distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record
Written by the judges who cited it.
The opinion
1 Eejraickk Lso. nJa@ckcsoozne,n E.csoqm. (SBN 166010)
2 COZEN O'CONNOR
601 S. Figueroa Street, Suite 3700
3 Los Angeles, CA 90017
Telephone: 213.892.7900
4 Facsimile: 213.892.7999
5 Attorneys for Defendants
NOVA LIFESTYLE, INC., THANH H. LAM and
6 JEFFERY CHUANG
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
GEORGE BARNEY, Individually and on ) Case No. 2:18-cv-10725-TJH (AFMx)
11 behalf of all others similarly situated, )
) STIPULATED [PROPOSED]
12 Plaintiff, ) PROTECTIVE ORDER
) GOVERNING CONFIDENTIAL
13 vs. ) INFORMATION
NOVA LIFESTYLE, INC., THANH H. )
14 LAM, an individual, YA MING WONG, )
an individual, JEFFERY CHUANG, an )
15 individual, and YUEN CHING HO, an )
individual, )
16 )
Defendants. )
17 )
18
19
20 STIPULATED PROTECTIVE ORDER
21
22 1. PURPOSES AND LIMITATIONS
23 Discovery in this action is likely to involve production of confidential,
24 proprietary,or private information for which special protection from public disclosure
25 and from use for any purpose other than pursuing this litigation may be warranted.
26 Accordingly, the Parties hereby stipulate to and petition the Court to enter the
27 following Stipulated Protective Order. The Parties acknowledge that this Order does
28 not confer blanket protections on all disclosures or responses to discovery and that
1 the protection it affords from public disclosure and use extends only to the limited
2 information or items that are entitled to confidential treatment under the applicable
3 legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
4 that this Stipulated Protective Order does not entitle them to file confidential
5 information under seal; Civil Local Rule 79-5 sets forth the procedures that must
6 be followed and the standards that will be applied when a partyseeks permission from
7 the court to file material under seal.
8
9 2. GOOD CAUSE STATEMENT
10 This action is likely to involve trade secrets and other valuable research,
11 development, commercial, financial, technical, and/or proprietary information for
12 which special protection from public disclosure and from use for any purpose other
13 than litigation of this action is warranted. Such confidential and proprietary materials
14 and information consist of, among other things, confidential business or financial
15 information, information regarding confidential business practices, policies and/or
16 procedures, or other confidential research, development, or commercial information
17 (including information implicating privacy rights of third parties), information
18 otherwise generally unavailable to the public, or which may be privileged or otherwise
19 protected from disclosure under state or federal statutes, court rules, case decisions,
20 or common law. Public disclosure of such information, documents, and materials
21 would result in prejudice or harm to the Parties by providing their respective
22 competitors with an unfair business advantage. Accordingly, to expedite the flow of
23 information, to facilitate the prompt resolution of disputes over confidentiality of
24 discovery 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
6 3. ACKNOWLEDGMENT OF UNDER SEAL FILING
7 PROCEDURE
8 The Parties further acknowledge, as set forth in Section 14.3, below, that this
9 Stipulated Protective Order does not entitle them to file confidential information
10 under seal. Local Civil Rule 79-5 sets forth the procedures that must be followed and
11 the standards that will be applied when a Party seeks permission from the Court to
12 file material under seal. There is a strong presumption that the public has a right of
13 access to judicial proceedings and records in civil cases. In connection with non-
14 dispositive motions, good cause must be shown to support a filing under seal. See
15 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006);
16 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002) (even
17 stipulated protective orders require good cause showing and a specific showing of
18 good cause or compelling reasons with proper evidentiary support and legal
19 justification, must be made with respect to Protected Material that a Party seeks to file
20 under seal). The Parties’ mere designation of Disclosure or Discovery Material as
21 CONFIDENTIAL does not – without the submission of competent evidence by
22 declaration establishing that the material sought to be filed under seal qualifies as
23 confidential, privileged, or 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 goodcause, for the sealing must be shown, and the relief
26 sought shall be narrowly tailored to serve the specific interest to be protected. See
27 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
28 or type of information, document, or thing sought to be filed or introduced under seal,
1 the Party seeking protection must articulate compelling reasons, supported by specific
2 facts and legal justification, for the requested sealing order. Again, competent
3 evidence supporting the application to file documents under seal must be provided by
4 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
12 4. DEFINITIONS
13 4.1 Action: Barney v. Nova Lifestyle, Inc., Case No. 2:18-cv-10725-TJH
14 (AFMx), U.S. District Court for the Central District of California.
15 4.2 Challenging Party: a Party or Non-Party that challenges the designation
16 of information or items under this Order.
17 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
18 how it is generated, stored or maintained) or tangible things that qualify for protection
19 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
20 Cause Statement.
21 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
22 support staff).
23 4.5 Designating Party: a Party or Non-Party that designates information or
24 items that it produces in disclosures or in responses to discovery as
25 “CONFIDENTIAL.”
26 4.6 Disclosure or Discovery Material: all items or information, regardless of
27 the medium or manner in which it is generated, stored, or maintained (including,
28
1 among other things, testimony, transcripts, and tangible things), that are produced or
2 generated in disclosures or responses to discovery.
3 4.7 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
5 an expert witness or as a consultant in this Action.
6 4.8 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 4.9 Non-Party: any natural person, partnership, corporation, association, or
10 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 Party
12 but are retained to represent a Party and have appeared in this Action on behalf of that
13 Party or are affiliated with a law firm that has appeared on behalf of that Party, and
14 includes support staff.
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 their
17 support staff).
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 support
21 services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium)
23 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 Material
27 from a Producing Party.
28
1 5. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 Protected Material, but also (1) any information copied or extracted from Protected
4 Material, (2) all copies, excerpts, summaries, or compilations of Protected Material,
5 and (3) any testimony, conversations, or presentations by Parties or their Counsel that
6 might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the
8 trial judge and other applicable authorities. This Order does not govern the use of
9 Protected Material at trial.
10
11 6. 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
14 as an exhibit at trial becomes public and will be presumptively available to all
15 members of the public, including the press, unless compelling reasons supported by
16 specific factual findings to proceed otherwise are made to the trial judge in advance
17 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
18 showing for sealing documents produced in discovery from “compelling reasons”
19 standard when merits-related documents are part of court record). Any such
20 information that becomes public will no longer be subject to the terms of this
21 Protective Order.
22 7. DESIGNATING PROTECTED MATERIAL
23 7.1 Exercise of Restraint and Care in Designating Material for Protection.
24 Each Party or Non-Party that designates information or items for protection under this
25 Order must take care to limit any such designation to specific material that qualifies
26 under the appropriate standards. The Designating Party must designate for protection
27 only those parts of material, documents, items, or oral or written communications that
28 qualify so that other portions of the material, documents, items, or communications
1 for which protection is not warranted are not swept unjustifiably within the ambit of
2 this Order.
3 Mass, indiscriminate, or routinized designations are prohibited. Designations
4 that are shown to be clearly unjustified or that have been made for an improper
5 purpose (e.g., to unnecessarily encumber the case development process or to impose
6 unnecessary expenses and burdens on other Parties) may expose the Designating Party
7 to sanctions.
8 If it comes to a Designating Party’s attention that information or items that it
9 designated for protection do not qualify for protection, that Designating Party must
10 promptly notify all other Parties that it is withdrawing the inapplicable designation.
11 7.2 Manner and Timing of Designations. Except as otherwise provided in
12 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
13 that qualifies for protection under this Order must be clearly so designated before the
14 material is disclosed or produced.
15 Designation in conformity with this Order requires:
16 (a) For information in documentary form (e.g., paper or electronic
17 documents, but excluding transcripts of depositions or other pretrial or
18 trial proceedings), that the Producing Party affix at a minimum, the
19 legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to
20 each page that contains protected material. If only a portion of the
21 material on a page qualifies for protection, the Producing Party also must
22 clearly identify the protected portion(s) (e.g., by making appropriate
23 markings in the margins). A Party or Non-Party that makes original
24 documents available for inspection need not designate them for
25 protection until after the inspecting Party has indicated which documents
26 it would like copied and produced. During the inspection and before the
27 designation, all of the material made available for inspection shall be
28 deemed “CONFIDENTIAL.” After the inspecting Party has identified
1 the documents it wants copied and produced, the Producing Party must
2 determine which documents, or portions thereof, qualify for protection
3 under this Order. Then, before producing the specified documents, the
4 Producing Party must affix the “CONFIDENTIAL” legend to each page
5 that contains Protected Material. If only a portion of the material on a
6 page qualifies for protection, the Producing Party also must clearly
7 identify the protected portion(s) (e.g., by making appropriate markings
8 in the margins).
9 (b) For testimony given in depositions that the Designating Party identifies
10 the Disclosure or Discovery Material on the record, before the close of
11 the deposition all protected testimony.
12 (c) For information produced in some form other than documentary and for
13 any other tangible items, that the Producing Party affix in a prominent
14 place on the exterior of the container or containers in which the
15 information is stored the “CONFIDENTIAL” legend. If only a portion
16 or portions of the information warrants protection, the Producing Party,
17 to the extent practicable, shall identify the protected portion(s).
18 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
19 failure to designate qualified information or items does not, standing alone, waive the
20 Designating Party’s right to secure protection under this Order for such material.
21 Upon timely correction of a designation, the Receiving Party must make reasonable
22 efforts to assure that the material is treated in accordance with the provisions of this
23 Order.
24
25
26
27
28
1 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
3 designation of confidentiality at any time that is consistent with the Court’s
4 Scheduling Order.
5 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
6 resolution process under Local Rule 37-1, et seq.
7 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
8 joint stipulation pursuant to Local Rule 37-2.
9 8.4 The burden of persuasion in any such challenge proceeding shall be on
10 the Designating Party. Frivolous challenges, and those made for an improper purpose
11 (e.g., to harass or impose unnecessary expenses and burdens on other Parties) may
12 expose the Challenging Party to sanctions. Unless the Designating Party has waived
13 or withdrawn the confidentiality designation, all Parties shall continue to afford the
14 material in question the level of protection to which it is entitled under the Producing
15 Party’s designation until the Court rules on the challenge.
16
17 9. ACCESS TO AND USE OF PROTECTED MATERIAL
18 9.1 Basic Principles. A Receiving Party may use Protected Material that is
19 disclosed or produced by another Party or by a Non-Party in connection with this
20 Action only for prosecuting, defending or attempting to settle this Action. Such
21 Protected Material may be disclosed only to the categories of persons and under the
22 conditions described in this Order. When the Action has been terminated, a Receiving
23 Party must comply with the provisions of section 15 below (FINAL DISPOSITION).
24 Protected Material must be stored and maintained by a Receiving Party at a location
25 and in a secure manner that ensures that access is limited to the persons authorized
26 under this Order.
27 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
28 otherwise ordered by the Court or permitted in writing by the Designating Party, a
1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only to:
3 (a) The Receiving Party’s Outside Counsel of Record in this Action, as well
4 as employees of said Outside Counsel of Record to whom it is reasonably
5 necessary to disclose the information for this Action;
6 (b) The officers, directors, and employees (including House Counsel) of the
7 Receiving Party to whom disclosure is reasonably necessary for this
8 Action;
9 (c) Experts (as defined in this Order) of the Receiving Party to whom
10 disclosure is reasonably necessary for this Action and who have signed
11 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (d) The Court and its personnel;
13 (e) Court reporters and their staff;
14 (f) Professional jury or trial consultants, mock jurors, and Professional
15 Vendors to whom disclosure is reasonably necessary for this Action and
16 who have signed the “Acknowledgment and Agreement to Be Bound”
17 (Exhibit A);
18 (g) The author or recipient of a document containing the information or a
19 custodian or other person who otherwise possessed or knew the
20 information;
21 (h) During their depositions, witnesses, and attorneys for witnesses, in the
22 Action to whom disclosure is reasonably necessary provided: (1) the
23 deposing Party requests that the witness sign the form attached as Exhibit
24 A hereto; and (2) they will not be permitted to keep any confidential
25 information unless they sign the “Acknowledgment and Agreement to
26 Be Bound” (Exhibit A), unless otherwise agreed by the Designating
27 Party or ordered by the Court. Pages of transcribed deposition testimony
28 or exhibits to depositions that reveal Protected Material may be
1 separately bound by the court reporter and may not be disclosed to
2 anyone except as permitted under this Stipulated Protective Order;
3 (i) Any mediators or settlement officers and their supporting personnel,
4 mutually agreed upon by any of the Parties engaged in settlement
5 discussions; and
6 (j) auditors, regulators, and other such entities as is reasonably necessary in
7 the ordinary course of business and who have signed the
8 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
9
10 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
11 PRODUCED IN OTHER LITIGATION
12 If a Party is served with a subpoena or a court order issued in other litigation
13 that compels disclosure of any information or items designated in this Action as
14 “CONFIDENTIAL,” that Party must:
15 (a) Promptly notify in writing the Designating Party, and such notification
16 shall include a copy of the subpoena or court order;
17 (b) Promptly notify in writing the party who caused the subpoena or order
18 to issue in the other litigation that some or all of the material covered by
19 the subpoena or order is subject to this Protective Order, and such
20 notification shall include a copy of this Stipulated Protective Order; and
21 (c) Cooperate with respect to all reasonable procedures sought to be pursued
22 by the Designating Party whose Protected Material may be affected. If
23 the Designating Party timely seeks a protective order, the Party served
24 with the subpoena or court order shall not produce any information
25 designated in this action as “CONFIDENTIAL” before a determination
26 by the court from which the subpoena or order issued, unless the Party
27 has obtained the Designating Party’s permission. The Designating Party
28 shall bear the burden and expense of seeking protection in that court of
1 its confidential material and nothing in these provisions should be
2 construed as authorizing or encouraging a Receiving Party in this Action
3 to disobey a lawful directive from another court.
4
5 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
6 BE PRODUCED IN THIS LITIGATION
7 The terms of this Order are applicable to information produced by a Non-Party
8 in this Action and designated as “CONFIDENTIAL.” Such information produced by
9 Non-Parties in connection with this litigation is protected by the remedies and relief
10 provided by this Order. Nothing in these provisions should be construed as prohibiting
11 a Non-Party from seeking additional protections.
12 In the event that a Party is required, by a valid discovery request, to produce a
13 Non-Party’s confidential information in its possession, and the Party is subject to an
14 agreement with the Non-Party not to produce the Non-Party’s confidential
15 information, then the Party shall:
16 (a) promptly notify in writing the Requesting Party and the Non-Party that
17 some or all of the information requested is subject to a confidentiality
18 agreement with a Non-Party;
19 (b) Promptly provide the Non-Party with a copy of the Stipulated Protective
20 Order in this Action, the relevant discovery request(s), and a reasonably
21 specific description of the information requested; and
22 (c) make the information requested available for inspection by the Non-
23 Party, if requested.
24 If the Non-Party fails to seek a protective order from this Court within 14 days
25 of receiving the notice and accompanying information, the Receiving Party may
26 produce the Non-Party’s confidential information responsive to the discovery request.
27 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
28 any information in its possession or control that is subject to the confidentiality
1 agreement with the Non-Party before a determination by the Court. Absent a court
2 order to the contrary, the Non-Party shall bear the burden and expense of seeking
3 protection in this court of its Protected Material.
4
5 12. UNAUTHORIZED DISCLOSURE OF PROTECTED
6 MATERIAL
7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
8 Protected Material to any person or in any circumstance not authorized under this
9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
10 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
11 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
12 persons to whom unauthorized disclosures were made of all the terms of this Order,
13 and (d) request such person or persons to execute the “Acknowledgment an
14 Agreement to Be Bound” attached hereto as Exhibit A.
15
16 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
17 OTHERWISE PROTECTED MATERIAL
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), insofar as the
24 Parties reach an agreement on the effect of disclosure of a communication or
25 information covered by the attorney-client privilege or work product protection, the
26 Parties may incorporate their agreement in the stipulated protective order submitted
27 to the Court.
28
1 14. MISCELLANEOUS
2 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
3 person to seek its modification by the Court in the future.
4 14.2 Right to Assert Other Objections. By stipulating to the entry of this
5 Protective Order, no Party waives any right it otherwise would have to object to
6 disclosing or producing any information or item on any ground not addressed in this
7 Stipulated Protective Order. Similarly, no Party waives any right to object on any
8 ground to use in evidence of any of the material covered by this Protective Order.
9 14.3 Filing Protected Material. A Party that seeks to file under seal any
10 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
11 only be filed under seal pursuant to a court order authorizing the sealing of the specific
12 Protected Material. If a Party’s request to file Protected Material under seal is denied
13 by the Court, then the Receiving Party may file the information in the public record
14 unless otherwise instructed by the Court.
15
16 15. FINAL DISPOSITION
17 After the final disposition of this Action and exhaustion of any related appeals,
18 within 60 days of a written request by the Designating Party, each Receiving Party
19 must return all Protected Material to the Producing Party or destroy such material. As
20 used in this subdivision, “all Protected Material” includes all copies, abstracts,
21 compilations, summaries, and any other format reproducing or capturing any of the
22 Protected Material. Whether the Protected Material is returned or destroyed, the
23 Receiving Party must submit a written certification to the Producing Party (and, if not
24 the same person or entity, to the Designating Party) by the 60-day deadline that (1)
25 identifies (by category, where appropriate) all the Protected Material that was returned
26 or destroyed, and (2) affirms that the Receiving Party has not retained any copies,
27 abstracts, compilations, summaries, or any other format reproducing or capturing any
28 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
1 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
2 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
3 reports, attorney work product, and consultant and expert work product, even if such
4 materials contain Protected Material. Any such archival copies that contain or
5 constitute Protected Material remain subject to this Protective Order.
6
7 16. VIOLATION
8 Any violation of this Order may be punished by appropriate measures
9 including, without limitation, contempt proceedings and/or monetary sanctions.
10
11
12
13
14 IT IS SO STIPULATED.
15
16
17
18
19 Dated: December 28, 2020 COZEN O’CONNOR
20
21 By:__/s/ Erik L. Jackson______________
Erik L. Jackson
22
Attorney for Defendants NOVA
23 LIFESTYLE, INC; THANH H. LAM
and JEFFREY CHUANG
24
25
26
27
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1|| Dated: December 28, 2020 ROSEN LAW FIRM PA
3 By:__/s/ Stephen M. Shepardson
4 Laurence M. Rosen
Phillip Kim
5 Stephen M. Shepardson
6 Attorney for Plaintiffs GEORGE
BARNEY; RICHARD DEUTNER;
7 ITENT BY EDV
?|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
10
11|| DATED: 1/14/2021 □
1 (dy Wi
13
14 Alexander F. MacKinnon
United States Magistrate Judge
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BEBOUND
11
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I, ___________________, of ____________________________, declare
13
under penalty of perjury that I have read in its entirety and understand the
14
Stipulated Protective Order that was issued by the United States District Court for
15
the Central District of California on ________ in the case of Barney v. Nova
16
Lifestyle, Inc., Case No. 2:18-cv-10725-TJH (AFMx). I agree to comply with and to
17
be bound by all the terms of this Stipulated Protective Order and I understand
18
and acknowledge that failure to so comply could expose me to sanctions and
19
punishment in the nature of contempt. I solemnly promise that I will not disclose in
20
any manner any information or item that is subject to this Stipulated Protective
21
Order to any person or entity except in strict compliance with the provisions of this
22
Order.
23
I further agree to submit to the jurisdiction of the United States District Court
24
for the Central District of California for the purpose of enforcing the terms of
25
this Stipulated Protective Order, even if such enforcement proceedings occur
26
after termination of this action. I hereby appoint ____________________ of
27
_________ as my California agent for service of process in connection with this
28
1 action or any proceedings related to enforcement of this Stipulated Protective
2 Order.
3
4 Date:
5
6 City and State where sworn and signed:
7 Printed name: ___________
8 Signature: __________________
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