unauthorized disclosures were made of all the terms of this Order,

8 and (d) request such person or persons to execute the "Acknowledgment and

9 Agreement to Be Bound" that is attached hereto as Exhibit A.

10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

11 PROTECTED MATERIAL

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

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

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

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

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

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

18 parties reach an agreement on the effect of disclosure of a communication or

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

20 parties may incorporate their agreement in the stipulated protective order submitted

21 to the court.

22 12. MISCELLANEOUS

23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

25 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

2 12.3 Filing Protected Material. A Party that seeks to file under seal any

3 Protected Material must comply with Local Civil Rule 79-5. Protected Material may

4 only be filed under seal pursuant to a court order authorizing the sealing of the

5 specific Protected Material at issue. If a Party's request to file Protected Material

6 under seal is denied by the court, then the Receiving Party may file the information

7 in the public record unless otherwise instructed by the court. Filing Protected

8 Material. A Party that seeks to file under seal any Protected Material must comply

9 with Local Civil Rule 79-5. Protected Material may only be filed under seal pursuant

10 to a court order authorizing the sealing of the specific Protected Material at issue. If

11 a Party's request to file Protected Material under seal is denied by the court, then the

12 Receiving Party may file the information in the public record unless otherwise

13 instructed by the court.

14 13. FINAL DISPOSITION

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

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

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

18 this subdivision, "all Protected Material" includes all copies, abstracts, compilations,

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

20 Material. Whether the Protected Material is returned or destroyed, the Receiving

21 Party must submit a written certification to the Producing Party (and, if not the same

22 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

23 (by category, where appropriate) all the Protected Material that was returned or

24 destroyed and (2) affirms that the Receiving Party has not retained any copies,

25 abstracts, compilations, summaries or any other format reproducing or capturing any

26 of the Protected Material. Notwithstanding this provision, Counsel are entitled to

27 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

28 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

1 reports, attorney work product, and consultant and expert work product, even if such

2 materials contain Protected Material. Any such archival copies that contain or

3 constitute Protected Material remain subject to this Protective Order as set forth in

4 Section 4 (DURATION).

5 14. VIOLATION

6 Any violation of this Order may be punished by appropriate measures

7 including, without limitation, contempt proceedings and/or monetary sanctions.

8

9 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

10 DATED: September 14, 2020 ROMANO STANCROFF PC

11

By: /s/ Mark Romano

12

Mark Romano

13 Timothy Whelan

Aliaksandra Valitskaya

14 Attorneys for Plaintiff

KIMBERLY SCOTT

15

DATED: September 14, 2020 BOWMAN AND BROOKE LLP

16

17 By: /s/ Freddy I. Fonseca

Brian Takahashi

18 Richard Stuhlbarg

Freddy I. Fonseca

19 Attorneys for Defendant

JAGUAR LAND ROVER NORTH

20 AMERICA, LLC

21

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

22

23 DATED: September 18, 2020 By: ______________________________

24 Hon. Sheri Pym

United States Magistrate Judge

25

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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

5 I have read in its entirety and understand the Stipulated Protective Order that was

6 issued by the United States District Court for the Central District of California on

7 [date] in the case of Kimberly Scott v. Jaguar Land Rover North America, LLC, et.

8 al., United States District Court — Central District, Case No. 5:19-cv-1873 JGB

9 (SPx). I agree to comply with and to be bound by all the terms of this Stipulated

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

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

12 promise that I will not disclose in any manner any information or item that is subject

13 to this Stipulated Protective Order to any person or entity except in strict compliance

14 with the 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 enforcing the terms of this Stipulated

17 Protective Order, even if such enforcement proceedings occur after termination of

18 this action. I hereby appoint __________________________ [print or type full

19 name] of _______________________________________ [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 Stipulated

22 Protective Order.

23

24 Date: ______________________________________

25 City and State where sworn and signed: _________________________________

26 Printed name: _______________________________

27 Signature:_______________________________

28

1 CERTIFICATE OF SERVICE

2 I hereby certify that on September 14, 2020, I filed the foregoing document

3 entitled STIPULATED PROTECTIVE ORDER; [PROPOSED] ORDER with

4 the clerk of court using the CM/ECF system, which will send a notice of electronic

5 filing to all counsel of record in this action.

6

7

/s/ Freddy I. Fonseca

8 Freddy I. Fonseca

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