Maria Cabrera Giron v. Metro Services Group

1 RDOenGnEisR CS. JHOuSieE (PSHta Ote’ BDaOr NNNo.E 1L8L4 377)

2 dhuie@rjo.com

Sharon O. Rossi (State Bar No. 232725)

3 srossi@rjo.com

Emily A. Wieser (State Bar No. 311315)

4 ewieser@rjo.com

311 California Street

5 San Francisco, California 94104

Telephone: 415.956.2828

6 Facsimile: 415.956.6457

7 Attorneys for Defendant

METRO SERVICES GROUP

8

9

10 UNITED STATES DISTRICT COURT

11 CENTRAL DISTRICT OF CALIFORNIA

12 MARIA CABRERA GIRON, an Case No. 2:21-cv-01424 FMO (AFMx)

individual, on her own behalf and on

13 behalf of all others similarly situated, [Removed from Los Angeles County Superior

Court, Case No. 20STCV16779]

14 Plaintiff,

CLASS ACTION

15 vs.

STIPULATED PROTECTIVE

16 METRO SERVICES GROUP, a ORDER1

California corporation; and DOES 1

17 through 100, inclusive,

18 Defendants. Date of first filing: April 29, 2020

19

20

21 1. A. PURPOSES AND LIMITATIONS

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

23 proprietary or private information for which special protection from public

24 disclosure and from use for any purpose other than prosecuting this litigation may

25 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

26 enter the following Stipulated Protective Order. The parties acknowledge that this

27

28 1 This Stipulated Protective Order is based substantially on the model protective

1 Order does not confer blanket protections on all disclosures or responses to

2 discovery and that the protection it affords from public disclosure and use extends

3 only to the limited information or items that are entitled to confidential treatment

4 under the applicable legal principles.

5 B. GOOD CAUSE STATEMENT

6 This action is likely to involve the sensitive, private, and confidential

7 information of third parties, trade secrets, customer and pricing lists and other

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

9 information for which special protection from public disclosure and from use for

10 any purpose other than prosecution of this action is warranted. Such confidential

11 and proprietary materials and information consist of, among other things, sensitive,

12 private, and confidential information of third parties, including employees of

13 Defendant, confidential business or financial information, information regarding

14 confidential business practices, or other confidential research, development, or

15 commercial information (including information implicating privacy rights of third

16 parties), information otherwise generally unavailable to the public, or which may be

17 privileged or otherwise protected from disclosure under state or federal statutes,

18 court rules, case decisions, or common law. Accordingly, to expedite the flow of

19 information, to facilitate the prompt resolution of disputes over confidentiality of

20 discovery materials, to adequately protect information the parties are entitled to

21 keep confidential, to ensure that the parties are permitted reasonable necessary uses

22 of such material in preparation for and in the conduct of trial, to address their

23 handling at the end of the litigation, and serve the ends of justice, a protective order

24 for such information is justified in this matter. It is the intent of the parties that

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

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

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

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

1 public record of this case.

2 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

3 SEAL

4 The parties further acknowledge, as set forth in Section 12.3, below,

5 that this Stipulated Protective Order does not entitle them to file confidential

6 information under seal; Local Civil Rule 79-5 sets forth the procedures that must be

7 followed and the standards that will be applied when a party seeks permission from

8 the court to file material under seal.

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

10 judicial proceedings and records in civil cases. In connection with non-dispositive

11 motions, good cause must be shown to support a filing under seal. See Kamakana

12 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v.

13 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v.

14 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

15 protective orders require good cause showing), and a specific showing of good

16 cause or compelling reasons with proper evidentiary support and legal justification,

17 must be made with respect to Protected Material that a party seeks to file under

18 seal. The parties’ mere designation of Disclosure or Discovery 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.

22 Further, if a party requests sealing related to a dispositive motion or

23 trial, then compelling reasons, not only good cause, for the sealing must be shown,

24 and the relief sought shall be narrowly tailored to serve the specific interest to be

25 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.

26 2010). For each item or type of information, document, or thing sought to be filed

27 or introduced under seal in connection with a dispositive motion or trial, the party

28 seeking protection must articulate compelling reasons, supported by specific facts

1 and legal justification, for the requested sealing order. Again, competent evidence

2 supporting the application to file documents under seal must be provided by

3 declaration.

4 Any document that is not confidential, privileged, or otherwise

5 protectable in its entirety will not be filed under seal if the confidential portions can

6 be redacted. If documents can be redacted, then a redacted version for public

7 viewing, omitting only the confidential, privileged, or otherwise protectable

8 portions of the document, shall be filed. Any application that seeks to file

9 documents under seal in their entirety should include an explanation of why

10 redaction is not feasible.

11 2. DEFINITIONS

12 2.1 Action: Maria Cabrera Giron v. Metro Services Group, Central

13 District of California, Case No. 2:21-cv-01424 FMO (AFMx) [Removed from Los

14 Angeles County Superior Court, Case No. 20STCV16779].

15 2.2 Challenging Party: a Party or Non-Party that challenges the

16 designation of information or items under this Order.

17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

19 protection under Federal Rule of Civil Procedure 26(c), and as specified above in

20 the Good Cause Statement.

21 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

22 their support staff).

23 2.5 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 2.6 Disclosure or Discovery Material: all items or information, regardless

27 of the medium or manner in which it is generated, stored, or maintained

28 (including, among other things, testimony, transcripts, and tangible things), that

1 are produced or generated in disclosures or responses to discovery in this matter.

2 2.7 Expert: a person with specialized knowledge or experience in a matter

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

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

5 2.8 House Counsel: attorneys who are employees of a party to this

6 Action. House Counsel does not include Outside Counsel of Record or any other

7 outside counsel.

8 2.9 Non-Party: any natural person, partnership, corporation, association or

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

10 2.10 Outside Counsel of Record: attorneys who are not employees of a

11 party to this Action but are retained to represent or advise a party to this Action

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

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

14 2.11 Party: any party to this Action, including all of its officers, directors,

15 employees, consultants, retained experts, and Outside Counsel of Record (and

16 their support staffs).

17 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

18 Discovery Material in this Action.

19 2.13 Professional Vendors: persons or entities that provide litigation

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

21 or demonstrations, and organizing, storing, or retrieving data in any form or

22 medium) and their employees and subcontractors.

23 2.14 Protected Material: any Disclosure or Discovery Material that is

24 designated as “CONFIDENTIAL.”

25 2.15 Receiving Party: a Party that receives Disclosure or Discovery

26 Material from a Producing Party.

27 3. SCOPE

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

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

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

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

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

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

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

7 4. DURATION

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

9 CONFIDENTIAL or maintained pursuant to this protective order used or

10 introduced as an exhibit at trial becomes public and will be presumptively available

11 to all members of the public, including the press, unless compelling reasons

12 supported by specific factual findings to proceed otherwise are made to the trial

13 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81

14 (distinguishing “good cause” showing for sealing documents produced in

15 discovery from “compelling reasons” standard when merits-related documents are

16 part of court record). Accordingly, the terms of this protective order do not extend

17 beyond the commencement of the trial.

18 5. DESIGNATING PROTECTED MATERIAL

19 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

22 qualifies under the appropriate standards. The Designating Party must designate

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

24 communications that qualify so that other portions of the material, documents,

25 items or communications for which protection is not warranted are not swept

26 unjustifiably within the ambit of this Order.

27 Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

2 impose unnecessary expenses and burdens on other parties) may expose the

3 Designating Party to sanctions.

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

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

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

7 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

9 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

10 under this Order must be clearly so designated before the material is disclosed or

11 produced.

12 Designation in conformity with this Order requires:

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

14 documents, but excluding transcripts of depositions or other pretrial or trial;

15 proceedings), that the Producing Party affix at minimum, the legend

16 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

17 contains protected material. If only a portion of the material on a page qualifies for

18 protection, the Producing Party also must clearly identify the protected portion(s)

19 (e.g., by making appropriate markings in the margins).

20 A Party or Non-Party that makes original documents available for

21 inspection need not designate them for protection until after the inspecting Party

22 has indicated which documents it would like copied and produced. During the

23 inspection and before the designation, all of the material made available for

24 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has

25 identified the documents it wants copied and produced, the Producing Party must

26 determine which documents, or portions thereof, qualify for protection under this

27 Order. Then, before producing the specified documents, the Producing Party must

28 affix the “CONFIDENTIAL legend” to each page that contains Protected Material.

1 If only a portion of the material on a page qualifies for protection, the Producing

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

3 appropriate markings in the margins).

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

5 identifies the Disclosure or Discovery Material on the record, before the close of

6 the deposition all protected testimony.

7 (c) for information produced in some form other than documentary

8 and for any other tangible items, that the Producing Party affix in a prominent place

9 on the exterior of the container or containers in which the information is stored the

10 legend “CONFIDENTIAL.” If only a portion or portions of the information

11 warrants protection, the Producing Party, to the extent practicable, shall identify the

12 protected portion(s).

13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

15 the Designating Party’s right to secure protection under this Order for such

16 material. Upon timely correction of a designation, the Receiving Party must make

17 reasonable efforts to assure that the material is treated in accordance with the

18 provisions of this Order.

19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

21 designation of confidentiality at any time that is consistent with the Court’s

22 Scheduling Order.

23 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

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

25 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

26 joint stipulation pursuant to Local Rule 37-2.

27 6.4 The burden of persuasion in any such challenge proceeding shall be on

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

1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

2 parties) may expose the Challenging Party to sanctions. Unless the Designating

3 Party has waived or withdrawn the confidentiality designation, all parties shall

4 continue to afford the material in question the level of protection to which it is

5 entitled under the Producing Party’s designation until the Court rules on the

6 challenge.

7 7. ACCESS TO AND USE OF PROTECTED MATERIAL

8 7.1 Basic Principles. A Receiving Party may use Protected Material that

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

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

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

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

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

14 DISPOSITION).

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

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

17 authorized under this Order.

18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

20 Receiving Party may disclose any information or item designated

21 “CONFIDENTIAL” only to:

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

23 as well as employees of said Outside Counsel of Record to whom it is reasonably

24 necessary to disclose the information for this Action;

25 (b) the officers, directors, and employees (including House

26 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for

27 this Action;

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

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

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

3 (d) the court and its personnel;

4 (e) court reporters and their staff;

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

6 Professional Vendors to whom disclosure is reasonably necessary for this Action

7 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

8 A);

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

10 or a custodian or other person who otherwise possessed or knew the information;

11 (h) during their depositions, witnesses, and attorneys for witnesses,

12 in the Action to whom disclosure is reasonably necessary provided: (1) the

13 deposing party requests that the witness sign the form attached as Exhibit 1 hereto;

14 and (2) they will not be permitted to keep any confidential information unless they

15 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless

16 otherwise agreed by the Designating Party or ordered by the court. Pages of

17 transcribed deposition testimony or exhibits to depositions that reveal Protected

18 Material may be separately bound by the court reporter and may not be disclosed to

19 anyone except as permitted under this Stipulated Protective Order; and

20 (i) any mediator or settlement officer, and their supporting

21 personnel, mutually agreed upon by any of the parties engaged in settlement

22 discussions.

23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

24 IN OTHER LITIGATION

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

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

27 “CONFIDENTIAL,” that Party must:

28 (a) promptly notify in writing the Designating Party. Such

1 notification shall include a copy of the subpoena or court order;

2 (b) promptly notify in writing the party who caused the subpoena or

3 order to issue in the other litigation that some or all of the material covered by the

4 subpoena or order is subject to this Protective Order. Such notification shall

5 include a copy of this Stipulated Protective Order; and

6 (c) cooperate with respect to all reasonable procedures sought to be

7 pursued by the Designating Party whose Protected Material may be affected.

8 If the Designating Party timely seeks a protective order, the Party

9 served with the subpoena or court order shall not produce any information

10 designated in this action as “CONFIDENTIAL” before a determination by the court

11 from which the subpoena or order issued, unless the Party has obtained the

12 Designating Party’s permission. The Designating Party shall bear the burden and

13 expense of seeking protection in that court of its confidential material and nothing

14 in these provisions should be construed as authorizing or encouraging a Receiving

15 Party in this Action to disobey a lawful directive from another court.

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

17 PRODUCED IN THIS LITIGATION.

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

19 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such

20 information produced by Non-Parties in connection with this litigation is protected

21 by the remedies and relief provided by this Order. Nothing in these provisions

22 should be construed as prohibiting a Non-Party from seeking additional protections.

23 (b) In the event that a Party is required, by a valid discovery

24 request, to produce a Non-Party’s confidential information in its possession, and the

25 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s

26 confidential information, then the Party shall:

27 (1) promptly notify in writing the Requesting Party and the

28 Non-Party that some or all of the information requested is subject to a

1 confidentiality agreement with a Non-Party;

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

3 Stipulated Protective Order in this Action, the relevant discovery request(s), and a

4 reasonably specific description of the information requested; and

5 (3) make the information requested available for inspection

6 by the Non-Party, if requested.

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

8 within 14 days of receiving the notice and accompanying information, the

9 Receiving Party may produce the Non-Party’s confidential information responsive

10 to the discovery request. If the Non-Party timely seeks a protective order, the

11 Receiving Party shall not produce any information in its possession or control that

12 is subject to the confidentiality agreement with the Non-Party before a

13 determination by the court. Absent a court order to the contrary, the Non-Party

14 shall bear the burden and expense of seeking protection in this court of its Protected

15 Material.

16 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

18 disclosed Protected Material to any person or in any circumstance not authorized

19 under this Stipulated Protective Order, the Receiving Party must immediately (a)

20 notify in writing the Designating Party of the unauthorized disclosures, (b) use its

21 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform

22 the person or persons to whom unauthorized disclosures were made of all the terms

23 of this Order, and (d) request such person or persons to execute the

24 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

25 A.

26 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

27 PROTECTED MATERIAL

28 When a Producing Party gives notice to receiving Parties that certain

1 inadvertently produced material is subject to a claim of privilege or other

2 protection, the obligations of the Receiving Parties are those set forth in Federal

3 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

4 whatever procedure may be established in an e-discovery order that provides for

5 production without prior privilege review. Pursuant to Federal Rule of Evidence

6 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

7 of a communication or information covered by the attorney-client privilege or

8 work product protection, the parties may incorporate their agreement in the

9 stipulated protective order submitted to the court.

10 12. MISCELLANEOUS

11 12.1 Right to Further Relief. Nothing in this Order abridges the right of

12 any person to seek its modification by the Court in the future.

13 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

15 disclosing or producing any information or item on any ground not addressed in

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

17 any ground to use in evidence of any of the material covered by this Protective

18 Order.

19 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

22 specific Protected Material at issue. If a Party’s request to file Protected Material

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

24 in the public record unless otherwise instructed by the court.

25 12.4 Agreement of the Parties. The Parties agree to be bound by this

26 Stipulated Protective Order pending its approval and entry by the Court. In the

27 event that the Court modifies this Stipulated Protective Order, or in the event that

28 the Court enters a different protective order, the Parties agree to be bound by this

1 Stipulated Protective Order until such time as the Court may enter such a different

2 order. It is the Parties’ intent to be bound by the terms of this stipulation and order

3 pending its entry, so as to allow for immediate production of Confidential

4 Information under the terms herein.

5 13. FINAL DISPOSITION

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

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

8 return all Protected Material to the Producing Party or destroy such material. As

9 used in this subdivision, “all Protected Material” includes all copies, abstracts,

10 compilations, summaries, and any other format reproducing or capturing any of the

11 Protected Material. Whether the Protected Material is returned or destroyed, the

12 Receiving Party must submit a written certification to the Producing Party (and, if

13 not the same person or entity, to the Designating Party) by the 60 day deadline that:

14 (1) identifies (by category, where appropriate) all the Protected Material that was

15 returned or destroyed; and (2) affirms that the Receiving Party has not retained any

16 copies, abstracts, compilations, summaries or any other format reproducing or

17 capturing any of the Protected Material. Notwithstanding this provision, Counsel

18 are entitled to retain an archival copy of all pleadings, motion papers, trial,

19 deposition, and hearing transcripts, legal memoranda, correspondence, deposition

20 and trial exhibits, expert reports, attorney work product, and consultant and expert

21 work product, even if such materials contain Protected Material. Any such

22 archival copies that contain or constitute Protected Material remain subject to this

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

24 ///

25 ///

26 ///

27 ///

28 ///

1] 14. VIOLATION

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

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

4

5 DATED: ___7/13/2021

6 || By: /s/ Aleksandra Urban

Kevin Lipeles

7 || Aleksandra Urban

LIPELES LAW GROUP, APC

8 || Attorneys for Plaintiff

9

10 | DATED: __7/13/2021

11 || By: /s/ Dennis C. Huie

Dennis C. Hute

12 Emily A. Wieser

13 || ROGERS JOSEPH O’DONNELL

Attorneys for Defendant

14

15 SIGNATURE ATTESTATION

I hereby attest that I have on file all holographic signatures

16

corresponding to any signatures indicated by a conformed signature (/S/) within thi

17

e-filed document.”

18

19 Dated: 7/13/2021 By: /s/ Dennis C. Huie

Dennis C. Hute

20 ROGERS JOSEPH O’DONNELL

Attorneys for Defendant

21

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

23

|| DATED: — 7/14/2021

CBee Meck

—_—_—_—_—.,

26

27 || HON. ALEXANDER F. MacKINNON

United States Magistrate Judge

28

Page

1 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND

2

3 I, ___________________________________________[print or type full name] of

4 __________________________________ [print or type full address], declare

5 under penalty of perjury that I have read in its entirety and understand the

6 Stipulated Protective Order that was issued by the United States District Court for

7 the Central District of California on [date] in the case of Maria Cabrera Giron v.

8 Metro Services Troup, Case No. 2:21-cv-01424 FMO (AFMx)[Removed from Los

9 Angeles County Superior Court, Case No. 20STCV16779]. I agree to comply with

10 and to be bound by all the terms of this Stipulated Protective Order and I

11 understand and acknowledge that failure to so comply could expose me to sanctions

12 and punishment in the nature of contempt. I solemnly promise that I will not

13 disclose in any manner any information or item that is subject to this Stipulated

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

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

16 States District Court for the Central District of California for enforcing the terms of

17 this Stipulated Protective Order, even if such enforcement proceedings occur after

18 termination of this action. I hereby appoint _______________________[print or

19 type full name] of __________________________________________ [print or

20 type full address and telephone number] as my California agent for service of

21 process in connection with this action or any proceedings related to enforcement of

22 this Stipulated Protective Order.

23 Date: ____________________________________

24 City and State where sworn and signed: _________________________________

25 Printed name: ______________________________________________________

26 Signature: _________________________________________________________

27

28