Opinion

Jesson Calloway v. Richman Property Services, Inc.

Court: District Court, C.D. California
Filed: Sep 24, 2024
Cited by: 0 cases
Authority: More cited than 31.2%

even stipulated 25 protective orders require good cause showing

How later courts described this case

even stipulated 25 protective orders require good cause showing

Written by the judges who cited it.

The opinion

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

JESSON CALLOWAY,

Case No. 2:24-cv-04232-ODW-

6 JOSEPH GARCIA,

SSC

ANTOINETTE SPOLIANSKY,

ERIC LATTIMORE, SPENCER Hon. Stephanie S. Christensen

8 PASKACH, SAMBIDHAN

KHANIYA, and UPASANA

9 STIPULATED PROTECTIVE

PANDEY,

ORDER1

Plaintiff(s),

v. DISCOVERY MATTER

RICHMAN PROPERTY

SERVICES, INC. and DOES 1

14 through 10,

15 Defendant(s).

1 This Stipulated Protective Order is substantially based on the model

protective order provided under Magistrate Judge Stephanie S.

1 1. INTRODUCTION

2 1.1 Purposes and Limitations. Discovery in this action may

3 involve production of confidential, proprietary, or private information for

4 which special protection from public disclosure and from use for any

5 purpose other than prosecuting this litigation may be warranted.

6 Accordingly, the parties hereby stipulate to and petition the court to

7 enter the following Stipulated Protective Order. The parties

acknowledge that this Order does not confer blanket protections on all

disclosures or responses to discovery 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 applicable

legal principles.

1.2 Good Cause Statement.

This action is likely to involve trade secrets, customer and pricing

lists and other valuable research, development, commercial, financial,

technical and proprietary information for which special protection from

public disclosure and from use for any purpose other than prosecution of

this action is warranted. Such confidential and proprietary materials

and information consist of, among other things, confidential business or

financial information, information regarding confidential business

22 practices, or other confidential research, development, or commercial

23 information (including information implicating privacy rights of third

24 parties), information otherwise generally unavailable to the public, or

25 which may be privileged or otherwise protected from disclosure under

26 state or federal statutes, court rules, case decisions, or common law.

27 Accordingly, to expedite the flow of information, to facilitate the prompt

1 adequately protect information the parties are entitled to keep

2 confidential, to ensure that the parties are permitted reasonable

3 necessary uses of such material in preparation for and in the conduct of

4 trial, to address their handling at the end of the litigation, and serve the

5 ends of justice, a protective order for such information is justified in this

6 matter. It is the intent of the parties that information will not be

7 designated as confidential for tactical reasons and that nothing be so

designated without a good faith belief that it has been maintained in a

confidential, non-public manner, and there is good cause why it should

not be part of the public record of this case.

1.3 Acknowledgment of Procedure for Filing Under Seal. The

parties further acknowledge, as set forth in Section 12.3, below, that this

Stipulated Protective Order does not entitle them to file confidential

information under seal; Local Rule 79-5 sets forth the procedures that

must be followed and the standards that will be applied when a party

seeks permission from the court to file material under seal.

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

to judicial proceedings and records in civil cases. In connection with

non-dispositive motions, good cause must be shown to support a filing

under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d

22 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors

23 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony

24 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

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

26 good cause or compelling reasons with proper evidentiary support and

27 legal justification, must be made with respect to Protected Material that

1 Disclosure or Discovery Material as CONFIDENTIAL does not—

2 without the submission of competent evidence by declaration,

3 establishing that the material sought to be filed under seal qualifies as

4 confidential, privileged, or otherwise protectable—constitute good cause.

5 Further, if a party requests sealing related to a dispositive motion

6 or trial, then compelling reasons, not only good cause, for the sealing

7 must be shown, and the relief sought shall be narrowly tailored to serve

the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,

605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of

information, document, or thing sought to be filed or introduced under

seal in connection with a dispositive motion or trial, the party seeking

protection must articulate compelling reasons, supported by specific

facts and legal justification, for the requested sealing order. Again,

competent evidence supporting the application to file documents under

seal must be provided by declaration.

Any document that is not confidential, privileged, or otherwise

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

portions can be redacted. If documents can be redacted, then a redacted

version for public viewing, omitting only the confidential, privileged, or

otherwise protectable portions of the document, shall be filed. Any

22 application that seeks to file documents under seal in their entirety

23 should include an explanation of why redaction is not feasible.

24 2. DEFINITIONS

25 2.1 Action: Calloway et al. v. Richman Property Services, Inc.,

26 C.D. Cal. Case No. 2:24-cv-04232-ODW-SSC and Completo et al. v.

Richman Property Services, Inc., C.D. Cal. Case No. 2:24-cv-04233-ODW-

1 SSC. The parties further agree that this Stipulated Protective Order will

2 also apply to additional cases that Plaintiffs’ counsel has or will file

3 against Defendant relating to ICRAA.

4 2.2 Challenging Party: a Party or Non-Party that challenges the

5 designation of information or items under this Order.

6 2.3 “CONFIDENTIAL” Information or Items: information

7 (regardless of how it is generated, stored or maintained) or tangible

things that qualify for protection under Rule 26(c) of the Federal Rules of

Civil Procedure, and as specified above in the Good Cause Statement.

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

well as their support staff).

2.5 Designating Party: a Party or Non-Party that designates

information or items that it produces in disclosures or in responses to

discovery as “CONFIDENTIAL.”

2.6 Disclosure or Discovery Material: all items or information,

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

maintained (including, among other things, testimony, transcripts, and

tangible things), that are produced or generated in disclosures or

responses to discovery in this matter.

2.7 Expert: a person with specialized knowledge or experience in

22 a matter pertinent to the litigation who has been retained by a Party or

23 its counsel to serve as an expert witness or as a consultant in this Action.

24 2.8 Final Disposition: the later of (1) dismissal of all claims and

25 defenses in this Action, with or without prejudice; and (2) final judgment

26 herein after the completion and exhaustion of all appeals, rehearings,

27 remands, trials, or reviews of this Action, including the time limits for

1 applicable law.

2 2.9 In-House Counsel: attorneys who are employees of a party to

3 this Action. In-House Counsel does not include Outside Counsel of

4 Record or any other outside counsel.

5 2.10 Non-Party: any natural person, partnership, corporation,

6 association, or other legal entity not named as a Party to this action.

7 2.11 Outside Counsel of Record: attorneys who are not employees

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

this Action and have appeared in this Action on behalf of that party or

are affiliated with a law firm which has appeared on behalf of that party,

and includes support staff.

2.12 Party: any party to this Action, including all of its officers,

directors, employees, consultants, retained experts, and Outside Counsel

of Record (and their support staffs).

2.13 Producing Party: a Party or Non-Party that produces

Disclosure or Discovery Material in this Action.

2.14 Professional Vendors: persons or entities that provide

litigation- support services (e.g., photocopying, videotaping, translating,

preparing exhibits or demonstrations, and organizing, storing, or

retrieving data in any form or medium) and their employees and

22 subcontractors.

23 2.15 Protected Material: any Disclosure or Discovery Material that

24 is designated as “CONFIDENTIAL.”

25 2.16 Receiving Party: a Party that receives Disclosure or Discovery

26 Material from a Producing Party.

1 3. SCOPE

2 The protections conferred by this Stipulation and Order cover not

3 only Protected Material (as defined above), but also (1) any information

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

5 summaries, or compilations of Protected Material; and (3) any

6 testimony, conversations, or presentations by Parties or their Counsel

7 that might reveal Protected Material.

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

orders of the trial judge. This Stipulated Protective Order does not

govern the use of Protected Material at trial.

3.1 Tenant’s File Exclusion: For the purposes of this Stipulated

Protective Order, Plaintiffs represent that all documents contained in

each individual Plaintiff Tenant’s file, including the entirety of their

rental application, their lease agreement, and any Investigative

Consumer Report prepared about each Plaintiff, do not contain

CONFIDENTIAL information relating to Plaintiffs. Defendant has

expressed concerns that such information may, among other reasons,

implicate the privacy rights of parties and third parties, and should be

designated as CONFIDENTIAL, but will produce such information

without designation pursuant to this representation by Plaintiffs.

22 Notwithstanding this section, the Parties agree that all public filings will

23 comply with Federal Rule of Civil Procedure 5.2.

24 4. TRIAL AND DURATION

25 The terms of this Stipulated Protective Order apply through Final

26 Disposition of the Action.

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

1 Order and used or introduced as an exhibit at trial becomes public and

2 will be presumptively available to all members of the public, including

3 the press, unless compelling reasons supported by specific factual

4 findings to proceed otherwise are made to the trial judge in advance of

5 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good

6 cause” showing for sealing documents produced in discovery from

7 “compelling reasons” standard when merits-related documents are part

of court record). Accordingly, for such materials, the terms of this

Stipulated Protective Order do not extend beyond the commencement of

the trial.

Even after Final Disposition of this litigation, the confidentiality

obligations imposed by this Stipulated Protective Order shall remain in

effect until a Designating Party agrees otherwise in writing or a court

order otherwise directs.

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for

Protection. Each Party or Non-Party that designates information or

items for protection under this Order must take care to limit any such

designation to specific material that qualifies under the appropriate

standards. The Designating Party must designate for protection only

22 those parts of material, documents, items, or oral or written

23 communications that qualify so that other portions of the material,

24 documents, items, or communications for which protection is not

25 warranted are not swept unjustifiably within the ambit of this Order.

26 Mass, indiscriminate, or routinized designations are prohibited.

27 Designations that are shown to be clearly unjustified or that have been

1 development process or to impose unnecessary expenses and burdens on

2 other parties) may expose the Designating Party to sanctions.

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

4 items that it designated for protection do not qualify for protection, that

5 Designating Party must promptly notify all other Parties that it is

6 withdrawing the inapplicable designation.

7 5.2 Manner and Timing of Designations. Except as otherwise

provided in this Stipulated Protective Order (see, e.g., second paragraph

of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure

or Discovery Material that qualifies for protection under this Stipulated

Protective Order must be clearly so designated before the material is

disclosed or produced.

Designation in conformity with this Stipulated Protective Order

requires:

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

documents, but excluding transcripts of depositions or other pretrial or

trial proceedings), that the Producing Party affix at a minimum, the

legend “CONFIDENTIAL” to each page that contains protected

material. If only a portion or portions of the material on a page

qualifies for protection, the Producing Party also must clearly identify

22 the protected portion(s) (e.g., by making appropriate markings in the

23 margins).

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

25 inspection need not designate them for protection until after the

26 inspecting Party has indicated which documents it would like copied

27 and produced. During the inspection and before the designation, all of

1 CONFIDENTIAL. After the inspecting Party has identified the

2 documents it wants copied and produced, the Producing Party must

3 determine which documents, or portions thereof, qualify for protection

4 under this Stipulated Protective Order. Then, before producing the

5 specified documents, the Producing Party must affix the

6 “CONFIDENTIAL” legend to each page that contains Protected

7 Material. If only a portion or portions of the material on a page

qualifies for protection, the Producing Party also must clearly identify

the protected portion(s) (e.g., by making appropriate markings in the

margins).

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

identify the Disclosure or Discovery Material on the record, before the

close of the deposition all protected testimony.

documentary and for any other tangible items, that the Producing Party

affix in a prominent place on the exterior of the container or containers

in which the information is stored the “CONFIDENTIAL” legend. If only

a portion or portions of the information warrants protection, the

Producing Party, to the extent practicable, shall identify the protected

portion(s).

22 5.3 Inadvertent Failures to Designate. If timely corrected, an

23 inadvertent failure to designate qualified information or items does not,

24 standing alone, waive the Designating Party’s right to secure protection

25 under this Order for such material. Upon timely correction of a

26 designation, the Receiving Party must make reasonable efforts to assure

27 that the material is treated in accordance with the provisions of this

1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

2 6.1 Timing of Challenges. Any Party or Non-Party may

3 challenge a designation of confidentiality at any time that is consistent

4 with the court’s Scheduling Order.

5 6.2 Meet and Confer. The Challenging Party shall initiate the

6 dispute resolution process under Local Rule 37.1 et seq. and with

7 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-

Discovery Motion Conference.”2

6.3 The burden of persuasion in any such challenge proceeding

shall be on the Designating Party. Frivolous challenges, and those

made for an improper purpose (e.g., to harass or impose unnecessary

expenses and burdens on other parties) may expose the Challenging

Party to sanctions. Unless the Designating Party has waived or

withdrawn the confidentiality designation, all parties shall continue to

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

entitled under the Producing Party’s designation until the court rules on

the challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

7.1 Basic Principles. A Receiving Party may use Protected

Material that is disclosed or produced by another Party or by a Non-

22 Party in connection with this Action only for prosecuting, defending, or

23 attempting to settle this Action. Such Protected Material may be

24 disclosed only to the categories of persons and under the conditions

25 described in this Order. When the Action reaches a Final Disposition, a

2 Judge Christensen’s Procedures are available at

1 Receiving Party must comply with the provisions of section 13 below.

2 Protected Material must be stored and maintained by a Receiving

3 Party at a location and in a secure manner that ensures that access is

4 limited to the persons authorized under this Stipulated Protective

5 Order.

6 7.2 Disclosure of “CONFIDENTIAL” Information or Items.

7 Unless otherwise ordered by the court or permitted in writing by the

Designating Party, a Receiving Party may disclose any information or

item designated “CONFIDENTIAL” only:

(a) to the Receiving Party’s Outside Counsel of Record in this

Action, as well as employees of said Outside Counsel of Record to whom

it is reasonably necessary to disclose the information for this Action;

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

Counsel) of the Receiving Party to whom disclosure is reasonably

necessary for this Action;

whom disclosure is reasonably necessary for this Action and who have

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

(d) to the court and its personnel;

(e) to court reporters and their staff;

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

23 Professional Vendors to whom disclosure is reasonably necessary for

24 this Action and who have signed the “Acknowledgment and Agreement

25 to Be Bound” (Exhibit A);

26 (g) to the author or recipient of a document containing the

27 information or a custodian or other person who otherwise possessed or

1 (h) during their depositions, to witnesses, and attorneys for

2 witnesses, in the Action to whom disclosure is reasonably necessary,

3 provided: (1) the deposing party requests that the witness sign the

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

5 witness will not be permitted to keep any confidential information

6 unless they sign the “Acknowledgment and Agreement to Be Bound”

7 (Exhibit A), unless otherwise agreed by the Designating Party or

ordered by the court. Pages of transcribed deposition testimony or

exhibits to depositions that reveal Protected Material may be separately

bound by the court reporter and may not be disclosed to anyone except

as permitted under this Stipulated Protective Order; and

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

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

settlement discussions.

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

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

other litigation that compels disclosure of any information or items

designated in this Action as “CONFIDENTIAL,” that Party must:

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

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

23 (b) promptly notify in writing the party who caused the

24 subpoena or order to issue in the other litigation that some or all of the

25 material covered by the subpoena or order is subject to this Protective

26 Order. Such notification shall include a copy of this Stipulated

27 Protective Order; and

1 be pursued by the Designating Party whose Protected Material may be

2 affected.

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

4 Party served with the subpoena or court order shall not produce any

5 information designated in this action as “CONFIDENTIAL” before a

6 determination by the court from which the subpoena or order issued,

7 unless the Party has obtained the Designating Party’s permission. The

Designating Party shall bear the burden and expense of seeking

protection in that court of its confidential material and nothing in these

provisions should be construed as authorizing or encouraging a

Receiving Party in this Action to disobey a lawful directive from another

court.

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

PRODUCED IN THIS LITIGATION

9.1 Application. The terms of this Stipulated Protective Order

are applicable to information produced by a Non-Party in this Action and

designated as “CONFIDENTIAL.” Such information produced by Non-

Parties in connection with this litigation is protected by the remedies

and relief provided by this Order. Nothing in these provisions should be

construed as prohibiting a Non-Party from seeking additional

22 protections.

23 9.2 Notification. In the event that a Party is required, by a valid

24 discovery request, to produce a Non-Party’s confidential information in

25 its possession, and the Party is subject to an agreement with the Non-

26 Party not to produce the Non-Party’s confidential information, then the

27 Party shall:

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

2 confidentiality agreement with a Non-Party;

3 (b) make the information requested available for inspection by

4 the Non-Party, if requested.

5 9.3 Conditions of Production. If the Non-Party fails to seek a

6 protective order from this court within 14 days of receiving the notice

7 and accompanying information, the Receiving Party may produce the

Non-Party’s confidential information responsive to the discovery request.

If the Non-Party timely seeks a protective order, the Receiving Party

shall not produce any information in its possession or control that is

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

determination by the court. Absent a court order to the contrary, the

Non-Party shall bear the burden and expense of seeking protection in

this court of its Protected Material.

10. UNAUTHORIZED DISCLOSURE OF PROTECTED

MATERIAL

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

has disclosed Protected Material to any person or in any circumstance

not authorized under this Stipulated Protective Order, the Receiving

Party must immediately (a) notify in writing the Designating Party of

22 the unauthorized disclosures, (b) use its best efforts to retrieve all

23 unauthorized copies of the Protected Material, (c) inform the person or

24 persons to whom unauthorized disclosures were made of all the terms of

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

26 “Acknowledgment and Agreement to Be Bound” (Exhibit A).

1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR

2 OTHERWISE PROTECTED MATERIAL

3 When a Producing Party gives notice to Receiving Parties that

4 certain inadvertently produced material is subject to a claim of privilege

5 or other protection, the obligations of the Receiving Parties are those set

6 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This

7 provision is not intended to modify whatever procedure may be

established in an e-discovery order that provides for production without

prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal

Rules of Evidence, insofar as the parties reach an agreement on the

effect of disclosure of a communication or information covered by the

attorney-client privilege or work product protection, the parties may

incorporate their agreement in the stipulated protective order

submitted to the court.

12. MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Stipulated

Protective Order abridges the right of any person to seek its

modification by the court in the future.

12.2 Right to Assert Other Objections. By stipulating to the entry

of this Stipulated Protective Order no Party waives any right it

22 otherwise would have to object to disclosing or producing any

23 information or item on any ground not addressed in this Stipulated

24 Protective Order. Similarly, no Party waives any right to object on any

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

26 Stipulated Protective Order.

27 12.3 Filing Protected Material. A Party that seeks to file under

1 Protected Material may only be filed under seal pursuant to a court

2 order authorizing the sealing of the specific Protected Material at issue.

3 If a Party's request to file Protected Material under seal is denied by the

4 court, then the Receiving Party may file the information in the public

5 record unless otherwise instructed by the court.

6 13. FINAL DISPOSITION

7 After the Final Disposition of this Action, as defined in paragraph

4, within 60 days of a written request by the Designating Party, each

Receiving Party must return all Protected Material to the Producing

Party or destroy such material. As used in this subdivision, “all

Protected Material” includes all copies, abstracts, compilations,

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

Protected Material. Whether the Protected Material is returned or

destroyed, the Receiving Party must submit a written certification to

the Producing Party (and, if not the same person or entity, to the

Designating Party) by the 60 day deadline that (1) identifies (by

category, where appropriate) all the Protected Material that was

returned or destroyed and (2) affirms that the Receiving Party has not

retained any copies, abstracts, compilations, summaries or any other

format reproducing or capturing any of the Protected Material.

22 Notwithstanding this provision, Counsel is entitled to retain an archival

23 copy of all pleadings, motion papers, trial, deposition, and hearing

24 transcripts, legal memoranda, correspondence, deposition and trial

25 exhibits, expert reports, attorney work product, and consultant and

26 expert work product, even if such materials contain Protected Material.

27 Any such archival copies that contain or constitute Protected Material

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.

1 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

3 DATED: September 23, LITIGATION ADVOCACY GROUP

2024 /s/ Glenn A. Murphy

5 Glenn A. Murphy

6 Attorneys for Plaintiffs

7 DATED: September 23, BROD LAW FIRM, P.C.

8 2024

? /s/ Gregory J. Brod

10 Gregory J. Brod

11 Attorneys for Plaintiffs

12 DATED: September 23, MANATT, PHELPS & PHILLIPS, LLP

13 2024

By: _/s/ Benjamin E. Strauss

Is Robert H. Platt

16 Benjamin E. Strauss

Attorneys for Defendant

RICHMAN PROPERTY SERVICES,

18 INC.

SIGNATURE ATTESTATION

Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, Benjamin E. Strauss, attest

that all other signatories listed, and on whose behalf this filing is

submitted, concur in the filing’s content and have authorized the filing.

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

29 DATED: September 24, 2024 LZ ~

STEPHANIE 8S. CHRISTENSEN

27 United States Magistrate Judge

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ________________________ [print or type full name], of

_________________ [print or type full address], declare under

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

Stipulated Protective Order that was issued by the United States

District Court for the Central District of California on [date] in the

cases of Calloway et al. v. Richman Property Services, Inc., Case No.

2:24-cv-04232-ODW-SSC and Completo et al. v. Richman Property

Services, Inc., Case No. 2:24-cv-04233-ODW-SSC. I agree to comply

with and to be bound by all the terms of this Stipulated Protective

Order and I understand and acknowledge that failure to so comply

14 could expose me to sanctions and punishment in the nature of

15 contempt. I solemnly promise that I will not disclose in any manner

16 any information or item that is subject to this Stipulated Protective

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

18 provisions of this Order.

19 I further agree to submit to the jurisdiction of the United States

20 District Court for the Central District of California for the purpose of

21 enforcing the terms of this Stipulated Protective Order, even if such

22 enforcement proceedings occur after termination of this action. I

hereby appoint ________________________ [print or type full name]

of _________ [print or type full address and telephone number] as

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.

5 Date: ___________________________

6 City and State where sworn and

7 signed: ___________________________

Printed name: ___________________________

Signature: ___________________________

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.