even 18 stipulated protective orders require good cause showing
How later courts described this case
- even 18 stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 MArOjuRnG PA. RNa, oL, EBWarI SN o&. 2B6O53C4K7I US LLP
2 Marcos Sasso, Bar No. 228905
2049 Century Park East, Suite 700
3 Los Angeles, CA 90067-3109
Tel: +1.310.907.1000
4 Fax: +1.310.907.1001
arjun.rao@morganlewis.com
5 marcos.sasso@morganlewis.com
6 MORGAN, LEWIS & BOCKIUS LLP
Christina Chen, Bar No. 294921
7 One Market, Spear Street Tower
San Francisco, CA 94105-1596
8 Tel: +1.415.442.1000
Fax: +1.415.442.1001
9 christina.chen@morganlewis.com
10 Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
11
12
13 UNITED STATES DISTRICT COURT
14 EASTERN DISTRICT OF CALIFORNIA
15
TIMOTHY SAUER, an individual, CASE NO.: 2:25-cv-0673-DAD-JDP
16
Plaintiff, [PROPOSED] STIPULATED
17 PROTECTIVE ORDER
v.
18
JPMORGAN CHASE BANK,
19 NATIONAL ASSOCIATION, and
DOES 1 to 100, inclusive,
20
Defendants.
21
22
23
24
25
26
27
28
1 1. 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 pursuing this litigation may be
5 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 2. GOOD CAUSE STATEMENT
12 This action is likely to involve discovery and disclosure of confidential,
13 private, and/or proprietary information for which special protection from public
14 disclosure and from use for any purpose other than prosecution of this action is
15 warranted pursuant to Federal Rule of Civil Procedure 26, subdivision (c). Such
16 information includes, but is not limited to, private financial information,
17 confidential or proprietary business or commercial information, , personal
18 identifying information, sensitive personal data, employment and personnel files,
19 security-related information, third-party privacy protected information, information
20 the disclosure of which could result in annoyance or embarrassment, information
21 otherwise generally unavailable to the public, and/or information which may be
22
privileged or otherwise protected from disclosure under state or federal statutes,
23
court rules, case decisions, or common law. Accordingly, to expedite the flow of
24
information, to facilitate the prompt resolution of disputes over confidentiality of
25
discovery materials, to adequately protect information the parties are entitled to
26
keep confidential, to ensure that the parties are permitted reasonable necessary uses
27
of such material in preparation for and in the conduct of trial, to address their
28
1 handling at the end of the litigation, and serve the ends of justice, the parties agree
2 that a protective order for such information is justified in this matter. It is the intent
3 of the parties that information will not be designated as confidential for tactical
4 reasons and that nothing be so designated without a good faith belief that it has
5 been maintained in a confidential, non-public manner, and there is good cause why
6 it should not be part of the public record of this case.
7 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
8 The parties further acknowledge, as set forth in Section 14.3, below, that this
9 Stipulated Protective Order does not entitle them to file confidential information
10 under seal; Local Rules 140 and 141 set forth the procedures that must be followed
11 and the standards that will be applied when a party seeks permission from the court
12 to file material under seal or redaction. There is a strong presumption that the public
13 has a right of access to judicial proceedings and records in civil cases. In connection
14 with non-dispositive motions, good cause must be shown to support a filing under
15 seal. See Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir.
16 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002),
17 Makar-Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
18 stipulated protective orders require good cause showing), and a specific showing of
19 good cause or compelling reasons with proper evidentiary support and legal
20 justification, must be made with respect to Protected Material that a party seeks to
21 file under seal. The parties’ mere designation of Disclosure or Discovery Material
22
as CONFIDENTIAL does not—without the submission of competent evidence by
23
declaration, establishing that the material sought to be filed under seal qualifies as
24
confidential, privileged, or otherwise protectable—constitute good cause.
25
Further, if a party requests sealing related to a dispositive motion or trial,
26
then compelling reasons, not only good cause, for the sealing must be shown, and
27
the relief sought shall be narrowly tailored to serve the specific interest to be
28
1 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir.
2 2010). For each item or type of information, document, or thing sought to be filed
3 or introduced under seal, the party seeking protection must articulate compelling
4 reasons, supported by specific facts and legal justification, for the requested sealing
5 order. Again, competent evidence supporting the application to file documents
6 under seal must be provided by declaration.
7 Any document that is not confidential, privileged, or otherwise protectable in
8 its entirety will not be filed under seal if the confidential portions can be redacted.
9 If documents can be redacted, then a redacted version for public viewing, omitting
10 only the confidential, privileged, or otherwise protectable portions of the document,
11 shall be filed. Any application that seeks to file documents under seal in their
12 entirety should include an explanation of why redaction is not feasible.
13 4. DEFINITIONS
14 4.1 Action: Timothy Sauer v. JPMorgan Chase Bank, N.A., Case No.
15 2:25-CV-00673-DAD-JDP.
16 4.2 Challenging Party: a Party or Non-Party that challenges the
17 designation of information or items under this Order.
18 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
19 how it is generated, stored or maintained) or tangible things that qualify for
20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
21 the Good Cause Statement.
22
4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
23
their support staff).
24
4.5 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
28
1 4.6 Disclosure or Discovery Material: all items or information, regardless
2 of the medium or manner in which it is generated, stored, or maintained (including,
3 among other things, testimony, transcripts, and tangible things), that are produced
4 or generated in disclosures or responses to discovery.
5 4.7 Expert: a person with specialized knowledge or experience in a matter
6 pertinent to the litigation who has been retained by a Party or its counsel to serve as
7 an expert witness or as a consultant in this Action.
8 4.8 House Counsel: attorneys who are employees of a party to this Action.
9 House Counsel does not include Outside Counsel of Record or any other outside
10 counsel.
11 4.9 Non-Party: any natural person, partnership, corporation, association or
12 other legal entity not named as a Party to this action.
13 4.10 Outside Counsel of Record: attorneys who are not employees of a
14 party to this Action but are retained to represent a party to this Action and have
15 appeared in this Action on behalf of that party or are affiliated with a law firm that
16 has appeared on behalf of that party, and includes support staff.
17 4.11 Party: any party to this Action, including all of its officers, directors,
18 employees, consultants, retained experts, and Outside Counsel of Record (and their
19 support staffs).
20 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
21 Discovery Material in this Action.
22
4.13 Professional Vendors: persons or entities that provide litigation
23
support services (e.g., photocopying, videotaping, translating, preparing exhibits or
24
demonstrations, and organizing, storing, or retrieving data in any form or medium)
25
and their employees and subcontractors.
26
4.14 Protected Material: any Disclosure or Discovery Material that is
27
28
1 designated as “CONFIDENTIAL.”
2 4.15 Receiving Party: a Party that receives Disclosure or Discovery
3 Material from a Producing Party.
4 5. SCOPE
5 The protections conferred by this Stipulation and Order cover not only
6 Protected Material (as defined above), but also (1) any information copied or
7 extracted from Protected Material; (2) all copies, excerpts, summaries, or
8 compilations of Protected Material; and (3) any testimony, conversations, or
9 presentations by Parties or their Counsel that might reveal Protected Material.
10 Any use of Protected Material at trial shall be governed by the orders of the
11 trial judge and other applicable authorities. This Order does not govern the use of
12 Protected Material at trial. In other words, this Order shall govern pretrial
13 proceedings only, and nothing set forth herein prohibits the use at trial of any
14 Confidential Information or affects the admissibility of any evidence. The
15 procedures to govern the use and disclosure of Confidential Information and the
16 redaction of any “Confidential” or “Confidential Information” designation may be
17 the subject of further agreement of the Parties or order of the Court. Nothing herein
18 shall be construed as limiting a Party’s use of its own Confidential Information and
19 such use shall not constitute a waiver of the terms of this Order or the status of such
20 information as Confidential Information. Any of the Parties can remove their
21 designation of Confidential Information from any information it has previously so
22
designated.
23
6. DURATION
24
Even after final disposition of this litigation, the confidentiality obligations
25
imposed by this Order shall remain in effect until a Designating Party agrees
26
otherwise in writing or a court order otherwise directs. Final disposition shall be
27
deemed to be the later of (1) dismissal of all claims and defenses in this action, with
28
1 or without prejudice; and (2) final judgment herein after the completion and
2 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
3 including the time limits for filing any motions or applications for extension of time
4 pursuant to applicable law.
5 7. DESIGNATING PROTECTED MATERIAL
6 7.1 Exercise of Restraint and Care in Designating Material for
7 Protection. Each Party or Non-Party that designates information or
8 items for protection under this Order must take care to limit any such designation to
9 specific material that qualifies under the appropriate standards. The Designating
10 Party must designate for protection only those parts of material, documents, items
11 or oral or written communications that qualify so that other portions of the material,
12 documents, items or communications for which protection is not warranted are not
13 swept unjustifiably within the ambit of this Order.
14 Mass, indiscriminate, or routinized designations are prohibited. Designations
15 that are shown to be clearly unjustified or that have been made for an improper
16 purpose (e.g., to unnecessarily encumber the case development process or to
17 impose unnecessary expenses and burdens on other parties) may expose the
18 Designating Party to sanctions.
19 If it comes to a Designating Party’s attention that information or items that it
20 designated for protection do not qualify for protection, that Designating Party must
21 promptly notify all other Parties that it is withdrawing the inapplicable designation.
22
7.2 Manner and Timing of Designations. Except as otherwise provided in
23
this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
24
that qualifies for protection under this Order must be clearly so designated before
25
the material is disclosed or produced.
26
Designation in conformity with this Order requires:
27
(a) for information in documentary form (e.g., paper or electronic
28
1 documents, but excluding transcripts of depositions or other pretrial or trial
2 proceedings), that the Producing Party affix at a minimum, the legend
3 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
4 contains protected material. If only a portion of the material on a page qualifies for
5 protection, the Producing Party also must clearly identify the protected portion(s)
6 (e.g., by making appropriate markings in the margins).
7 A Party or Non-Party that makes original documents available for inspection
8 need not designate them for protection until after the inspecting Party has indicated
9 which documents it would like copied and produced. During the inspection and
10 before the designation, all of the material made available for inspection shall be
11 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
12 documents it wants copied and produced, the Producing Party must determine
13 which documents, or portions thereof, qualify for protection under this Order.
14 Then, before producing the specified documents, the Producing Party must affix the
15 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
16 portion of the material on a page qualifies for protection, the Producing Party also
17 must clearly identify the protected portion(s) (e.g., by making appropriate markings
18 in the margins).
19 (b) deposition testimony will be deemed confidential only if
20 designated as such at any time before the close of the deposition by either: (1)
21 identifying the specific testimony to be treated as “CONFIDENTIAL”; or (2)
22
requesting that the entire transcript and all exhibits thereto be treated as
23
“CONFIDENTIAL” until thirty (30) days after receipt by the Designating Party of
24
the deposition transcript from the court reporter. Any designation of deposition
25
testimony must be specific as to the portions of the transcript and/or any exhibits to
26
be protected, except that any exhibit that has previously been marked as
27
“CONFIDENTIAL” at the time of production, and which still bears that mark at the
28
1 time of its use in a deposition, shall be presumed to be confidential under this Order
2 without further designation. For testimony or documents to continue to be treated
3 as Protected Material after the expiration of the 30-day period, the Designating
4 Party must identify, in writing to all parties and within the 30-day period unless
5 otherwise agreed to by all parties, the specific portions of the transcript and exhibits
6 attached thereto it designates as “CONFIDENTIAL.” In circumstances where
7 portions of the transcript are designated as “CONFIDENTIAL,” the transcript pages
8 containing Protected Information may be separately bound by the court reporter,
9 who must affix to the top of each page the legend “Confidential,” as instructed by
10 the Designating Party.
11 (c) for information produced in some form other than documentary and
12 for any other tangible items, that the Producing Party affix in a prominent place on
13 the exterior of the container or containers in which the information is stored the
14 legend “CONFIDENTIAL.” If only a portion or portions of the information
15 warrants protection, the Producing Party, to the extent practicable, shall identify the
16 protected portion(s).
17 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
18 failure to designate qualified information or items does not, standing alone, waive
19 the Designating Party’s right to secure protection under this Order for such
20 material. Upon timely correction of a designation, the Receiving Party must make
21 reasonable efforts to assure that the material is treated in accordance with the
22
provisions of this Order.
23
24
25
26
27
28
1 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
3 designation of confidentiality at any time that is consistent with the Court’s
4 Scheduling Order.
5 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
6 resolution process under Local Rule 251.
7 8.3 The burden of persuasion in any such challenge proceeding shall be on
8 the Designating Party. Frivolous challenges, and those made for an improper
9 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
10 parties) may expose the Challenging Party to sanctions. Unless the Designating
11 Party has waived or withdrawn the confidentiality designation, all parties shall
12 continue to afford the material in question the level of protection to which it is
13 entitled under the Producing Party’s designation until the Court rules on the
14 challenge.
15 9. ACCESS TO AND USE OF PROTECTED MATERIAL
16 9.1 Basic Principles. A Receiving Party may use Protected Material that is
17 disclosed or produced by another Party or by a Non-Party in connection with this
18 Action only for prosecuting, defending or attempting to settle this Action. Such
19 Protected Material may be disclosed only to the categories of persons and under the
20 conditions described in this Order. When the Action has been terminated, a
21 Receiving Party must comply with the provisions of Section 15 below (FINAL
22
DISPOSITION).
23
Protected Material must be stored and maintained by a Receiving Party at a
24
location and in a secure manner that ensures that access is limited to the persons
25
authorized under this Order.
26
9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
27
28
1 otherwise ordered by the court or permitted in writing by the Designating Party, a
2 Receiving Party may disclose any information or item designated
3 “CONFIDENTIAL” only to:
4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
5 well as employees of said Outside Counsel of Record to whom it is reasonably
6 necessary to disclose the information for this Action;
7 (b) the officers, directors, and employees (including House Counsel) of
8 the Receiving Party to whom disclosure is reasonably necessary for this Action;
9 (c) Experts (as defined in this Order) of the Receiving Party to whom
10 disclosure is reasonably necessary for this Action and who have signed the
11 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (d) the Court and its personnel;
13 (e) court reporters and their staff;
14 (f) professional jury or trial consultants, mock jurors, and Professional
15 Vendors to whom disclosure is reasonably necessary for this Action and who have
16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (g) the author or recipient of a document containing the information or
18 a custodian or other person who otherwise possessed or knew the information;
19 (h) during their depositions, witnesses, and attorneys for witnesses, in
20 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
21 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
22
they will not be permitted to keep any confidential information unless they sign the
23
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
24
agreed by the Designating Party or ordered by the court.
25
(i) any mediators or settlement officers and their supporting personnel,
26
mutually agreed upon by any of the parties engaged in settlement discussions.
27
10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
28 PRODUCED IN OTHER LITIGATION
1 If a Party is served with a subpoena or a court order issued in other litigation
2 that compels disclosure of any information or items designated in this Action as
3 “CONFIDENTIAL,” that Party must:
4 (a) promptly notify in writing the Designating Party. Such notification
5 shall include a copy of the subpoena or court order;
6 (b) promptly notify in writing the party who caused the subpoena or
7 order to issue in the other litigation that some or all of the material covered by the
8 subpoena or order is subject to this Protective Order. Such notification shall include
9 a copy of this Stipulated Protective Order; and
10 (c) cooperate with respect to all reasonable procedures sought to be
11 pursued by the Designating Party whose Protected Material may be affected. If the
12 Designating Party timely seeks a protective order, the Party served with the
13 subpoena or court order shall not produce any information designated in this action
14 as “CONFIDENTIAL” before a determination by the court from which the
15 subpoena or order issued, unless the Party has obtained the Designating Party’s
16 permission. The Designating Party shall bear the burden and expense of seeking
17 protection in that court of its confidential material and nothing in these provisions
18 should be construed as authorizing or encouraging a Receiving Party in this Action
19 to disobey a lawful directive from another court.
20 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
21 BE PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a
22
23 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
24 produced by Non-Parties in connection with this litigation is protected by the
25 remedies and relief provided by this Order. Nothing in these provisions should be
26 construed as prohibiting a Non-Party from seeking additional protections.
27 (b) In the event that a Party is required, by a valid discovery request, to
28 produce a Non-Party’s confidential information in its possession, and the Party is
1 subject to an agreement with the Non-Party not to produce the Non-Party’s
2 confidential information, then the Party shall:
3 (1) promptly notify in writing the Requesting Party and the Non-Party
4 that some or all of the information requested is subject to a confidentiality
5 agreement with a Non-Party;
6 (2) promptly provide the Non-Party with a copy of the Stipulated
7 Protective Order in this Action, the relevant discovery request(s), and a reasonably
8 specific description of the information requested; and
9 (3) make the information requested available for inspection by the
10 Non-Party, if requested.
11 (c) If the Non-Party fails to seek a protective order from this court within
12 fourteen (14) days of receiving the notice and accompanying information, the
13 Receiving Party may produce the Non-Party’s confidential information responsive
14 to the discovery request. If the Non-Party timely seeks a protective order, the
15 Receiving Party shall not produce any information in its possession or control that
16 is subject to the confidentiality agreement with the Non-Party before a
17 determination by the court. Absent a court order to the contrary, the Non-Party
18 shall bear the burden and expense of seeking protection in this court of its Protected
19 Material.
20 12. UNAUTHORIZED DISCLOSURE OF PROTECTED
21 MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
22
23 Protected Material to any person or in any circumstance not authorized under this
24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
25 writing the Designating Party of the unauthorized disclosures, (b) use its best
26 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
27 person or persons to whom unauthorized disclosures were made of all the terms of
28
1 this Order, and (d) request such person or persons to execute the “Acknowledgment
2 an Agreement to Be Bound” attached hereto as Exhibit A.
3 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL
4
5 When a Producing Party gives notice to Receiving Parties that certain
6 inadvertently produced material is subject to a claim of privilege or other
7 protection, the obligations of the Receiving Parties are those set forth in Federal
8 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
9 whatever procedure may be established in an e-discovery order that provides for
10 production without prior privilege review. Pursuant to Federal Rule of Evidence
11 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
12 of a communication or information covered by the attorney-client privilege or work
13 product protection, the parties may incorporate their agreement in the stipulated
14 protective order submitted to the court.
15
16
14. MISCELLANEOUS
17
14.1 Right to Further Relief. Nothing in this Stipulated Protective Order
18
shall be construed as prohibiting any Party or Non-Party from seeking additional or
19
different protections or other relief. Nothing in this Order abridges the right of any
20
person to seek its modification by the Court in the future.
21
14.2 Right to Assert Other Objections. By stipulating to the entry of this
22
Protective Order, no Party waives any right it otherwise would have to object to
23
disclosing or producing any information or item on any ground not addressed in
24
this Stipulated Protective Order. Similarly, no Party waives any right to object on
25
any ground to use in evidence of any of the material covered by this Protective
26
Order.
27
14.3 Filing Protected Material. A Party that seeks to file under seal any
28
1 Protected Material must comply with Local Civil Rule 141. Protected Material
2 may only be filed under seal pursuant to a court order authorizing the sealing of the
3 specific Protected Material. If a Party’s request to file Protected Material under
4 seal is denied by the Court, then the Receiving Party may file the information in the
5 public record unless otherwise instructed by the Court.
6 15. FINAL DISPOSITION
7 After the final disposition of this Action, as defined in Paragraph 6, within
8 sixty (60) days of a written request by the Designating Party, each Receiving Party
9 must return all Protected Material to the Producing Party or destroy such material.
10 As used in this subdivision, “all Protected Material” includes all copies, abstracts,
11 compilations, summaries, and any other format reproducing or capturing any of the
12 Protected Material. Whether the Protected Material is returned or destroyed, the
13 Receiving Party must submit a written certification to the Producing Party (and, if
14 not the same person or entity, to the Designating Party) by the 60-day deadline that
15 (1) identifies (by category, where appropriate) all the Protected Material that was
16 returned or destroyed and (2) affirms that the Receiving Party has not retained any
17 copies, abstracts, compilations, summaries or any other format reproducing or
18 capturing any of the Protected Material. Notwithstanding this provision, Counsel
19 are entitled to retain an archival copy of all pleadings, motion papers, trial,
20 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
21 and trial exhibits, expert reports, attorney work product, and consultant and expert
22
work product, even if such materials contain Protected Material. Any such archival
23
copies that contain or constitute Protected Material remain subject to this Protective
24
Order as set forth in Section 6 (DURATION).
25
16. VIOLATION
26
Any violation of this Order may be punished by appropriate measures
27
including, without limitation, contempt proceedings and/or monetary sanctions.
28
! || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3
4 DATED: September 16, 2025 /s/ Meghan Baker
Attorneys for Plaintiff Timothy Sauer
5
6
DATED: September 16, 2025 /s/ Arjun Rao
7 Attorneys for Defendant JPMorgan Chase
8 Bank, N.A.
9 | FOR GOOD CAUSE SHOWN,
10
11 || IT IS SO ORDERED.
12 /
13 || Dated: _ September 18, 2025 ¢_——
JEREMY D. PETERSON
14 UNITED STATES MAGISTRATE JUDGE
15
16
17
18
19
20
21
22
23
24
25
26
27
28
LEWIS & 16
LLP
1
2
EXHIBIT A
3
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
4
I, ____________________________ [print or type full name], of
5
_______________________ [print or type full address], declare under penalty of
6
perjury that I have read in its entirety and understand the Stipulated Protective
7
Order that was issued by the United States District Court for the Central District of
8
California on ____________________ [date] in the case of Timothy Sauer v.
9
JPMorgan Chase Bank, N.A., Case No. 2:25-CV-00673-DAD-JDP. I agree to
10
comply with and to be bound by all the terms of this Stipulated Protective Order
11
and I understand and acknowledge that failure to so comply could expose me to
12
sanctions and punishment in the nature of contempt. I solemnly promise that I will
13
not disclose in any manner any information or item that is subject to this Stipulated
14
Protective Order to any person or entity except in strict compliance with the
15
provisions of this Order. I further agree to submit to the jurisdiction of the United
16
States District Court for the Eastern District of California for the purpose of
17
enforcing the terms of this Stipulated Protective Order, even if such enforcement
18
proceedings occur after termination of this action.
19
I hereby appoint _____________________________ [print or type full
20
name] of ____________________________________ [print or type full address
21
and telephone number] as my California agent for service of process in connection
22
with this action or any proceedings related to enforcement of this Stipulated
23
Protective Order.
24
25
Date: ____________________________
26
City and State where sworn and signed: __________________________________
27
Printed Name: _____________________
28