The opinion
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6 UNITED STATES DISTRICT COURT
7 FOR THE EASTERN DISTRICT OF CALIFORNIA
° MICHAEL ASHKER, Case No. 2:24-cv-03297-DC-CSK
" Plaintiff, ORDER GRANTING MODIFIED
11 STIPULATED PROTECTIVE ORDER
12 (ECF No .20)
FORTRESS NORTH AMERICA,
13 |} L.L.C., et al.,
14 Defendants.
15
16 The Court has reviewed the parties’ stipulated protective order below (ECF No.
17 || 20), and finds it comports with the relevant authorities and the Court’s Local Rule. See
18 || L.R. 141.1. The Court APPROVES the protective order, subject to the following
19 || clarification.
20 The Court’s Local Rules indicate that once an action is closed, it “will not retain
21 || jurisdiction over enforcement of the terms of any protective order filed in that action.” L.R.
22 || 141.1(f); see Bylin Heating Sys., Inc. v. Thermal Techs., Inc., 2012 WL 13237584, at *2
23 || (E.D. Cal. Oct. 29, 2012) (noting that courts in the district generally do not retain
24 || jurisdiction for disputes concerning protective orders after closure of the case). Thus, the
25 || Court will not retain jurisdiction over this protective order once the case is closed.
26 || Dated: October 6, 2025
27 Ch Spo \
GHI 500 KIM
28 |] + ashks2e7.24 UNITED STATES MAGISTRATE JUDGE
1 DOWNEY BRAND LLP
MEGHAN M. BAKER (Bar No. 243765)
2 mbaker@downeybrand.com
ALEXANDRA K. LAFOUNTAIN (Bar No. 301003)
3 alafountain@downeybrand.com
621 Capitol Mall, 18th Floor
4 Sacramento, California 95814
Telephone: 916.444.1000
5 Facsimile: 916.444.2100
6 Attorneys for Plaintiff MICHAEL ASHKER
7 TORY E. GRIFFIN (Bar No. 186181)
AVALON JOHNSON FITZGERALD (Bar No. 288167)
8 REYNOLDS TILBURY WOODWARD LLP
11601 Blocker Drive, Ste. 105
9 Auburn, CA 95603
Phone: (530) 885-8500
10 Fax: (530) 885-8113
Email: tgriffin@rtwlawllp.com
11
JAMES F. BENNETT (MO BAR NO. 46826, Pro Hac Vice)
12 REBECCA MCLAUGHLIN (MO BAR. NO. 71969, Pro Hac Vice)
DOWD BENNETT LLP
13 7676 Forsyth Blvd., Suite 1900
St. Louis, MO 63105
14 Phone: (314) 889-7300
Email: jbennett@dowdbennett.com
15 Email: rmclaughlin@dowdbennett.com
16 Attorneys for Defendants Fortress North America, LLC, and
Compass Minerals International, Inc.
17
18 UNITED STATES DISTRICT COURT
19 EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION
20
21 MICHAEL ASHKER, Case No. 2:24-cv-03297-DC-CSK
22 Plaintiff, Related Case No: 2:24-cv-03298-DC-CSK
23 v. STIPULATED PROTECTIVE ORDER
24 FORTRESS NORTH AMERICA, LLC, a
California limited liability company,
25 COMPASS MINERALS INTERNATIONAL,
INC., a Delaware corporation, and DOES - 10,
26 inclusive,
27 Defendants.
1 1. INTRODUCTION
2 1.1 PURPOSES AND LIMITATIONS
3 Disclosure and discovery activity in this action are likely to involve production of
4 confidential, proprietary, or private information for which special protection from public
5 disclosure and from use for any purpose other than prosecuting this litigation may be warranted.
6 Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated
7 Protective Order. The parties acknowledge that this Order does not confer blanket protections on
8 all disclosures or responses to discovery and that the protection it affords from public disclosure
9 and use extends only to the limited information or items that are entitled to confidential treatment
10 under the applicable legal principles. The parties further acknowledge, as set forth in Section 12.3,
11 below, that this Stipulated Protective Order does not entitle them to file confidential information
12 under seal; Local Rule 141 sets forth the procedures that must be followed and the standards that
13 will be applied when a party seeks permission from the court to file material under seal.
14 1.2 GOOD CAUSE STATEMENT
15 This action is likely to involve confidential documents relating to private employment
16 records, personnel file documents, financial records, and personal identifying information of
17 parties and third-party witnesses (i.e., addresses, telephone numbers) for which special protection
18 from public disclosure and from use for any purpose other than prosecution of this action is not
19 warranted. Such private, confidential, and proprietary materials and information consist of, among
20 other things, documents produced in connection with employee records, personnel file
21 information, personal identifying information of any party or third-party witnesses otherwise
22 generally unavailable to the public, private financial information, confidential corporate records,
23 and other information that may be privileged or otherwise protected from disclosure under state or
24 federal statutes, court rules, case decisions, or common law.
25 Without a Protective Order, uncontrolled disclosure of the above-identified categories of
26 materials would result in harm, including invasion of the privacy interests of the parties and non-
27 party witnesses and improper disclosure of sensitive and confidential information of the parties
1 information, and private contact information. There is good cause and a particularized need for a
2 Protective Order to preserve the interests of confidentiality and privacy in employment and
3 personnel records, private and internal corporate records, sensitive financial information, and the
4 personal identifying information of parties and third-party witnesses. Accordingly, to expedite the
5 flow of information, to facilitate the prompt resolution of disputes over confidentiality of
6 discovery materials, to adequately protect information the parties are entitled to keep confidential,
7 to ensure that the parties are permitted reasonably necessary uses of such material in preparation
8 for and in the conduct of trial, to address their handling at the end of the litigation, and serve the
9 ends of justice, a protective order for such information is justified in this matter.
10 It is the intent of the parties that information will not be designated as confidential for
11 tactical reasons and that nothing be so designated without a good faith belief that it has been
12 maintained in a confidential, non-public manner, and there is good cause why it should not be part
13 of the public record in this case. The parties therefore stipulate that there is Good Cause for, and
14 hereby jointly request that the honorable Court issue and enter, a Protective Order regarding
15 confidential documents consistent with the terms and provisions of this Stipulation.
16 2. DEFINITIONS
17 2.1 Challenging Party: a Party or Non-Party that challenges the designation of
18 information or items under this Order.
19 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is
20 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule
21 of Civil Procedure 26(c). Pursuant to Local Rule 141.1(c)(1), the parties identify the following
22 types of information they believe to be eligible for protection under this Order: (i) personnel files,
23 (ii) employment records, (iii) investigation records and other documents relating to employee and
24 personnel issues, (iv) personal information of the parties in this litigation or of non-parties,
25 including but not limited to, social security numbers, phone numbers, and home addresses, and (v)
26 personal and corporate financial records.
27 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as
1 2.4 Designating Party: a Party or Non-Party that designates information or items that it
2 produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
3 2.5 Disclosure or Discovery Material: all items or information, regardless of the
4 medium or manner in which it is generated, stored, or maintained (including, among other things,
5 testimony, transcripts, and tangible things), that are produced or generated in disclosures or
6 responses to discovery in this matter.
7 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to
8 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
9 consultant in this action.
10 2.7 House Counsel: attorneys who are employees of a party to this action. House
11 Counsel does not include Outside Counsel of Record or any other outside counsel.
12 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal
13 entity not named as a Party to this action.
14 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this
15 action but are retained to represent or advise a party to this action and have appeared in this action
16 on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
17 2.10 Party: any party to this action, including all of its officers, directors, employees,
18 consultants, retained experts, and Outside Counsel of Record (and their support staffs).
19 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
20 Material in this action.
21 2.12 Professional Vendors: persons or entities that provide litigation support services
22 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
23 organizing, storing, or retrieving data in any form or medium) and their employees and
24 subcontractors.
25 2.13 Protected Material: any Disclosure or Discovery Material that is designated as
26 “CONFIDENTIAL.”
27 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only Protected Material
3 (as defined above), but also (1) any information copied or extracted from Protected Material; (2)
4 all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
5 conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
6 However, the protections conferred by this Stipulation and Order do not cover the following
7 information: (a) any information that is in the public domain at the time of disclosure to a
8 Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a
9 result of publication not involving a violation of this Order, including becoming part of the public
10 record through trial or otherwise; and (b) any information known to the Receiving Party prior to
11 the disclosure or obtained by the Receiving Party after the disclosure from a source who obtained
12 the information lawfully and under no obligation of confidentiality to the Designating Party. Any
13 use of Protected Material at trial shall be governed by a separate agreement or order.
14 4. DURATION
15 Even after final disposition of this litigation, the confidentiality obligations imposed by
16 this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court
17 order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all
18 claims and defenses in this action, with or without prejudice; and (2) final judgment herein after
19 the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
20 including the time limits for filing any motions or applications for extension of time pursuant to
21 applicable law.
22 5. DESIGNATING PROTECTED MATERIAL
23 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party
24 or Non-Party that designates information or items for protection under this Order must take care to
25 limit any such designation to specific material that qualifies under the appropriate standards. The
26 Designating Party must designate for protection only those parts of material, documents, items, or
27 oral or written communications that qualify – so that other portions of the material, documents,
1 the ambit of this Order.
2 Mass, indiscriminate, or routinized designations are prohibited. Designations that are
3 shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
4 unnecessarily encumber or retard the case development process or to impose unnecessary
5 expenses and burdens on other parties) expose the Designating Party to sanctions.
6 If it comes to a Designating Party’s attention that information or items that it designated
7 for protection do not qualify for protection, that Designating Party must promptly notify all other
8 Parties that it is withdrawing the mistaken designation.
9 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order
10 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
11 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
12 designated before the material is disclosed or produced.
13 Designation in conformity with this Order requires:
14 (a) For information in documentary form (e.g., paper or electronic documents, but
15 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party
16 affix the legend “CONFIDENTIAL” to each page that contains protected material.
17 A Party or Non-Party that makes original documents or materials available for
18 inspection need not designate them for protection until after the inspecting Party has indicated
19 which material it would like copied and produced. During the inspection and before the
20 designation, all of the material made available for inspection shall be deemed
21 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied and
22 produced, the Producing Party must determine which documents, or portions thereof, qualify for
23 protection under this Order. Then, before producing the specified documents, the Producing Party
24 must affix the “CONFIDENTIAL” legend to each page that contains Protected Material.
25 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the
26 Designating Party identify on the record, before the close of the deposition, hearing, or other
27 proceeding, all protected testimony, with an exception that the Parties retain the right to designate
1 available.
2 (c) for information produced in some form other than documentary and for any other
3 tangible items, that the Producing Party affix in a prominent place on the exterior of the container
4 or containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a
5 portion or portions of the information or item warrant protection, the Producing Party, to the
6 extent practicable, shall identify the protected portion(s).
7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
8 designate qualified information or items does not, standing alone, waive the Designating Party’s
9 right to secure protection under this Order for such material. Upon timely correction of a
10 designation, the Receiving Party must make reasonable efforts to assure the Producing Party that
11 the material is treated in accordance with the provisions of this Order.
12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
14 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
15 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic
16 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to
17 challenge a confidentiality designation by electing not to mount a challenge promptly after the
18 original designation is disclosed.
19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
20 process by providing written notice of each designation it is challenging and describing the basis
21 for each challenge. To avoid ambiguity as to whether a challenge has been made, the written
22 notice must recite that the challenge to confidentiality is being made in accordance with this
23 specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in
24 good faith and must begin the process by conferring directly (in voice to voice dialogue; other
25 forms of communication are not sufficient) within 14 days of the date of service of notice. In
26 conferring, the Challenging Party must explain the basis for its belief that the confidentiality
27 designation was not proper and must give the Designating Party an opportunity to review the
1 explain the basis for the chosen designation. A Challenging Party may proceed to the next stage of
2 the challenge process only if it has engaged in this meet and confer process first or establishes that
3 the Designating Party is unwilling to participate in the meet and confer process in a timely
4 manner.
5 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court
6 intervention, the Designating Party shall file and serve a motion to retain confidentiality under
7 Local Rule 230 (and in compliance with Local Rule 141, if applicable) within 21 days of the
8 initial notice of challenge or within 14 days of the parties agreeing that the meet and confer
9 process will not resolve their dispute, whichever is earlier. Each such motion must be
10 accompanied by a competent declaration affirming that the movant has complied with the meet
11 and confer requirements imposed in the preceding paragraph. Failure by the Designating Party to
12 make such a motion including the required declaration within 21 days (or 14 days, if applicable)
13 shall automatically waive the confidentiality designation for each challenged designation. In
14 addition, the Challenging Party may file a motion challenging a confidentiality designation at any
15 time if there is good cause for doing so, including a challenge to the designation of a deposition
16 transcript or any portions thereof. Any motion brought pursuant to this provision must be
17 accompanied by a competent declaration affirming that the movant has complied with the meet
18 and confer requirements imposed by the preceding paragraph.
19 The burden of persuasion in any such challenge proceeding shall be on the Designating
20 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
21 unnecessary expenses and burdens on other parties) may expose the Challenging Party to
22 sanctions. Unless the Designating Party has waived the confidentiality designation by failing to
23 file a motion to retain confidentiality as described above, all parties shall continue to afford the
24 material in question the level of protection to which it is entitled under the Producing Party’s
25 designation until the court rules on the challenge.
26 7. ACCESS TO AND USE OF PROTECTED MATERIAL
27 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or
1 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to
2 the categories of persons and under the conditions described in this Order. When the litigation has
3 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
4 DISPOSITION).
5 Protected Material must be stored and maintained by a Receiving Party at a location and in
6 a secure manner that ensures that access is limited to the persons authorized under this Order.
7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered
8 by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
9 information or item designated “CONFIDENTIAL” only to:
10 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as
11 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the
12 information for this litigation;
13 (b) the officers, directors, and employees (including House Counsel) of the Receiving
14 Party to whom disclosure is reasonably necessary for this litigation and who have signed the
15 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
17 reasonably necessary for this litigation and who have signed the “Acknowledgment and
18 Agreement to Be Bound” (Exhibit A);
19 (d) the court, court personnel, and court appointed or party agreed upon mediators;
20 (e) court reporters and their staff, professional jury or trial consultants, mock jurors,
21 and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who
22 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
23 (f) during their depositions, witnesses in the action to whom disclosure is reasonably
24 necessary. Pages of transcribed deposition testimony or exhibits to depositions that reveal
25 Protected Material must be separately bound by the court reporter and may not be disclosed to
26 anyone except as permitted under this Stipulated Protective Order.
27 (g) the author or recipient of a document containing the information or a custodian or
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
2 LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation that compels
4 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
5 must:
6 (a) promptly notify in writing the Designating Party. Such notification shall include a
7 copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order to issue in
9 the other litigation that some or all of the material covered by the subpoena or order is subject to
10 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order;
11 and
12 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
13 Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with the subpoena
15 or court order shall not produce any information designated in this action as “CONFIDENTIAL”
16 before a determination by the court from which the subpoena or order issued, unless the Party has
17 obtained the Designating Party’s permission. The Designating Party shall bear the burden and
18 expense of seeking protection in that court of its confidential material – and nothing in these
19 provisions should be construed as authorizing or encouraging a Receiving Party in this action to
20 disobey a lawful directive from another court.
21 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
22 LITIGATION
23 (a) The terms of this Order are applicable to information produced by a Non-Party in
24 this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in
25 connection with this litigation is protected by the remedies and relief provided by this Order.
26 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking
27 additional protections.
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
3 Material to any person or in any circumstance not authorized under this Stipulated Protective
4 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the
5 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected
6 Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the
7 terms of this Order, and (d) request such person or persons to execute the “Acknowledgment and
8 Agreement to Be Bound” that is attached hereto as Exhibit A.
9 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
10 MATERIAL
11 When a Producing Party gives notice to Receiving Parties that certain inadvertently
12 produced material is subject to a claim of privilege or other protection, the obligations of the
13 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
14 provision is not intended to modify whatever procedure may be established in an e-discovery order
15 that provides for production without prior privilege review. Pursuant to Federal Rule of Evidence
16 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a
17 communication or information covered by the attorney-client privilege or work product protection,
18 the parties may incorporate their agreement in the stipulated protective order submitted to the
19 court.
20 12. MISCELLANEOUS
21 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to
22 seek its modification by the court in the future.
23 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
24 Order no Party waives any right it otherwise would have to object to disclosing or producing any
25 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
26 Party waives any right to object on any ground to use in evidence of any of the material covered
27 by this Protective Order.
1 or a court order secured after appropriate notice to all interested persons, a Party may not file in
2 the public record in this action any Protected Material. A Party that seeks to file under seal any
3 Protected Material must comply with Local Rule 141. Protected Material may only be filed under
4 seal pursuant to a court order authorizing the sealing of the specific Protected Material at issue.
5 Pursuant to Local Rule 141, a sealing order will issue only upon a request establishing that the
6 Protected Material at issue is privileged, protectable as a trade secret, or otherwise entitled to
7 protection under the law. If a Receiving Party’s request to file Protected Material under seal
8 pursuant to Local Rule 141 is denied by the court, then the Receiving Party may file the
9 information in the public record unless otherwise instructed by the court.
10 13. FINAL DISPOSITION
11 Within 60 days after the final disposition of this action, as defined in paragraph 4, each
12 Receiving Party must return all Protected Material to the Producing Party or destroy such material.
13 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
14 summaries, and any other format reproducing or capturing any of the Protected Material. Whether
15 the Protected Material is returned or destroyed, the Receiving Party must submit a written
16 certification to the Producing Party (and, if not the same person or entity, to the Designating Party)
17 by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected
18 OutsideMaterial that was returned or destroyed and (2) affirms that the Receiving Party has not
19 retained any copies, abstracts, compilations, summaries or any other format reproducing or
20 capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to
21 retain a copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
22 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product,
23 and consultant and expert work product, even if such materials contain Protected Material. Any
24 such archival copies that contain or constitute Protected Material remain subject to this Protective
25 Order as set forth in Section 4 (DURATION).
26 / / /
27 / / /
1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2 DATED: September 25, 2025 DOWNEY BRAND LLP
3
4 By: /s/ Meghan M. Baker
MEGHAN M. BAKER
5 ALEXANDRA K. LAFOUNTAIN
Attorneys for Plaintiff
6 Michael Ashker
7
8
9 DATED: September 25, 2025 DOWD BENNETT LLP
10
By: /s/ Rebecca R. Mclaughlin
11
JAMES F. BENNETT
12 REBECCA R. McLAUGHLIN
Attorneys for Defendants
13 Fortress North America, LLC, and Compass
Minerals International, Inc.
14
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27
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
5 perjury that I have read in its entirety and understand the Stipulated Protective Order that was
6 issued by the United States District Court for the Eastern District of California on
7 __________[date] in the case of Ashker v. Fortress North America LLC, et al., Case No. 2:24-cv-
8 03297-DC-CSK. I agree to comply with and to be bound by all the terms of this Stipulated
9 Protective Order and I understand and acknowledge that failure to so comply could expose me to
10 sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in
11 any manner any information or item that is subject to this Stipulated Protective Order to any
12 person or entity except in strict compliance with the provisions of this Order.
13 I further agree to submit to the jurisdiction of the United States District Court for the
14 Eastern District of California for the purpose of enforcing the terms of this Stipulated Protective
15 Order, even if such enforcement proceedings occur after termination of this action.
16
17 Date:
18 City and State where sworn and signed: _________________________________
19 Printed name: _______________________________
20 Signature: __________________________________
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