even stipulated protective orders require 17 good cause showing
How later courts described this case
- even stipulated protective orders require 17 good cause showing
Written by the judges who cited it.
The opinion
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6 UNITED STATES DISTRICT COURT
7 CENTRAL DISTRICT OF CALIFORNIA
8
9 TRUSTEES OF THE BRICK Case No. 2:21-cv-03906-DMG-PD
MASONS’ HEALTH AND WELFARE
10 TRUST FUND, SOUTHERN Honorable Patricia A. Donahue
CALIFORNIA BRICKLAYERS Ctrm. 580
11 PENSION FUND, BRICK MASONS’
PENSION TRUST FUND, and BRICK
12 MASONS’ APPRENTICESHIP AND STIPULATED PROTECTIVE
TRAINING TRUST FUND, ORDER
13
Plaintiff,
14
v.
15
BIELSKI SPECIALTY SERVICES,
16 INC., a California Corporation;
BIELSKI SERVICES, INC., a
17 California Corporation,
18 Defendants.
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
23 disclosure and from use for any purpose other than prosecuting this litigation may be
24 warranted. Accordingly, the parties hereby stipulate to and petition the Court to
25 enter the following Stipulated Protective Order. The parties acknowledge that this
26 Order does not confer blanket protections on all disclosures or responses to discovery
27 and that the protection it affords from public disclosure and use extends only to the
limited information or items that are entitled to confidential treatment under the
1
applicable legal principles.
2
B. GOOD CAUSE STATEMENT
3
4 This action is likely to involve various categories of confidential information.
5 Discovery in this action which seeks money damages allegedly due to employee
6 benefit plans and for specific performance of obligation to produce records for audit
7 will likely seek non-public, private information from both parties and nonparties,
8 including, but not limited to, tax information and other private documents regarding
9 the Plaintiff Trustees of Pension Benefit Trusts, their confidential business
10 information concerning their establishment, operations and practices, together with
11 Defendants’ non-public, proprietary business operations, privacy protected
12 information otherwise generally unavailable to the public, or which may be
13 privileged or otherwise protected from disclosure under state or federal statutes,
14 court rules, case decisions, or common law. This information includes that
15 concerning the respective Defendants’ current and former employees, relative to
16 those individuals’ last known contact address information. The need for disclosure
17 in this case is balanced against the need to protect that information from disclosure
18 to any interests and individuals outside those individuals specifically described
19 herein.
20 Accordingly, to expedite the flow of information, to facilitate the prompt
21 resolution of disputes over confidentiality of discovery materials, to adequately
22 protect information the parties are entitled to keep confidential, to ensure that the
23 parties are permitted reasonable necessary uses of such material in preparation for
24 and in the conduct of trial, to address their handling at the end of the litigation, and
25 serve the ends of justice, the parties submit that a protective order for such
26 information is justified in this matter.
27 It is the intent of the parties that information will not be designated as
good faith belief that it has been maintained in a confidential, non-public manner,
1
and there is “good cause” within the meaning of applicable law why it should not be
2
part of the public record of this case.
3
4 C. PARTIES’ ACKNOWLEDGMENT OF PROCEDURE FOR FILING
5 UNDER SEAL
6 The parties further acknowledge, as set forth in Section 12.3, below, that this
7 Stipulated Protective Order does not entitle them to file confidential information
8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
9 the standards that will be applied when a party seeks permission from the court to
10 file material under seal.
11 There is a strong presumption that the public has a right of access to judicial
12 proceedings and records in civil cases. In connection with non-dispositive motions,
13 good cause must be shown to support a filing under seal. See Kamakana v. City and
14 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
15 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
16 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
17 good cause showing), and a specific showing of good cause or compelling reasons
18 with proper evidentiary support and legal justification, must be made with respect to
19 Protected Material that a party seeks to file under seal. The parties’ mere designation
20 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the
21 submission of competent evidence by declaration, establishing that the material
22 sought to be filed under seal qualifies as confidential, privileged, or otherwise
23 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
under seal in connection with a dispositive motion or trial, the party seeking
1
protection must articulate compelling reasons, supported by specific facts and legal
2
justification, for the requested sealing order. Again, competent evidence supporting
3
the application to file documents under seal must be provided by declaration.
4
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.
7 If documents can be redacted, then a redacted version for public viewing, omitting
8 only the confidential, privileged, or otherwise protectable portions of the document,
9 shall be filed. Any application that seeks to file documents under seal in their
10 entirety should include an explanation of why redaction is not feasible.
11 2. DEFINITIONS
12 2.1 Action: Trustees of the Brick Masons’ Health and Welfare
13 Trust Fund of Southern California, etc., et al. v. Bielski Specialty Services,
14 Inc., filed in the U.S. District Court for the Central District of California,
15 bearing Case No. 2:21-cv-03906-DMG-PD.
16 2.2 Challenging Party: a Party or Non-Party that challenges
17 the designation of information or items under this Order.
18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
19 how it is generated, stored or maintained) or tangible things that qualify for
20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the
21 Good Cause Statement.
22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
23 their support staff).
24 2.5 Designating Party: a Party or Non-Party that designates information or
25 items that it produces in disclosures or in responses to discovery as
26 “CONFIDENTIAL.”
27 2.6 Disclosure or Discovery Material: all items or information, regardless
among other things, testimony, transcripts, and tangible things), that are produced or
1
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 as
4
an expert witness or as a consultant in this Action.
5
6 2.8 House Counsel: attorneys who are employees of a party to this Action.
7 House Counsel does not include Outside Counsel of Record or any other outside
8 counsel.
9 2.9 Non-Party: any natural person, partnership, corporation, association,
10 or other legal entity not named as a Party to this action.
11 2.10 Outside Counsel of Record: attorneys who are not employees of a party
12 to this Action but are retained to represent or advise a party to this Action and have
13 appeared in this Action on behalf of that party or are affiliated with a law firm which
14 has appeared on behalf of that party, and includes support staff.
15 2.11 Party: any party to this Action, including all of its officers, directors,
16 employees, consultants, retained experts, and Outside Counsel of Record (and their
17 support staffs).
18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 Discovery Material in this Action.
20 2.13 Professional Vendors: persons or entities that provide litigation
21 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium)
23 and their employees and subcontractors.
24 2.14 Protected Material: any Disclosure or Discovery Material that is
25 designated as “CONFIDENTIAL.”
26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
27 from a Producing Party.
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
6 Any use of Protected Material at trial shall be governed by the orders of the
7 trial judge. This Order does not govern the use of Protected Material at trial.
8 4. DURATION
9 FINAL DISPOSITION of the action is defined as the conclusion of any
10 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal
11 has run. Except as set forth below, the terms of this protective order apply through
12 FINAL DISPOSITION of the action. The parties may stipulate that they will be
13 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
14 but will have to file a separate action for enforcement of the agreement once all
15 proceedings in this case are complete.
16 Once a case proceeds to trial, information that was designated as
17 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
18 as an exhibit at trial becomes public and will be presumptively available to all
19 members of the public, including the press, unless compelling reasons supported by
20 specific factual findings to proceed otherwise are made to the trial judge in advance
21 of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d at 1180-81
22 (distinguishing “good cause” showing for sealing documents produced in discovery
23 from “compelling reasons” standard when merits-related documents are part of court
24 record). Accordingly, for such materials, the terms of this protective order do not
25 extend beyond the commencement of the trial.
26 5. DESIGNATING PROTECTED MATERIAL
27 5.1 Exercise of Restraint and Care in Designating Material for Protection.
this Order must take care to limit any such designation to specific material that
1
qualifies under the appropriate standards. The Designating Party must designate for
2
protection only those parts of material, documents, items, or oral or written
3
communications that qualify so that other portions of the material, documents, items,
4
or communications for which protection is not warranted are not swept unjustifiably
5
within the ambit of this Order.
6
7 Mass, indiscriminate, or routinized designations are prohibited. Designations
8 that are shown to be clearly unjustified or that have been made for an improper
9 purpose (e.g., to unnecessarily encumber the case development process or to impose
10 unnecessary expenses and burdens on other parties) may expose the Designating
11 Party to sanctions.
12 If it comes to a Designating Party’s attention that information or items that it
13 designated for protection do not qualify for protection; that Designating Party must
14 promptly notify all other Parties that it is withdrawing the inapplicable designation.
15 5.2 Manner and Timing of Designations. Except as otherwise provided in
16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
18 under this Order must be clearly so designated before the material is disclosed or
19 produced.
20 Designation in conformity with this Order requires:
21 (a) for information in documentary form (e.g., paper or electronic
22 documents, but excluding transcripts of depositions or other pretrial or trial
23 proceedings), that the Producing Party affix at a minimum, the legend
24 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
25 contains protected material. If only a portion or portions of the material on a page
26 qualifies for protection, the Producing Party also must clearly identify the protected
27 portion(s) (e.g., by making appropriate markings in the margins).
need not designate them for protection until after the inspecting Party has indicated
1
which documents it would like copied and produced. During the inspection and
2
before the designation, all of the material made available for inspection shall be
3
deemed “CONFIDENTIAL.” After the inspecting Party has identified the
4
documents it wants copied and produced, the Producing Party must determine which
5
documents, or portions thereof, qualify for protection under this Order. Then, before
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producing the specified documents, the Producing Party must affix the
7
“CONFIDENTIAL legend” to each page that contains Protected Material. If only a
8
portion or portions of the material on a page qualifies for protection, the Producing
9
Party also must clearly identify the protected portion(s) (e.g., by making appropriate
10
markings in the margins).
11
12 (b) for testimony given in depositions that the Designating Party identify
13 the Disclosure or Discovery Material on the record, before the close of the deposition
14 all protected testimony.
15 (c) for information produced in some form other than documentary and for
16 any other tangible items, that the Producing Party affix in a prominent place on the
17 exterior of the container or containers in which the information is stored the legend
18 “CONFIDENTIAL.” If only a portion or portions of the information warrants
19 protection, the Producing Party, to the extent practicable, shall identify the protected
20 portion(s).
21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
22 failure to designate qualified information or items does not, standing alone, waive
23 the Designating Party’s right to secure protection under this Order for such material.
24 Upon timely correction of a designation, the Receiving Party must make reasonable
25 efforts to assure that the material is treated in accordance with the provisions of this
26 Order.
27 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
designation of confidentiality at any time that is consistent with the Court’s
1
Scheduling Order.
2
6.2 Meet and Confer. The Challenging Party shall initiate the dispute
3
resolution process under Local Rule 37.1 et seq. All parties shall cooperate with the
4
dispute resolution process.
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6 6.3 The burden of persuasion in any such challenge proceeding shall be on
7 the Designating Party. Frivolous challenges, and those made for an improper
8 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
9 may expose the Challenging Party to sanctions. Unless the Designating Party has
10 waived or withdrawn the confidentiality designation, all parties shall continue to
11 afford the material in question the level of protection to which it is entitled under the
12 Producing Party’s designation until the Court rules on the challenge.
13 7. ACCESS TO AND USE OF PROTECTED MATERIAL
14 7.1 Basic Principles. A Receiving Party may use Protected Material that is
15 disclosed or produced by another Party or by a Non-Party in connection with this
16 Action only for prosecuting, defending, or attempting to settle this Action. Such
17 Protected Material may be disclosed only to the categories of persons and under the
18 conditions described in this Order. When the Action has been terminated, a
19 Receiving Party must comply with the provisions of section 13 below (FINAL
20 DISPOSITION).
21 Protected Material must be stored and maintained by a Receiving Party at a
22 location and in a secure manner that ensures that access is limited to the persons
23 authorized under this Order.
24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
25 otherwise ordered by the court or permitted in writing by the Designating Party, a
26 Receiving Party may disclose any information or item designated
27 “CONFIDENTIAL” only to:
as employees of said Outside Counsel of Record to whom it is reasonably necessary
1
to disclose the information for this Action;
2
(b) the officers, directors, and employees (including House Counsel) of the
3
Receiving Party to whom disclosure is reasonably necessary for this Action;
4
5 (c) Experts (as defined in this Order) of the Receiving Party to whom
6 disclosure is reasonably necessary for this Action and who have signed the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
8 (d) the court and its personnel;
9 (e) court reporters and their staff;
10 (f) professional jury or trial consultants, mock jurors, and Professional
11 Vendors to whom disclosure is reasonably necessary for this Action and who have
12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13 (g) the author or recipient of a document containing the information or a
14 custodian or other person who otherwise possessed or knew the information;
15 (h) during their depositions, witnesses, and attorneys for witnesses, in the
16 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
17 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
18 not be permitted to keep any confidential information unless they sign the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
20 agreed by the Designating Party or ordered by the court. Pages of transcribed
21 deposition testimony or exhibits to depositions that reveal Protected Material may
22 be separately bound by the court reporter and may not be disclosed to anyone except
23 as permitted under this Stipulated Protective Order; and
24 (i) any mediator or settlement officer, and their supporting personnel,
25 mutually agreed upon by any of the parties engaged in settlement discussions.
26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
27 IN OTHER LITIGATION
that compels disclosure of any information or items designated in this Action as
1
“CONFIDENTIAL,” that Party must:
2
(a) promptly notify in writing the Designating Party. Such notification
3
shall include a copy of the subpoena or court order;
4
5 (b) promptly notify in writing the party who caused the subpoena or order
6 to issue in the other litigation that some or all of the material covered by the subpoena
7 or order is subject to this Protective Order. Such notification shall include a copy of
8 this Stipulated Protective Order; and
9 (c) cooperate with respect to all reasonable procedures sought to be pursued
10 by the Designating Party whose Protected Material may be affected.
11 If the Designating Party timely seeks a protective order, the Party served
12 with the subpoena or court order shall not produce any information designated in this
13 action as “CONFIDENTIAL” before a determination by the court from which the
14 subpoena or order issued, unless the Party has obtained the Designating Party’s
15 permission. The Designating Party shall bear the burden and expense of seeking
16 protection in that court of its confidential material and nothing in these provisions
17 should be construed as authorizing or encouraging a Receiving Party in this Action
18 to disobey a lawful directive from another court.
19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT
20 TO BE PRODUCED IN THIS LITIGATION
21 (a) The terms of this Order are applicable to information produced by a
22 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
23 produced by Non-Parties in connection with this litigation is protected by the
24 remedies and relief provided by this Order. Nothing in these provisions should be
25 construed as prohibiting a Non-Party from seeking additional protections.
26 (b) In the event that a Party is required, by a valid discovery request, to
27 produce a Non-Party’s confidential information in its possession, and the Party is
confidential information, then the Party shall:
1
(1) promptly notify in writing the Requesting Party and the Non-Party
2
that some or all of the information requested is subject to a confidentiality agreement
3
with a Non-Party;
4
5 (2) promptly provide the Non-Party with a copy of the Stipulated
6 Protective Order in this Action, the relevant discovery request(s), and a reasonably
7 specific description of the information requested; and
8 (3) make the information requested available for inspection by the
9 Non-Party, if requested.
10 (c) If the Non-Party fails to seek a protective order from this court within
11 14 days of receiving the notice and accompanying information, the Receiving Party
12 may produce the Non-Party’s confidential information responsive to the discovery
13 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
14 not produce any information in its possession or control that is subject to the
15 confidentiality agreement with the Non-Party before a determination by the court.
16 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
17 of seeking protection in this court of its Protected Material.
18 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
20 Protected Material to any person or in any circumstance not authorized under this
21 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
22 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
23 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
24 persons to whom unauthorized disclosures were made of all the terms of this Order,
25 and (d) request such person or persons to execute the “Acknowledgment and
26 Agreement to Be Bound” that is attached hereto as Exhibit A.
27 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
When a Producing Party gives notice to Receiving Parties that certain
1
inadvertently produced material is subject to a claim of privilege or other protection,
2
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
3
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
4
may be established in an e-discovery order that provides for production without prior
5
privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as
6
the parties reach an agreement on the effect of disclosure of a communication or
7
information covered by the attorney-client privilege or work product protection, the
8
parties may incorporate their agreement in the stipulated protective order submitted
9
to the court.
10
11 12. MISCELLANEOUS
12 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
13 person to seek its modification by the Court in the future.
14 12.2 Right to Assert Other Objections. By stipulating to the entry of this
15 Protective Order no Party waives any right it otherwise would have to object to
16 disclosing or producing any information or item on any ground not addressed in this
17 Stipulated Protective Order. Similarly, no Party waives any right to object on any
18 ground to use in evidence of any of the material covered by this Protective Order.
19 12.3 Filing Protected Material. A Party that seeks to file under seal any
20 Protected Material must comply with Civil Local 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 13. FINAL DISPOSITION
26 After the final disposition of this Action, as defined in paragraph 4, within 60
27 days of a written request by the Designating Party, each Receiving Party must return
this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
1
summaries, and any other format reproducing or capturing any of the Protected
2
Material. The Producing Party may request that the Receiving Party submit a
3
written certification to the Producing Party (and, if not the same person or entity, to
4
the Designating Party) by the 60 day deadline that (1) identifies (by category, where
5
appropriate) all the Protected Material that was returned or destroyed and (2)affirms
6
that the Receiving Party has not retained any copies, abstracts, compilations,
7
summaries or any other format reproducing or capturing any of the Protected
8
Material.
9
10 Notwithstanding this provision, Counsel are entitled to retain an archival copy
11 of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
12 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
13 work product, and consultant and expert work product, even if such materials contain
14 Protected Material. Any such archival copies that contain or constitute Protected
15 Material remain subject to this Protective Order as set forth in Section 4, which is
16 defined as the conclusion of any appellate proceedings, or, if no appeal is taken,
17 when the time for filing of an appeal has run.
18 [Remainder of Page intentionally Blank]
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1 14. SANCTIONS FOR VIOLATIONS Any violation of this Order may
|| be punished by any and all appropriate measures including, without limitation,
3 || contempt proceedings and/or monetary sanctions.
4 || IT ISSO STIPULATED, THROUGH COUNSEL OF RECORD.
5
6 || DATED: July 14, 2021 BARTON, KLUGMAN & OETTING LLP
7
By:___/s/ Terry L. Higham
8 Joseph Carpello, APLC
Terry L. Higham, APLC
9 Attorneys for Defendants BIELSKI SERVICES,
INC. and BIELSKI SPECIALTY SERVICES,
10 INC.
11 || DATED: July 14, 2021 THE WAGNER LAW GROUP
12
By:___/s/ Neelam Chandna
Neelam Chandna
14 Jordan Mamorsky
David Gabor
15 Attorneys for Plaintiffs
Trustees of the Brick Masons’ Health and Welfare
16 Fund, Southern California Bricklayers Pension
Fund, Brick Masons’ Pension Fund and Brick
7 Masons’ Apprenticeship and Training Trust Fund
18 |) FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
19
20 || DATED: August 05, 2021
21
2 7 abuser Lona
93 || Hon. Patricia A. Donahue
United States Magistrate Judge
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1 ATTESTATION REGARDING SIGNATURES
2 I, Terry L. Higham, attest that all signatories listed herein, and on whose
3 behalf this filing is made, concur in the document’s content and have authorized this
4 filing.
By: __ /s/ Terry L. Higham
5 Terry L. Higham, APLC
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1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3 I, ________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury
5 of the laws of the United States of America, that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States
7 District Court for the Central District of California on _______ in the case of
8 Trustees of the Brick Masons’ Health and Welfare Trust Fund of Southern
9 California, etc., et al. v. Bielski Specialty Services, Inc., filed in the U.S. District
10 Court for the Central District of California, bearing Case No. 2:21-cv-03906-DMG-
11 PD. I agree to comply with and to be bound by all the terms of this Stipulated
12 Protective Order and I understand and acknowledge that failure to so comply could
13 expose me to monetary sanctions and punishment in the nature of contempt. I
14 solemnly promise that I will not disclose in any manner any information or item
15 that is subject to this Stipulated Protective Order to any person or entity except in
16 strict compliance with the provisions of this Order.
17 I further agree to submit to the jurisdiction of the United States District Court for
18 the Central District of California for the purpose of enforcing the terms of this
19 Stipulated Protective Order, even if such enforcement proceedings occur after
20 termination of this action. I hereby appoint ________________________ [print
21 or type full name] of _________ [print or type full address and telephone number]
22 as my California agent for service of process in connection with this action or any
23 proceedings related to enforcement of this Stipulated Protective Order.
24 Date: __________________________
25
City and State where sworn and signed: _____________________________
26
Printed name: ____________________________________
27