even stipulated 8 protective orders require good cause showing
How later courts described this case
- even stipulated 8 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 William Moran II
2 Bill@awlegalfirm.com
ARTHUR WILLIAM, LLP
3 10015 Old Columbia Rd.
4 Columbia, MD 21046
Tel: 520-604-0260
5
Attorneys for Plaintiff Michael Gruen
6
UNITED STATES DISTRICT COURT
7
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
8
9 MICHAEL GRUEN, Case No. 2:24-cv-01777
10 Hon. André Birotte Jr.
Plaintiff,
11 Hon. Stephanie S. Christensen
v.
12
13 JOSHUA RICHARDS, an individual;
CHRISTOPHER SAWTELLE, an
14
individual; CROSSCHECK STUDIOS,
15 LLC, a California Limited Liability
Company; BUDDY’S HARD, LLC, a
16
Delaware Limited Liability Company;
17 CREATIVE ARTISTS AGENCY,
LLC, a Delaware Limited Liability
18
Company; CAA HOLDINGS, LLC, a
19 Delaware Limited Liability Company,
20
Defendants.
21
22
1. INTRODUCTION
23
1.1 Purposes and Limitations. Discovery in this action is likely to
24
involve production of confidential, proprietary, or private information for
25
which special protection from public disclosure and from use for any
26
purpose other than prosecuting this litigation may be warranted.
27
1 enter the following Stipulated Protective Order. The parties
2 acknowledge that this Order does not confer blanket protections on all
3 disclosures or responses to discovery and that the protection it affords
4 from public disclosure and use extends only to the limited information or
5 items that are entitled to confidential treatment under the applicable
6 legal principles.
7 1.2 Good Cause Statement. The Parties acknowledge that
8 Plaintiff’s Third Amended Complaint is not presently settled and is
9
subject to a forthcoming motion to dismiss, which may define the scope of
10
discovery in this case. The outcome of that motion may impact the degree
11
to which discovery may potentially involve the sharing of confidential
12
business or personnel information including but not limited to contract
13
and negotiation documents between CrossCheck Studios and Amazon
14
Studios (now Amazon MGM Studios). There may be a possibility that this
15
disclosure would reveal certain pending or upcoming projects risking
16
potential financial loss. Further, the rates paid, deliverables and
17
intellectual property required, and other material terms may compromise
18
one or more parties’ negotiations of current or future contracts. Discovery
19
in this matter may also reveal certain sensitive information such as but
20
not limited to contract rates, personal financial records, business practices
21
22 and activities, and private matters the disclosure of which to the general
23 public could lead to lost financial opportunities, oppression, harassment,
24 or ridicule unnecessary to the resolution of the dispute at hand.
25 This action may involve customer and pricing lists and other
26 valuable commercial, financial, technical and/or proprietary information
27 for which special protection from public disclosure and from use for any
1 confidential and proprietary materials and information consist of, among
2 other things, confidential business or financial information, information
3 regarding confidential business practices, or other confidential
4 development, or commercial information (including information
5 implicating privacy rights of third parties), information otherwise
6 generally unavailable to the public, or which may be privileged or
7 otherwise protected from disclosure under state or federal statutes, court
8 rules, case decisions, or common law. Accordingly, to expedite the flow of
9
information, to facilitate the prompt resolution of disputes over
10
confidentiality of discovery materials, to adequately protect information
11
the parties are entitled to keep confidential, to ensure that the parties
12
are permitted reasonable necessary uses of such material in preparation
13
for and in the conduct of trial, to address their handling at the end of the
14
litigation, and serve the ends of justice, a protective order for such
15
information is justified in this matter. It is the intent of the parties that
16
information will not be designated as confidential for tactical reasons
17
and that nothing be so designated without a good faith belief that it has
18
been maintained in a confidential, non-public manner, and there is good
19
cause why it should not be part of the public record of this case. Nothing
20
in the foregoing should be deemed to be an admission or concession by
21
22 any party that particular information is appropriately discoverable.
23 1.3 Acknowledgment of Procedure for Filing Under Seal. The
24 parties further acknowledge, as set forth in Section 12.3, below, that this
25 Stipulated Protective Order does not entitle them to file confidential
26 information under seal; Local Rule 79-5 sets forth the procedures that
27 must be followed and the standards that will be applied when a party
1 There is a strong presumption that the public has a right of access
2 to judicial proceedings and records in civil cases. In connection with
3 non-dispositive motions, good cause must be shown to support a filing
4 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
5 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
6 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
7 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
8 protective orders require good cause showing), and a specific showing of
9
good cause or compelling reasons with proper evidentiary support and
10
legal justification, must be made with respect to Protected Material that
11
a party seeks to file under seal. The parties’ mere designation of
12
Disclosure or Discovery Material as CONFIDENTIAL does not—
13
without the submission of competent evidence by declaration,
14
establishing that the material sought to be filed under seal qualifies as
15
confidential, privileged, or otherwise protectable—constitute good cause.
16
Further, if a party requests sealing related to a dispositive motion
17
or trial, then compelling reasons, not only good cause, for the sealing
18
must be shown, and the relief sought shall be narrowly tailored to serve
19
the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
20
605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
21
22 information, document, or thing sought to be filed or introduced under
23 seal in connection with a dispositive motion or trial, the party seeking
24 protection must articulate compelling reasons, supported by specific
25 facts and legal justification, for the requested sealing order. Again,
26 competent evidence supporting the application to file documents under
27 seal must be provided by declaration.
1 protectable in its entirety will not be filed under seal if the confidential
2 portions can be redacted. If documents can be redacted, then a redacted
3 version for public viewing, omitting only the confidential, privileged, or
4 otherwise protectable portions of the document, shall be filed. Any
5 application that seeks to file documents under seal in their entirety
6 should include an explanation of why redaction is not feasible.
7 2. DEFINITIONS
8
2.1 Action: this pending federal lawsuit.
9
2.2 Challenging Party: a Party or Non-Party that challenges the
10
designation of information or items under this Order.
11
2.3 “CONFIDENTIAL” Information or Items: information
12
(regardless of how it is generated, stored or maintained) or tangible
13
things that qualify for protection under Rule 26(c) of the Federal Rules of
14
Civil Procedure, and as specified above in the Good Cause Statement.
15
2.4 Counsel: Outside Counsel of Record and House Counsel (as
16
well as their support staff).
17
18 2.5 Designating Party: a Party or Non-Party that designates
19 information or items that it produces in disclosures or in responses to
20 discovery as “CONFIDENTIAL.”
21 2.6 Disclosure or Discovery Material: all items or information,
22 regardless of the medium or manner in which it is generated, stored, or
23 maintained (including, among other things, testimony, transcripts, and
24 tangible things), that are produced or generated in disclosures or
25 responses to discovery in this matter.
26 2.7 Expert: a person with specialized knowledge or experience in
27
a matter pertinent to the litigation who has been retained by a Party or
1 its counsel to serve as an expert witness or as a consultant in this Action.
2 2.8 Final Disposition: the later of (1) dismissal of all claims and
3 defenses in this Action, with or without prejudice; and (2) final judgment
4 herein after the completion and exhaustion of all appeals, rehearings,
5 remands, trials, or reviews of this Action, including the time limits for
6 filing any motions or applications for extension of time pursuant to
7 applicable law.
8
2.9 In-House Counsel: attorneys who are employees of a party to
9
this Action. In-House Counsel does not include Outside Counsel of
10
Record or any other outside counsel.
11
2.10 Non-Party: any natural person, partnership, corporation,
12
association, or other legal entity not named as a Party to this action.
13
2.11 Outside Counsel of Record: attorneys who are not employees
14
of a party to this Action but are retained to represent or advise a party to
15
this Action and have appeared in this Action on behalf of that party or
16
are affiliated with a law firm which has appeared on behalf of that party,
17
and includes support staff.
18
2.12 Party: any party to this Action, including all of its officers,
19
directors, employees, consultants, retained experts, and Outside Counsel
20
of Record (and their support staffs).
21
22 2.13 Producing Party: a Party or Non-Party that produces
23 Disclosure or Discovery Material in this Action.
24 2.14 Professional Vendors: persons or entities that provide
25 litigation- support services (e.g., photocopying, videotaping, translating,
26 preparing exhibits or demonstrations, and organizing, storing, or
27 retrieving data in any form or medium) and their employees and
1 2.15 Protected Material: any Disclosure or Discovery Material that
2 is designated as “CONFIDENTIAL.”
3 2.16 Receiving Party: a Party that receives Disclosure or Discovery
4 Material from a Producing Party.
5 3. SCOPE
6
The protections conferred by this Stipulation and Order cover not
7
only Protected Material (as defined above), but also (1) any information
8
copied or extracted from Protected Material; (2) all copies, excerpts,
9
summaries, or compilations of Protected Material; and (3) any
10
testimony, conversations, or presentations by Parties or their Counsel
11
that might reveal Protected Material.
12
Any use of Protected Material at trial shall be governed by the
13
orders of the trial judge. This Stipulated Protective Order does not
14
govern the use of Protected Material at trial.
15
4. TRIAL AND DURATION
16
17 The terms of this Stipulated Protective Order apply through Final
18 Disposition of the Action.
19
Once a case proceeds to trial, information that was designated as
20
CONFIDENTIAL or maintained pursuant to this Stipulated Protective
21
Order and used or introduced as an exhibit at trial becomes public and
22
will be presumptively available to all members of the public, including
23
the press, unless compelling reasons supported by specific factual
24
findings to proceed otherwise are made to the trial judge in advance of
25
the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good
26
cause” showing for sealing documents produced in discovery from
27
1 of court record). Accordingly, for such materials, the terms of this
2 Stipulated Protective Order do not extend beyond the commencement of
3 the trial.
4 Even after Final Disposition of this litigation, the confidentiality
5 obligations imposed by this Stipulated Protective Order shall remain in
6 effect until a Designating Party agrees otherwise in writing or a court
7 order otherwise directs.
8 5. DESIGNATING PROTECTED MATERIAL
9
5.1 Exercise of Restraint and Care in Designating Material for
10
Protection. Each Party or Non-Party that designates information or
11
items for protection under this Order must take care to limit any such
12
designation to specific material that qualifies under the appropriate
13
standards. The Designating Party must designate for protection only
14
those parts of material, documents, items, or oral or written
15
communications that qualify so that other portions of the material,
16
documents, items, or communications for which protection is not
17
18 warranted are not swept unjustifiably within the ambit of this Order.
19 Mass, indiscriminate, or routinized designations are prohibited.
20 Designations that are shown to be clearly unjustified or that have been
21 made for an improper purpose (e.g., to unnecessarily encumber the case
22 development process or to impose unnecessary expenses and burdens on
23 other parties) may expose the Designating Party to sanctions.
24 If it comes to a Designating Party’s attention that information or
25 items that it designated for protection do not qualify for protection, that
26 Designating Party must promptly notify all other Parties that it is
27
withdrawing the inapplicable designation.
1 5.2 Manner and Timing of Designations. Except as otherwise
2 provided in this Stipulated Protective Order (see, e.g., second paragraph
3 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
4 or Discovery Material that qualifies for protection under this Stipulated
5 Protective Order must be clearly so designated before the material is
6 disclosed or produced.
7 Designation in conformity with this Stipulated Protective Order
8 requires:
9
(a) for information in documentary form (e.g., paper or electronic
10
documents, but excluding transcripts of depositions or other pretrial or
11
trial proceedings), that the Producing Party affix at a minimum, the
12
legend “CONFIDENTIAL” to each page that contains protected
13
material. If only a portion or portions of the material on a page
14
qualifies for protection, the Producing Party also must clearly identify
15
the protected portion(s) (e.g., by making appropriate markings in the
16
margins).
17
A Party or Non-Party that makes original documents available for
18
inspection need not designate them for protection until after the
19
inspecting Party has indicated which documents it would like copied
20
and produced. During the inspection and before the designation, all of
21
22 the material made available for inspection shall be deemed
23 CONFIDENTIAL. After the inspecting Party has identified the
24 documents it wants copied and produced, the Producing Party must
25 determine which documents, or portions thereof, qualify for protection
26 under this Stipulated Protective Order. Then, before producing the
27 specified documents, the Producing Party must affix the
1 Material. If only a portion or portions of the material on a page
2 qualifies for protection, the Producing Party also must clearly identify
3 the protected portion(s) (e.g., by making appropriate markings in the
4 margins).
5 (b) for testimony given in depositions that the Designating Party
6 identify the Disclosure or Discovery Material on the record, before the
7 close of the deposition all protected testimony.
8
(c) for information produced in some form other than
9
documentary and for any other tangible items, that the Producing Party
10
affix in a prominent place on the exterior of the container or containers
11
in which the information is stored the “CONFIDENTIAL” legend. If only
12
a portion or portions of the information warrants protection, the
13
Producing Party, to the extent practicable, shall identify the protected
14
portion(s).
15
5.3 Inadvertent Failures to Designate. If timely corrected, an
16
inadvertent failure to designate qualified information or items does not,
17
18 standing alone, waive the Designating Party’s right to secure protection
19 under this Order for such material. Upon timely correction of a
20 designation, the Receiving Party must make reasonable efforts to assure
21 that the material is treated in accordance with the provisions of this
22 Stipulated Protective Order.
23 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
24
6.1 Timing of Challenges. Any Party or Non-Party may
25
challenge a designation of confidentiality at any time that is consistent
26
with the court’s Scheduling Order.
27
6.2 Meet and Confer. The Challenging Party shall initiate the
1 dispute resolution process under Local Rule 37.1 et seq. and with
2 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-
3 Discovery Motion Conference.”1
4 6.3 The burden of persuasion in any such challenge proceeding
5 shall be on the Designating Party. Frivolous challenges, and those
6 made for an improper purpose (e.g., to harass or impose unnecessary
7 expenses and burdens on other parties) may expose the Challenging
8 Party to sanctions. Unless the Designating Party has waived or
9
withdrawn the confidentiality designation, all parties shall continue to
10
afford the material in question the level of protection to which it is
11
entitled under the Producing Party’s designation until the court rules on
12
the challenge.
13
7. ACCESS TO AND USE OF PROTECTED MATERIAL
14
7.1 Basic Principles. A Receiving Party may use Protected
15
Material that is disclosed or produced by another Party or by a Non-
16
Party in connection with this Action only for prosecuting, defending, or
17
18 attempting to settle this Action. Such Protected Material may be
19 disclosed only to the categories of persons and under the conditions
20 described in this Order. When the Action reaches a Final Disposition, a
21 Receiving Party must comply with the provisions of section 13 below.
22 Protected Material must be stored and maintained by a Receiving
23 Party at a location and in a secure manner that ensures that access is
24 limited to the persons authorized under this Stipulated Protective
25 Order.
26
27
1 Judge Christensen’s Procedures are available at
1 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
2 Unless otherwise ordered by the court or permitted in writing by the
3 Designating Party, a Receiving Party may disclose any information or
4 item designated “CONFIDENTIAL” only:
5 (a) to the Receiving Party’s Outside Counsel of Record in this
6 Action, as well as employees of said Outside Counsel of Record to whom
7 it is reasonably necessary to disclose the information for this Action;
8
(b) to the officers, directors, and employees (including House
9
Counsel) of the Receiving Party to whom disclosure is reasonably
10
necessary for this Action;
11
(c) to Experts (as defined in this Order) of the Receiving Party to
12
whom disclosure is reasonably necessary for this Action and who have
13
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14
(d) to the court and its personnel;
15
(e) to court reporters and their staff;
16
(f) to professional jury or trial consultants, mock jurors, and
17
Professional Vendors to whom disclosure is reasonably necessary for
18
this Action and who have signed the “Acknowledgment and Agreement
19
to Be Bound” (Exhibit A);
20
(g) to the author or recipient of a document containing the
21
22 information or a custodian or other person who otherwise possessed or
23 knew the information;
24 (h) during their depositions, to witnesses, and attorneys for
25 witnesses, in the Action to whom disclosure is reasonably necessary,
26 provided: (1) the deposing party requests that the witness sign the
27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
1 unless they sign the “Acknowledgment and Agreement to Be Bound”
2 (Exhibit A), unless otherwise agreed by the Designating Party or
3 ordered by the court. Pages of transcribed deposition testimony or
4 exhibits to depositions that reveal Protected Material may be separately
5 bound by the court reporter and may not be disclosed to anyone except
6 as permitted under this Stipulated Protective Order; and
7 (i) to any mediator or settlement officer, and their supporting
8 personnel, mutually agreed upon by any of the parties engaged in
9
settlement discussions.
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
16 (a) promptly notify in writing the Designating Party. Such
17 notification shall include a copy of the subpoena or court order;
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
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
10
PRODUCED IN THIS LITIGATION
11
9.1 Application. The terms of this Stipulated Protective Order
12
are applicable to information produced by a Non-Party in this Action and
13
designated as “CONFIDENTIAL.” Such information produced by Non-
14
Parties in connection with this litigation is protected by the remedies
15
and relief provided by this Order. Nothing in these provisions should be
16
construed as prohibiting a Non-Party from seeking additional
17
protections.
18
9.2 Notification. In the event that a Party is required, by a valid
19
discovery request, to produce a Non-Party’s confidential information in
20
its possession, and the Party is subject to an agreement with the Non-
21
22 Party not to produce the Non-Party’s confidential information, then the
23 Party shall:
24 (a) promptly notify in writing the Requesting Party and the
25 Non-Party that some or all of the information requested is subject to a
26 confidentiality agreement with a Non-Party;
27 (b) make the information requested available for inspection by
1 9.3 Conditions of Production. If the Non-Party fails to seek a
2 protective order from this court within 14 days of receiving the notice
3 and accompanying information, the Receiving Party may produce the
4 Non-Party’s confidential information responsive to the discovery request.
5 If the Non-Party timely seeks a protective order, the Receiving Party
6 shall not produce any information in its possession or control that is
7 subject to the confidentiality agreement with the Non-Party before a
8 determination by the court. Absent a court order to the contrary, the
9
Non-Party shall bear the burden and expense of seeking protection in
10
this court of its Protected Material.
11
10. UNAUTHORIZED DISCLOSURE OF PROTECTED
12
MATERIAL
13
If a Receiving Party learns that, by inadvertence or otherwise, it
14
has disclosed Protected Material to any person or in any circumstance
15
not authorized under this Stipulated Protective Order, the Receiving
16
Party must immediately (a) notify in writing the Designating Party of
17
18 the unauthorized disclosures, (b) use its best efforts to retrieve all
19 unauthorized copies of the Protected Material, (c) inform the person or
20 persons to whom unauthorized disclosures were made of all the terms of
21 this Order, and (d) request such person or persons to execute the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
23
11. INADVERTENT PRODUCTION OF PRIVILEGED OR
24
OTHERWISE PROTECTED MATERIAL
25
When a Producing Party gives notice to Receiving Parties that
26
certain inadvertently produced material is subject to a claim of privilege
27
1 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
2 provision is not intended to modify whatever procedure may be
3 established in an e-discovery order that provides for production without
4 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
5 Rules of Evidence, insofar as the parties reach an agreement on the
6 effect of disclosure of a communication or information covered by the
7 attorney-client privilege or work product protection, the parties may
8 incorporate their agreement in the stipulated protective order
9
submitted to the court.
10
12. MISCELLANEOUS
11
12.1 Right to Further Relief. Nothing in this Stipulated
12
Protective Order abridges the right of any person to seek its
13
modification by the court in the future.
14
12.2 Right to Assert Other Objections. By stipulating to the entry
15
of this Stipulated Protective Order no Party waives any right it
16
otherwise would have to object to disclosing or producing any
17
18 information or item on any ground not addressed in this Stipulated
19 Protective Order. Similarly, no Party waives any right to object on any
20 ground to use in evidence of any of the material covered by this
21 Stipulated Protective Order.
22 12.3 Filing Protected Material. A Party that seeks to file under
23 seal any Protected Material must comply with Local Rule 79-5.
24 Protected Material may only be filed under seal pursuant to a court
25 order authorizing the sealing of the specific Protected Material at issue.
26 If a Party's request to file Protected Material under seal is denied by the
27
court, then the Receiving Party may file the information in the public
1 record unless otherwise instructed by the court.
2 13. FINAL DISPOSITION
3 After the Final Disposition of this Action, as defined in paragraph
4
4, within 60 days of a written request by the Designating Party, each
5
Receiving Party must return all Protected Material to the Producing
6
Party or destroy such material. As used in this subdivision, “all
7
Protected Material” includes all copies, abstracts, compilations,
8
summaries, and any other format reproducing or capturing any of the
9
Protected Material. Whether the Protected Material is returned or
10
destroyed, the Receiving Party must submit a written certification to
11
the Producing Party (and, if not the same person or entity, to the
12
Designating Party) by the 60 day deadline that (1) identifies (by
13
category, where appropriate) all the Protected Material that was
14
returned or destroyed and (2) affirms that the Receiving Party has not
15
retained any copies, abstracts, compilations, summaries or any other
16
format reproducing or capturing any of the Protected Material.
17
18 Notwithstanding this provision, Counsel is entitled to retain an archival
19 copy of all pleadings, motion papers, trial, deposition, and hearing
20 transcripts, legal memoranda, correspondence, deposition and trial
21 exhibits, expert reports, attorney work product, and consultant and
22 expert work product, even if such materials contain Protected Material.
23 Any such archival copies that contain or constitute Protected Material
24 remain subject to this Protective Order as set forth in Section 4.
25 14. VIOLATION
26 Any violation of this Stipulated Protective Order may be punished
27
by any and all appropriate measures including, without limitation,
1 || contempt proceedings and/or monetary sanctions.
2
3 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
A
5 DATED: 04/30/2025 Aijhiar dare, Xr
6 William Moran II
7 Attorney for Plaintiff Michael Gruen
8
DATED: 04/30/2025 ade QR,
9 TT
10 Jeremiah Reynolds
Attorney for Defendants Joshua
1 Richards, Christopher Sawtelle,
12 CrossCheck Studios, LLC and
3 Buddy’s Hard, LLC
14
15
'° || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
17
18 DATED: May 1, 2025
19
STEPHANIE 8S. CHRISTENSEN
20 United States Magistrate Judge
21
22
23
24
25
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