even stipulated 24 protective orders require good cause showing
How later courts described this case
- even stipulated 24 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1
Teresa C. Senior, CA Bar No. 129316
2 Jeffrey B. Maltzman, CA Bar No. 131758
MALTZMAN & PARTNERS, PA
3 Physical Address: 2011 Palomar Airport Road, Suite 101
Carlsbad, CA 92011
4 Mailing Address: 55 Miracle Mile, Suite 320
Coral Gables, FL 33134
5
Telephone: (213) 330-0535
6 Facsimile: (213) 330-0534
E-mail: teresas@maltzmanpartners.com and
7 jeffreym@maltzmanpartners.com
8
Attorneys for Defendant, PRINCESS CRUISE LINES, LTD.
9
10 UNITED STATES DISTRICT COURT
11 CENTRAL DISTRICT OF CALIFORNIA
12
13 THERESA M. MEYER, an
Case No. 2:24-cv-01987-JLS-SSC
individual,
14
15 Plaintiff(s), STIPULATED PROTECTIVE
ORDER1
16 v.
17 Judge: Hon. Josephine L. Staton
PRINCESS CRUISE LINES, Mag, J.: Hon. Stephanie S.
18 LTD., DESTINATIONS NORTH Christensen
AMERICA LLC; AND
19 DESTINATIONS NORTH
AMERICA USA, INC.,
20
Defendant(s).
21
22
23
1. INTRODUCTION
24
25
26
1 This Stipulated Protective Order is substantially based on the model
27 protective order provided under Magistrate Judge Stephanie S.
1 1.1 Purposes and Limitations. Discovery in this action is likely to
2 involve production of confidential, trade secret and/or proprietary
3 information for which special protection from public disclosure and from
4 use for any purpose other than prosecuting this litigation may be
5 warranted. Accordingly, the parties hereby stipulate to and petition the
6 court to enter the following Stipulated Protective Order. The parties
7 acknowledge that this Order does not confer blanket protections on all
8
disclosures or responses to discovery and that the protection it affords
9
from public disclosure and use extends only to the limited information or
10
items that are entitled to confidential treatment under the applicable
11
legal principles.
12
1.2 Good Cause Statement.
13
This action is likely to involve trade secrets, customer and pricing
14
lists and other valuable research, development, commercial, financial,
15
technical and/or proprietary information for which special protection
16
from public disclosure and from use for any purpose other than
17
prosecution of this action is warranted. Such confidential and
18
proprietary materials and information consist of, among other things,
19
confidential business or financial information, information regarding
20
confidential business practices, or other confidential research,
21
22 development, or commercial information (including information
23 implicating privacy rights of third parties), information otherwise
24 generally unavailable to the public, or which may be privileged or
25 otherwise protected from disclosure under state or federal statutes, court
26 rules, case decisions, or common law. Accordingly, to expedite the flow of
27 information, to facilitate the prompt resolution of disputes over
1 the parties are entitled to keep confidential, to ensure that the parties
2 are permitted reasonable necessary uses of such material in preparation
3 for and in the conduct of trial, to address their handling at the end of the
4 litigation, and serve the ends of justice, a protective order for such
5 information is justified in this matter. It is the intent of the parties that
6 information will not be designated as confidential for tactical reasons
7 and that nothing be so designated without a good faith belief that it has
8
been maintained in a confidential, non-public manner, and there is good
9
cause why it should not be part of the public record of this case.
10
1.3 Acknowledgment of Procedure for Filing Under Seal. The
11
parties further acknowledge, as set forth in Section 12.3, below, that this
12
Stipulated Protective Order does not entitle them to file confidential
13
information under seal; Local Rule 79-5 sets forth the procedures that
14
must be followed and the standards that will be applied when a party
15
seeks permission from the court to file material under seal.
16
There is a strong presumption that the public has a right of access
17
to judicial proceedings and records in civil cases. In connection with
18
non-dispositive motions, good cause must be shown to support a filing
19
under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
20
1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
21
22 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
23 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
24 protective orders require good cause showing), and a specific showing of
25 good cause or compelling reasons with proper evidentiary support and
26 legal justification, must be made with respect to Protected Material that
27 a party seeks to file under seal. The parties’ mere designation of
1 without the submission of competent evidence by declaration,
2 establishing that the material sought to be filed under seal qualifies as
3 confidential, privileged, or otherwise protectable—constitute good cause.
4 Further, if a party requests sealing related to a dispositive motion
5 or trial, then compelling reasons, not only good cause, for the sealing
6 must be shown, and the relief sought shall be narrowly tailored to serve
7 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
8
605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
9
information, document, or thing sought to be filed or introduced under
10
seal in connection with a dispositive motion or trial, the party seeking
11
protection must articulate compelling reasons, supported by specific
12
facts and legal justification, for the requested sealing order. Again,
13
competent evidence supporting the application to file documents under
14
seal must be provided by declaration.
15
Any document that is not confidential, privileged, or otherwise
16
protectable in its entirety will not be filed under seal if the confidential
17
portions can be redacted. If documents can be redacted, then a redacted
18
version for public viewing, omitting only the confidential, privileged, or
19
otherwise protectable portions of the document, shall be filed. Any
20
application that seeks to file documents under seal in their entirety
21
22 should include an explanation of why redaction is not feasible.
23
24 2. DEFINITIONS
25 2.1 Action: this pending federal lawsuit.
26 2.2 Challenging Party: a Party or Non-Party that challenges the
27
designation of information or items under this Order.
1 2.3 “CONFIDENTIAL” Information or Items: information
2 (regardless of how it is generated, stored or maintained) or tangible
3 things that qualify for protection under Rule 26(c) of the Federal Rules of
4 Civil Procedure, and as specified above in the Good Cause Statement.
5 2.4 Counsel: Outside Counsel of Record and House Counsel (as
6 well as their support staff).
7 2.5 Designating Party: a Party or Non-Party that designates
8
information or items that it produces in disclosures or in responses to
9
discovery as “CONFIDENTIAL.”
10
2.6 Disclosure or Discovery Material: all items or information,
11
regardless of the medium or manner in which it is generated, stored, or
12
maintained (including, among other things, testimony, transcripts, and
13
tangible things), that are produced or generated in disclosures or
14
responses to discovery in this matter.
15
2.7 Expert: a person with specialized knowledge or experience in
16
a matter pertinent to the litigation who has been retained by a Party or
17
its counsel to serve as an expert witness or as a consultant in this Action.
18
2.8 Final Disposition: the later of (1) dismissal of all claims and
19
defenses in this Action, with or without prejudice; and (2) final judgment
20
herein after the completion and exhaustion of all appeals, rehearings,
21
22 remands, trials, or reviews of this Action, including the time limits for
23 filing any motions or applications for extension of time pursuant to
24 applicable law.
25 2.9 In-House Counsel: attorneys who are employees of a party to
26 this Action. In-House Counsel does not include Outside Counsel of
27 Record or any other outside counsel.
1 association, or other legal entity not named as a Party to this action.
2 2.11 Outside Counsel of Record: attorneys who are not employees
3 of a party to this Action but are retained to represent or advise a party to
4 this Action and have appeared in this Action on behalf of that party or
5 are affiliated with a law firm which has appeared on behalf of that party,
6 and includes support staff.
7 2.12 Party: any party to this Action, including all of its officers,
8
directors, employees, consultants, retained experts, and Outside Counsel
9
of Record (and their support staffs).
10
2.13 Producing Party: a Party or Non-Party that produces
11
Disclosure or Discovery Material in this Action.
12
2.14 Professional Vendors: persons or entities that provide
13
litigation- support services (e.g., photocopying, videotaping, translating,
14
preparing exhibits or demonstrations, and organizing, storing, or
15
retrieving data in any form or medium) and their employees and
16
subcontractors.
17
2.15 Protected Material: any Disclosure or Discovery Material that
18
is designated as “CONFIDENTIAL.”
19
2.16 Receiving Party: a Party that receives Disclosure or Discovery
20
Material from a Producing Party.
21
22
23 3. SCOPE
24 The protections conferred by this Stipulation and Order cover not
25 only Protected Material (as defined above), but also (1) any information
26 copied or extracted from Protected Material; (2) all copies, excerpts,
27
summaries, or compilations of Protected Material; and (3) any
1 testimony, conversations, or presentations by Parties or their Counsel
2 that might reveal Protected Material.
3 Any use of Protected Material at trial shall be governed by the
4 orders of the trial judge. This Stipulated Protective Order does not
5 govern the use of Protected Material at trial.
6
7 4. TRIAL AND DURATION
8
The terms of this Stipulated Protective Order apply through Final
9
Disposition of the Action.
10
Once a case proceeds to trial, information that was designated as
11
CONFIDENTIAL or maintained pursuant to this Stipulated Protective
12
Order and used or introduced as an exhibit at trial becomes public and
13
will be presumptively available to all members of the public, including
14
the press, unless compelling reasons supported by specific factual
15
findings to proceed otherwise are made to the trial judge in advance of
16
the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good
17
cause” showing for sealing documents produced in discovery from
18
“compelling reasons” standard when merits-related documents are part
19
of court record). Accordingly, for such materials, the terms of this
20
Stipulated Protective Order do not extend beyond the commencement of
21
the trial.
22
Even after Final Disposition of this litigation, the confidentiality
23
obligations imposed by this Stipulated Protective Order shall remain in
24
effect until a Designating Party agrees otherwise in writing or a court
25
order otherwise directs.
26
27
5. DESIGNATING PROTECTED MATERIAL
1 5.1 Exercise of Restraint and Care in Designating Material for
2 Protection. Each Party or Non-Party that designates information or
3 items for protection under this Order must take care to limit any such
4 designation to specific material that qualifies under the appropriate
5 standards. The Designating Party must designate for protection only
6 those parts of material, documents, items, or oral or written
7 communications that qualify so that other portions of the material,
8 documents, items, or communications for which protection is not
9 warranted are not swept unjustifiably within the ambit of this Order.
10 Mass, indiscriminate, or routinized designations are prohibited.
11 Designations that are shown to be clearly unjustified or that have been
12 made for an improper purpose (e.g., to unnecessarily encumber the case
13 development process or to impose unnecessary expenses and burdens on
14 other parties) may expose the Designating Party to sanctions.
15 If it comes to a Designating Party’s attention that information or items
16 that it designated for protection do not qualify for protection, that
17 Designating Party must promptly notify all other Parties that it is
18 withdrawing the inapplicable designation
19
20 5.2 Manner and Timing of Designations. Except as otherwise
21 provided in this Stipulated Protective Order (see, e.g., second paragraph
22 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
23 or Discovery Material that qualifies for protection under this Stipulated
24 Protective Order must be clearly so designated before the material is
25 disclosed or produced.
26 Designation in conformity with this Stipulated Protective Order
27 requires:
1 documents, but excluding transcripts of depositions or other pretrial or
2 trial proceedings), that the Producing Party affix at a minimum, the
3 legend “CONFIDENTIAL” to each page that contains protected
4 material. If only a portion or portions of the material on a page
5 qualifies for protection, the Producing Party also must clearly identify
6 the protected portion(s) (e.g., by making appropriate markings in the
7 margins).
8
A Party or Non-Party that makes original documents available for
9
inspection need not designate them for protection until after the
10
inspecting Party has indicated which documents it would like copied
11
and produced. During the inspection and before the designation, all of
12
the material made available for inspection shall be deemed
13
CONFIDENTIAL. After the inspecting Party has identified the
14
documents it wants copied and produced, the Producing Party must
15
determine which documents, or portions thereof, qualify for protection
16
under this Stipulated Protective Order. Then, before producing the
17
specified documents, the Producing Party must affix the
18
“CONFIDENTIAL” legend to each page that contains Protected
19
Material. If only a portion or portions of the material on a page
20
qualifies for protection, the Producing Party also must clearly identify
21
22 the protected portion(s) (e.g., by making appropriate markings in the
23 margins).
24 (b) for testimony given in depositions that the Designating Party
25 identify the Disclosure or Discovery Material on the record, before the
26 close of the deposition all protected testimony.
27 (c) for information produced in some form other than
1 affix in a prominent place on the exterior of the container or containers
2 in which the information is stored the “CONFIDENTIAL” legend. If only
3 a portion or portions of the information warrants protection, the
4 Producing Party, to the extent practicable, shall identify the protected
5 portion(s).
6
5.3 Inadvertent Failures to Designate. If timely corrected, an
7
inadvertent failure to designate qualified information or items does not,
8
standing alone, waive the Designating Party’s right to secure protection
9
under this Order for such material. Upon timely correction of a
10
designation, the Receiving Party must make reasonable efforts to assure
11
that the material is treated in accordance with the provisions of this
12
Stipulated Protective Order.
13
14
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
15
16 6.1 Timing of Challenges. Any Party or Non-Party may
17 challenge a designation of confidentiality at any time that is consistent
18 with the court’s Scheduling Order.
19 6.2 Meet and Confer. The Challenging Party shall initiate the
20 dispute resolution process under Local Rule 37.1 et seq. and with
21 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-
22 Discovery Motion Conference.”2
23
6.3 The burden of persuasion in any such challenge proceeding
24
shall be on the Designating Party. Frivolous challenges, and those
25
made for an improper purpose (e.g., to harass or impose unnecessary
26
27
2 Judge Christensen’s Procedures are available at
1 expenses and burdens on other parties) may expose the Challenging
2 Party to sanctions. Unless the Designating Party has waived or
3 withdrawn the confidentiality designation, all parties shall continue to
4 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
6 the challenge.
7
8
7. ACCESS TO AND USE OF PROTECTED MATERIAL
9
7.1 Basic Principles. A Receiving Party may use Protected
10
Material that is disclosed or produced by another Party or by a Non-
11
Party in connection with this Action only for prosecuting, defending, or
12
attempting to settle this Action. Such Protected Material may be
13
disclosed only to the categories of persons and under the conditions
14
described in this Order. When the Action reaches a Final Disposition, a
15
Receiving Party must comply with the provisions of section 13 below.
16
17 Protected Material must be stored and maintained by a Receiving
18 Party at a location and in a secure manner that ensures that access is
19 limited to the persons authorized under this Stipulated Protective
20 Order.
21 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
22 Unless otherwise ordered by the court or permitted in writing by the
23 Designating Party, a Receiving Party may disclose any information or
24 item designated “CONFIDENTIAL” only:
25 (a) to the Receiving Party’s Outside Counsel of Record in this
26
Action, as well as employees of said Outside Counsel of Record to whom
27
it is reasonably necessary to disclose the information for this Action;
1 (b) to the officers, directors, and employees (including House
2 Counsel) of the Receiving Party to whom disclosure is reasonably
3 necessary for this Action;
4 (c) to Experts (as defined in this Order) of the Receiving Party to
5 whom disclosure is reasonably necessary for this Action and who have
6 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
7 (d) to the court and its personnel;
8
(e) to court reporters and their staff;
9
(f) to professional jury or trial consultants, mock jurors, and
10
Professional Vendors to whom disclosure is reasonably necessary for
11
this Action and who have signed the “Acknowledgment and Agreement
12
to Be Bound” (Exhibit A);
13
(g) to the author or recipient of a document containing the
14
information or a custodian or other person who otherwise possessed or
15
knew the information;
16
(h) during their depositions, to witnesses, and attorneys for
17
witnesses, in the Action to whom disclosure is reasonably necessary,
18
provided: (1) the deposing party requests that the witness sign the
19
“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
20
witness will not be permitted to keep any confidential information
21
22 unless they sign the “Acknowledgment and Agreement to Be Bound”
23 (Exhibit A), unless otherwise agreed by the Designating Party or
24 ordered by the court. Pages of transcribed deposition testimony or
25 exhibits to depositions that reveal Protected Material may be separately
26 bound by the court reporter and may not be disclosed to anyone except
27 as permitted under this Stipulated Protective Order; and
1 personnel, mutually agreed upon by any of the parties engaged in
2 settlement discussions.
3
4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
5 PRODUCED IN OTHER LITIGATION
6
If a Party is served with a subpoena or a court order issued in
7
other litigation that compels disclosure of any information or items
8
designated in this Action as “CONFIDENTIAL,” that Party must:
9
(a) promptly notify in writing the Designating Party. Such
10
notification shall include a copy of the subpoena or court order;
11
(b) promptly notify in writing the party who caused the
12
subpoena or order to issue in the other litigation that some or all of the
13
14 material covered by the subpoena or order is subject to this Protective
15 Order. Such notification shall include a copy of this Stipulated
16 Protective Order; and
17 (c) cooperate with respect to all reasonable procedures sought to
18 be pursued by the Designating Party whose Protected Material may be
19 affected.
20 If the Designating Party timely seeks a protective order, the
21 Party served with the subpoena or court order shall not produce any
22 information designated in this action as “CONFIDENTIAL” before a
23
determination by the court from which the subpoena or order issued,
24
unless the Party has obtained the Designating Party’s permission. The
25
Designating Party shall bear the burden and expense of seeking
26
protection in that court of its confidential material and nothing in these
27
provisions should be construed as authorizing or encouraging a
1 Receiving Party in this Action to disobey a lawful directive from another
2 court.
3
4 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
5 PRODUCED IN THIS LITIGATION
6 9.1 Application. The terms of this Stipulated Protective Order
7 are applicable to information produced by a Non-Party in this Action and
8
designated as “CONFIDENTIAL.” Such information produced by Non-
9
Parties in connection with this litigation is protected by the remedies
10
and relief provided by this Order. Nothing in these provisions should be
11
construed as prohibiting a Non-Party from seeking additional
12
protections.
13
9.2 Notification. In the event that a Party is required, by a valid
14
discovery request, to produce a Non-Party’s confidential information in
15
its possession, and the Party is subject to an agreement with the Non-
16
Party not to produce the Non-Party’s confidential information, then the
17
Party shall:
18
(a) promptly notify in writing the Requesting Party and the
19
Non-Party that some or all of the information requested is subject to a
20
21 confidentiality agreement with a Non-Party;
22 (b) make the information requested available for inspection by
23 the Non-Party, if requested.
24 9.3 Conditions of Production. If the Non-Party fails to seek a
25 protective order from this court within 14 days of receiving the notice
26 and accompanying information, the Receiving Party may produce the
27 Non-Party’s confidential information responsive to the discovery request.
1 shall not produce any information in its possession or control that is
2 subject to the confidentiality agreement with the Non-Party before a
3 determination by the court. Absent a court order to the contrary, the
4 Non-Party shall bear the burden and expense of seeking protection in
5 this court of its Protected Material.
6
7 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
8
MATERIAL
9
If a Receiving Party learns that, by inadvertence or otherwise, it
10
has disclosed Protected Material to any person or in any circumstance
11
not authorized under this Stipulated Protective Order, the Receiving
12
Party must immediately (a) notify in writing the Designating Party of
13
the unauthorized disclosures, (b) use its best efforts to retrieve all
14
unauthorized copies of the Protected Material, (c) inform the person or
15
persons to whom unauthorized disclosures were made of all the terms of
16
17 this Order, and (d) request such person or persons to execute the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
19
20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
21 OTHERWISE PROTECTED MATERIAL
22
When a Producing Party gives notice to Receiving Parties that
23
certain inadvertently produced material is subject to a claim of privilege
24
or other protection, the obligations of the Receiving Parties are those set
25
forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
26
provision is not intended to modify whatever procedure may be
27
1 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
2 Rules of Evidence, insofar as the parties reach an agreement on the
3 effect of disclosure of a communication or information covered by the
4 attorney-client privilege or work product protection, the parties may
5 incorporate their agreement in the stipulated protective order
6 submitted to the court.
7
8
12. MISCELLANEOUS
9
12.1 Right to Further Relief. Nothing in this Stipulated
10
Protective Order abridges the right of any person to seek its
11
modification by the court in the future.
12
12.2 Right to Assert Other Objections. By stipulating to the entry
13
of this Stipulated Protective Order no Party waives any right it
14
otherwise would have to object to disclosing or producing any
15
information or item on any ground not addressed in this Stipulated
16
17 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
19 Stipulated Protective Order.
20 12.3 Filing Protected Material. A Party that seeks to file under
21 seal any Protected Material must comply with Local Rule 79-5.
22 Protected Material may only be filed under seal pursuant to a court
23 order authorizing the sealing of the specific Protected Material at issue.
24 If a Party's request to file Protected Material under seal is denied by the
25 court, then the Receiving Party may file the information in the public
26
record unless otherwise instructed by the court.
27
1 13. FINAL DISPOSITION
2 After the Final Disposition of this Action, as defined in paragraph
3 4, within 60 days of a written request by the Designating Party, each
4
Receiving Party must return all Protected Material to the Producing
5
Party or destroy such material. As used in this subdivision, “all
6
Protected Material” includes all copies, abstracts, compilations,
7
summaries, and any other format reproducing or capturing any of the
8
Protected Material. Whether the Protected Material is returned or
9
destroyed, the Receiving Party must submit a written certification to
10
the Producing Party (and, if not the same person or entity, to the
11
Designating Party) by the 60 day deadline that (1) identifies (by
12
category, where appropriate) all the Protected Material that was
13
returned or destroyed and (2) affirms that the Receiving Party has not
14
retained any copies, abstracts, compilations, summaries or any other
15
format reproducing or capturing any of the Protected Material.
16
Notwithstanding this provision, Counsel is entitled to retain an archival
17
18 copy of all pleadings, motion papers, trial, deposition, and hearing
19 transcripts, legal memoranda, correspondence, deposition and trial
20 exhibits, expert reports, attorney work product, and consultant and
21 expert work product, even if such materials contain Protected Material.
22 Any such archival copies that contain or constitute Protected Material
23 remain subject to this Protective Order as set forth in Section 4.
24
25
26
27
1 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished
3 by any and all appropriate measures including, without limitation,
4 contempt proceedings and/or monetary sanctions.
5
6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8
CONLOGUE LAW, LLP
9
10
11 By: / s / Kevin S. Conlogue
12 Kevin S. Conlogue
Attorneys for Plaintiff
13
THERESA M. MEYER
14
15
16 MALTZMAN & PARTNERS, PA
17
18
By: / s / Teresa C. Senior
19
Jeffrey B. Maltzman (Board Certified
20 Legal Specialist in Admiralty &
21 Maritime Law)
Teresa C. Senior
22
Attorneys for Defendant
23 PRINCESS CRUISE LINES, LTD.
24
25
26
27
1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2 Z—
3 DATED: August 9, 2024
4 STEPHANIE 8S. CHRISTENSEN
5 United States Magistrate Judge
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1]
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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
5
penalty of perjury that I have read in its entirety and understand the
6
Stipulated Protective Order that was issued by the United States
7
District Court for the Central District of California on [date] in the
8
case of __________ [insert formal name of the case and the
9
number and initials assigned to it by the court]. I agree to
10
comply with and to be bound by all the terms of this Stipulated
11
Protective Order and I understand and acknowledge that failure to so
12
comply could expose me to sanctions and punishment in the nature of
13
14 contempt. I solemnly promise that I will not disclose in any manner
15 any information or item that is subject to this Stipulated Protective
16 Order to any person or entity except in strict compliance with the
17 provisions of this Order.
18 I further agree to submit to the jurisdiction of the United States
19 District Court for the Central District of California for the purpose of
20 enforcing the terms of this Stipulated Protective Order, even if such
21 enforcement proceedings occur after termination of this action. I
22 hereby appoint ________________________ [print or type full name]
23
of _________ [print or type full address and telephone number] as
24
25
26
27
1 my California agent for service of process in connection with this action
2 or any proceedings related to enforcement of this Stipulated Protective
3 Order.
4
5 Date: ___________________________
6 City and State where sworn and
7 signed: ___________________________
8
Printed name: ___________________________
9
Signature: ___________________________
10
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