even stipulated 21 protective orders require good cause showing
How later courts described this case
- even stipulated 21 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 || THE LAW OFFICES OF DANIEL A. KAPLAN
Daniel A. Kaplan (SBN 179517)
2 || 555 West Beech Street, Suite 500
San Dicgo, CA 92101
3 || Tel: (61 □ 685-3988
Fax: (61 ) 684-3239
4 || Email: dkaplan@danielkaplanlaw.com
5 || PANAKOS LAW, APC
Aaron D. Sadock Esq. (SBN 28213 1)
6 || Veronica E. McKnight, Esq. (SBN 306562)
555 West Beech Street, Suite 500
7 || San Diego, California 92101
Telephone: (619) 800-0529
8 || Email: asadock@panakoslaw.com
9 Email: bmcknight@panakoslaw.com
Attorneys for Defendant
10 GERARD DOUGLAS
11 || Additional counsel listed on next page
12
13 UNITED STATES DISTRICT COURT
14 CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION
15
16 || CATALINA YACHTS, INC., a Case No. 2:25-cv-04090-SVW-RAO
17 California corporation,
18 Plaintiff, STIPULATED PROTECTIVE
Vv. ORDER
19
20 || SHARON DAY, an individual; Dis. Judge: Hon. Stephen V. Wilson
1 GERARD DOUGLAS, an individual; Mag. Judge: Hon. Rozella A. Oliver
and DOES 1 through 10, inclusive, Courtroom: 10A
22 Action Filed: May 7, 2025
23 Defendants.
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STIPULATED PROTECTIVE ORDER
Doc ID: ¢48ce69b02305F1 □□□□□□□□□□□□□□□□□□□□□□□□□
1 || Michael C. Lieb (SBN 126831)
mlieb@ecilaw com
2 || Zoe M. Vallier (SBN 324324)
zvallier@ecjlaw.com
3 || ERVIN EN & JESSUP LLP
9401 Wilshire Boulevard, Twelfth Floor
4 || Beverly Hills, California 90212-2974
Telephone: G 10) 273-6333
5 || Facsimile: (310) 859-2325
6 Attorneys for Plaintiff
7 CATALINA YACHTS, INC.
8 || SHUMAKER, LOOP & KENDRICK, LLP
Steven M. Berman (SBN 256846)
9 sberman@shumaker.com
101 East Kennedy Boulevard, Suite 2800
10 || Tampa, Florida 33602
Telephone: (813) 229-7600
11 |! Facsimile: (813) 229-1660 .
12 || Attorney for Defendant
3 SHARON DAY
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STIPULATED PROTECTIVE ORDER
Doc ID: ¢48cc69b02305f1 □□□□□□□□□□□□□□□□□□□□□□□□□
1 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
4 disclosure and from use for any purpose other than prosecuting this litigation may
5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
6 enter the following Stipulated Protective Order. The parties acknowledge that this
7 Order does not confer blanket protections on all disclosures or responses to
8 discovery and that the protection it affords from public disclosure and use extends
9 only to the limited information or items that are entitled to confidential treatment
10 under the applicable legal principles.
11 B. GOOD CAUSE STATEMENT
12 This action is likely to involve trade secrets, development, commercial,
13 financial, technical and/or proprietary information for which special protection
14 from public disclosure and from use for any purpose other than prosecution of this
15 action is warranted. Such confidential and proprietary materials and information
16 consist of, among other things, confidential business or financial information,
17 information regarding confidential business practices, or other confidential
18 research, development, or commercial information (including information
19 implicating privacy rights of third parties), information otherwise generally
20 unavailable to the public, or which may be privileged or otherwise protected from
21 disclosure under state or federal statutes, court rules, case decisions, or common
22 law. Specifically, the parties are aware that confidentiality provisions exist within
23 documents related to the sale of certain assets from Catalina Yachts, Inc. Given the
24 sensitive business and financial information contained therein, the Parties agree
25 this protective order is necessary. Accordingly, to expedite the flow of information,
26 to facilitate the prompt resolution of disputes over confidentiality of discovery
27 materials, to adequately protect information the parties are entitled to keep
1 such material in preparation for and in the conduct of trial, to address their
2 handling at the end of the litigation, and serve the ends of justice, a protective order
3 for such information is justified in this matter. It is the intent of the parties that
4 information will not be designated as confidential for tactical reasons and that
5 nothing be so designated without a good faith belief that it has been maintained in
6 a confidential, non-public manner, and there is good cause why it should not be
7 part of the public record of this case.
8 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
9 SEAL
10 The parties further acknowledge, as set forth in Section 12.3, below, that
11 this Stipulated Protective Order does not entitle them to file confidential
12 information under seal; Local Civil Rule 79-5 sets forth the procedures that must
13 be followed and the standards that will be applied when a party seeks permission
14 from the court to file material under seal.
15 There is a strong presumption that the public has a right of access to judicial
16 proceedings and records in civil cases. In connection with non-dispositive
17 motions, good cause must be shown to support a filing under seal. See Kamakana
18 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v.
19 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v.
20 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
21 protective orders require good cause showing), and a specific showing of good
22 cause or compelling reasons with proper evidentiary support and legal justification,
23 must be made with respect to Protected Material that a party seeks to file under
24 seal. The parties’ mere designation of Disclosure or Discovery Material as
25 CONFIDENTIAL does not—without the submission of competent evidence by
26 declaration, establishing that the material sought to be filed under seal qualifies as
27 confidential, privileged, or otherwise protectable—constitute good cause.
1 Further, if a party requests sealing related to a dispositive motion or trial,
2 then compelling reasons, not only good cause, for the sealing must be shown, and
3 the relief sought shall be narrowly tailored to serve the specific interest to be
4 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.
5 2010). For each item or type of information, document, or thing sought to be filed
6 or introduced under seal in connection with a dispositive motion or trial, the party
7 seeking protection must articulate compelling reasons, supported by specific facts
8 and legal justification, for the requested sealing order. Again, competent evidence
9 supporting the application to file documents under seal must be provided by
10 declaration.
11 Any document that is not confidential, privileged, or otherwise protectable
12 in its entirety will not be filed under seal if the confidential portions can be
13 redacted. If documents can be redacted, then a redacted version for public
14 viewing, omitting only the confidential, privileged, or otherwise protectable
15 portions of the document shall be filed. Any application that seeks to file
16 documents under seal in their entirety should include an explanation of why
17 redaction is not feasible.
18 2. DEFINITIONS
19 2.1 Action: Catalina Yachts, Inc. v. Sharon Day et al., Civil Action No.
20 2:25-cv-04090-SVW-RAO.
21 2.2 Challenging Party: a Party or Non-Party that challenges the
22 designation of information or items under this Order.
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
26 the Good Cause Statement.
27 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
1 2.5 Designating Party: a Party or Non-Party that designates information
2 or items that it produces in disclosures or in responses to discovery as
3 “CONFIDENTIAL.”
4 2.6 Disclosure or Discovery Material: all items or information, regardless
5 of the medium or manner in which it is generated, stored, or maintained (including,
6 among other things, testimony, transcripts, and tangible things) that are produced
7 or generated in disclosures or responses to discovery in this matter.
8 2.7 Expert: a person with specialized knowledge or experience in a
9 matter pertinent to the litigation who has been retained by a Party or its counsel to
10 serve as an expert witness or as a consultant in this Action.
11 2.8 House Counsel: attorneys who are employees of a party to this
12 Action. House Counsel does not include Outside Counsel of Record or any other
13 outside counsel.
14 2.9 Non-Party: any natural person, partnership, corporation, association
15 or other legal entity not named as a Party to this action.
16 2.10 Outside Counsel of Record: attorneys who are not employees of a
17 party to this Action but are retained to represent or advise a party to this Action
18 and have appeared in this Action on behalf of that party or are affiliated with a law
19 firm that has appeared on behalf of that party, and includes support staff.
20 2.11 Party: any party to this Action, including all of its officers, directors,
21 employees, consultants, retained experts, and Outside Counsel of Record (and their
22 support staffs).
23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
24 Discovery Material in this Action.
25 2.13 Professional Vendors: persons or entities that provide litigation
26 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
27 demonstrations, and organizing, storing, or retrieving data in any form or medium)
1 2.14 Protected Material: any Disclosure or Discovery Material that is
2 designated as “CONFIDENTIAL.”
3 2.15 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 only
7 Protected Material (as defined above), but also (1) any information copied or
8 extracted from Protected Material; (2) all copies, excerpts, summaries, or
9 compilations of Protected Material; and (3) any testimony, conversations, or
10 presentations by Parties or their Counsel that might reveal Protected Material.
11 Any use of Protected Material at trial shall be governed by the orders of the
12 trial judge. This Order does not govern the use of Protected Material at trial.
13 4. DURATION
14 Once a case proceeds to trial, information that was designated as
15 CONFIDENTIAL or maintained pursuant to this protective order used or
16 introduced as an exhibit at trial becomes public and will be presumptively
17 available to all members of the public, including the press, unless compelling
18 reasons supported by specific factual findings to proceed otherwise are made to the
19 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
20 (distinguishing “good cause” showing for sealing documents produced in
21 discovery from “compelling reasons” standard when merits-related documents are
22 part of court record). Accordingly, the terms of this protective order do not extend
23 beyond the commencement of the trial.
24 5. DESIGNATING PROTECTED MATERIAL
25 5.1 Exercise of Restraint and Care in Designating Material for Protection.
26 Each Party or Non-Party that designates information or items for protection under
27 this Order must take care to limit any such designation to specific material that
1 for protection only those parts of material, documents, items or oral or written
2 communications that qualify so that other portions of the material, documents,
3 items or communications for which protection is not warranted are not swept
4 unjustifiably within the ambit of this Order.
5 Mass, indiscriminate or routinized designations are prohibited. Designations
6 that are shown to be clearly unjustified or that have been made for an improper
7 purpose (e.g., to unnecessarily encumber the case development process or to
8 impose unnecessary expenses and burdens on other parties) may expose the
9 Designating Party to sanctions.
10 If it comes to a Designating Party’s attention that information or items that it
11 designated for protection do not qualify for protection, that Designating Party must
12 promptly notify all other Parties that it is withdrawing the inapplicable designation.
13 5.2 Manner and Timing of Designations. Except as otherwise provided in
14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
15 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
16 under this Order must be clearly so designated before the material is disclosed or
17 produced.
18 Designation in conformity with this Order requires:
19 (a) for information in documentary form (e.g., paper or electronic
20 documents, but excluding transcripts of depositions or other pretrial or trial
21 proceedings), that the Producing Party affix at a minimum, the legend
22 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
23 contains protected material. If only a portion of the material on a page qualifies for
24 protection, the Producing Party also must clearly identify the protected portion(s)
25 (e.g., by making appropriate markings in the margins).
26 A Party or Non-Party that makes original documents available for inspection
27 need not designate them for protection until after the inspecting Party has indicated
1 before the designation, all of the material made available for inspection shall be
2 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
3 documents it wants copied and produced, the Producing Party must determine
4 which documents, or portions thereof, qualify for protection under this Order.
5 Then, before producing the specified documents, the Producing Party must affix
6 the “CONFIDENTIAL legend” to each page that contains Protected Material. If
7 only a portion of the material on a page qualifies for protection, the Producing
8 Party also must clearly identify the protected portion(s) (e.g., by making
9 appropriate markings in the margins).
10 (b) for testimony given in depositions that the Designating Party identifies
11 the Disclosure or Discovery Material on the record, before the close of the
12 deposition all protected testimony.
13 (c) for information produced in some form other than documentary and for
14 any other tangible items, that the Producing Party affix in a prominent place on the
15 exterior of the container or containers in which the information is stored the legend
16 “CONFIDENTIAL.” If only a portion or portions of the information warrants
17 protection, the Producing Party, to the extent practicable, shall identify the
18 protected portion(s).
19 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
20 failure to designate qualified information or items does not, standing alone, waive
21 the Designating Party’s right to secure protection under this Order for such
22 material. Upon timely correction of a designation, the Receiving Party must make
23 reasonable efforts to assure that the material is treated in accordance with the
24 provisions of this Order.
25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
26 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
27 designation of confidentiality at any time that is consistent with the Court’s
1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
2 resolution process under Local Rule 37.1 et seq.
3 6.3 The burden of persuasion in any such challenge proceeding shall be
4 on the Designating Party. Frivolous challenges, and those made for an improper
5 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
6 parties) may expose the Challenging Party to sanctions. Unless the Designating
7 Party has waived or withdrawn the confidentiality designation, all parties shall
8 continue to 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 the
10 challenge.
11 7. ACCESS TO AND USE OF PROTECTED MATERIAL
12 7.1 Basic Principles. A Receiving Party may use Protected Material that
13 is disclosed or produced by another Party or by a Non-Party in connection with this
14 Action only for prosecuting, defending or attempting to settle this Action. Such
15 Protected Material may be disclosed only to the categories of persons and under
16 the conditions described in this Order. When the Action has been terminated, a
17 Receiving Party must comply with the provisions of section 13 below (FINAL
18 DISPOSITION).
19 Protected Material must be stored and maintained by a Receiving Party at a
20 location and in a secure manner that ensures that access is limited to the persons
21 authorized under this Order.
22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
23 otherwise ordered by the court or permitted in writing by the Designating Party, a
24 Receiving Party may disclose any information or item designated
25 “CONFIDENTIAL” only to:
26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
27 as employees of said Outside Counsel of Record to whom it is reasonably
1 (b) the officers, directors, and employees (including House Counsel) of the
2 Receiving Party to whom disclosure is reasonably necessary for this Action;
3 (c) Experts (as defined in this Order) of the Receiving Party to whom
4 disclosure is reasonably necessary for this Action and who have signed the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
6 (d) the court and its personnel;
7 (e) court reporters and their staff;
8 (f) professional jury or trial consultants, mock jurors, and Professional
9 Vendors to whom disclosure is reasonably necessary for this Action and who have
10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
11 (g) the author or recipient of a document containing the information or a
12 custodian or other person who otherwise possessed or knew the information;
13 (h) during their depositions, witnesses, and attorneys for witnesses, in the
14 Action to whom disclosure is reasonably necessary provided: (1) the deposing
15 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
16 they will not be permitted to keep any confidential information unless they sign the
17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
18 agreed by the Designating Party or ordered by the court. Pages of transcribed
19 deposition testimony or exhibits to depositions that reveal Protected Material may
20 be separately bound by the court reporter and may not be disclosed to anyone
21 except as permitted under this Stipulated Protective Order; and
22 (i) any mediator or settlement officer, and their supporting personnel,
23 mutually agreed upon by any of the parties engaged in settlement discussions.
24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
25 IN OTHER LITIGATION
26 If a Party is served with a subpoena or a court order issued in other litigation
27 that compels disclosure of any information or items designated in this Action as
1 (a) promptly notify in writing the Designating Party. Such notification shall
2 include a copy of the subpoena or court order;
3 (b) promptly notify in writing the party who caused the subpoena or order to
4 issue in the other litigation that some or all of the material covered by the subpoena
5 or order is subject to this Protective Order. Such notification shall include a copy
6 of this Stipulated Protective Order; and
7 (c) cooperate with respect to all reasonable procedures sought to be pursued
8 by the Designating Party whose Protected Material may be affected.
9 If the Designating Party timely seeks a protective order, the Party served
10 with the subpoena or court order shall not produce any information designated in
11 this action as “CONFIDENTIAL” before a determination by the court from which
12 the subpoena or order issued, unless the Party has obtained the Designating Party’s
13 permission. The Designating Party shall bear the burden and expense of seeking
14 protection in that court of its confidential material and nothing in these provisions
15 should be construed as authorizing or encouraging a Receiving Party in this Action
16 to disobey a lawful directive from another court.
17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
18 PRODUCED IN THIS LITIGATION
19 (a) The terms of this Order are applicable to information produced by a
20 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
21 produced by Non-Parties in connection with this litigation is protected by the
22 remedies and relief provided by this Order. Nothing in these provisions should be
23 construed as prohibiting a Non-Party from seeking additional protections.
24 (b) In the event that a Party is required, by a valid discovery request, to
25 produce a Non-Party’s confidential information in its possession, and the Party is
26 subject to an agreement with the Non-Party not to produce the Non-Party’s
27 confidential information, then the Party shall:
1 (1) promptly notify in writing the Requesting Party and the Non-
2 Party that some or all of the information requested is subject to a confidentiality
3 agreement with a Non-Party;
4 (2) promptly provide the Non-Party with a copy of the Stipulated
5 Protective Order in this Action, the relevant discovery request(s), and a reasonably
6 specific description of the information requested; and
7 (3) make the information requested available for inspection by the
8 Non-Party, if requested.
9 (c) If the Non-Party fails to seek a protective order from this court within 14
10 days of receiving the notice and accompanying information, the Receiving Party
11 may produce the Non-Party’s confidential information responsive to the discovery
12 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
13 not produce any information in its possession or control that is subject to the
14 confidentiality agreement with the Non-Party before a determination by the court.
15 Absent a court order to the contrary, the Non-Party shall bear the burden and
16 expense of seeking protection in this court of its Protected Material.
17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
18 If a Receiving Party learns that, by inadvertence or otherwise, it has
19 disclosed Protected Material to any person or in any circumstance not authorized
20 under this Stipulated Protective Order, the Receiving Party must immediately (a)
21 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
22 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
23 the person or persons to whom unauthorized disclosures were made of all the terms
24 of this Order, and (d) request such person or persons to execute the
25 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
26 A.
27 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
1 When a Producing Party gives notice to Receiving Parties that certain
2 inadvertently produced material is subject to a claim of privilege or other
3 protection, the obligations of the Receiving Parties are those set forth in Federal
4 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
5 whatever procedure may be established in an e-discovery order that provides for
6 production without prior privilege review. Pursuant to Federal Rule of Evidence
7 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
8 of a communication or information covered by the attorney-client privilege or
9 work product protection, the parties may incorporate their agreement in the
10 stipulated protective order submitted to the court.
11 12. MISCELLANEOUS
12 12.1 Right to Further Relief. Nothing in this Order abridges the right of
13 any person to seek its modification by the Court in the future.
14 12.2 Right to Assert Other Objections. By stipulating to the entry of this
15 Protective Order, no Party waives any right it otherwise would have to object to
16 disclosing or producing any information or item on any ground not addressed in
17 this Stipulated Protective Order. Similarly, no Party waives any right to object on
18 any ground to use in evidence of any of the material covered by this Protective
19 Order.
20 12.3 Filing Protected Material. A Party that seeks to file under seal any
21 Protected Material must comply with Local Civil Rule 79-5. Protected Material
22 may only be filed under seal pursuant to a court order authorizing the sealing of the
23 specific Protected Material at issue. If a Party’s request to file Protected Material
24 under seal is denied by the court, then the Receiving Party may file the information
25 in the public record unless otherwise instructed by the court.
26 13. FINAL DISPOSITION
27 After the final disposition of this Action, as defined in paragraph 4, within
1 return all Protected Material to the Producing Party or destroy such material. As
2 used in this subdivision, “all Protected Material” includes all copies, abstracts,
3 compilations, summaries, and any other format reproducing or capturing any of the
4 Protected Material. Whether the Protected Material is returned or destroyed, the
5 Receiving Party must submit a written certification to the Producing Party (and, if
6 not the same person or entity, to the Designating Party) by the 60 day deadline that
7 (1) identifies (by category, where appropriate) all the Protected Material that was
8 returned or destroyed and (2) affirms that the Receiving Party has not retained any
9 copies, abstracts, compilations, summaries or any other format reproducing or
10 capturing any of the Protected Material. Notwithstanding this provision, Counsel
11 are entitled to retain an archival copy of all pleadings, motion papers, trial,
12 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
13 and trial exhibits, expert reports, attorney work product, and consultant and expert
14 work product, even if such materials contain Protected Material. Any such
15 archival copies that contain or constitute Protected Material remain subject to this
16 Protective Order as set forth in Section 4 (DURATION).
17 ///
18 ///
19 ///
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25 ///
26 ///
27 ///
1 || 14. VIOLATION
2 || Any violation of this Order may be punished by appropriate measures including,
3 || without limitation, contempt proceedings and/or monetary sanctions.
4 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5
Dated: 07 / 21 / 2025 ERVIN COHEN & JESSUP LLP
6
7 By: Vichael Lieb
g Michael C. Lieb
Attorneys for Plaintiff
? CATALINA YACHTS, INC.
10
Il || Dated: 07 / 20 / 2025 LAW OFFICES OF DANIEL A. KAPLAN
Manel A kagl
. an
13 By: oe
Daniel A. Kaplan
14 Attorneys for Defendant
15 GERARD DOUGLAS
16
17 || Dated: 7/20/2025 PANAKOS LAW, APC
18
By: // Veronica E. McKnight
19 Veronica E. McKnight
20 Attorneys for Defendant
> GERARD DOUGLAS
22
33 Dated: 7/25/2025 SHUMAKER, LOOP & KENDRICK LLP
24 By: /s/ Steven M. Berman
25 Steven M. Berman
5 Attorneys for Defendant
6 SHARON DAY
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1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
3 || DATED: 7/25/2025,
4 .
s|Rayells, Or, OC
6 || United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on _____________ [date] in the case of Catalina Yachts, Inc. v. Sharon Day et al.,
8 Civil Action No. 2:25-cv-04090-SVW-RAO. I agree to comply with and to be
9 bound by all the terms of this Stipulated Protective Order and I understand and
10 acknowledge that failure to so comply could expose me to sanctions and
11 punishment in the nature of contempt. I solemnly promise that I will not disclose
12 in any manner any information or item that is subject to this Stipulated Protective
13 Order to any person or entity except in strict compliance with the provisions of this
14 Order.
15 I further agree to submit to the jurisdiction of the United States District Court for
16 the Central District of California for enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of
18 this action. I hereby appoint __________________________ [print or type full
19 name] of _______________________________________ [print or type full
20 address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27