Opinion

Court: District Court, C.D. California
Filed: Oct 24, 2025
Cited by: 0 cases
Authority: More cited than 35.9%

even stipulated protective orders 25 require good cause showing

How later courts described this case

even stipulated protective orders 25 require good cause showing

Written by the judges who cited it.

The opinion

1 KEMNITZER, BARRON & KRIEG, LLP

KRISTIN KEMNITZER Bar No. 278946

2 ADAM J. MCNEILE Bar No. 280296

MALACHI J. HASWELL Bar No. 307729

3 KATHERINE SASS Bar No. 326185

1120 Mar West St., Ste. C-2

4 Tiburon, CA 94920

Telephone: (415) 632-1900

5 Facsimile: (415) 632-1901

kristin@kbklegal.com

6 adam@kbklegal.com

kai@kbklegal.com

7 katie@kbklegal.com

Attorneys for Plaintiff TAYLOR HANEY

David A. Berkley (Bar No. 260105)

9 Monique G. Matar (Bar No. 317145)

WOMBLE BOND DICKINSON (US) LLP

10 400 Spectrum Center Drive, Suite 1700

Irvine, CA 92618

11 Telephone: (714) 557-3800

Facsimile: (714) 557-3347

12 Email: David.Berkley@wbd-us.com

Email: Monique.Matar@wbd-us.com

Attorneys for Defendant

14 SERVICE FINANCE COMPANY, LLC

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Taylor Haney

Case No.: 5:25−cv−01338−KK

20 Plaintiff(s),

(SSCx)

21 v.

22 Service Finance Company STIPULATED PROTECTIVE

ORDER1

23 Defendant(s).

1 This Stipulated Protective Order is substantially based on the model

protective order provided under Magistrate Judge Stephanie S.

1 1. INTRODUCTION

2 1.1 Purposes and Limitations. Discovery in this action is likely to

3 involve production of confidential, proprietary, or private information for

4 which special protection from public disclosure and from use for any

5 purpose other than prosecuting this litigation may be warranted.

6 Accordingly, the parties hereby stipulate to and petition the court to enter

7 the following Stipulated Protective Order. The parties acknowledge that

this Order does not confer blanket protections on all disclosures or

responses to discovery and that the protection it affords from public

disclosure and use extends only to the limited information or items that

are entitled to confidential treatment under the applicable legal

principles.

1.2 Good Cause Statement.

This action is likely to involve trade secrets, customer and pricing

lists and other valuable research, development, commercial, financial,

technical and/or proprietary information for which special protection from

public disclosure and from use for any purpose other than prosecution of

this action is warranted. Such confidential and proprietary materials and

information consist of, among other things, confidential business or

financial information, information regarding confidential business

22 practices, or other confidential research, development, or commercial

23 information (including information implicating privacy rights of third

24 parties), information otherwise generally unavailable to the public, or

25 which may be privileged or otherwise protected from disclosure under

26 state or federal statutes, court rules, case decisions, or common law.

27 Accordingly, to expedite the flow of information, to facilitate the prompt

1 adequately protect information the parties are entitled to keep

2 confidential, to ensure that the parties are permitted reasonable necessary

3 uses of such material in preparation for and in the conduct of trial, to

4 address their handling at the end of the litigation, and serve the ends of

5 justice, a protective order for such information is justified in this matter.

6 It is the intent of the parties that information will not be designated as

7 confidential for tactical reasons and that nothing be so designated without

a good faith belief that it has been maintained in a confidential, non-public

manner, and there is good cause why it should not be part of the public

record of this case.

1.3 Acknowledgment of Procedure for Filing Under Seal. The

parties further acknowledge, as set forth in Section 12.3, below, that this

Stipulated Protective Order does not entitle them to file confidential

information under seal; Local Rule 79-5 sets forth the procedures that

must be followed and the standards that will be applied when a party

seeks permission from the court to file material under seal.

There is a strong presumption that the public has a right of access

to judicial proceedings and records in civil cases. In connection with non-

dispositive motions, good cause must be shown to support a filing under

seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176

22 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307

23 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., Inc.,

24 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

25 require good cause showing), and a specific showing of good cause or

26 compelling reasons with proper evidentiary support and legal

27 justification, must be made with respect to Protected Material that a

1 or Discovery Material as CONFIDENTIAL does not—without the

2 submission of competent evidence by declaration, establishing that the

3 material sought to be filed under seal qualifies as confidential, privileged,

4 or otherwise protectable—constitute good cause.

5 Further, if a party requests sealing related to a dispositive motion

6 or trial, then compelling reasons, not only good cause, for the sealing must

7 be shown, and the relief sought shall be narrowly tailored to serve the

specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 605

F.3d 665, 677–79 (9th Cir. 2010). For each item or type of information,

document, or thing sought to be filed or introduced under seal in

connection with a dispositive motion or trial, the party seeking protection

must articulate compelling reasons, supported by specific facts and legal

justification, for the requested sealing order. Again, competent evidence

supporting the application to file documents under seal must be provided

by declaration.

Any document that is not confidential, privileged, or otherwise

protectable in its entirety will not be filed under seal if the confidential

portions can be redacted. If documents can be redacted, then a redacted

version for public viewing, omitting only the confidential, privileged, or

otherwise protectable portions of the document, shall be filed. Any

22 application that seeks to file documents under seal in their entirety

23 should include an explanation of why redaction is not feasible.

24 2. DEFINITIONS

25 2.1 Action: This pending federal lawsuit.

26 2.2 Challenging Party: a Party or Non-Party that challenges the

designation of information or items under this Order.

1 2.3 “CONFIDENTIAL” Information or Items: information

2 (regardless of how it is generated, stored or maintained) or tangible things

3 that qualify for protection under Rule 26(c) of the Federal Rules of Civil

4 Procedure, and as specified above in the Good Cause Statement.

5 2.4 Counsel: Outside Counsel of Record and House Counsel (as

6 well as their support staff).

7 2.5 Designating Party: a Party or Non-Party that designates

information or items that it produces in disclosures or in responses to

discovery as “CONFIDENTIAL.”

2.6 Disclosure or Discovery Material: all items or information,

regardless of the medium or manner in which it is generated, stored, or

maintained (including, among other things, testimony, transcripts, and

tangible things), that are produced or generated in disclosures or

responses to discovery in this matter.

2.7 Expert: a person with specialized knowledge or experience in a

matter pertinent to the litigation who has been retained by a Party or its

counsel to serve as an expert witness or as a consultant in this Action.

2.8 Final Disposition: the later of (1) dismissal of all claims and

defenses in this Action, with or without prejudice; and (2) final judgment

herein after the completion and exhaustion of all appeals, rehearings,

22 remands, trials, or reviews of this Action, including the time limits for

23 filing any motions or applications for extension of time pursuant to

24 applicable law.

25 2.9 In-House Counsel: attorneys who are employees of a party to

26 this Action. In-House Counsel does not include Outside Counsel of Record

27 or any other outside counsel.

1 association, or other legal entity not named as a Party to this action.

2 2.11 Outside Counsel of Record: attorneys who are not employees of

3 a party to this Action but are retained to represent or advise a party to

4 this Action and have appeared in this Action on behalf of that party or are

5 affiliated with a law firm which has appeared on behalf of that party, and

6 includes support staff.

7 2.12 Party: any party to this Action, including all of its officers,

directors, employees, consultants, retained experts, and Outside Counsel

of Record (and their support staffs).

2.13 Producing Party: a Party or Non-Party that produces

Disclosure or Discovery Material in this Action.

2.14 Professional Vendors: persons or entities that provide

litigation- support services (e.g., photocopying, videotaping, translating,

preparing exhibits or demonstrations, and organizing, storing, or

retrieving data in any form or medium) and their employees and

subcontractors.

2.15 Protected Material: any Disclosure or Discovery Material that

is designated as “CONFIDENTIAL.”

2.16 Receiving Party: a Party that receives Disclosure or Discovery

Material from a Producing Party.

22 3. SCOPE

23 The protections conferred by this Stipulation and Order cover not

24 only Protected Material (as defined above), but also (1) any information

25 copied or extracted from Protected Material; (2) all copies, excerpts,

26 summaries, or compilations of Protected Material; and (3) any testimony,

conversations, or presentations by Parties or their Counsel that might

1 reveal Protected Material.

2 Any use of Protected Material at trial shall be governed by the

3 orders of the trial judge. This Stipulated Protective Order does not

4 govern the use of Protected Material at trial.

5 4. USE OF ANY ARTIFICAL INTELIGENCE (“AI”) PLATFORMS

The Parties acknowledge the inherent risks of sharing confidential

information with generative AI platforms (i.e., that platforms retain and

learn from the uploaded information). Accordingly, the Parties agree that

they are expressly prohibited from inputting any information produced

pursuant to this Stipulated Protective Order to any open Generative AI

platform, subject to this Section.

Specifically, any and all information or documentation produced by

any Party designated and properly marked as CONFIDENTIAL shall not

be submitted to any open Generative AI tool (e.g., ChatGPT) or any

substantially similar tool that is available to the public. Providing

information designated and properly marked as CONFIDENTIAL to an

open tool is considered disclosure to a third party and is strictly prohibited.

Before any Party receiving information designated as CONFIDENTIAL

submits such information to any closed Generative AI tool, the receiving

party shall ensure that the tool is not accessible to the public, is used in a

secure, controlled environment, and gives the receiving party the

capability to delete all such confidential information from the tool at the

close of the matter. The receiving Party will be responsible for destroying

such confidential produced information from such tools at the end of the

matter.

26 5. TRIAL AND DURATION

The terms of this Stipulated Protective Order apply through Final

1 Disposition of the Action.

2 Once a case proceeds to trial, information that was designated as

3 CONFIDENTIAL or maintained pursuant to this Stipulated Protective

Order and used or introduced as an exhibit at trial becomes public and

will be presumptively available to all members of the public, including

the press, unless compelling reasons supported by specific factual

findings to proceed otherwise are made to the trial judge in advance of

the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good

cause” showing for sealing documents produced in discovery from

“compelling reasons” standard when merits-related documents are part

of court record). Accordingly, for such materials, the terms of this

Stipulated Protective Order do not extend beyond the commencement of

the trial.

Even after Final Disposition of this litigation, the confidentiality

obligations imposed by this Stipulated Protective Order shall remain in

effect until a Designating Party agrees otherwise in writing or a court

18 order otherwise directs.

19 6. DESIGNATING PROTECTED MATERIAL

20 5.1 Exercise of Restraint and Care in Designating Material for

21 Protection. Each Party or Non-Party that designates information or items

22 for protection under this Order must take care to limit any such

designation to specific material that qualifies under the appropriate

standards. The Designating Party must designate for protection only

those parts of material, documents, items, or oral or written

communications that qualify so that other portions of the material,

documents, items, or communications for which protection is not

1 warranted are not swept unjustifiably within the ambit of this Order.

2 Mass, indiscriminate, or routinized designations are prohibited.

3 Designations that are shown to be clearly unjustified or that have been

4 made for an improper purpose (e.g., to unnecessarily encumber the case

5 development process or to impose unnecessary expenses and burdens on

6 other parties) may expose the Designating Party to sanctions.

7 If it comes to a Designating Party’s attention that information or

items that it designated for protection do not qualify for protection, that

Designating Party must promptly notify all other Parties that it is

withdrawing the inapplicable designation.

5.2 Manner and Timing of Designations. Except as otherwise

provided in this Stipulated Protective Order (see, e.g., second paragraph of

section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or

Discovery Material that qualifies for protection under this Stipulated

Protective Order must be clearly so designated before the material is

disclosed or produced.

18 Designation in conformity with this Stipulated Protective Order

19 requires:

20 (a) for information in documentary form (e.g., paper or electronic

21 documents, but excluding transcripts of depositions or other pretrial or

22 trial proceedings), that the Producing Party affix at a minimum, the

23 legend “CONFIDENTIAL” to each page that contains protected material.

24 If only a portion or portions of the material on a page qualifies for

25 protection, the Producing Party also must clearly identify the protected

portion(s) (e.g., by making appropriate markings in the margins).

A Party or Non-Party that makes original documents available for

1 inspection need not designate them for protection until after the

2 inspecting Party has indicated which documents it would like copied and

3 produced. During the inspection and before the designation, all of the

4 material made available for inspection shall be deemed

5 CONFIDENTIAL. After the inspecting Party has identified the

6 documents it wants copied and produced, the Producing Party must

7 determine which documents, or portions thereof, qualify for protection

under this Stipulated Protective Order. Then, before producing the

specified documents, the Producing Party must affix the

“CONFIDENTIAL” legend to each page that contains Protected Material.

If only a portion or portions of the material on a page qualifies for

protection, the Producing Party also must clearly identify the protected

portion(s) (e.g., by making appropriate markings in the margins).

(b) for testimony given in depositions that the Designating Party

identify the Disclosure or Discovery Material on the record, before the

close of the deposition all protected testimony.

documentary and for any other tangible items, that the Producing Party

affix in a prominent place on the exterior of the container or containers in

which the information is stored the “CONFIDENTIAL” legend. If only a

22 portion or portions of the information warrants protection, the Producing

23 Party, to the extent practicable, shall identify the protected portion(s).

24 5.3 Inadvertent Failures to Designate. If timely corrected, an

25 inadvertent failure to designate qualified information or items does not,

26 standing alone, waive the Designating Party’s right to secure protection

under this Order for such material. Upon timely correction of a

1 designation, the Receiving Party must make reasonable efforts to assure

2 that the material is treated in accordance with the provisions of this

3 Stipulated Protective Order.

4 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS

7.1 Timing of Challenges. Any Party or Non-Party may challenge

a designation of confidentiality at any time that is consistent with the

court’s Scheduling Order.

7.2 Meet and Confer. The Challenging Party shall initiate the

dispute resolution process under Local Rule 37.1 et seq. and with Section

2 of Judge Christensen’s Civil Procedures titled “Brief Pre-Discovery

Motion Conference.”2

7.3 The burden of persuasion in any such challenge proceeding

shall be on the Designating Party. Frivolous challenges, and those made

for an improper purpose (e.g., to harass or impose unnecessary expenses

and burdens on other parties) may expose the Challenging Party to

sanctions. Unless the Designating Party has waived or withdrawn the

18 confidentiality designation, all parties shall continue to afford the

19 material in question the level of protection to which it is entitled under

20 the Producing Party’s designation until the court rules on the challenge.

21 8. ACCESS TO AND USE OF PROTECTED MATERIAL

22 8.1 Basic Principles. A Receiving Party may use Protected

Material that is disclosed or produced by another Party or by a Non-Party

in connection with this Action only for prosecuting, defending, or

attempting to settle this Action. Such Protected Material may be

2 Judge Christensen’s Procedures are available at

1 disclosed only to the categories of persons and under the conditions

2 described in this Order. When the Action reaches a Final Disposition, a

3 Receiving Party must comply with the provisions of section 13 below.

4 Protected Material must be stored and maintained by a Receiving

5 Party at a location and in a secure manner that ensures that access is

6 limited to the persons authorized under this Stipulated Protective Order.

7 8.2 Disclosure of “CONFIDENTIAL” Information or Items.

Unless otherwise ordered by the court or permitted in writing by the

Designating Party, a Receiving Party may disclose any information or

item designated “CONFIDENTIAL” only:

(a) to the Receiving Party’s Outside Counsel of Record in this

Action, as well as employees of said Outside Counsel of Record to whom

it is reasonably necessary to disclose the information for this Action;

(b) to the officers, directors, and employees (including House

Counsel) of the Receiving Party to whom disclosure is reasonably

necessary for this Action;

whom disclosure is reasonably necessary for this Action and who have

signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

(d) to the court and its personnel;

22 (e) to court reporters and their staff;

23 (f) to professional jury or trial consultants, mock jurors, and

24 Professional Vendors to whom disclosure is reasonably necessary for this

25 Action and who have signed the “Acknowledgment and Agreement to Be

26 Bound” (Exhibit A);

27 (g) to the author or recipient of a document containing the

1 knew the information;

2 (h) during their depositions, to witnesses, and attorneys for

3 witnesses, in the Action to whom disclosure is reasonably necessary,

4 provided: (1) the deposing party requests that the witness sign the

5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the

6 witness will not be permitted to keep any confidential information unless

7 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),

unless otherwise agreed by the Designating Party or ordered by the court.

Pages of transcribed deposition testimony or exhibits to depositions that

reveal Protected Material may be separately bound by the court reporter

and may not be disclosed to anyone except as permitted under this

Stipulated Protective Order; and

(i) to any mediator or settlement officer, and their supporting

personnel, mutually agreed upon by any of the parties engaged in

settlement discussions.

9. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

19 If a Party is served with a subpoena or a court order issued in other

20 litigation that compels disclosure of any information or items designated

21 in this Action as “CONFIDENTIAL,” that Party must:

22 (a) promptly notify in writing the Designating Party. Such

notification shall include a copy of the subpoena or court order;

(b) promptly notify in writing the party who caused the subpoena

or order to issue in the other litigation that some or all of the material

covered by the subpoena or order is subject to this Protective Order. Such

notification shall include a copy of this Stipulated Protective Order; and

1 (c) cooperate with respect to all reasonable procedures sought to

2 be pursued by the Designating Party whose Protected Material may be

3 affected.

4 If the Designating Party timely seeks a protective order, the

5 Party served with the subpoena or court order shall not produce any

6 information designated in this action as “CONFIDENTIAL” before a

7 determination by the court from which the subpoena or order issued,

unless the Party has obtained the Designating Party’s permission. The

Designating Party shall bear the burden and expense of seeking

protection in that court of its confidential material and nothing in these

provisions should be construed as authorizing or encouraging a Receiving

Party in this Action to disobey a lawful directive from another court.

10. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

9.1 Application. The terms of this Stipulated Protective Order are

applicable to information produced by a Non-Party in this Action and

designated as “CONFIDENTIAL.” Such information produced by Non-

Parties in connection with this litigation is protected by the remedies and

relief provided by this Order. Nothing in these provisions should be

construed as prohibiting a Non-Party from seeking additional protections.

22 9.2 Notification. In the event that a Party is required, by a valid

23 discovery request, to produce a Non-Party’s confidential information in its

24 possession, and the Party is subject to an agreement with the Non-Party

25 not to produce the Non-Party’s confidential information, then the Party

26 shall:

27 (a) promptly notify in writing the Requesting Party and the Non-

1 confidentiality agreement with a Non-Party;

2 (b) make the information requested available for inspection by

3 the Non-Party, if requested.

4 9.3 Conditions of Production. If the Non-Party fails to seek a

5 protective order from this court within 14 days of receiving the notice and

6 accompanying information, the Receiving Party may produce the Non-

7 Party’s confidential information responsive to the discovery request. If the

Non-Party timely seeks a protective order, the Receiving Party shall not

produce any information in its possession or control that is subject to the

confidentiality agreement with the Non-Party before a determination by

the court. Absent a court order to the contrary, the Non-Party shall bear

the burden and expense of seeking protection in this court of its Protected

Material.

11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it

has disclosed Protected Material to any person or in any circumstance not

18 authorized under this Stipulated Protective Order, the Receiving Party

19 must immediately (a) notify in writing the Designating Party of the

20 unauthorized disclosures, (b) use its best efforts to retrieve all

21 unauthorized copies of the Protected Material, (c) inform the person or

22 persons to whom unauthorized disclosures were made of all the terms of

23 this Order, and (d) request such person or persons to execute the

24 “Acknowledgment and Agreement to Be Bound” (Exhibit A).

12. INADVERTENT PRODUCTION OF PRIVILEGED OR

OTHERWISE PROTECTED MATERIAL

1 certain inadvertently produced material is subject to a claim of privilege

2 or other protection, the obligations of the Receiving Parties are those set

3 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This

4 provision is not intended to modify whatever procedure may be

5 established in an e-discovery order that provides for production without

6 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal

7 Rules of Evidence, insofar as the parties reach an agreement on the effect

of disclosure of a communication or information covered by the attorney-

client privilege or work product protection, the parties may incorporate

their agreement in the stipulated protective order submitted to the court.

13. MISCELLANEOUS

13.1 Right to Further Relief. Nothing in this Stipulated Protective

Order abridges the right of any person to seek its modification by the

court in the future.

13.2 Right to Assert Other Objections. By stipulating to the entry

of this Stipulated Protective Order no Party waives any right it otherwise

18 would have to object to disclosing or producing any information or item

19 on any ground not addressed in this Stipulated Protective Order.

20 Similarly, no Party waives any right to object on any ground to use in

21 evidence of any of the material covered by this Stipulated Protective

22 Order.

23 13.3 Filing Protected Material. A Party that seeks to file under

24 seal any Protected Material must comply with Local Rule 79-5. Protected

25 Material may only be filed under seal pursuant to a court order

26 authorizing the sealing of the specific Protected Material at issue. If a

Party's request to file Protected Material under seal is denied by the

1 court, then the Receiving Party may file the information in the public

2 record unless otherwise instructed by the court.

3 14. FINAL DISPOSITION

After the Final Disposition of this Action, as defined in paragraph

4, within 60 days of a written request by the Designating Party, each

Receiving Party must return all Protected Material to the Producing

Party or destroy such material. As used in this subdivision, “all Protected

Material” includes all copies, abstracts, compilations, summaries, and

any other format reproducing or capturing any of the Protected Material.

Whether the Protected Material is returned or destroyed, the Receiving

Party must submit a written certification to the Producing Party (and, if

not the same person or entity, to the Designating Party) by the 60 day

deadline that (1) identifies (by category, where appropriate) all the

Protected Material that was returned or destroyed and (2) affirms that

the Receiving Party has not retained any copies, abstracts, compilations,

summaries or any other format reproducing or capturing any of the

18 Protected Material. Notwithstanding this provision, Counsel is entitled

19 to retain an archival copy of all pleadings, motion papers, trial,

20 deposition, and hearing transcripts, legal memoranda, correspondence,

21 deposition and trial exhibits, expert reports, attorney work product, and

22 consultant and expert work product, even if such materials contain

23 Protected Material. Any such archival copies that contain or constitute

24 Protected Material remain subject to this Protective Order as set forth in

25 Section 4.

15. VIOLATION

Any violation of this Stipulated Protective Order may be punished

1 || by any and all appropriate measures including, without limitation,

2 || contempt proceedings and/or monetary sanctions.

4 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

Dated: October 10, 2025 KEMNITZER, BARRON & KRIEG, LLP

8 By: /s/ Kristin Kemnitzer

9 KRISTIN KEMNITZER

Attorneys for Plaintiff

Dated: October 10, 2025 WOMBLE BOND DICKINSON (US) LLP

13 By: /s/ David A. Berkley

14 DAVID A. BERKLEY

MONIQUE G. MATAR

I5 Attorneys for Defendant

16 SERVICE FINANCE COMPANY, INC

|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: October 24, 2025

STEPHANIE 8. CHRISTENSEN

22 United States Magistrate Judge

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ________________________ [print or type full name], of

_________________ [print or type full address], declare under

penalty of perjury that I have read in its entirety and understand the

Stipulated Protective Order that was issued by the United States

District Court for the Central District of California on [date] in the

case of __________ [insert formal name of the case and the

number and initials assigned to it by the court]. I agree to

comply with and to be bound by all the terms of this Stipulated

Protective Order and I understand and acknowledge that failure to so

comply could expose me to sanctions and punishment in the nature of

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]

of _________ [print or type full address and telephone number] as

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.

5 Date: ___________________________

6 City and State where sworn and

7 signed: ___________________________

Printed name: ___________________________

Signature: ___________________________

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