# Jon Spielberger v. Envoy Air, Inc.

> District Court, C.D. California · May 15, 2020

URL: https://www.frixlaw.com/law-library/cases/10042650

## Case

- **Court:** District Court, C.D. California
- **Decided:** May 15, 2020
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 JON SPIELBERGER; HUGO Case No. 2:19-cv-08558 MWF (ks)
NUNEZ; BENJAMIN R.
11 MALDANADO; OLIVER [PROPOSED] STIPULATED
THOMAS, EDWARD ALVA; PROTECTIVE ORDER
12
MARIA QUINTANA; LUIS
Judge: Hon. Michael W. Fitzgerald
13 GOMEZ; JAVIER FRIZ; Room: 5A
LIXANDER RUBALCAVA;
14 MARCO NUNEZ; SOUHIL ACHI;
GUILLERMO MERINO; OSCAR
15 RODRIGUEZ LOPEZ; SHEHADEH
ACHI; MARIBEL PRADO;
16 JOVHANY MORALES; LORENA
GONZALEZ; DAVID ROLON;
17 MARIELA CORTEZ; SANDRA
WEATHERSBY; FABIAN
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CABRERA,
19 Plaintiffs,
20 v.
21 ENVOY AIR, INC.; Does 1 to 15
22 Defendants.
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1 1. A. PURPOSE AND LIMITATIONS
2 Discovery in this action is likely to involve production and disclosure of
3 confidential, proprietary or private information for which special protection from
4 public disclosure and from use for any purpose other than prosecuting this litigation
5 may be warranted. Accordingly, the parties hereby stipulate to and petition the
6 Court to enter the following Stipulated Protective Order. The parties acknowledge
7 that this Order does not confer blanket protections on all disclosures or responses to
8 discovery and that the protection it affords from public disclosure and use extends
9 only to the limited information or items that are entitled to confidential treatment
10 under the applicable legal principles.
11 B. GOOD CAUSE STATEMENT
12 This action is likely to involve trade secrets, commercial, financial, technical
13 and/or proprietary information for which special protection from public disclosure
14 and from use for any purpose other than prosecution of this action is warranted.
15 Such confidential and proprietary materials and information consist of, among other
16 things, confidential business or financial information, information regarding
17 confidential business practices, or other confidential research, development, or
18 commercial information (including information implicating privacy rights of third
19 parties), information otherwise generally unavailable to the public, or which may be
20 privileged or otherwise protected from disclosure under state or federal statutes,
21 court rules, case decisions, or common law. Accordingly, to expedite the flow of
22 information, to facilitate the prompt resolution of disputes over confidentiality of
23 discovery materials, to adequately protect information the parties are entitled to
24 keep confidential, to ensure that the parties are permitted reasonable necessary uses
25 of such material in preparation for and in the conduct of trial, to address their
26 handling at the end of the litigation, and serve the ends of justice, a protective order
27 for such information is justified in this matter. It is the intent of the parties that
28 information will not be designated as confidential for tactical reasons and that
1 nothing be so designated without a good faith belief that it has been maintained in a
2 confidential, non-public manner, and there is good cause why it should not be part
3 of the public record of this case.
4 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
5 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
9 and the standards that will be applied when a Party seeks permission from the court
10 to 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 &
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
17 require good cause showing), and a specific showing of good cause or compelling
18 reasons with proper evidentiary support and legal justification, must be made with
19 respect to Protected Material that a Party seeks to file under seal. The parties’ mere
20 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
21 without the submission of competent evidence by declaration, establishing that the
22 material sought to be filed under seal qualifies as confidential, privileged, or
23 otherwise protectable—constitute good cause.
24 Further, if a Party requests sealing related to a dispositive motion or trial,
25 then compelling reasons, not only good cause, for the sealing must be shown, and
26 the relief sought shall be narrowly tailored to serve the specific interest to be
27 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.
28 2010). For each item or type of information, document, or thing sought to be filed
1 or introduced under seal in connection with a dispositive motion or trial, the Party
2 seeking protection must articulate compelling reasons, supported by specific facts
3 and legal justification, for the requested sealing order. Again, competent evidence
4 supporting the application to file documents under seal must be provided by
5 declaration.
6 Any document that is not confidential, privileged, or otherwise protectable in
7 its entirety will not be filed under seal if the confidential portions can be redacted.
8 If documents can be redacted, then a redacted version for public viewing, omitting
9 only the confidential, privileged, or otherwise protectable portions of the document,
10 shall be filed. Any application that seeks to file documents under seal in their
11 entirety should include an explanation of why redaction is not feasible.
12 2. DEFINITIONS
13 2.1 Action: the above-captioned matter, Spielberger et al. v. Envoy Air,
14 Inc., Case No. 2:19-CV-08558 MWF (ks).
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 or 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 (including,
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1 among other things, testimony, transcripts, and tangible things), that are produced
2 or generated in disclosures or responses to discovery in this matter.
3 2.7 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 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 or
10 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
12 party to this Action but are retained to represent or advise a party to this Action and
13 have appeared in this Action on behalf of that party or are affiliated with a law firm
14 that 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
27 Material from a Producing Party.
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1 3. SCOPE
2 The protections conferred by this Stipulated Protective Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the
8 Honorable Michael W. Fitzgerald. This Order does not govern the use of Protected
9 Material at trial.
10 4. DURATION
11 Once a case proceeds to trial, information that was designated as
12 CONFIDENTIAL or maintained pursuant to this protective order used or
13 introduced as an exhibit at trial becomes public and will be presumptively available
14 to all members of the public, including the press, unless compelling reasons
15 supported by specific factual findings to proceed otherwise are made to the trial
16 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing
17 “good cause” showing for sealing documents produced in discovery from
18 “compelling reasons” standard when merits-related documents are part of court
19 record). Accordingly, the terms of this protective order do not extend beyond the
20 commencement of the trial.
21 5. DESIGNATING PROTECTED MATERIAL
22 5.1 Exercise of Restraint and Care in Designating Material for Protection.
23 Each Party or Non-Party that designates information or items for protection under
24 this Order must take care to limit any such designation to specific material that
25 qualifies under the appropriate standards. The Designating Party must designate for
26 protection only those parts of material, documents, items or oral or written
27 communications that qualify so that other portions of the material, documents,
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1 items or communications for which protection is not warranted are not swept
2 unjustifiably within the ambit of 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
6 impose unnecessary expenses and burdens on other parties) may expose the
7 Designating Party 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 5.2 Manner and Timing of Designations. Except as otherwise provided in
12 this Order (see, e.g., second and third paragraphs of Section 5.2(a) below), or as
13 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for
14 protection under this Order must be clearly so designated before the material is
15 disclosed or produced.
16 Designation in conformity with this Order requires:
17 (a) for information in documentary form (e.g., paper or electronic
18 documents, but excluding transcripts of depositions or other pretrial or trial
19 proceedings), that the Producing Party affix at a minimum, the legend
20 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) to each page that
21 contains Protected Material. If only a portion of the material on a page qualifies for
22 protection, the Producing Party also must clearly identify the protected portion(s)
23 (e.g., by making appropriate markings in the margins).
24 A Party or Non-Party that makes original documents available for
25 inspection need not designate them for protection until after the inspecting Party
26 has indicated which documents it would like copied and produced. During the
27 inspection and before the designation, all of the material made available for
28 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
1 identified the documents it wants copied and produced, the Producing Party must
2 determine which documents, or portions thereof, qualify for protection under this
3 Order. Then, before producing the specified documents, the Producing Party must
4 affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
5 If only a portion of the material on a page qualifies for protection, the Producing
6 Party also must clearly identify the protected portion(s) (e.g., by making
7 appropriate markings in the margins).
8 Documents produced or disclosed prior to the date that this Order is
9 executed by the Parties may be designated confidential by providing written notice
10 to all Parties within 30 days of the execution of this Order by the Parties.
11 (b) for testimony given in depositions that the Designating Party
12 identifies the Disclosure or Discovery Material on the record, before the close of
13 the deposition all protected testimony.
14 Testimony taken at a deposition, conference or hearing prior to the
15 date this Order is executed by the Parties may be designated confidential by
16 providing written notice to all Parties within 30 days of the execution of this Order
17 by the Parties.
18 (c) for information produced in some form other than documentary,
19 and for any other tangible items, that the Producing Party affix in a prominent place
20 on the exterior of the container or containers in which the information or item is
21 stored the legend “CONFIDENTIAL.” If only a portion or portions of the
22 information warrants protection, the Producing Party, to the extent practicable, shall
23 identify the protected portion(s).
24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
25 failure to designate qualified information or items does not, standing alone, waive
26 the Designating Party’s right to secure protection under this Order for such
27 material. Upon timely correction of a designation, the Receiving Party must make
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1 reasonable efforts to assure that the material is treated in accordance with the
2 provisions of this Order.
3 6. DESIGNATING PROTECTED MATERIAL
4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
5 designation of confidentiality at any time that is consistent with the Court’s
6 Scheduling Order.
7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
8 resolution process under Local Rule 37-1 et seq.
9 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
10 joint stipulation pursuant to Local Rule 37-2.
11 6.4 The burden of persuasion in any such challenge proceeding shall be on
12 the Designating Party. Frivolous challenges, and those made for an improper
13 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
14 parties) may expose the Challenging Party to sanctions. Unless the Designating
15 Party has waived or withdrawn the confidentiality designation, all parties shall
16 continue to afford the material in question the level of protection to which it is
17 entitled under the Producing Party’s designation until the Court rules on the
18 challenge.
19 7. ACCESS TO AND USE OF PROTECTED MATERIAL
20 7.1 Basic Principles. A Receiving Party may use Protected Material that is
21 disclosed or produced by another Party or by a Non-Party in connection with this
22 Action only for prosecuting, defending, or attempting to settle this Action. Such
23 Protected Material may be disclosed only to the categories of persons and under the
24 conditions described in this Order. When the Action has been terminated, a
25 Receiving Party must comply with the provisions of Section 13 below (FINAL
26 DISPOSITION).
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1 Protected Material must be stored and maintained by a Receiving Party at a
2 location and in a secure manner that ensures that access is limited to the persons
3 authorized under this Order.
4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
5 otherwise ordered by the Court or permitted in writing by the Designating Party, a
6 Receiving Party may disclose any information or item designated
7 “CONFIDENTIAL” only to:
8 (a) the Receiving Party’s Outside Counsel of record in this Action,
9 as well as employees of said Outside Counsel to whom it is reasonably necessary to
10 disclose the information for this Action;
11 (b) the Receiving Party’s House Counsel, as well as staff of said
12 House Counsel to whom it is reasonably necessary to disclose the information for
13 this Action (including, for example, assistants, secretaries, and paralegals);
14 (c) the officers, directors, or employees of the Receiving Party to
15 whom disclosure is reasonably necessary for this Action;
16 (d) Experts (as defined in this Order) of the Receiving Party to
17 whom disclosure is reasonably necessary for this Action and who have signed the
18 “Acknowledgment and Agreement to Be Bound” (attached hereto as Exhibit 1);
19 (e) the Court and its personnel;
20 (f) court reporters and their staff;
21 (g) professional jury or trial consultants, mock jurors, and
22 Professional Vendors to whom disclosure is reasonably necessary for this Action
23 and who have signed the “Acknowledgment and Agreement to Be Bound”
24 (attached hereto as Exhibit 1);
25 (h) during their depositions, witnesses, and attorneys for witnesses,
26 in the Action to whom disclosure is reasonably necessary provided: (1) the
27 deposing party requests that the witness sign the form attached as Exhibit 1 hereto;
28 and (2) they will not be permitted to keep any confidential information unless they
1 sign the “Acknowledgment and Agreement to Be Bound” (attached hereto as
2 Exhibit 1), unless otherwise agreed by the Designating Party or ordered by the
3 court. Pages of transcribed deposition testimony or exhibits to depositions that
4 reveal Protected Material may be separately bound by the court reporter and may
5 not be disclosed to anyone except as permitted under this Stipulated Protective
6 Order; and
7 (i) any mediator or settlement officer, and their supporting
8 personnel, mutually agreed upon by any of the parties engaged in settlement
9 discussions.
10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
11 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. Such
16 notification shall include a copy of the subpoena or court order;
17 (b) promptly notify in writing the party who caused the subpoena or
18 order to issue in the other litigation that some or all of the material covered by the
19 subpoena or order is subject to this Protective Order. Such notification shall include
20 a copy of this Stipulated Protective Order; and
21 (c) cooperate with respect to all reasonable procedures sought to be
22 pursued by the Designating Party whose Protected Material may be affected. If the
23 Designating Party timely seeks a protective order, the Party served with the
24 subpoena or court order shall not produce any information designated in this action
25 as “CONFIDENTIAL” before a determination by the court from which the
26 subpoena or order issued, unless the Party has obtained the Designating Party’s
27 permission. The Designating Party shall bear the burden and expense of seeking
28 protection in that court of its confidential material and nothing in these provisions
1 should be construed as authorizing or encouraging a Receiving Party in this Action
2 to disobey a lawful directive from another court.
3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 (a) The terms of this Order are applicable to information produced
6 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
7 information produced by Non-Parties in connection with this litigation is protected
8 by the remedies and relief provided by this Order. Nothing in these provisions
9 should be construed as prohibiting a Non-Party from seeking additional protections.
10 (b) In the event that a Party is required, by a valid discovery
11 request, to produce a Non-Party’s confidential information in its possession, and the
12 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s
13 confidential information, then the Party shall:
14 (1) promptly notify in writing the Requesting Party and the
15 Non-Party that some or all of the information requested is subject to a
16 confidentiality agreement with a Non-Party;
17 (2) promptly provide the Non-Party with a copy of the
18 Stipulated Protective Order in this Action, the relevant discovery request(s), and a
19 reasonably specific description of the information requested; and
20 (3) make the information requested available for inspection
21 by the Non-Party, if requested.
22 (c) If the Non-Party fails to seek a protective order from this court
23 within 14 days of receiving the notice and accompanying information, the
24 Receiving Party may produce the Non-Party’s confidential information responsive
25 to the discovery request. If the Non-Party timely seeks a protective order, the
26 Receiving Party shall not produce any information in its possession or control that
27 is subject to the confidentiality agreement with the Non-Party before a
28 determination by the court. Absent a court order to the contrary, the Non-Party
1 shall bear the burden and expense of seeking protection in this court of its Protected
2 Material.
3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
5 Protected Material to any person or in any circumstance not authorized under this
6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
7 writing the Designating Party of the unauthorized disclosures, (b) use its best
8 efforts to retrieve all copies of the Protected Material, (c) inform the person or
9 persons to whom unauthorized disclosures were made of all the terms of this
10 Stipulated Protective Order, and (d) request such person or persons to execute the
11 “Acknowledgment and Agreement to Be Bound” attached hereto as Exhibit 1.
12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
13 PROTECTED MATERIAL
14 When a Producing Party gives notice to Receiving Parties that certain inadvertently
15 produced material is subject to a claim of privilege or other protection, the
16 obligations of the Receiving Parties are those set forth in Federal Rule of Civil
17 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
18 procedure may be established in an e-discovery order that provides for production
19 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
20 (e), insofar as the parties reach an agreement on the effect of disclosure of a
21 communication or information covered by the attorney-client privilege or work
22 product protection, the parties may incorporate their agreement in the stipulated
23 protective order submitted to the court.
24 12. MISCELLANEOUS
25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
26 person to seek its modification by the Court in the future.
27 12.2 Right to Assert Other Objections. By stipulating to the entry of this
28 Protective Order, no Party waives any right it otherwise would have to object to
1 disclosing or producing any information or item on any ground not addressed in
2 this Stipulated Protective Order. Similarly, no Party waives any right to object on
3 any ground to use in evidence of any of the material covered by this Protective
4 Order.
5 12.3 Filing Protected Material. A Party that seeks to file under seal any
6 Protected Material must comply with Local Civil Rule 79-5. Protected Material
7 may only be filed under seal pursuant to a court order authorizing the sealing of the
8 specific Protected Material at issue. If a Party’s request to file Protected Material
9 under seal is denied by the court, then the Receiving Party may file the information
10 in the public record unless otherwise instructed by the court.
11 12.4 This Stipulation and Protective Order is entered into without prejudice
12 to the right of any Party to knowingly waive the applicability of this Stipulation and
13 Protective Order to any Confidential Materials designated by that Party. If the
14 Designating Party uses Confidential Materials in a non-Confidential manner, then
15 the Designating Party shall advise all parties that the designation no longer applies.
16 If the Designating Party does not advise the parties that the designation no longer
17 applies and has not taken action to cure the non-Confidential use of the Confidential
18 Materials (by, for example, filing a motion to seal Confidential Materials that have
19 been filed publicly) within 14 days of the non-Confidential use, then the Receiving
20 Party may appropriately conclude that the Designating Party intended to waive the
21 Confidential designation.
22 12.5 This Order shall be deemed contractually binding upon each Party
23 upon each Party’s execution of this Order, notwithstanding whether the Court has
24 signed this Order.
25 13. FINAL DISPOSITION
26 After the final disposition of this Action, within 60 days of a written request
27 by the Designating Party, each Receiving Party must return all Protected Material to
28 the Producing Party or destroy such material. As used in this subdivision, “all
1 | Protected Material” includes all copies, abstracts, compilations, summaries, and any
2 | other format reproducing or capturing any of the Protected Material. Whether the
3 | Protected Material is returned or destroyed, the Receiving Party must submit a
4 | written certification to the Producing Party (and, if not the same person or entity, to
5 | the Designating Party) by the 60 day deadline that (1) identifies (by category, where
6 | appropriate) all the Protected Material that was returned or destroyed and (2)
7 | affirms that the Receiving Party has not retained any copies, abstracts,
8 | compilations, summaries or any other format reproducing or capturing any of the
9 | Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
10 | archival copy of all pleadings, motion papers, trial, deposition, and hearing
11 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
12 | reports, attorney work product, and consultant and expert work product, even if
13 | such materials contain Protected Material. Any such archival copies that contain or
14 } constitute Protected Material remain subject to this Protective Order as set forth in
15 | Section 4 (DURATION).
16} 14. VIOLATION
Ly Any violation of this Order may be punished by appropriate measures
18 | including, without limitation, contempt proceedings and/or monetary sanctions.
19
20 Based on the stipulation of the parties and for good cause shown, IT IS SO
21 | ORDERED.
22
23 Dated: May 15, 2020
LSonem_L- Blowin
Wim
25 KAREN L. STEVENSON
%6 UNITED STATES MAGISTRATE JUDGE
aT
28
14 SEIRUERTED PROTEC TE □□□□□

1 EXHIBIT 1
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of
4 ___________________________ [print or type full address], declare under penalty
5 of perjury that I have read in its entirety and understand the Stipulated Protective
6 Order that was issued by the United States District Court, Central District of
7 California, on May 15, 2020 in Spielberger et al. v. Envoy Air, Inc. (Case No. 2:19-
8 CV-08558 MWF (ks)). I agree to comply with and to be bound by all the terms of
9 the Stipulated Protective Order, including, but not limited to, the provisions dealing
10 with disclosure of materials designated “CONFIDENTIAL,” and I understand and
11 acknowledge that failure to so comply could expose me to sanctions and
12 punishment in the nature of contempt. I solemnly promise that I will not disclose in
13 any manner any information or item that is subject to the Stipulated Protective
14 Order to any person or entity except in strict compliance with the provisions of the
15 Order.
16 I further agree to submit to the jurisdiction and venue of the United States
17 District Court, Central District of California, for the purpose of enforcing the terms
18 of the Stipulated Protective Order, even if such enforcement proceedings occur
19 after termination of this action. I hereby appoint___________________________
20 [print or type full name], of ___________________________ [print or type full
21 address] as my California agent for service of process in connection with this action
22 or any proceedings related to enforcement of this Stipulated Protective Order.
23
Date:____________________________
24
City and State where sworn and signed:____________________________
25
26 Printed name:____________________________
27
28 Signature:____________________________

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10042650. Public record. Not legal advice.