distinguishing “good cause” showing for 1 merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” showing for 1 merits-related documents are part of court record
- even stipulated protective orders require good 13 cause showing
Written by the judges who cited it.
The opinion
1 Ronald P. Oines (Bar No. 145016)
2 Email: roines@rutan.com
RUTAN & TUCKER, LLP
3 18575 Jamboree Road, 9th Floor
4 Irvine, California 92612
Telephone: 714.641.5100
5 Facsimile: 714.546.9035
6
Wendy C. Larson (Bar No. 235037)
7
Email: wlarson@pirkeybarber.com
8 Brandon M. Ress (Pro Hac Vice)
Email: bress@pirkeybarber.com
9
PIRKEY BARBER PLLC
10 1801 East 6th Street, Suite 300
Austin, TX 78702
11
Telephone: 512.322.5200
12 Facsimile: 512.322.5201
13 Attorneys for Plaintiff Sweet James LLP
14
15
UNITED STATES DISTRICT COURT
16
FOR THE CENTRAL DISTRICT OF CALIFORNIA
17
18 SWEET JAMES LLP,
Case No. 8:23-cv-01415-JWH-DFM
19 Plaintiff,
20 v. STIPULATED PROTECTIVE
ORDER
21 SWEET JUSTICE, P.C., and
RAFAEL CONTRERAS SWEET,
22
Defendants.
23
24
25 1. A. PURPOSES AND LIMITATIONS
26 Discovery in this action is likely to involve production of confidential,
27 proprietary or private information for which special protection from public disclosure
1 Accordingly, the parties hereby stipulate to and petition the Court to enter the
2 following Stipulated Protective Order. The parties acknowledge that this Order does
3 not confer blanket protections on all disclosures or responses to discovery and that
4 the protection it affords from public disclosure and use extends only to the limited
5 information or items that are entitled to confidential treatment under the applicable
6 legal principles.
7 B. GOOD CAUSE STATEMENT
8 This action is likely to involve trade secrets, customer and pricing lists and
9 other valuable commercial, financial, technical and/or proprietary information for
10 which special protection from public disclosure and from use for any purpose other
11 than prosecution of this action is warranted. Such confidential and proprietary
12 materials and information consist of, among other things, confidential business or
13 financial information, information regarding confidential business practices, or other
14 confidential commercial information (including information implicating privacy
15 rights of third parties), information otherwise generally unavailable to the public, or
16 which may be privileged or otherwise protected from disclosure under state or federal
17 statutes, court rules, case decisions, or common law. Accordingly, to expedite the
18 flow of information, to facilitate the prompt resolution of disputes over confidentiality
19 of discovery materials, to adequately protect information the parties are entitled to
20 keep confidential, to ensure that the parties are permitted reasonable necessary uses
21 of such material in preparation for and in the conduct of trial, to address their handling
22 at the end of the litigation, and serve the ends of justice, a protective order for such
23 information is justified in this matter. It is the intent of the parties that information
24 will not be designated as confidential for tactical reasons and that nothing be so
25 designated without a good faith belief that it has been maintained in a confidential,
26 non-public manner, and there is good cause why it should not be part of the public
27 record of this case.
1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
2 The parties further acknowledge, as set forth in Section 12.3, below, that this
3 Stipulated Protective Order does not entitle them to file confidential information
4 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
5 the standards that will be applied when a party seeks permission from the court to file
6 material under seal.
7 There is a strong presumption that the public has a right of access to judicial
8 proceedings and records in civil cases. In connection with non-dispositive motions,
9 good cause must be shown to support a filing under seal. See Kamakana v. City and
10 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
11 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,
12 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good
13 cause showing), and a specific showing of good cause or compelling reasons with
14 proper evidentiary support and legal justification, must be made with respect to
15 Protected Material that a party seeks to file under seal. The parties’ mere designation
16 of Disclosure or Discovery Material as CONFIDENTIAL or HIGHLY
17 CONFIDENTIAL – ATTORNEYS’ EYES ONLY does not—without the submission
18 of competent evidence by declaration, establishing that the material sought to be filed
19 under seal qualifies as confidential, privileged, or otherwise protectable—constitute
20 good cause.
21 Further, if a party requests sealing related to a dispositive motion or trial, then
22 compelling reasons, not only good cause, for the sealing must be shown, and the relief
23 sought shall be narrowly tailored to serve the specific interest to be protected. See
24 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
25 or type of information, document, or thing sought to be filed or introduced under seal
26 in connection with a dispositive motion or trial, the party seeking protection must
27 articulate compelling reasons, supported by specific facts and legal justification, for
1 the requested sealing order. Again, competent evidence supporting the application to
2 file documents under seal must be provided by declaration.
3 Any document that is not confidential, privileged, or otherwise protectable in
4 its entirety will not be filed under seal if the confidential portions can be redacted. If
5 documents can be redacted, then a redacted version for public viewing, omitting only
6 the confidential, privileged, or otherwise protectable portions of the document, shall
7 be filed. Any application that seeks to file documents under seal in their entirety
8 should include an explanation of why redaction is not feasible.
9 2. DEFINITIONS
10 2.1 Action: Sweet James LLP v. Sweet Justice, P.C. et al, Case No. 8:23-cv-
11 01415-JWH-DFM
12 2.2 Challenging Party: a Party or Non-Party that challenges the designation
13 of information or items under this Order.
14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
15 how it is generated, stored or maintained) or tangible things that qualify for protection
16 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
17 Cause Statement.
18 2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
19 Information or Items: This action requires a two-tiered, attorneys’ eyes only
20 protective order that designates certain material as “Highly Confidential – Attorneys’
21 Eyes Only.” Because the parties participate in the same industry, documents such as,
22 but not limited to, customer lists, advertising expenditures, and financial information,
23 are extremely sensitive business information that must remain confidential to avoid
24 one party gaining a competitive advantage over the other.
25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
26 support staff).
27 2.5 Designating Party: a Party or Non-Party that designates information or
1 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
2 ONLY.”
3 2.6 Disclosure or Discovery Material: all items or information, regardless of
4 the medium or manner in which it is generated, stored, or maintained (including,
5 among other things, testimony, transcripts, and tangible things), that are produced or
6 generated in disclosures or responses to discovery in this matter.
7 2.7 Expert: a person with specialized knowledge or experience in a matter
8 pertinent to the litigation who has been retained by a Party or its counsel to serve as
9 an expert witness or as a consultant in this Action.
10 2.8 House Counsel: attorneys who are employees of a party to this Action.
11 House Counsel does not include Outside Counsel of Record or any other outside
12 counsel.
13 2.9 Non-Party: any natural person, partnership, corporation, association or
14 other legal entity not named as a Party to this action.
15 2.10 Outside Counsel of Record: attorneys who are not employees of a party
16 to this Action but are retained to represent or advise a party to this Action and have
17 appeared in this Action on behalf of that party or are affiliated with a law firm that
18 has appeared on behalf of that party, and includes support staff.
19 2.11 Party: any party to this Action, including all of its officers, directors,
20 employees, consultants, retained experts, and Outside Counsel of Record (and their
21 support staffs).
22 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
23 Discovery Material in this Action.
24 2.13 Professional Vendors: persons or entities that provide litigation support
25 services (e.g., photocopying, videotaping, translating, preparing exhibits or
26 demonstrations, and organizing, storing, or retrieving data in any form or medium)
27 and their employees and subcontractors.
1 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
2 EYES ONLY.”
3 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
4 from a Producing Party.
5 3. SCOPE
6 The protections conferred by this Stipulation and Order cover not only
7 Protected Material (as defined above), but also (1) any information copied or extracted
8 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
9 Protected Material; and (3) any testimony, conversations, or presentations by Parties
10 or their Counsel that might reveal Protected Material.
11 Any use of Protected Material at trial shall be governed by the orders of the
12 trial judge. This Order does not govern the use of Protected Material at trial.
13 4. DURATION
14 FINAL DISPOSITION of the action is defined as the conclusion of any
15 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal
16 has run. Except as set forth below, the terms of this protective order apply through
17 FINAL DISPOSITION of the action. The parties may stipulate that they will be
18 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
19 but will have to file a separate action for enforcement of the agreement once all
20 proceedings in this case are complete.
21 Once a case proceeds to trial, information that was designated as
22 CONFIDENTIAL, designated as HIGHLY CONFIDENTIAL – ATTORNEYS’
23 EYES ONLY, or maintained pursuant to this protective order used or introduced as
24 an exhibit at trial becomes public and will be presumptively available to all members
25 of the public, including the press, unless compelling reasons supported by specific
26 factual findings to proceed otherwise are made to the trial judge in advance of the
27 trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for
1 merits-related documents are part of court record). Accordingly, for such materials,
2 the terms of this protective order do not extend beyond the commencement of the
3 trial.
4 5. DESIGNATING PROTECTED MATERIAL
5 5.1 Exercise of Restraint and Care in Designating Material for Protection.
6 Each Party or Non-Party that designates information or items for protection
7 under this Order must take care to limit any such designation to specific material that
8 qualifies under the appropriate standards. The Designating Party must designate for
9 protection only those parts of material, documents, items or oral or written
10 communications that qualify so that other portions of the material, documents, items
11 or communications for which protection is not warranted are not swept unjustifiably
12 within the ambit of this Order.
13 Mass, indiscriminate or routinized designations are prohibited. Designations
14 that are shown to be clearly unjustified or that have been made for an improper
15 purpose (e.g., to unnecessarily encumber the case development process or to impose
16 unnecessary expenses and burdens on other parties) may expose the Designating Party
17 to sanctions.
18 If it comes to a Designating Party’s attention that information or items that it
19 designated for protection do not qualify for protection, that Designating Party must
20 promptly notify all other Parties that it is withdrawing the inapplicable designation.
21 5.2 Manner and Timing of Designations. Except as otherwise provided in
22 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
23 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
24 under this Order must be clearly so designated before the material is disclosed or
25 produced.
26 Designation in conformity with this Order requires:
27 (a) for information in documentary form (e.g., paper or electronic
1 proceedings), that the Producing Party affix at a minimum, the legend
2 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
3 ONLY” as applicable (hereinafter “Confidentiality Legend”), to each page that
4 contains protected material. If only a portion of the material on a page qualifies for
5 protection, the Producing Party also must clearly identify the protected portion(s)
6 (e.g., by making appropriate markings in the margins).
7 A Party or Non-Party that makes original documents available for inspection
8 need not designate them for protection until after the inspecting Party has indicated
9 which documents it would like copied and produced. During the inspection and before
10 the designation, all of the material made available for inspection shall be deemed
11 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” After the inspecting
12 Party has identified the documents it wants copied and produced, the Producing Party
13 must determine which documents, or portions thereof, qualify for protection under
14 this Order. Then, before producing the specified documents, the Producing Party must
15 affix the “Confidentiality Legend” to each page that contains Protected Material. If
16 only a portion of the material on a page qualifies for protection, the Producing Party
17 also must clearly identify the protected portion(s) (e.g., by making appropriate
18 markings in the margins).
19 (b) for testimony given in depositions that the Designating Party identifies
20 the Disclosure or Discovery Material on the record, before the close of the deposition
21 all protected testimony.
22 (c) for information produced in some form other than documentary and for
23 any other tangible items, that the Producing Party affix in a prominent place on the
24 exterior of the container or containers in which the information is stored the
25 Confidentiality Legend. If only a portion or portions of the information warrants
26 protection, the Producing Party, to the extent practicable, shall identify the protected
27 portion(s).
1 failure to designate qualified information or items does not, standing alone, waive the
2 Designating Party’s right to secure protection under this Order for such material.
3 Upon timely correction of a designation, the Receiving Party must make reasonable
4 efforts to assure that the material is treated in accordance with the provisions of this
5 Order.
6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
8 designation of confidentiality at any time that is consistent with the Court’s
9 Scheduling Order.
10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
11 resolution process under Local Rule 37.1 et seq.
12 6.3 The burden of persuasion in any such challenge proceeding shall be on
13 the Designating Party. Frivolous challenges, and those made for an improper purpose
14 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
15 expose the Challenging Party to sanctions. Unless the Designating Party has waived
16 or withdrawn the confidentiality designation, all parties shall continue to afford the
17 material in question the level of protection to which it is entitled under the Producing
18 Party’s designation until the Court rules on the 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 Receiving
25 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
26 Protected Material must be stored and maintained by a Receiving Party at a
27 location and in a secure manner that ensures that access is limited to the persons
1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
2 otherwise ordered by the court or permitted in writing by the Designating Party, a
3 Receiving Party may disclose any information or item designated
4 “CONFIDENTIAL” only to:
5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
6 as employees of said Outside Counsel of Record to whom it is reasonably necessary
7 to disclose the information for this Action;
8 (b) the officers, directors, and employees (including House Counsel) of the
9 Receiving Party to whom disclosure is reasonably necessary for this Action;
10 (c) Experts (as defined in this Order) of the Receiving Party to whom
11 disclosure is reasonably necessary for this Action and who have signed the
12 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13 (d) the court and its personnel;
14 (e) court reporters and their staff;
15 (f) professional jury or trial consultants, mock jurors, and Professional
16 Vendors to whom disclosure is reasonably necessary for this Action and who have
17 signed the “Acknowledgment and Agreement to Be Bound” (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 information;
20 (h) during their depositions, witnesses, and attorneys for witnesses, in the
21 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
22 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
23 not be permitted to keep any confidential information unless they sign the
24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
25 agreed by the Designating Party or ordered by the court. Pages of transcribed
26 deposition testimony or exhibits to depositions that reveal Protected Material may be
27 separately bound by the court reporter and may not be disclosed to anyone except as
1 (i) any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions.
3 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
4 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in
5 writing by the Designating Party, a Receiving Party may disclose any information or
6 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only
7 to the persons identified in Paragraph 7.2(a), (c), (d), (e), (f), (g), or (i).
8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
9 OTHER LITIGATION
10 If a Party is served with a subpoena or a court order issued in other litigation
11 that compels disclosure of any information or items designated in this Action as
12 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
13 ONLY,” that Party must:
14 (a) promptly notify in writing the Designating Party. Such notification shall
15 include a copy of the subpoena or court order;
16 (b) promptly notify in writing the party who caused the subpoena or order
17 to issue in the other litigation that some or all of the material covered by the subpoena
18 or order is subject to this Protective Order. Such notification shall include a copy of
19 this Stipulated Protective Order; and
20 (c) cooperate with respect to all reasonable procedures sought to be pursued
21 by the Designating Party whose Protected Material may be affected.
22 If the Designating Party timely seeks a protective order, the Party served with
23 the subpoena or court order shall not produce any information designated in this action
24 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
25 ONLY” before a determination by the court from which the subpoena or order issued,
26 unless the Party has obtained the Designating Party’s permission. The Designating
27 Party shall bear the burden and expense of seeking protection in that court of its
1 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
2 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 by a Non-
6 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
7 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by
8 Non-Parties in connection with this litigation is protected by the remedies and relief
9 provided by this Order. Nothing in these provisions should be construed as prohibiting
10 a Non-Party from seeking additional protections.
11 (b) In the event that a Party is required, by a valid discovery request, to
12 produce a Non-Party’s confidential information in its possession, and the Party is
13 subject to an agreement with the Non-Party not to produce the Non-Party’s
14 confidential information, then the Party shall:
15 (1) promptly notify in writing the Requesting Party and the Non-Party
16 that some or all of the information requested is subject to a confidentiality agreement
17 with a Non-Party;
18 (2) promptly provide the Non-Party with a copy of the Stipulated
19 Protective Order in this Action, the relevant discovery request(s), and a reasonably
20 specific description of the information requested; and
21 (3) make the information requested available for inspection by the Non-
22 Party, if requested.
23 (c) If the Non-Party fails to seek a protective order from this court within 14
24 days of receiving the notice and accompanying information, the Receiving Party may
25 produce the Non-Party’s confidential information responsive to the discovery request.
26 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
27 any information in its possession or control that is subject to the confidentiality
1 order to the contrary, the Non-Party shall bear the burden and expense of seeking
2 protection in this court of its Protected 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 efforts
8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
9 persons to whom unauthorized disclosures were made of all the terms of this Order,
10 and (d) request such person or persons to execute the “Acknowledgment and
11 Agreement to Be Bound” that is attached hereto as Exhibit A.
12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
13 PROTECTED MATERIAL
14 When a Producing Party gives notice to Receiving Parties that certain
15 inadvertently produced material is subject to a claim of privilege or other protection,
16 the 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 procedure
18 may be established in an e-discovery order that provides for production without prior
19 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
20 parties reach an agreement on the effect of disclosure of a communication or
21 information covered by the attorney-client privilege or work product protection, the
22 parties may incorporate their agreement in the stipulated protective order submitted
23 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
1 disclosing or producing any information or item on any ground not addressed in this
2 Stipulated Protective Order. Similarly, no Party waives any right to object on any
3 ground to use in evidence of any of the material covered by this Protective Order.
4 12.3 Filing Protected Material. A Party that seeks to file under seal any
5 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
6 only be filed under seal pursuant to a court order authorizing the sealing of the specific
7 Protected Material at issue. If a Party’s request to file Protected Material under seal is
8 denied by the court, then the Receiving Party may file the information in the public
9 record unless otherwise instructed by the court.
10 13. FINAL DISPOSITION
11 After the final disposition of this Action, as defined in paragraph 4, within 60
12 days of a written request by the Designating Party, each Receiving Party must return
13 all Protected Material to the Producing Party or destroy such material. As used in this
14 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
15 summaries, and any other format reproducing or capturing any of the Protected
16 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
17 must submit a written certification to the Producing Party (and, if not the same person
18 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
19 category, where appropriate) all the Protected Material that was returned or destroyed
20 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
21 compilations, summaries or any other format reproducing or capturing any of the
22 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
23 archival copy of all pleadings, motion papers, trial, deposition, and hearing
24 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
25 reports, attorney work product, and consultant and expert work product, even if such
26 materials contain Protected Material. Any such archival copies that contain or
27 constitute Protected Material remain subject to this Protective Order as set forth in
1 |} 14. VIOLATION
2 || Any violation of this Order may be punished by appropriate measures including,
3 || without limitation, contempt proceedings and/or monetary sanctions.
4
5 IT IS SO ORDERED
6 DATED: June 18, 2024 L, + n_\>
4 Dougl: 3 F. McCormick
United States Magistrate Judge
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1 IT IS SO STIPULATED, BY AND THROUGH COUNSEL OF RECORD.
2
3 Dated: June 18, 2024 PIRKEY BARBER PLLC
4
By: /s/ Wendy C. Larson
5 Wendy C. Larson (Bar No. 235037)
Brandon M. Ress (Pro Hac Vice)
6
-and-
7
RUTAN & TUCKER, LLP
8 Ronald P. Oines (Bar No. 145016)
9 Attorneys for Plaintiff
10
11
Dated: June 18, 2024 THE KINDER LAW GROUP, APC
12
13 By: /s/ Brian P. Kinder (with permission)
Brian P. Kinder (Bar No. 212332)
14
Attorneys for Defendants
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of perjury that
6 I have read in its entirety and understand the Stipulated Protective Order that was
7 issued by the United States District Court for the Central District of California on
8 [date] in the case of Sweet James LLP v. Sweet Justice, P.C. et al, Case No. 8:23-cv-
9 01415-JWH-DFM. I agree to comply with and to be bound by all the terms of this
10 Stipulated Protective Order and I understand and acknowledge that failure to so
11 comply could expose me to sanctions and punishment in the nature of contempt. I
12 solemnly promise that I will not disclose in any manner any information or item that
13 is subject to this Stipulated Protective Order to any person or entity except in strict
14 compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of this
18 action. I hereby appoint __________________________ [print or type full name] of
19 _______________________________________ [print or type full address and
20 telephone number] as my California agent for service of process in connection with
21 this action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27