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
1 SEYFARTH SHAW LLP LAW OFFICES OF
Kathleen Cahill Slaught (SBN 168129) JONATHAN A. STIEGLITZ
2
kslaught@seyfarth.com Jonathan A. Stieglitz (SBN
3 560 Mission Street, 31st Floor 278028)
San Francisco, California 94105 jonathanstieglitz@gmail.com
4 Telephone: (415) 397-2823 11845 W. Olympic Blvd., Ste.
Facsimile: (415) 397-8549 800
5 Los Angeles, CA 90064
Ryan R. Tikker (SBN 312860) Tel: (323) 979-2063
6
rtikker@seyfarth.com Fax: (323) 488-6478
7 2029 Century Park East, Suite 3500
Los Angeles, California 90067 Attorneys for Plaintiffs
8 Telephone: (310) 277-7200 EMSURGCARE AND
Facsimile: (310) 201-5219 EMERGENCY SURGICAL
9 ASSISTANT
Attorneys for Defendant OXFORD
10
HEALTH INSURANCE, INC.
11
12
13
14
UNITED STATES DISTRICT COURT
15
CENTRAL DISTRICT OF CALIFORNIA
16
17 EMSURGCARE and
EMERGENCY SURGICAL Case No. 2:24-cv-04612-SVW-
18
ASSISTANT, SSC
19 Plaintiff(s),
v.
20 STIPULATED PROTECTIVE
OXFORD HEALTH ORDER1
21 INSURANCE, INC.
Defendant(s).
22
23 1. INTRODUCTION
24
25
26
27
1 This Stipulated Protective Order is substantially based on the model
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, proprietary, or private information for
3 which special protection from public disclosure and from use for any
4 purpose other than prosecuting this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the court to
6 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 confidential health information,
14
trade secrets, customer and pricing lists and other valuable research,
15
development, commercial, financial, and/or proprietary information for
16
which special protection from public disclosure and from use for any
17
purpose other than prosecution of this action is warranted. Such
18
confidential and proprietary materials and information consist of, among
19
other things, confidential health information, confidential business or
20
financial information, information regarding confidential business
21
practices, or other confidential research, development, or commercial
22
information (including information implicating privacy rights of third
23
parties), information otherwise generally unavailable to the public, or
24
which may be privileged or otherwise protected from disclosure under
25
state or federal statutes, court rules, case decisions, or common law.
26
Accordingly, to expedite the flow of information, to facilitate the prompt
27
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
8 designated without a good faith belief that it has been maintained in a
9 confidential, non-public manner, and there is good cause why it should
10 not be part of the public record of this case.
11
12 1.3 Acknowledgment of Procedure for Filing Under Seal. The
13 parties further acknowledge, as set forth in Section 12.3, below, that this
14 Stipulated Protective Order does not entitle them to file confidential
15 information under seal; Local Rule 79-5 sets forth the procedures that
16 must be followed and the standards that will be applied when a party
17 seeks permission from the court to file material under seal.
18
There is a strong presumption that the public has a right of access
19
to judicial proceedings and records in civil cases. In connection with
20
non-dispositive motions, good cause must be shown to support a filing
21
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
1 a party seeks to file under seal. The parties’ mere designation of
2 Disclosure or Discovery Material as CONFIDENTIAL does not—
3 without the submission of competent evidence by declaration,
4 establishing that the material sought to be filed under seal qualifies as
5 confidential, privileged, or otherwise protectable—constitute good cause.
6 Further, if a party requests sealing related to a dispositive motion
7 or trial, then compelling reasons, not only good cause, for the sealing
8
must be shown, and the relief sought shall be narrowly tailored to serve
9
the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
10
605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
11
information, document, or thing sought to be filed or introduced under
12
seal in connection with a dispositive motion or trial, the party seeking
13
protection must articulate compelling reasons, supported by specific
14
facts and legal justification, for the requested sealing order. Again,
15
competent evidence supporting the application to file documents under
16
seal must be provided by declaration.
17
Any document that is not confidential, privileged, or otherwise
18
protectable in its entirety will not be filed under seal if the confidential
19
portions can be redacted. If documents can be redacted, then a redacted
20
version for public viewing, omitting only the confidential, privileged, or
21
22 otherwise protectable portions of the document, shall be filed. Any
23 application that seeks to file documents under seal in their entirety
24 should include an explanation of why redaction is not feasible.
25
26 2. DEFINITIONS
27
2.1 Action: Emsurgcare and Emergency Surgical Assistant v.
1 Oxford Health Insurance, Inc., 2:24-cv-04612-SVW-SSC.
2 2.2 Challenging Party: a Party or Non-Party that challenges the
3 designation of information or items under this Order.
4 2.3 “CONFIDENTIAL” Information or Items: information
5 (regardless of how it is generated, stored or maintained) or tangible
6 things that qualify for protection under Rule 26(c) of the Federal Rules of
7 Civil Procedure, and as specified above in the Good Cause Statement.
8
2.4 Counsel: Outside Counsel of Record and House Counsel (as
9
well as their support staff).
10
2.5 Designating Party: a Party or Non-Party that designates
11
information or items that it produces in disclosures or in responses to
12
discovery as “CONFIDENTIAL.”
13
2.6 Disclosure or Discovery Material: all items or information,
14
regardless of the medium or manner in which it is generated, stored, or
15
maintained (including, among other things, testimony, transcripts, and
16
tangible things), that are produced or generated in disclosures or
17
responses to discovery in this matter.
18
2.7 Expert: a person with specialized knowledge or experience in
19
a matter pertinent to the litigation who has been retained by a Party or
20
its counsel to serve as an expert witness or as a consultant in this Action.
21
22 2.8 Final Disposition: the later of (1) dismissal of all claims and
23 defenses in this Action, with or without prejudice; and (2) final judgment
24 herein after the completion and exhaustion of all appeals, rehearings,
25 remands, trials, or reviews of this Action, including the time limits for
26 filing any motions or applications for extension of time pursuant to
27 applicable law.
1 this Action. In-House Counsel does not include Outside Counsel of
2 Record or any other outside counsel.
3 2.10 Non-Party: any natural person, partnership, corporation,
4 association, or other legal entity not named as a Party to this action.
5 2.11 Outside Counsel of Record: attorneys who are not employees
6 of a party to this Action but are retained to represent or advise a party to
7 this Action and have appeared in this Action on behalf of that party or
8
are affiliated with a law firm which has appeared on behalf of that party,
9
and includes support staff.
10
2.12 Party: any party to this Action, including all of its officers,
11
directors, employees, consultants, retained experts, and Outside Counsel
12
of Record (and their support staffs).
13
2.13 Producing Party: a Party or Non-Party that produces
14
Disclosure or Discovery Material in this Action.
15
2.14 Professional Vendors: persons or entities that provide
16
litigation- support services (e.g., photocopying, videotaping, translating,
17
preparing exhibits or demonstrations, and organizing, storing, or
18
retrieving data in any form or medium) and their employees and
19
subcontractors.
20
2.15 Protected Material: any Disclosure or Discovery Material that
21
22 is designated as “CONFIDENTIAL.”
23 2.16 Receiving Party: a Party that receives Disclosure or Discovery
24 Material from a Producing Party.
25
26 3. SCOPE
27
The protections conferred by this Stipulation and Order cover not
1 only Protected Material (as defined above), but also (1) any information
2 copied or extracted from Protected Material; (2) all copies, excerpts,
3 summaries, or compilations of Protected Material; and (3) any
4 testimony, conversations, or presentations by Parties or their Counsel
5 that might reveal Protected Material.
6 Any use of Protected Material at trial shall be governed by the
7 orders of the trial judge. This Stipulated Protective Order does not
8
govern the use of Protected Material at trial.
9
10
4. TRIAL AND DURATION
11
The terms of this Stipulated Protective Order apply through Final
12
Disposition of the Action.
13
14 Once a case proceeds to trial, information that was designated as
15 CONFIDENTIAL or maintained pursuant to this Stipulated Protective
16 Order and used or introduced as an exhibit at trial becomes public and
17 will be presumptively available to all members of the public, including
18 the press, unless compelling reasons supported by specific factual
19 findings to proceed otherwise are made to the trial judge in advance of
20 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good
21 cause” showing for sealing documents produced in discovery from
22 “compelling reasons” standard when merits-related documents are part
23
of court record). Accordingly, for such materials, the terms of this
24
Stipulated Protective Order do not extend beyond the commencement of
25
the trial.
26
Even after Final Disposition of this litigation, the confidentiality
27
obligations imposed by this Stipulated Protective Order shall remain in
1 effect until a Designating Party agrees otherwise in writing or a court
2 order otherwise directs.
3
4 5. DESIGNATING PROTECTED MATERIAL
5
5.1 Exercise of Restraint and Care in Designating Material for
6
Protection. Each Party or Non-Party that designates information or
7
items for protection under this Order must take care to limit any such
8
designation to specific material that qualifies under the appropriate
9
standards. The Designating Party must designate for protection only
10
those parts of material, documents, items, or oral or written
11
communications that qualify so that other portions of the material,
12
documents, items, or communications for which protection is not
13
warranted are not swept unjustifiably within the ambit of this Order.
14
Mass, indiscriminate, or routinized designations are prohibited.
15
Designations that are shown to be clearly unjustified or that have been
16
made for an improper purpose (e.g., to unnecessarily encumber the case
17
18 development process or to impose unnecessary expenses and burdens on
19 other parties) may expose the Designating Party to sanctions.
20 If it comes to a Designating Party’s attention that information or
21 items that it designated for protection do not qualify for protection, that
22 Designating Party must promptly notify all other Parties that it is
23 withdrawing the inapplicable designation.
24
5.2 Manner and Timing of Designations. Except as otherwise
25
provided in this Stipulated Protective Order (see, e.g., second paragraph
26
of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
27
or Discovery Material that qualifies for protection under this Stipulated
1 Protective Order must be clearly so designated before the material is
2 disclosed or produced.
3 Designation in conformity with this Stipulated Protective Order
4 requires:
5 (a) for information in documentary form (e.g., paper or electronic
6 documents, but excluding transcripts of depositions or other pretrial or
7 trial proceedings), that the Producing Party affix at a minimum, the
8
legend “CONFIDENTIAL” to each page that contains protected
9
material. If only a portion or portions of the material on a page
10
qualifies for protection, the Producing Party also must clearly identify
11
the protected portion(s) (e.g., by making appropriate markings in the
12
margins).
13
A Party or Non-Party that makes original documents available for
14
inspection need not designate them for protection until after the
15
inspecting Party has indicated which documents it would like copied
16
and produced. During the inspection and before the designation, all of
17
the material made available for inspection shall be deemed
18
CONFIDENTIAL. After the inspecting Party has identified the
19
documents it wants copied and produced, the Producing Party must
20
21 determine which documents, or portions thereof, qualify for protection
22 under this Stipulated Protective Order. Then, before producing the
23 specified documents, the Producing Party must affix the
24 “CONFIDENTIAL” legend to each page that contains Protected
25 Material. If only a portion or portions of the material on a page
26 qualifies for protection, the Producing Party also must clearly identify
27 the protected portion(s) (e.g., by making appropriate markings in the
1 (b) for testimony given in depositions that the Designating Party
2 identify the Disclosure or Discovery Material on the record, before the
3 close of the deposition all protected testimony.
4 (c) for information produced in some form other than
5 documentary and for any other tangible items, that the Producing Party
6 affix in a prominent place on the exterior of the container or containers
7 in which the information is stored the “CONFIDENTIAL” legend. If only
8
a portion or portions of the information warrants protection, the
9
Producing Party, to the extent practicable, shall identify the protected
10
portion(s).
11
5.3 Inadvertent Failures to Designate. If timely corrected, an
12
inadvertent failure to designate qualified information or items does not,
13
standing alone, waive the Designating Party’s right to secure protection
14
under this Order for such material. Upon timely correction of a
15
designation, the Receiving Party must make reasonable efforts to assure
16
that the material is treated in accordance with the provisions of this
17
18 Stipulated Protective Order.
19
20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
21 6.1 Timing of Challenges. Any Party or Non-Party may
22 challenge a designation of confidentiality at any time that is consistent
23
with the court’s Scheduling Order.
24
6.2 Meet and Confer. The Challenging Party shall initiate the
25
dispute resolution process under Local Rule 37.1 et seq. and with
26
Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-
27
1 Discovery Motion Conference.”2
2 6.3 The burden of persuasion in any such challenge proceeding
3 shall be on the Designating Party. Frivolous challenges, and those
4 made for an improper purpose (e.g., to harass or impose unnecessary
5 expenses and burdens on other parties) may expose the Challenging
6 Party to sanctions. Unless the Designating Party has waived or
7 withdrawn the confidentiality designation, all parties shall continue to
8
afford the material in question the level of protection to which it is
9
entitled under the Producing Party’s designation until the court rules on
10
the challenge.
11
12
7. ACCESS TO AND USE OF PROTECTED MATERIAL
13
7.1 Basic Principles. A Receiving Party may use Protected
14
Material that is disclosed or produced by another Party or by a Non-
15
Party in connection with this Action only for prosecuting, defending, or
16
17 attempting to settle this Action. Such Protected Material may be
18 disclosed only to the categories of persons and under the conditions
19 described in this Order. When the Action reaches a Final Disposition, a
20 Receiving Party must comply with the provisions of section 13 below.
21 Protected Material must be stored and maintained by a Receiving
22 Party at a location and in a secure manner that ensures that access is
23 limited to the persons authorized under this Stipulated Protective
24 Order.
25 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
26
27
2 Judge Christensen’s Procedures are available at
1 Unless otherwise ordered by the court or permitted in writing by the
2 Designating Party, a Receiving Party may disclose any information or
3 item designated “CONFIDENTIAL” only:
4 (a) to the Receiving Party’s Outside Counsel of Record in this
5 Action, as well as employees of said Outside Counsel of Record to whom
6 it is reasonably necessary to disclose the information for this Action;
7 (b) to the officers, directors, and employees (including House
8
Counsel) of the Receiving Party to whom disclosure is reasonably
9
necessary for this Action;
10
(c) to Experts (as defined in this Order) of the Receiving Party to
11
whom disclosure is reasonably necessary for this Action and who have
12
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13
(d) to the court and its personnel;
14
(e) to court reporters and their staff;
15
(f) to professional jury or trial consultants, mock jurors, and
16
Professional Vendors to whom disclosure is reasonably necessary for
17
this Action and who have signed the “Acknowledgment and Agreement
18
to Be Bound” (Exhibit A);
19
(g) to the author or recipient of a document containing the
20
information or a custodian or other person who otherwise possessed or
21
22 knew the information;
23 (h) during their depositions, to witnesses, and attorneys for
24 witnesses, in the Action to whom disclosure is reasonably necessary,
25 provided: (1) the deposing party requests that the witness sign the
26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
27 witness will not be permitted to keep any confidential information
1 (Exhibit A), unless otherwise agreed by the Designating Party or
2 ordered by the court. Pages of transcribed deposition testimony or
3 exhibits to depositions that reveal Protected Material may be separately
4 bound by the court reporter and may not be disclosed to anyone except
5 as permitted under this Stipulated Protective Order; and
6 (i) to any mediator or settlement officer, and their supporting
7 personnel, mutually agreed upon by any of the parties engaged in
8
settlement discussions.
9
10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
11 PRODUCED IN OTHER LITIGATION
12
If a Party is served with a subpoena or a court order issued in
13
other litigation that compels disclosure of any information or items
14
designated in this Action as “CONFIDENTIAL,” that Party must:
15
(a) promptly notify in writing the Designating Party. Such
16
notification shall include a copy of the subpoena or court order;
17
18 (b) promptly notify in writing the party who caused the
19 subpoena or order to issue in the other litigation that some or all of the
20 material covered by the subpoena or order is subject to this Protective
21 Order. Such notification shall include a copy of this Stipulated
22 Protective Order; and
23 (c) cooperate with respect to all reasonable procedures sought to
24 be pursued by the Designating Party whose Protected Material may be
25 affected.
26 If the Designating Party timely seeks a protective order, the
27
Party served with the subpoena or court order shall not produce any
1 information designated in this action as “CONFIDENTIAL” before a
2 determination by the court from which the subpoena or order issued,
3 unless the Party has obtained the Designating Party’s permission. The
4 Designating Party shall bear the burden and expense of seeking
5 protection in that court of its confidential material and nothing in these
6 provisions should be construed as authorizing or encouraging a
7 Receiving Party in this Action to disobey a lawful directive from another
8
court.
9
10
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
11
PRODUCED IN THIS LITIGATION
12
9.1 Application. The terms of this Stipulated Protective Order
13
are applicable to information produced by a Non-Party in this Action and
14
designated as “CONFIDENTIAL.” Such information produced by Non-
15
Parties in connection with this litigation is protected by the remedies
16
and relief provided by this Order. Nothing in these provisions should be
17
construed as prohibiting a Non-Party from seeking additional
18
protections.
19
9.2 Notification. In the event that a Party is required, by a valid
20
21 discovery request, to produce a Non-Party’s confidential information in
22 its possession, and the Party is subject to an agreement with the Non-
23 Party not to produce the Non-Party’s confidential information, then the
24 Party shall:
25 (a) promptly notify in writing the Requesting Party and the
26 Non-Party that some or all of the information requested is subject to a
27 confidentiality agreement with a Non-Party;
1 the Non-Party, if requested.
2 9.3 Conditions of Production. If the Non-Party fails to seek a
3 protective order from this court within 14 days of receiving the notice
4 and accompanying information, the Receiving Party may produce the
5 Non-Party’s confidential information responsive to the discovery request.
6 If the Non-Party timely seeks a protective order, the Receiving Party
7 shall not produce any information in its possession or control that is
8
subject to the confidentiality agreement with the Non-Party before a
9
determination by the court. Absent a court order to the contrary, the
10
Non-Party shall bear the burden and expense of seeking protection in
11
this court of its Protected Material.
12
13
10. UNAUTHORIZED DISCLOSURE OF PROTECTED
14
MATERIAL
15
If a Receiving Party learns that, by inadvertence or otherwise, it
16
17 has disclosed Protected Material to any person or in any circumstance
18 not authorized under this Stipulated Protective Order, the Receiving
19 Party must immediately (a) notify in writing the Designating Party of
20 the unauthorized disclosures, (b) use its best efforts to retrieve all
21 unauthorized copies of the Protected Material, (c) inform the person or
22 persons to whom unauthorized disclosures were made of all the terms of
23 this Order, and (d) request such person or persons to execute the
24 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
25
26
11. INADVERTENT PRODUCTION OF PRIVILEGED OR
27
OTHERWISE PROTECTED MATERIAL
1 When a Producing Party gives notice to Receiving Parties that
2 certain inadvertently produced material is subject to a claim of privilege
3 or other protection, the obligations of the Receiving Parties are those set
4 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
5 provision is not intended to modify whatever procedure may be
6 established in an e-discovery order that provides for production without
7 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
8
Rules of Evidence, insofar as the parties reach an agreement on the
9
effect of disclosure of a communication or information covered by the
10
attorney-client privilege or work product protection, the parties may
11
incorporate their agreement in the stipulated protective order
12
submitted to the court.
13
14
12. MISCELLANEOUS
15
12.1 Right to Further Relief. Nothing in this Stipulated
16
17 Protective Order abridges the right of any person to seek its
18 modification by the court in the future.
19 12.2 Right to Assert Other Objections. By stipulating to the entry
20 of this Stipulated Protective Order no Party waives any right it
21 otherwise would have to object to disclosing or producing any
22 information or item on any ground not addressed in this Stipulated
23 Protective Order. Similarly, no Party waives any right to object on any
24 ground to use in evidence of any of the material covered by this
25 Stipulated Protective Order.
26
12.3 Filing Protected Material. A Party that seeks to file under
27
seal any Protected Material must comply with Local Rule 79-5.
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
7 13. FINAL DISPOSITION
8
After the Final Disposition of this Action, as defined in paragraph
9
4, within 60 days of a written request by the Designating Party, each
10
Receiving Party must return all Protected Material to the Producing
11
Party or destroy such material. As used in this subdivision, “all
12
Protected Material” includes all copies, abstracts, compilations,
13
summaries, and any other format reproducing or capturing any of the
14
Protected Material. Whether the Protected Material is returned or
15
destroyed, the Receiving Party must submit a written certification to
16
the Producing Party (and, if not the same person or entity, to the
17
18 Designating Party) by the 60 day deadline that (1) identifies (by
19 category, where appropriate) all the Protected Material that was
20 returned or destroyed and (2) affirms that the Receiving Party has not
21 retained any copies, abstracts, compilations, summaries or any other
22 format reproducing or capturing any of the Protected Material.
23 Notwithstanding this provision, Counsel is entitled to retain an archival
24 copy of all pleadings, motion papers, trial, deposition, and hearing
25 transcripts, legal memoranda, correspondence, deposition and trial
26 exhibits, expert reports, attorney work product, and consultant and
27
expert work product, even if such materials contain Protected Material.
1 || Any such archival copies that contain or constitute Protected Material
2 || remain subject to this Protective Order as set forth in Section 4.
3
* || 14. VIOLATION
° Any violation of this Stipulated Protective Order may be punished
by any and all appropriate measures including, without limitation,
contempt proceedings and/or monetary sanctions.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
11
|| DATED:_Hebruary 18, 2025 /s/ Jonathan A. Stieglitz
Jonathan A. Stieglitz
14 Attorney(s) for Plaintiff(s)
15
16 || DATED: February 13, 2025 /s/ Kathleen Cahill Slaught
7 Kathleen Cahill Slaught
18 Ryan R. Tikker
19 Attorney(s) for Defendant(s)
20
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
°° DATED: February 14, 2025 BE
STEPHANIE S. CHRISTENSEN
25 United States Magistrate Judge
26
27
28
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
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27