even stipulated protective orders require good 18 ||cause showing
How later courts described this case
- even stipulated protective orders require good 18 ||cause showing
Written by the judges who cited it.
The opinion
1 |} MICHAEL A.S. NEWMAN (SBN 205299)
MNewman@maynardnexsen.com
2 || JOHN R. HORSTMANN (SBN 327129)
Tlorsmann cemay nar dnexsen.com
3 || MAYNARD NEXSEN LLP
10100 Santa Monica Boulevard, Suite 550
4 || Los Angeles, CA 90067
5 Telephone: 310.596.4500
Attorneys for Defendant
6 || Farmers New World Life Insurance Company
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 ||) ISABEL SHAFF, Case No. 2:17-cv-03610-JAK-E
12 Plaintiff, (Honorable John A. Kronstadt)
13 V.
14 ||} FARMERS NEW WORLD LIFE STIPULATED PROTECTIVE
INSURANCE COMPANY AKA ORDER
15 || FARMERS LIFE INSURANCE, and
6 DOES | to 50, inclusive,
Defendants.
17
18 Complaint Filed: December 14, 2016
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28
STIPLIT ATED PROTECTIVE ORDER
I 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 || proprietary or private information for which special protection from public disclosure
4 || and from use for any purpose other than prosecuting this litigation may be warranted.
5 || Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 || following Stipulated Protective Order. The parties acknowledge that this Order does
7 ||not confer blanket protections on all disclosures or responses to discovery and that
8 ||the protection it affords from public disclosure and use extends only to the limited
9 ||information or items that are entitled to confidential treatment under the applicable
10 || legal principles.
11 B. GOOD CAUSE STATEMENT
12 This action is likely to involve trade secrets, customer and pricing lists and
13 |/other valuable research, development, commercial, financial, technical and/or
14 || proprietary information for which special protection from public disclosure and from
IS |)use for any purpose other than prosecution of this action is warranted. Such
16 || confidential and proprietary materials and information consist of, among other things,
17 ||confidential business or financial information, information regarding confidential
18 |/business practices, or other confidential research, development, or commercial
19 |/information (including information implicating privacy rights of third parties),
20 || information otherwise generally unavailable to the public, or which may be privileged
21 || or otherwise protected from disclosure under state or federal statutes, court rules, case
22 decisions, or common law. Accordingly, to expedite the flow of information, to
23 || facilitate the prompt resolution of disputes over confidentiality of discovery materials,
24 ||to adequately protect information the parties are entitled to keep confidential, to
25 || ensure that the parties are permitted reasonable necessary uses of such material in
26 || preparation for and in the conduct of trial, to address their handling at the end of the
27 || litigation, and serve the ends of justice, a protective order for such information is
28 justified in this matter. It is the intent of the parties that information will not be
STIPL]T ATED PROTECTIVE ORDER
1 ||designated as confidential for tactical reasons and that nothing be so designated
2 || without a good faith belief that it has been maintained in a confidential, non-public
3 manner, and there is good cause why it should not be part of the public record of this
4 || case.
5 C. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER
6 SEAL
7 The parties further acknowledge, as set forth in Section 12.3, below, that this
8 Stipulated Protective Order does not entitle them to file confidential information
9 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
10 || the standards that will be applied when a party seeks permission from the court to file
11 |) material under seal.
12 There is a strong presumption that the public has a right of access to judicial
13 || proceedings and records in civil cases. In connection with non-dispositive motions,
14 || good cause must be shown to support a filing under seal. See Kamakana v. City and
1S || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir._2006), Phillips v. Gen. Motors
16 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,
17 || 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good
18 ||cause showing), and a specific showing of good cause or compelling reasons with
19 ||)proper evidentiary support and legal justification, must be made with respect to
20 || Protected Material that a party seeks to file under seal. The parties’ mere designation
21 ||of Disclosure or Discovery Material as CONFIDENTIAL does not— without the
22 ||submission of competent evidence by declaration, establishing that the material
23 ||sought to be filed under seal qualifies as confidential, privileged, or otherwise
24 || protectable—constitute good cause.
25 Further, if a party requests sealing related to a dispositive motion or trial, then
26 || compelling reasons, not only good cause, for the sealing must be shown, and the relief
27 ||sought shall be narrowly tailored to serve the specific interest to be protected. See
28 || Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir_2010). For each
- STIPL]T ATED PROTECTIVE ORDER
1 || item or type of information, document, or thing sought to be filed or introduced under
2 || seal in connection with a dispositive motion or trial, the party seeking protection must
3 || articulate compelling reasons, supported by specific facts and legal justification, for
4 || the requested sealing order. Again, competent evidence supporting the application to
5 || file documents under seal must be provided by declaration.
6 Any document that is not confidential, privileged, or otherwise protectable in
7 entirety will not be filed under seal if the confidential portions can be redacted. If
8 || documents can be redacted, then a redacted version for public viewing, omitting only
9 || the confidential, privileged, or otherwise protectable portions of the document, shall
10 filed. Any application that seeks to file documents under seal in their entirety
11 || should include an explanation of why redaction is not feasible.
12 DEFINITIONS
13 2.1 Action: Isabel Shaff v. Farmers New World Life Insurance Company,
14 || United States District Court for the Central District of California, Case No. 2:17-cv-
15 ||03610-JAK-E.
16 2.2 Challenging Party: a Party or Non-Party that challenges the designation
17 || of information or items under this Order.
18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
19 || how it is generated, stored or maintained) or tangible things that qualify for protection
20 || under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
21 || Cause Statement.
22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
23 || support staff).
24 2.5 Designating Party: a Party or Non-Party that designates information or
25 ||items that it produces in disclosures or in responses to discovery as
26 || “CONFIDENTIAL.”
27 2.6 Disclosure or Discovery Material: all items or information, regardless of
28 ||the medium or manner in which it is generated, stored, or maintained (including,
; STIPL]T ATED PROTECTIVE ORDER
1 || among other things, testimony, transcripts, and tangible things), that are produced or
2 || generated in disclosures or responses to discovery in this matter.
3 2.7 Expert: a person with specialized knowledge or experience in a matter
4 || pertinent to the litigation who has been retained by a Party or its counsel to serve as
5 expert witness or as a consultant in this Action.
6 2.8 House Counsel: attorneys who are employees of a party to this Action.
7 ||House Counsel does not include Outside Counsel of Record or any other outside
8 || counsel.
9 2.9 Non-Party: any natural person, partnership, corporation, association or
10 || other legal entity not named as a Party to this action.
1] 2.10 Outside Counsel of Record: attorneys who are not employees of a party
12 ||to this Action but are retained to represent or advise a party to this Action and have
13 || appeared in this Action on behalf of that party or are affiliated with a law firm that
14 || has appeared on behalf of that party, and includes support staff.
15 2.11 Party: any party to this Action, including all of its officers, directors,
16 |)employees, consultants, retained experts, and Outside Counsel of Record (and their
17 || support staffs).
18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 |) Discovery Material in this Action.
20 2.13 Professional Vendors: persons or entities that provide litigation support
21 ||services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium)
23 || and their employees and subcontractors.
24 2.14 Protected Material: any Disclosure or Discovery Material that is
25 || designated as “CONFIDENTIAL.”
26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
27 || from a Producing Party.
28
STIPL]T ATED PROTECTIVE ORDER
1 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 extracted
4 ||from Protected Material; (2) all copies, excerpts, summaries, or compilations of
5 || Protected Material; and (3) any testimony, conversations, or presentations by Parties
6 || or their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the
8 || trial judge. This Order does not govern the use of Protected Material at trial.
9 || 4. DURATION
10 Once a case proceeds to trial, information that was designated as
11 |} CONFIDENTIAL or maintained pursuant to this protective order used or introduced
12 ||as an exhibit at trial becomes public and will be presumptively available to all
13 |}members of the public, including the press, unless compelling reasons supported by
14 || specific factual findings to proceed otherwise are made to the trial judge in advance
IS |/of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
16 ||showing for sealing documents produced in discovery from “compelling reasons”
17 |) standard when merits-related documents are part of court record). Accordingly, the
18 || terms of this protective order do not extend beyond the commencement of the trial.
19 ||5. DESIGNATED PROTECTED MATERIAL
20 5.1 Exercise of Restraint and Care in Designating Material for Protection.
21 || Each Party or Non-Party that designates information or items for protection under this
22 || Order must take care to limit any such designation to specific material that qualifies
23 || under the appropriate standards. The Designating Party must designate for protection
24 || only those parts of material, documents, items or oral or written communications that
25 || qualify so that other portions of the material, documents, items or communications
26 || for which protection is not warranted are not swept unjustifiably within the ambit of
27 || this Order,
28
>
STIPL]T ATED PROTECTIVE ORDER
1 Mass, indiscriminate or routinized designations are prohibited. Designations
2 ||/that are shown to be clearly unjustified or that have been made for an improper
3 || purpose (e.g., to unnecessarily encumber the case development process or to impose
4 || unnecessary expenses and burdens on other parties) may expose the Designating Party
5 || to sanctions.
6 If it comes to a Designating Party’s attention that information or items that it
7 || designated for protection do not qualify for protection, that Designating Party must
8 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
9 5.2 Manner and Timing of Designations. Except as otherwise provided in
10 ||this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
11 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
12 || under this Order must be clearly so designated before the material is disclosed or
13 || produced.
14 Designation in conformity with this Order requires:
15 (a) for information in documentary form (e.g., paper or electronic
16 |}documents, but excluding transcripts of depositions or other pretrial or trial
17 ||proceedings), that the Producing Party affix at a minimum, the legend
18 ||““CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
19 |) contains protected material. If only a portion of the material on a page qualifies for
20 || protection, the Producing Party also must clearly identify the protected portion(s)
21 || (e.g., by making appropriate markings in the margins).
22 A Party or Non-Party that makes original documents available for inspection
23 ||need not designate them for protection until after the inspecting Party has indicated
24 || which documents it would like copied and produced. During the inspection and before
25 ||the designation, all of the material made available for inspection shall be deemed
26 ||“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
27 ||copied and produced, the Producing Party must determine which documents, or
28 || portions thereof, qualify for protection under this Order. Then, before producing the
6 STIPL]T ATED PROTECTIVE ORDER
1 || specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
2 ||to each page that contains Protected Material. If only a portion of the material on a
3 ||page qualifies for protection, the Producing Party also must clearly identify the
4 || protected portion(s) (e.g., by making appropriate markings in the margins).
5 (b) for testimony given in depositions that the Designating Party identifies
6 || the Disclosure or Discovery Material on the record, before the close of the deposition
7 all protected testimony.
8 (c) for information produced in some form other than documentary and for
9 || any other tangible items, that the Producing Party affix in a prominent place on the
10 || exterior of the container or containers in which the information is stored the legend
11 }|}“CONFIDENTIAL.” If only a portion or portions of the information warrants
12 || protection, the Producing Party, to the extent practicable, shall identify the protected
13 |) portion(s).
14 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent
15 || failure to designate qualified information or items does not, standing alone, waive the
16 || Designating Party’s right to secure protection under this Order for such material.
17 || Upon timely correction of a designation, the Receiving Party must make reasonable
18 || efforts to assure that the material is treated in accordance with the provisions of this
19 || Order.
20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
21 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
22 ||designation of confidentiality at any time that is consistent with the Court’s
23 || Scheduling Order,
24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
25 || resolution process under Local Rule 37-1 et seq.
26 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
27 || joint stipulation pursuant to Local Rule 37-2.
28
STIPL]T ATED PROTECTIVE ORDER
1 6.4 The burden of persuasion in any such challenge proceeding shall be on
2 || the Designating Party. Frivolous challenges, and those made for an improper purpose
3 ||(e.g., to harass or impose unnecessary expenses and burdens on other parties) may
4 || expose the Challenging Party to sanctions. Unless the Designating Party has waived
5 withdrawn the confidentiality designation, all parties shall continue to afford the
6 || material in question the level of protection to which it is entitled under the Producing
7 || Party’s designation until the Court rules on the challenge.
8 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL
9 7.1. Basic Principles. A Receiving Party may use Protected Material that is
10 || disclosed or produced by another Party or by a Non-Party in connection with this
11 || Action only for prosecuting, defending or attempting to settle this Action. Such
12 || Protected Material may be disclosed only to the categories of persons and under the
13 || conditions described in this Order. When the Action has been terminated, a Receiving
14 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
15 Protected Material must be stored and maintained by a Receiving Party at a
16 location and in a secure manner that ensures that access is limited to the persons
17 || authorized under this Order.
18 72 Disclosure _of “CONFIDENTIAL” Information or Items. Unless
19 || otherwise ordered by the court or permitted in writing by the Designating Party, a
20 ||Receiving Party may disclose any information or item designated
21 ||“CONFIDENTIAL” only to:
22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
23 ||as employees of said Outside Counsel of Record to whom it is reasonably necessary
24 || to disclose the information for this Action;
25 (b) the officers, directors, and employees (including House Counsel) of the
26 || Receiving Party to whom disclosure is reasonably necessary for this Action;
27
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STIPL]T ATED PROTECTIVE ORDER
(c) Experts (as defined in this Order) of the Receiving Party to whom
2 ||disclosure is reasonably necessary for this Action and who have signed the
3 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (d) the court and its personnel;
5 (e) court reporters and their staff;
6 (f) professional jury or trial consultants, mock jurors, and Professional
7 || Vendors to whom disclosure is reasonably necessary for this Action and who have
8 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (g) the author or recipient of a document containing the information or a
10 || custodian or other person who otherwise possessed or knew the information;
1] (h) during their depositions, witnesses, and attorneys for witnesses, in the
12 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party
13 requests that the witness sign the form attached as Exhibit | hereto; and (2) they will
14 |;not be permitted to keep any confidential information unless they sign the
IS ||“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
16 |/agreed by the Designating Party or ordered by the court. Pages of transcribed
17 || deposition testimony or exhibits to depositions that reveal Protected Material may be
18 || separately bound by the court reporter and may not be disclosed to anyone except as
19 || permitted under this Stipulated Protective Order; and
20 (i) any mediator or settlement officer, and their supporting personnel,
21 || mutually agreed upon by any of the parties engaged in settlement discussions.
22 1\8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
23 OTHER LITIGATION
24 If a Party is served with a subpoena or a court order issued in other litigation
25 ||that compels disclosure of any information or items designated in this Action as
26 ||““CONFIDENTIAL,” that Party must:
27 (a) promptly notify in writing the Designating Party. Such notification shall
28 || include a copy of the subpoena or court order;
STIPL]T ATED PROTECTIVE ORDER
1 (b) promptly notify in writing the party who caused the subpoena or order to
2 ||issue in the other litigation that some or all of the material covered by the subpoena
3 |) or order is subject to this Protective Order. Such notification shall include a copy of
4 || this Stipulated Protective Order; and
5 (c) cooperate with respect to all reasonable procedures sought to be pursued
6 || by the Designating Party whose Protected Material may be affected.
7 If the Designating Party timely seeks a protective order, the Party served with
8 || the subpoena or court order shall not produce any information designated in this action
9 |) as “CONFIDENTIAL” before a determination by the court from which the subpoena
10 || or order issued, unless the Party has obtained the Designating Party’s permission. The
11 || Designating Party shall bear the burden and expense of seeking protection in that court
12 || of its confidential material and nothing in these provisions should be construed as
13 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
14 || directive from another court.
15 A__NON-PARTY’S PROTECTED MATERIAL SOUGHT □□ BE
16 PRODUCED IN THIS LITIGATION
17 (a) terms of this Order are applicable to information produced by a Non-
18 ||Party in this Action and designated as “CONFIDENTIAL.” Such information
19 ||produced by Non-Parties in connection with this litigation is protected by the
20 ||remedies and relief provided by this Order. Nothing in these provisions should be
21 || construed as prohibiting a Non-Party from seeking additional protections.
22 (b) In the event that a Party is required, by a valid discovery request, to
23 || produce a Non-Party’s confidential information in its possession, and the Party is
24 ||subject to an agreement with the Non-Party not to produce the Non-Party’s
25 || confidential information, then the Party shall:
26 (1) promptly notify in writing the Requesting Party and the Non-Party
27 || that some or all of the information requested is subject to a confidentiality agreement
28 || with a Non-Party;
i STIPL]T ATED PROTECTIVE ORDER
1 (2) promptly provide the Non-Party with a copy of the Stipulated
2 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
3 || specific description of the information requested; and
4 (3) make the information requested available for inspection by the
5 || Non-Party, if requested.
6 (c) Ifthe Non-Party fails to seek a protective order from this court within 14
7 || days of receiving the notice and accompanying information, the Receiving Party may
8 || produce the Non-Party’s confidential information responsive to the discovery request.
9 || If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
10 ||any information in its possession or control that is subject to the confidentiality
11 |)agreement with the Non-Party before a determination by the court. Absent a court
12 || order to the contrary, the Non-Party shall bear the burden and expense of seeking
13 || protection in this court of its Protected Material.
14 |}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
16 || Protected Material to any person or in any circumstance not authorized under this
17 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in
18 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
19 |) to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
20 || persons to whom unauthorized disclosures were made of all the terms of this Order,
21 ||and (d) request such person or persons to execute the “Acknowledgment and
22 || Agreement to Be Bound” that is attached hereto as Exhibit A.
23 |}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
24 PROTECTED MATERIAL
25 When a Producing Party gives notice to Receiving Parties that certain
26 || inadvertently produced material is subject to a claim of privilege or other protection,
27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
28 || Procedure 26(b)\(5)\(B). This provision is not intended to modify whatever procedure
STIPL]T ATED PROTECTIVE ORDER
1 || may be established in an e-discovery order that provides for production without prior
2 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
3 ||parties reach an agreement on the effect of disclosure of a communication or
4 || information covered by the attorney-client privilege or work product protection, the
5 || parties may incorporate their agreement in the stipulated protective order submitted
6 || to the court.
7{|12. MISCELLANEOUS
8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
9 || person to seek its modification by the Court in the future.
10 12.2 Right to Assert Other Objections. By stipulating to the entry of this
11 || Protective Order, no Party waives any right it otherwise would have to object to
12 || disclosing or producing any information or item on any ground not addressed in this
13 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
14 |) ground to use in evidence of any of the material covered by this Protective Order.
15 12.3 Filing Protected Material. A Party that seeks to file under seal any
16 || Protected Material must comply with Local Civil Rule 79-5. Protected Material may
17 || only be filed under seal pursuant to a court order authorizing the sealing of the specific
18 || Protected Material at issue. If a Party’s request to file Protected Material under seal is
19 || denied by the court, then the Receiving Party may file the information in the public
20 ||record unless otherwise instructed by the court.
21 ||/13. FINAL DISPOSITION
22 After the final disposition of this Action, as defined in paragraph 4, within 60
23 || days of a written request by the Designating Party, each Receiving Party must return
24 || all Protected Material to the Producing Party or destroy such material. As used in this
25 || subdivision, “all Protected Material” includes all copies, abstracts, compilations,
26 ||summaries, and any other format reproducing or capturing any of the Protected
27 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party
28 || must submit a written certification to the Producing Party (and, if not the same person
- STIPL]T ATED PROTECTIVE ORDER
1 |/or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
2 || category, where appropriate) all the Protected Material that was returned or destroyed
3 ||and (2) affirms that the Receiving Party has not retained any copies, abstracts,
4 ||compilations, summaries or any other format reproducing or capturing any of the
5 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
6 ||archival copy of all pleadings, motion papers, trial, deposition, and hearing
7 ||transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
8 || reports, attorney work product, and consultant and expert work product, even if such
9 ||materials contain Protected Material. Any such archival copies that contain or
10 || constitute Protected Material remain subject to this Protective Order as set forth in
11 || Section 4 (DURATION).
12 |}14. VIOLATION
13 Any violation of this Order may be punished by appropriate measures
14 |) including, without limitation, contempt proceedings and/or monetary sanctions.
15 IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
16 We hereby attest that concurrence in the filing of this stipulation was obtained
17 || by each of the below identified signatories.
18
19
20
21 ||DATED: April 29, 2025 WINTERS & ASSOCIATES
22
By: /s/Sarah Ball
23 JACK B. WINTERS, JR. □□□
24 Attorneys. for Plaintiff
5 Isabel Shaft
26
27
28
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STIPL]T ATED PROTECTIVE ORDER
1
2
3
4 ||DATED: April 29, 2025 MAYNARD NEXSEN LLP
5
By: /s/Michael A.S. Newman
6 MICHAEL A.S.NEWMAN.—
JOHN R. HORSTMAN
7 ttorneys for _efendant
Farmers New World Life Insurance
8 Company
9
10 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
11 ZB Zz
3 DATED: April 30, 2025 Charles F. Eick
4 United States Magistrate Judge
15
16
17 Pursuant to Local Rule 5-4.3.4(a)(2)(i), the filer attests that all other
18 || signatories listed, and on whose behalf the filing is submitted, concur in the filing’s
19 || content and have authorized the filing.
20
21
22
23
24
25
26
27
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STIPLIT ATED PROTECTIVE ORDER
l EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
41 [print or type full name], of
5 [print or type full address], declare under penalty of perjury
6 || that I have read in its entirety and understand the Stipulated Protective Order that was
7 || issued by the United States District Court for the Central District of California on [date]
8 ||in the case of Isabel Shaff v. Farmers New World Life Insurance Company, United
9 || States District Court for the Central District of California, Case No. 2:17-cv-03610-
10 || JAK-E. I agree to 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 comply could
12 || expose me to sanctions and punishment in the nature of contempt. I solemnly promise
13 || that I will not disclose in any manner any information or item that is subject to this
14 || Stipulated Protective Order to any person or entity except in strict compliance with the
15 || provisions of this Order.
16 ||I further agree to submit to the jurisdiction of the United States District Court for the
17 || Central District of California for enforcing the terms of this Stipulated Protective Order,
18 || even if such enforcement proceedings occur after termination of this action.
19 ||T hereby appoint [print or type full name] of
20 [print or type full address and
21 telephone number] as my California agent for service of process in connection with
22 ||this action or any proceedings related to enforcement of this Stipulated Protective
23 || Order.
24 || Date:
25 || City and State where sworn and signed:
26 || Printed name:
27
28 || Signature:
15
STIPL]T ATED PROTECTIVE ORDER