The opinion
1 Tionna Carvalho (SBN 299010)
tcarvalho@slpattorney.com
2 Elizabeth A LaRocque (SBN 219977)
elarocque@slpattorney.com
3 STRATEGIC LEGAL PRACTICES, APC
1888 Century Park East, Floor 19
4 Los Angeles, CA 90067
Tel: (310)929-4900
5 Fax: (310)943-3838
Attorneys for Plaintiffs,
6 NICOLE MARIE STRANGE and
WILLIAM MICHAEL STRANGE
7
8 SPENCER P. HUGRET (SBN: 240424)
shugret@grsm.com
9 JEANETTE SUAREZ (SBN: 255141)
jsuarez@grsm.com
10 SARAH CARLSON LAMBERT (SBN: 247360)
slambert@grsm.com
11 GORDON REES SCULLY MANSUKHANI, LLP
315 Pacific Avenue
12 San Francisco, CA 94111
Telephone: (415) 986-5900
13 Facsimile: (415) 986-8054
Attorneys for Defendant
14 JAGUAR LAND ROVER NORTH AMERICA, LLC
15 UNITED STATES DISTRICT COURT
16 EASTERN DISTRICT OF CALIFORNIA
17
18 NICOLE MARIE STRANGE and ) No. 2:24-cv-0382 TLN DB
WILLIAM MICHAEL STRANGE, )
19 )
Plaintiffs, )
20 ) STIPULATED PROTECTIVE
21
vs.
)
ORDER – DISCOVERY ONLY
)
JAGUAR LAND ROVER NORTH
22 AMERICA LLC; and DOES 1 )
through 10, inclusive )
23 )
Defendants. )
24
25 1. PURPOSES AND LIMITATIONS
26 Disclosure and discovery activity in this action are likely to involve
27 production of confidential, proprietary, or private information for which special
1 prosecuting this litigation may be warranted. Accordingly, the parties hereby
2 stipulate to and petition the court to enter the following Stipulated Protective
3 Order. The parties acknowledge that this Order does not confer blanket protections
4 on all disclosures or responses to discovery and that the protection it affords from
5 public disclosure and use extends only to the limited information or items that are
6 entitled to confidential treatment under the applicable legal principles. The parties
7 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
8 Protective Order does not entitle them to file confidential information under seal;
9 Civil Local Rule 141 sets forth the procedures that must be followed and the
10 standards that will be applied when a party seeks permission from the court to file
11 material under seal.
12
13 2. DEFINITIONS
14 2.1 Challenging Party: a Party or Non-Party that challenges the
15 designation of information or items under this Order.
16 2.2 “CONFIDENTIAL” Information or Items: information (regardless of
17 how it is generated, stored or maintained) or tangible things that qualify for
18 protection under Federal Rule of Civil Procedure 26(c).
19 2.3 Counsel (without qualifier): Outside Counsel of Record and House
20 Counsel (as well as their support staff).
21 2.4 Designating Party: a Party or Non-Party that designates information
22 or items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL.”
24 2.5 Disclosure or Discovery Material: all items or information, regardless
25 of the medium or manner in which it is generated, stored, or maintained (including,
26 among other things, testimony, transcripts, and tangible things), that are produced
27 or generated in disclosures or responses to discovery in this matter.
1 2.6 Expert: a person with specialized knowledge or experience in a matter
2 pertinent to the litigation who has been retained by a Party or its counsel to serve
3 as an expert witness or as a consultant in this action.
4 2.7 House Counsel: attorneys who are employees of a party to this action.
5 House Counsel does not include Outside Counsel of Record or any other outside
6 counsel.
7 2.8 Non-Party: any natural person, partnership, corporation, association,
8 or other legal entity not named as a Party to this action.
9 2.9 Outside Counsel of Record: attorneys who are not employees of a
10 party to this action but are retained to represent or advise a party to this action and
11 have appeared in this action on behalf of that party or are affiliated with a law firm
12 which has appeared on behalf of that party.
13 2.10 Party: any party to this action, including all of its officers, directors,
14 employees, consultants, retained experts, and Outside Counsel of Record (and
15 their support staffs).
16 2.11 Producing Party: a Party or Non-Party that produces Disclosure or
17 Discovery Material in this action.
18 2.12 Professional Vendors: persons or entities that provide litigation
19 support services (e.g., photocopying, videotaping, translating, preparing exhibits
20 or demonstrations, and organizing, storing, or retrieving data in any form or
21 medium) and their employees and subcontractors.
22 2.13 Protected Material: any Disclosure or Discovery Material that is
23 designated as “CONFIDENTIAL.”
24 2.14 Receiving Party: a Party that receives Disclosure or Discovery
25 Material from a Producing Party.
26 //
27 //
//
1 3. SCOPE
2 The protections conferred by this Stipulation and 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 However, the protections conferred by this Stipulation and Order do not cover the
8 following information: (a) any information that is in the public domain at the time
9 of disclosure to a Receiving Party or becomes part of the public domain after its
10 disclosure to a Receiving Party as a result of publication not involving a violation
11 of this Order, including becoming part of the public record through trial or
12 otherwise; and (b) any information known to the Receiving Party prior to the
13 disclosure or obtained by the Receiving Party after the disclosure from a source
14 who obtained the information lawfully and under no obligation of confidentiality
15 to the Designating Party. Any use of Protected Material at trial shall be governed
16 by a separate agreement or order.
17
18 4. DURATION
19 Even after final disposition of this litigation, the confidentiality obligations
20 imposed by this Order shall remain in effect until a Designating Party agrees
21 otherwise in writing or a court order otherwise directs. Final disposition shall be
22 deemed to be the later of (1) dismissal of all claims and defenses in this action,
23 with or without prejudice; and (2) final judgment herein after the completion and
24 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
25 including the time limits for filing any motions or applications for extension of
26 time pursuant to applicable law.
27
1 5. DESIGNATING PROTECTED MATERIAL
2 5.1 Exercise of Restraint and Care in Designating Material for Protection.
3 Each Party or Non-Party that designates information or items for protection under
4 this Order must take care to limit any such designation to specific material that
5 qualifies under the appropriate standards. The Designating Party must designate
6 for protection only those parts of material, documents, items, or oral or written
7 communications that qualify – so that other portions of the material, documents,
8 items, or communications for which protection is not warranted are not swept
9 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 made for
12 an improper purpose (e.g., to unnecessarily encumber or retard the case
13 development process or to impose unnecessary expenses and burdens on other
14 parties) expose the Designating Party to sanctions.
15 If it comes to a Designating Party’s attention that information or items that
16 it designated for protection do not qualify for protection, that Designating Party
17 must promptly notify all other Parties that it is withdrawing the mistaken
18 designation.
19 5.2 Manner and Timing of Designations. Except as otherwise provided in
20 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
21 stipulated or ordered, Disclosure or Discovery Material that qualifies for
22 protection under this Order must be clearly so designated before the material is
23 disclosed or produced.
24 Designation in conformity with this Order requires:
25 (a) For information in documentary form (e.g., paper or electronic
26 documents, but excluding transcripts of depositions or other pretrial or trial
27 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to
each page that contains protected material. If only a portion or portions of the
1 material on a page qualifies for protection, the Producing Party also must clearly
2 identify the protected portion(s) (e.g., by making appropriate markings in the
3 margins).
4 A Party or Non-Party that makes original documents or materials available
5 for inspection need not designate them for protection until after the inspecting
6 Party has indicated which material it would like copied and produced. During the
7 inspection and before the designation, all of the material made available for
8 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
9 identified the documents it wants copied and produced, the Producing Party must
10 determine which documents, or portions thereof, qualify for protection under this
11 Order. Then, before producing the specified documents, the Producing Party must
12 affix the “CONFIDENTIAL” legend to each page that contains Protected
13 Material. If only a portion or portions of the material on a page qualifies for
14 protection, the Producing Party also must clearly identify the protected portion(s)
15 (e.g., by making appropriate markings in the margins).
16 (b) for testimony given in deposition or in other pretrial or trial
17 proceedings, that the Designating Party identify on the record, before the close of
18 the deposition, hearing, or other proceeding, all protected testimony.
19 (c) for information produced in some form other than documentary
20 and for any other tangible items, that the Producing Party affix in a prominent
21 place on the exterior of the container or containers in which the information or
22 item is stored the legend “CONFIDENTIAL.” If only a portion or portions of the
23 information or item warrant protection, the Producing Party, to the extent
24 practicable, shall identify the protected portion(s).
25 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
26 failure to designate qualified information or items does not, standing alone, waive
27 the Designating Party’s right to secure protection under this Order for such
material. Upon timely correction of a designation, the Receiving Party must make
1 reasonable efforts to assure that the material is treated in accordance with the
2 provisions of this Order.
3
4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
6 designation of confidentiality at any time. Unless a prompt challenge to a
7 Designating Party’s confidentiality designation is necessary to avoid foreseeable,
8 substantial unfairness, unnecessary economic burdens, or a significant disruption
9 or delay of the litigation, a Party does not waive its right to challenge a
10 confidentiality designation by electing not to mount a challenge promptly after the
11 original designation is disclosed.
12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
13 resolution process by providing written notice of each designation it is challenging
14 and describing the basis for each challenge. To avoid ambiguity as to whether a
15 challenge has been made, the written notice must recite that the challenge to
16 confidentiality is being made in accordance with this specific paragraph of the
17 Protective Order. The parties shall attempt to resolve each challenge in good faith
18 and must begin the process by conferring directly (in voice to voice dialogue; other
19 forms of communication are not sufficient) within 14 days of the date of service
20 of notice. In conferring, the Challenging Party must explain the basis for its belief
21 that the confidentiality designation was not proper and must give the Designating
22 Party an opportunity to review the designated material, to reconsider the
23 circumstances, and, if no change in designation is offered, to explain the basis for
24 the chosen designation. A Challenging Party may proceed to the next stage of the
25 challenge process only if it has engaged in this meet and confer process first or
26 establishes that the Designating Party is unwilling to participate in the meet and
27 confer process in a timely manner.
1 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without
2 court intervention, the Designating Party shall file and serve a motion to retain
3 confidentiality within 21 days of the initial notice of challenge or within 14 days
4 of the parties agreeing that the meet and confer process will not resolve their
5 dispute, whichever is earlier. Each such motion must be accompanied by a
6 competent declaration affirming that the movant has complied with the meet and
7 confer requirements imposed in the preceding paragraph. Failure by the
8 Designating Party to make such a motion including the required declaration within
9 21 days (or 14 days, if applicable) shall automatically waive the confidentiality
10 designation for each challenged designation. In addition, the Challenging Party
11 may file a motion challenging a confidentiality designation at any time if there is
12 good cause for doing so, including a challenge to the designation of a deposition
13 transcript or any portions thereof. Any motion brought pursuant to this provision
14 must be accompanied by a competent declaration affirming that the movant has
15 complied with the meet and confer requirements imposed by the preceding
16 paragraph.
17 The burden of persuasion in any such challenge proceeding shall be on the
18 Designating Party. Frivolous challenges, and those made for an improper purpose
19 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
20 expose the Challenging Party to sanctions. Unless the Designating Party has
21 waived the confidentiality designation by failing to file a motion to retain
22 confidentiality as described above, all parties shall continue to afford the material
23 in question the level of protection to which it is entitled under the Producing
24 Party’s designation until the court rules on the challenge.
25
26 7. ACCESS TO AND USE OF PROTECTED MATERIAL
27 7.1 Basic Principles. A Receiving Party may use Protected Material that
is disclosed or produced by another Party or by a Non-Party in connection with
1 this case only for prosecuting, defending, or attempting to settle this litigation.
2 Such Protected Material may be disclosed only to the categories of persons and
3 under the conditions described in this Order. When the litigation has been
4 terminated, a Receiving Party must comply with the provisions of section 13 below
5 (FINAL DISPOSITION).
6 Protected Material must be stored and maintained by a Receiving Party at a
7 location and in a secure manner that ensures that access is limited to the persons
8 authorized under this Order.
9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
10 otherwise ordered by the court or permitted in writing by the Designating Party, a
11 Receiving Party may disclose any information or item designated
12 “CONFIDENTIAL” only to:
13 (a) the Receiving Party’s Outside Counsel of Record in this action, as
14 well as employees of said Outside Counsel of Record to whom it is reasonably
15 necessary to disclose the information for this litigation and who have signed the
16 Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
17 A;
18 (b) the officers, directors, and employees (including House Counsel)
19 of the Receiving Party to whom disclosure is reasonably necessary for this
20 litigation and who have signed the “Acknowledgment and Agreement to Be
21 Bound” (Exhibit A);
22 (c) Experts (as defined in this Order) of the Receiving Party to whom
23 disclosure is reasonably necessary for this litigation and who have signed the
24 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (d) the court and its personnel;
26 (e) court reporters and their staff, professional jury or trial consultants,
27 mock jurors, and Professional Vendors to whom disclosure is reasonably
1 necessary for this litigation and who have signed the “Acknowledgment and
2 Agreement to Be Bound” (Exhibit A);
3 (f) during their depositions, witnesses in the action to whom disclosure
4 is reasonably necessary and who have signed the “Acknowledgment and
5 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
6 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits
7 to depositions that reveal Protected Material must be separately bound by the court
8 reporter and may not be disclosed to anyone except as permitted under this
9 Stipulated Protective Order.
10 (g) the author or recipient of a document containing the information
11 or a custodian or other person who otherwise possessed or knew the information.
12
13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
14 IN OTHER LITIGATION
15 If a Party is served with a subpoena or a court order issued in other litigation
16 that compels disclosure of any information or items designated in this action as
17 “CONFIDENTIAL,” that Party must:
18 (a) promptly notify in writing the Designating Party. Such notification
19 shall include a copy of the subpoena or court order;
20 (b) promptly notify in writing the party who caused the subpoena or
21 order to issue in the other litigation that some or all of the material covered by the
22 subpoena or order is subject to this Protective Order. Such notification shall
23 include a copy of this Stipulated Protective Order; and
24 (c) cooperate with respect to all reasonable procedures sought to be
25 pursued by the Designating Party whose Protected Material may be affected.
26 If the Designating Party timely seeks a protective order, the Party served
27 with the subpoena or court order shall not produce any information designated in
this action as “CONFIDENTIAL” before a determination by the court from which
1 the subpoena or order issued, unless the Party has obtained the Designating Party’s
2 permission. The Designating Party shall bear the burden and expense of seeking
3 protection in that court of its confidential material – and nothing in these
4 provisions should be construed as authorizing or encouraging a Receiving Party in
5 this action to disobey a lawful directive from another court.
6
7 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
8 PRODUCED IN THIS LITIGATION
9 (a) The terms of this Order are applicable to information produced by a Non-
10 Party in this action and designated as “CONFIDENTIAL.” Such information
11 produced by Non-Parties in connection with this litigation is protected by the
12 remedies and relief provided by this Order. Nothing in these provisions should be
13 construed as prohibiting a Non-Party from seeking additional protections.
14 (b) In the event that a Party is required, by a valid discovery request, to
15 produce a Non-Party’s confidential information in its possession, and the Party is
16 subject to an agreement with the Non-Party not to produce the Non-Party’s
17 confidential information, then the Party shall:
18 (1) promptly notify in writing the Requesting Party and the Non-Party
19 that some or all of the information requested is subject to a confidentiality
20 agreement with a Non-Party;
21 (2) promptly provide the Non-Party with a copy of the Stipulated
22 Protective Order in this litigation, the relevant discovery request(s), and a
23 reasonably specific description of the information requested; and
24 (3) make the information requested available for inspection by the
25 Non-Party.
26 (c) If the Non-Party fails to object or seek a protective order from this court
27 within 14 days of receiving the notice and accompanying information, the
Receiving Party may produce the Non-Party’s confidential information responsive
1 to the discovery request. If the Non-Party timely seeks a protective order, the
2 Receiving Party shall not produce any information in its possession or control that
3 is subject to the confidentiality agreement with the Non-Party before a
4 determination by the court. Absent a court order to the contrary, the Non-Party
5 shall bear the burden and expense of seeking protection in this court of its
6 Protected Material.
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8 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
9 If a Receiving Party learns that, by inadvertence or otherwise, it has
10 disclosed Protected Material to any person or in any circumstance not authorized
11 under this Stipulated Protective Order, the Receiving Party must immediately (a)
12 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
13 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
14 the person or persons to whom unauthorized disclosures were made of all the terms
15 of this Order, and (d) request such person or persons to execute the
16 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
17 A.
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19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
20 PROTECTED MATERIAL
21 When a Producing Party gives notice to Receiving Parties that certain
22 inadvertently produced material is subject to a claim of privilege or other
23 protection, the obligations of the Receiving Parties are those set forth in Federal
24 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
25 whatever procedure may be established in an e-discovery order that provides for
26 production without prior privilege review. Pursuant to Federal Rule of Evidence
27 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
of a communication or information covered by the attorney-client privilege or
1 work product protection, the parties may incorporate their agreement in the
2 stipulated protective order submitted to the court.
3
4 12. MISCELLANEOUS
5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
6 person to seek its modification by the court in the future.
7 12.2 Right to Assert Other Objections. By stipulating to the entry of this
8 Protective Order no Party waives any right it otherwise would have to object to
9 disclosing or producing any information or item on any ground not addressed in
10 this Stipulated Protective Order. Similarly, no Party waives any right to object on
11 any ground to use in evidence of any of the material covered by this Protective
12 Order.
13 12.3 Filing Protected Material. Without written permission from the
14 Designating Party or a court order secured after appropriate notice to all interested
15 persons, a Party may not file in the public record in this action any Protected
16 Material. A Party that seeks to file under seal any Protected Material must comply
17 with Local Rule 141. Protected Material may only be filed under seal pursuant to
18 a court order authorizing the sealing of the specific Protected Material at issue. A
19 sealing order will issue only upon a request establishing that the Protected Material
20 at issue is privileged, protectable as a trade secret, or otherwise entitled to
21 protection under the law. If a Receiving Party's request to file Protected Material
22 under seal is denied by the court, then the Receiving Party may file the information
23 in the public record unless otherwise instructed by the court.
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25 13. FINAL DISPOSITION
26 Upon final termination of this action, including any and all appeals, counsel
27 for each party must, upon request of the producing party, return all confidential
information to the party that produced the information, including any copies,
1 excerpts, and summaries of that information, or must destroy same at the option
2 of the receiving party, and must purge all such information from all machine-
3 readable media on which it resides. Notwithstanding the foregoing, counsel for
4 each party may retain all pleadings, briefs, memoranda, motions, and other
5 documents filed with the Court that refer to or incorporate confidential
6 information, and will continue to be bound by this Order with respect to all such
7 retained information. Further, attorney work product materials that contain
8 confidential information need not be destroyed, but, if they are not destroyed, the
9 person in possession of the attorney work product will continue to be bound by
10 this Order with respect to all such retained information.
11 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
12
DATED: June 20, 2024 STRATEGIC LEGAL PRACTICES, APC
13
14
BY: /s/ Elizabeth A. LaRocque
15 Tionna Carvalho
Elizabeth A. LaRocque
16 Attorneys for Plaintiffs,
NICOLE MARIE STRANGE and
17 WILLIAM MICHAEL STRANGE
18
DATED: June 18, 2024 GORDON REES SCULLY MASUKHANI, LLP
19
20 BY: /s/ Sarah Carlson Lambert ___________
Spencer P. Hugret
21 Jeanette Suarez
Sarah Carlson Lambert
22 Attorneys for Defendant,
LAND ROVER NORTH AMERICA, LLC
23
24 ////
25
26
27
1 ORDER
2 Pursuant to the parties’ stipulation, IT IS SO ORDERED.
3 IT IS FURTHER ORDERED THAT:
4 1. Requests to seal documents shall be made by motion before the same judge who will
5 decide the matter related to that request to seal.
6 2. The designation of documents (including transcripts of testimony) as confidential
7 pursuant to this order does not automatically entitle the parties to file such a document with the
8 court under seal. Parties are advised that any request to seal documents in this district is
9 governed by Local Rule 141. In brief, Local Rule 141 provides that documents may only be
10 sealed by a written order of the court after a specific request to seal has been made. L.R. 141(a).
11 However, a mere request to seal is not enough under the local rules. In particular, Local Rule
12 141(b) requires that “[t]he ‘Request to Seal Documents’ shall set forth the statutory or other
13 authority for sealing, the requested duration, the identity, by name or category, of persons to be
14 permitted access to the document, and all relevant information.” L.R. 141(b).
15 3. A request to seal material must normally meet the high threshold of showing that
16 “compelling reasons” support secrecy; however, where the material is, at most, “tangentially
17 related” to the merits of a case, the request to seal may be granted on a showing of “good cause.”
18 Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1096-1102 (9th Cir. 2016);
19 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1178-80 (9th Cir. 2006).
20 4. Nothing in this order shall limit the testimony of parties or non-parties, or the use of
21 certain documents, at any court hearing or trial – such determinations will only be made by the
22 court at the hearing or trial, or upon an appropriate motion.
23 5. With respect to motions regarding any disputes concerning this protective order which
24 the parties cannot informally resolve, the parties shall follow the procedures outlined in Local
25 Rule 251. Absent a showing of good cause, the court will not hear discovery disputes on an ex
26 parte basis or on shortened time.
27
1 6. The parties may not modify the terms of this Protective Order without the court’s
2 approval. If the parties agree to a potential modification, they shall submit a stipulation and
3 proposed order for the court’s consideration.
4 7. Pursuant to Local Rule 141.1(f), the court will not retain jurisdiction over enforcement
5 of the terms of this Protective Order after the action is terminated.
6 8. Any provision in the parties’ stipulation that is in conflict with anything in this order
7 is hereby DISAPPROVED.
8 DATED: June 21, 2024 /s/ DEBORAH BARNES
UNITED STATES MAGISTRATE JUDGE
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Eastern District of California
7 on [ ] in the case of Nicole Marie Strange and William Michael Strange v. Land
8 Rover North America, LLC; Case No.2:24-cv-00382-TLN-DB. I agree to comply
9 with and to be bound by all the terms of this Stipulated Protective Order and I
10 understand and acknowledge that failure to so comply could expose me to
11 sanctions and punishment in the nature of contempt. I solemnly promise that I will
12 not disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the
14 provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District
16 Court for the Eastern District of California for the purpose of enforcing the terms
17 of this Stipulated Protective Order, even if such enforcement proceedings occur
18 after termination of this action.
19 I hereby appoint __________________________ [print or type full name]
20 of _______________________________________ [print or type full address and
21 telephone number] as my California agent for service of process in connection
22 with this action or any proceedings related to enforcement of this Stipulated
23 Protective Order.
24 Date: ______________________________________
25 City and State where sworn and signed: __________________________
26 Printed name: _______________________________
Signature: __________________________________
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1 SIGNATURE ATTESTATION
2 Pursuant to Local Rule 131(e), I hereby attest that the other signatory to this document
3 has authorized submission of the document on her behalf.
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6 Dated: June 20, 2024 By: /s/ Elizabeth A. Larocque
Elizabeth A. LaRocque
7 Attorneys for Plaintiffs
NICOLE MARIE STRANGE and
8 WILLIAM MICHAEL STRANGE
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