The opinion
1 KHAI LEQUANG (STATE BAR NO. 202922)
klequang@orrick.com
2 RICHARD W. KREBS (STATE BAR NO. 278701)
rkrebs@orrick.com
3 ORRICK, HERRINGTON & SUTCLIFFE LLP
2050 Main Street
4 Suite 1100 NOTE: CHANGES MADE BY THE COURT
Irvine, CA 92614-8255
5 Telephone: +1 949 567 6700
6 Attorneys for Plaintiff LIFE OPPORTUNITY
FUND I, LP
7
8
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
12 LIFE OPPORTUNITY FUND I, LP, Case No. 2:24-cv-09016-JAK (JPRx)
13 Plaintiff, STIPULATED PROTECTIVE
ORDER
14 v.
(DISCOVERY MATTER)
15 EVELYN FELICIANO,
16 Defendant.
17
18
19
20
21
22
23
24
25
26
27
28
1 1. INTRODUCTION
2 1.1 PURPOSES AND LIMITATIONS
3 Discovery in this action may involve production of confidential, proprietary,
4 or private information for which special protection from public disclosure and from
5 use for any purpose other than prosecuting this litigation may be warranted.
6 Accordingly, the Parties hereby stipulate to and petition the Court to enter the
7 following Stipulated Protective Order. The Parties acknowledge that this Order does
8 not confer blanket protections on all disclosures or responses to discovery and that
9 the protection it affords applies only to specific categories of documents and
10 information that contain confidential, proprietary, or legally protected materials. The
11 burden of establishing confidentiality rests solely with the Designating Party, who
12 must demonstrate good cause under applicable legal principles. The Parties further
13 acknowledge, as set forth in Section 12.3 below, that this Order does not entitle them
14 to file Confidential Information under seal; rather, the Designating Party must
15 establish compelling reasons for such sealing under applicable law, including Civil
16 Local Rule 79-5 and Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172 (9th Cir.
17 2006). Blanket confidentiality designations shall not justify sealing.
18 1.2 GOOD CAUSE STATEMENT
19 This action is likely to involve the exchange of documents and information
20 reflecting private medical and financial information, as well as proprietary, non-
21 public information regarding business practices and trade secrets for which special
22 protection from public disclosure and from use for any purpose other than
23 prosecution of this action is warranted. Such confidential and proprietary materials
24 and information may consist of, among other things, confidential business or
25 financial information, information regarding confidential business practices, or other
26 confidential research, development, or commercial information (including
27 information implicating privacy rights of third parties), information otherwise
28 generally unavailable to the public, or which may be privileged or otherwise
1 protected from disclosure under state or federal statutes, court rules, case decisions,
2 or common law. Accordingly, to expedite the flow of information, to facilitate the
3 prompt resolution of disputes over confidentiality of discovery materials, to
4 adequately protect information the parties are entitled to keep confidential, to ensure
5 that the parties are permitted reasonable necessary uses of such material in
6 preparation for and in the conduct of trial, to address their handling at the end of the
7 litigation, and serve the ends of justice, a protective order for such information is
8 justified in this matter. It is the intent of the parties that information will not be
9 designated as confidential for tactical, strategic, or obstructive purposes, and that no
10 material shall be designated as confidential without a reasonable, good faith belief
11 that such information is legally protected, not publicly available, and necessary to
12 prevent specific harm from disclosure.
13 2. DEFINITIONS
14 2.1 Action: Life Opportunity Fund I, LP v. Evelyn Feliciano, Case No. 2:24-
15 cv-09016-JAK-JPR.
16 2.1 Challenging Party: A Party or Nonparty that challenges the designation
17 of information or items under this Order. The Challenging Party shall not be required
18 to prove that the designation is improper; rather, the burden shall be on the
19 Designating Party to establish the basis for confidentiality. Frivolous challenges, and
20 those made for an improper purpose (for example, to harass or impose unnecessary
21 expenses and burdens on other parties), may expose the Challenging Party to
22 sanctions.
23 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of
24 how it is generated, stored, or maintained) or tangible things that qualify for
25 protection under Federal Rule of Civil Procedure 26(c) and as specified above in the
26 Good Cause Statement. Confidentiality shall not be asserted over documents that are
27 publicly available, contain general business practices, or are otherwise not legally
28 protected. Indiscriminate or routinized designations are prohibited.
1 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
2 their support staff).
3 2.5 Designating Party: A Party or Nonparty that designates information or
4 items that it produces in disclosures or in responses to discovery as
5 “CONFIDENTIAL.” Any such designation must be made in good faith and must be
6 narrowly tailored to include only material that qualifies for protection. Designations
7 that are shown to be clearly unjustified or that have been made for an improper
8 purpose (for example, to unnecessarily encumber the case-development process or to
9 impose unnecessary expenses and burdens on other parties) may expose the
10 Designating Party to sanctions.
11 2.6 Disclosure or Discovery Material: all items or information, regardless
12 of the medium or manner in which it is generated, stored, or maintained (including,
13 among other things, testimony, transcripts, and tangible things), that are produced or
14 generated in disclosures or responses to discovery in this matter.
15 2.7 Expert: a person with specialized knowledge or experience in a matter
16 pertinent to the litigation who has been retained by a Party or its counsel to serve as
17 an expert witness or as a consultant in this action.
18 2.8 House Counsel: attorneys who are employees of a Party to this Action.
19 House Counsel does not include Outside Counsel of Record or any other outside
20 counsel.
21 2.9 Nonparty: any natural person, partnership, corporation, association, or
22 other legal entity not named as a Party to this action.
23 2.10 Outside Counsel of Record: attorneys who are not employees of a Party
24 to this Action but are retained to represent or advise a Party and have appeared in this
25 Action on behalf of that Party or are affiliated with a law firm that has appeared on
26 behalf of that Party, including support staff.
27 2.11 Party: any Party to this Action, including all of its officers, directors,
28 employees, consultants, retained experts, and Outside Counsel of Record (and their
1 support staffs).
2 2.12 Producing Party: a Party or Nonparty that produces Disclosure or
3 Discovery Material in this Action.
4 2.13 Professional Vendors: Persons or entities that provide litigation support
5 services (for example, photocopying, videotaping, translating, preparing exhibits or
6 demonstrations, and organizing, storing, or retrieving data in any form or medium)
7 and their employees and subcontractors. Professional Vendors shall not use or
8 disclose Confidential Material for any purpose outside the scope of this litigation and
9 must sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A) before
10 receiving such material.
11 2.14 Protected Material: any Disclosure or Discovery Material that is
12 designated as “CONFIDENTIAL” in strict compliance with the standards set forth
13 in this Order. Protected Material must be limited to non-public, sensitive business,
14 financial, medical, or proprietary information that would cause specific harm if
15 disclosed. Generic business documents, publicly available information, or materials
16 produced without reasonable justification for confidentiality shall not qualify as
17 Protected Material.
18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
19 from a Producing Party.
20 3. SCOPE
21 The protections conferred by this Stipulation and Order cover not only
22 properly designated Protected Material (as defined above) but also any information
23 copied or extracted from Protected Material; all copies, excerpts, summaries, or
24 compilations of Protected Material; and any testimony, conversations, or
25 presentations by Parties or their Counsel that might reveal Protected Material, but
26 shall not extend to derivative materials that do not independently contain confidential
27 information.
28 Any use of Protected Material at trial will be governed by the orders of the trial
1 judge. This Order does not govern the use of Protected Material at trial.
2 4. DURATION
3 Even after final disposition of this litigation, the confidentiality obligations
4 imposed by this Order will remain in effect until a Designating Party agrees otherwise
5 in writing or a court order otherwise directs. Final disposition is the later of (1)
6 dismissal of all claims and defenses in this Action, with or without prejudice, or (2)
7 final judgment after the completion and exhaustion of all appeals, rehearings,
8 remands, trials, or reviews of this Action, including the time limits for filing any
9 motions or applications for extension of time under applicable law.
10 5. DESIGNATING PROTECTED MATERIAL
11 5.1 Each Party or Nonparty that designates information or items for
12 protection under this Order must take care to narrowly tailor designations to only
13 those specific portions of material that qualify under the appropriate standards. To
14 the extent practicable, the Designating Party must designate for protection only those
15 parts of material, documents, items, or oral or written communications that qualify
16 so that other portions of the material, documents, items, or communications for which
17 protection is not warranted are not swept unjustifiably within the ambit of this Order.
18 Indiscriminate or routinized designations are prohibited. Designations that are
19 shown to be clearly unjustified or that have been made for an improper purpose (for
20 example, to unnecessarily encumber the case-development process or to impose
21 unnecessary expenses and burdens on other parties) may expose the Designating
22 Party to sanctions.
23 If it comes to a Designating Party’s attention that information or items it
24 designated for protection do not qualify for that level of protection, that Designating
25 Party must within seven (7) days of such discovery notify all other Parties that it is
26 withdrawing the inapplicable designation.
27 5.2 Except as otherwise provided in this Order, only those portions of
28 Disclosure or Discovery Material that legitimately qualify for protection under this
1 Order must be clearly designated before the material is disclosed or produced.
2 Designation in conformity with this Order requires the following:
3 (a) for information in documentary form (for example, paper or electronic
4 documents but excluding transcripts of depositions or other pretrial or trial
5 proceedings), the Producing Party must affix at a minimum the legend
6 “CONFIDENTIAL” to each page that contains Protected Material. If only a portion
7 or portions of the material on a page qualify for protection, the Producing Party
8 should to the extent practicable, clearly identify the protected portion(s) (for example,
9 by making appropriate markings in the margins).
10 A Party or Nonparty that makes original documents available for inspection
11 need not designate them for protection until after the inspecting Party has indicated
12 which documents it would like copied and produced. During the inspection and
13 before the designation, all material made available for inspection must be treated as
14 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
15 copied and produced, the Producing Party must determine which documents, or
16 portions thereof, qualify for protection under this Order. Then, before producing the
17 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend
18 to each page that contains Protected Material. If only a portion or portions of the
19 material on a page qualify for protection, the Producing Party should to the extent
20 practical clearly identify the protected portion(s) (for example, by making
21 appropriate markings in the margins).
22 (b) For testimony given in depositions, the Designating Party must identify the
23 Disclosure or Discovery Material that is protected clearly and with specificity on the
24 record, before the close of the deposition. If a confidentiality designation is not made
25 on the record, the party seeking protection must provide written notice identifying
26 the specific confidential testimony within thirty (30) days after receiving the
27 transcript, or confidentiality shall be waived.
28 (c) For information produced in some form other than documentary and for
1 any other tangible items, the Producing Party must affix in a prominent place on the
2 exterior of the container or containers in which the information is stored the legend
3 “CONFIDENTIAL.” Wherever possible, specific portions of the material that require
4 confidentiality should be clearly identified rather than designating the entire
5 container or dataset. Indiscriminate or routinized designations are prohibited.
6 5.3 If timely corrected, an inadvertent failure to designate qualified
7 information or items does not, standing alone, waive the Designating Party’s right to
8 secure protection under this Order for that material. However, corrections must be
9 made within fourteen (14) days of discovering the omission. Failure to timely correct
10 a designation shall constitute a waiver of confidentiality, unless the Designating Party
11 demonstrates good cause for the delay. On timely correction of a designation, the
12 Receiving Party must make reasonable efforts to assure that the material is treated in
13 accordance with the provisions of this Order.
14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
15 6.1 Any Party or Nonparty may challenge a designation of confidentiality
16 at any time consistent with the Court’s scheduling order. A challenge shall not be
17 deemed untimely on the basis that the material has been designated for an extended
18 period.
19 6.2 The Challenging Party must initiate the dispute-resolution process (and,
20 if necessary, file a discovery motion) under Local Rule 37.
21 6.3 The burden of persuasion in any such proceeding is on the Designating
22 Party, who must demonstrate, with specificity, why the confidentiality designation is
23 justified under applicable law. Generalized claims of competitive harm or privacy
24 concerns shall not suffice. Frivolous challenges, and those made for an improper
25 purpose (for example, to harass or impose unnecessary expenses and burdens on
26 other parties), may expose the Challenging Party to sanctions. Unless the Designating
27 Party has waived or withdrawn the confidentiality designation, all parties must
28 continue to afford the material in question the level of protection to which it is entitled
1 under the Producing Party’s designation until the Court rules on the challenge.
2 7. ACCESS TO AND USE OF PROTECTED MATERIAL
3 7.1 A Receiving Party may use Protected Material that is disclosed or
4 produced by another Party or by a Nonparty in connection with this Action only for
5 prosecuting, defending, or attempting to settle this Action. Protected Material may
6 not be used in any other litigation, administrative proceeding, or for commercial
7 advantage, competitive purposes, or media dissemination, absent a Court order or
8 written consent of the Designating Party. Such Protected Material may be disclosed
9 only to the categories of people and under the conditions described in this Order.
10 When the Action has been terminated, a Receiving Party must comply with the
11 provisions of Section 13 below (FINAL DISPOSITION).
12 Protected Material must be stored and maintained by a Receiving Party at a
13 location and in a manner sufficiently secure to ensure that access is limited to the
14 people authorized under this Order.
15 7.2 Unless otherwise ordered by the Court or permitted in writing by the
16 Designating Party, a Receiving Party may disclose any information or item
17 designated “CONFIDENTIAL” only to the following people:
18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
19 employees of that Outside Counsel of Record to whom it is reasonably necessary to
20 disclose the information for this Action;
21 (b) the officers, directors, and employees (including House Counsel) of the
22 Receiving Party to whom disclosure is reasonably necessary for this Action;
23 (c) Experts (as defined in this Order) of the Receiving Party to whom
24 disclosure is reasonably necessary for this Action and who have signed the
25 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
26 (d) the Court and its personnel;
27 (e) court reporters and their staff;
28 (f) professional jury or trial consultants, mock jurors, and Professional
1 Vendors to whom disclosure is reasonably necessary for this Action and who have
2 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
3 (g) the author or recipient of a document containing the information or a
4 custodian or other person who otherwise possessed or knew the information;
5 (h) during their depositions, witnesses and attorneys for witnesses to whom
6 disclosure is reasonably necessary, provided that the deposing party requests that the
7 witness sign the form attached as Exhibit A. If a witness refuses to sign the
8 acknowledgment form, the Party seeking to disclose the Protected Material must
9 obtain leave of Court before proceeding with the disclosure. Witnesses will not be
10 permitted to keep any confidential information unless they sign the form, unless
11 otherwise agreed by the Designating Party or ordered by the Court. Pages of
12 transcribed deposition testimony or exhibits to depositions that reveal Protected
13 Material may be separately bound by the court reporter and may not be disclosed to
14 anyone except as permitted under this Order; and
15 (i) any mediator or settlement officer, and their supporting personnel, mutually
16 agreed on by any of the Parties engaged in settlement discussions or appointed by the
17 Court.
18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
19 IN OTHER LITIGATION
20 If a Party is served with a subpoena, civil investigative demand, discovery
21 request, or court order issued in other litigation or government investigation that
22 seeks disclosure of any information or items designated in this Action as
23 “CONFIDENTIAL,” that Party must:
24 (a) promptly notify in writing the Designating Party no later than five (5)
25 business days after receipt of the subpoena, request, or order, and before producing
26 any materials. Such notification must include a copy of the subpoena, request, or
27 court order unless prohibited by law .
28 (b) promptly notify in writing the party who caused the subpoena or order to
1 issue in the other litigation that some or all of the material covered by the subpoena
2 or order is subject to this Protective Order. Such notification must include a copy of
3 this Order; and
4 (c) cooperate with respect to all reasonable procedures sought to be pursued
5 by the Designating Party whose Protected Material may be affected.
6 If the Designating Party timely seeks a protective order, the Party served with
7 the subpoena, request, or order shall not produce any information designated in this
8 Action as “CONFIDENTIAL” unless and until either (i) the relevant court compels
9 production despite the protective order, or (ii) the Designating Party consents in
10 writing to disclosure. The Receiving Party must take all reasonable steps to object to
11 disclosure and preserve the confidentiality of the Protected Material until the court
12 rules. The Designating Party bears the burden and expense of seeking protection of
13 its Confidential Material. Unless required by law, the Receiving Party shall not
14 voluntarily comply with a subpoena or order requiring disclosure of Protected
15 Material without first providing the Designating Party an opportunity to seek a
16 protective order. Nothing in these provisions should be construed as authorizing or
17 encouraging a Receiving Party to disobey a lawful directive from another court;
18 however, the Receiving Party must assert all reasonable objections to production
19 based on this Protective Order and applicable law.
20 9. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE
21 PRODUCED IN THIS LITIGATION
22 (a) The terms of this Order are applicable to information produced by a
23 Nonparty in this Action and designated as “CONFIDENTIAL.” Such information is
24 protected by the remedies and relief provided by this Order. A Nonparty’s
25 designation of information as “CONFIDENTIAL” shall be given the same force and
26 effect as a Party’s designation under this Order, and any Party receiving Nonparty
27 Protected Material must comply with the obligations imposed herein. Nothing in
28 these provisions should be construed as prohibiting a Nonparty from seeking
1 additional protections or moving to intervene for the purpose of enforcing its
2 confidentiality rights.
3 (b) In the event that a Party is required by a valid discovery request or subpoena
4 to produce a Nonparty’s Confidential Information in its possession, and the Party is
5 subject to an agreement with the Nonparty not to produce such information, then the
6 Party must within five (5) business days of receipt:
7 (1) promptly notify in writing the Requesting Party and the Nonparty
8 (no later than five (5) business days after receiving the request) that some or all of
9 the information requested is subject to a confidentiality agreement with a Nonparty.
10 The notification must include a specific explanation of the confidentiality obligations
11 and provide the Nonparty with sufficient details to evaluate the scope of the
12 disclosure request.
13 (2) promptly provide the Nonparty with a copy of this Order, the
14 relevant discovery request(s), and a reasonably specific description of the
15 information requested; and
16 (3) make the information requested available for inspection and review
17 by the Nonparty, if requested. No disclosure shall occur before the Nonparty has had
18 an opportunity to inspect the documents and assert objections or seek a protective
19 order.
20 (c) If the Nonparty fails to seek a protective order or provide written objections
21 within 21 days of receiving the notice and accompanying information, the Receiving
22 Party may produce the Nonparty’s Confidential Information responsive to the
23 discovery request, but only to the extent required by law. The Producing Party shall
24 not voluntarily disclose the information absent a legal obligation to do so. If the
25 Nonparty timely seeks a protective order, the Receiving Party must not produce any
26 information in its possession or control that is subject to the confidentiality agreement
27 with the Nonparty before a ruling on the protective-order request. Absent a court
28 order to the contrary, the Nonparty must bear the burden and expense of seeking
1 protection of its Protected Material.
2 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
3 If a Receiving Party learns that by inadvertence or otherwise, it has disclosed
4 Protected Material to any person or in any circumstance not authorized under this
5 Order, the Receiving Party must within three (3) business days notify the Designating
6 Party in writing of the unauthorized disclosure, describing the circumstances of the
7 disclosure and identifying all individuals or entities who received the Protected
8 Material. The Receiving Party must also immediately take all necessary steps to
9 retrieve all unauthorized copies of the Protected Material and prevent further
10 disclosure. The Receiving Party shall request that the unauthorized recipient execute
11 the “Acknowledgment and Agreement to Be Bound” (Exhibit A), and if such
12 recipient refuses to do so, the Receiving Party must inform the Designating Party
13 immediately.
14 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
15 When a Producing Party gives notice to Receiving Parties that certain
16 inadvertently produced material is subject to a claim of privilege or other protection,
17 the Receiving Party must immediately cease all review, dissemination, or use of the
18 disputed material and comply with the obligations set forth in Federal Rule of Civil
19 Procedure 26(b)(5)(B). The Receiving Party shall return, sequester, or destroy the
20 inadvertently disclosed material within five (5) business days of receiving notice and
21 confirm compliance in writing to the Producing Party. If the Receiving Party disputes
22 the claim of privilege, it must promptly present the material to the Court under seal
23 for a determination, and until the Court resolves the issue, the material shall not be
24 used in any manner.
25 12. MISCELLANEOUS
26 12.1 Nothing in this Order abridges the right of any person to seek its
27 modification by the Court. However, absent a court order, no modification shall be
28 made unless the requesting Party demonstrates a material change in circumstances
1 warranting such modification.
2 12.2 By stipulating to the entry of this Order, no Party waives any right it
3 otherwise would have to object to disclosing or producing any information or item
4 on any ground not addressed in this Order, including but not limited to attorney-client
5 privilege, work-product doctrine, or any statutory or constitutional protection.
6 Similarly, no Party waives any right to object to the admissibility of any material
7 covered by this Order at trial or in any proceeding.
8 12.3 A Party that seeks to file under seal any Protected Material must comply
9 with Civil Local Rule 79-5. No material shall be filed under seal absent a specific
10 showing of good cause (for non-dispositive motions) or compelling reasons (for
11 dispositive motions), consistent with Kamakana v. City & Cnty. of Honolulu, 447
12 F.3d 1172 (9th Cir. 2006). Blanket confidentiality designations are insufficient to
13 justify sealing.
14 13. FINAL DISPOSITION
15 After the final disposition of this Action, as defined in paragraph 4, within 60
16 days of a written request by the Designating Party, each Receiving Party shall, at its
17 option, either (i) return all Protected Material to the Producing Party, or (ii) securely
18 destroy such material, including any electronically stored copies. The Receiving
19 Party must not retain Protected Material for any purpose other than as permitted by
20 this Order. As used in this subdivision, “all Protected Material” includes all copies,
21 abstracts, compilations, summaries, and any other format reproducing or capturing
22 any of the Protected Material. Whether the Protected Material is returned or
23 destroyed, the Receiving Party must submit a written certification to the Producing
24 Party (and, if not the same person or entity, to the Designating Party) by the 60-day
25 deadline that identifies (by category, when appropriate) all the Protected Material
26 that was returned or destroyed and affirms that the Receiving Party has not retained
27 any copies, abstracts, compilations, summaries, or any other format reproducing or
28 capturing any of the Protected Material. Notwithstanding this provision, Counsel are
1 || entitled to retain an archival copy of all pleadings; motion papers; trial, deposition,
2 || and hearing transcripts; legal memoranda; correspondence; deposition and trial
3 || exhibits; expert reports; attorney work product; and consultant and expert work
4 || product even if such materials contain Protected Material. Any such archival copies
5 || that contain or constitute Protected Material remain subject to this Order as set forth
6 || in Section 4 (DURATION).
71 14. SANCTIONS
8 Any willful violation of this Order may be punished by civil or criminal
9 || contempt, financial or evidentiary sanctions, reference to disciplinary authorities, or
10 || other appropriate action at the discretion of the Court.
11
12 | IT TS SO STIPULATED, THROUGH COUNSEL OF RECORD.
13
14 || Dated: February 27, 2025 ORRICK, HERRINGTON &
15 SUTCLIFFE LLP
16 By: /s/ Richard W._Krebs
Khai Let puang
17 Richard W. Krebs
18 Attorneys for Plaintiff Life
19 Opportunity Fund I, LP
20 TTC
51 || Dated: February 27, 2025 JACK FERNANDES LAW, APC
By: /s/Jack J. Fernandes
22 Jack J. Fernandes, Esq.
23 Attorney for Defendant Evelyn
Feliciano
35 IT IS SO ORDERED.
26 fr Prewhutl~
Dated: 2/27/2025
27 JEAN P. ROSENBLUTH
28 United States Magistrate Judge
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [full name], of _________________
4 [full address], declare under penalty of perjury that I have read in its entirety and
5 understand the Stipulated Protective Order that was issued by the U.S. District Court
6 for the Central District of California in the case of Life Opportunity Fund I, LP v.
7 Evelyn Feliciano, Case No. 2:24−cv−09016−JAK-JPR. I agree to comply with and
8 to be bound by all terms of this Stipulated Protective Order, and I understand and
9 acknowledge that failure to so comply could expose me to sanctions and punishment,
10 including contempt. I solemnly promise that I will not disclose in any manner any
11 information or item that is subject to this Stipulated Protective Order to any person
12 or entity except in strict compliance with the provisions of this Order.
13 I further agree to submit to the jurisdiction of the U.S. District Court for the
14 Central District of California for the purpose of enforcing the terms of this Stipulated
15 Protective Order, even if such enforcement proceedings occur after termination of
16 this action. I hereby appoint __________________________ [full name] of
17 _______________________________________ [full address and telephone
18 number] as my California agent for service of process in connection with this action
19 or any proceedings related to enforcement of this Stipulated Protective Order.
20
21 Date: ______________________________________
22
23 City and State where signed: _________________________________
24
25 Printed name: _______________________________
26
27 Signature: __________________________________
28