# Opinion

> District Court, C.D. California · February 25, 2026

URL: https://www.frixlaw.com/law-library/cases/11367641

## Case

- **Full name:** Akmaral Babas Takhirov v. Nissan Motor Acceptance Company, LLC
- **Court:** District Court, C.D. California
- **Decided:** February 25, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 F. Jay Rahimi, Esq. (SBN: 305286)
E-mail: Jay@LALSLaw.com
2 Los Angeles Legal Solutions
17207 Ventura Blvd., Suite 4
3 Encino, CA 91316
Telephone: (818) 510.0555
4 Facsimile: (818) 510.0590

5 Attorneys for Plaintiff,
Akmaral Babas Takhirov
6

7 Genevieve Walser-Jolly (SBN 262784)
Genevieve.Walser-Jolly@wbd-us.com
8 Monique Matar (SBN 317145)
Monique.Matar@wbd-us.com
9 WOMBLE BOND DICKINSON (US) LLP
400 Spectrum Center Drive, Suite 1700
10
Irvine, California 92618
11 Telephone: (714) 557-3800
Facsimile: (714) 557-3347
12

13 Attorneys for Defendant
NISSAN MOTOR ACCEPTANCE
14
COMPANY, LLC
15
UNITED STATES DISTRICT COURT
16
CENTRAL DISTRICT OF CALIFORNIA
17

18
AKMARAL BABAS TAKHIROV, Case No. 2:25-CV-08408-SSC
19

Plaintiff,
20 STIPULATED PROTECTIVE
21 vs. ORDER1

22 NISSAN MOTOR ACCEPTANCE

COMPANY, LLC. et al.,
23
24 Defendants.

25
26
27
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
7 enter the following Stipulated Protective Order. The parties
8
acknowledge that this Order does not confer blanket protections on all
9
disclosures or responses to discovery and that the protection it affords
10
from public disclosure and use extends only to the limited information or
11
items that are entitled to confidential treatment under the applicable
12
legal principles.
13
1.2 Good Cause Statement. This action is likely to involve trade
14
secrets, customer and pricing lists and other valuable research,
15
development, commercial, financial, technical and/or proprietary
16
information for which special protection from public disclosure and from
17
use for any purpose other than prosecution of this action is warranted.
18
Such confidential and proprietary materials and information consist of,
19
among other things, confidential business or financial information,
20
information regarding confidential business practices, or other
21
22 confidential research, development, or commercial information (including
23 information implicating privacy rights of third parties), information
24 otherwise generally unavailable to the public, or which may be privileged
25 or otherwise protected from disclosure under state or federal statutes,
26 court rules, case decisions, or common law. Accordingly, to expedite the
27 flow of information, to facilitate the prompt resolution of disputes over
1 the parties are entitled to keep confidential, to ensure that the parties
2 are permitted reasonable necessary uses of such material in preparation
3 for and in the conduct of trial, to address their handling at the end of the
4 litigation, and serve the ends of justice, a protective order for such
5 information is justified in this matter. It is the intent of the parties that
6 information will not be designated as confidential for tactical reasons
7 and that nothing be so designated without a good faith belief that it has
8
been maintained in a confidential, non-public manner, and there is good
9
cause why it should not be part of the public record of this case.
10
1.3 Acknowledgment of Procedure for Filing Under Seal. The
11
parties further acknowledge, as set forth in Section 12.3, below, that this
12
Stipulated Protective Order does not entitle them to file confidential
13
information under seal; Local Rule 79-5 sets forth the procedures that
14
must be followed and the standards that will be applied when a party
15
seeks permission from the court to file material under seal.
16
There is a strong presumption that the public has a right of access
17
to judicial proceedings and records in civil cases. In connection with
18
non-dispositive motions, good cause must be shown to support a filing
19
under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
20
1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
21
22 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
23 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
24 protective orders require good cause showing), and a specific showing of
25 good cause or compelling reasons with proper evidentiary support and
26 legal justification, must be made with respect to Protected Material that
27 a party seeks to file under seal. The parties’ mere designation of
1 without the submission of competent evidence by declaration,
2 establishing that the material sought to be filed under seal qualifies as
3 confidential, privileged, or otherwise protectable—constitute good cause.
4 Further, if a party requests sealing related to a dispositive motion
5 or trial, then compelling reasons, not only good cause, for the sealing
6 must be shown, and the relief sought shall be narrowly tailored to serve
7 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
8
605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
9
information, document, or thing sought to be filed or introduced under
10
seal in connection with a dispositive motion or trial, the party seeking
11
protection must articulate compelling reasons, supported by specific
12
facts and legal justification, for the requested sealing order. Again,
13
competent evidence supporting the application to file documents under
14
seal must be provided by declaration.
15
Any document that is not confidential, privileged, or otherwise
16
protectable in its entirety will not be filed under seal if the confidential
17
portions can be redacted. If documents can be redacted, then a redacted
18
version for public viewing, omitting only the confidential, privileged, or
19
otherwise protectable portions of the document, shall be filed. Any
20
application that seeks to file documents under seal in their entirety
21
22 should include an explanation of why redaction is not feasible.
23
24 2. DEFINITIONS
25 2.1 Action: This pending litigation captioned as AKMARAL
26 BABAS TAKHIROV, Plaintiff, vs. NISSAN MOTOR ACCEPTANCE
27 COMPANY, LLC. et al., Defendants, Case No. 2:25-CV-08408-SSC.
1 designation of information or items under this Order.
2 2.3 “CONFIDENTIAL” Information or Items: information
3 (regardless of how it is generated, stored or maintained) or tangible
4 things that qualify for protection under Rule 26(c) of the Federal Rules of
5 Civil Procedure, and as specified above in the Good Cause Statement.
6 2.4 Counsel: Outside Counsel of Record and House Counsel (as
7 well as their support staff).
8
2.5 Designating Party: a Party or Non-Party that designates
9
information or items that it produces in disclosures or in responses to
10
discovery as “CONFIDENTIAL.”
11
2.6 Disclosure or Discovery Material: all items or information,
12
regardless of the medium or manner in which it is generated, stored, or
13
maintained (including, among other things, testimony, transcripts, and
14
tangible things), that are produced or generated in disclosures or
15
responses to discovery in this matter.
16
2.7 Expert: a person with specialized knowledge or experience in
17
a matter pertinent to the litigation who has been retained by a Party or
18
its counsel to serve as an expert witness or as a consultant in this Action.
19
2.8 Final Disposition: the later of (1) dismissal of all claims and
20
defenses in this Action, with or without prejudice; and (2) final judgment
21
22 herein after the completion and exhaustion of all appeals, rehearings,
23 remands, trials, or reviews of this Action, including the time limits for
24 filing any motions or applications for extension of time pursuant to
25 applicable law.
26 2.9 In-House Counsel: attorneys who are employees of a party to
27 this Action. In-House Counsel does not include Outside Counsel of
1 2.10 Non-Party: any natural person, partnership, corporation,
2 association, or other legal entity not named as a Party to this action.
3 2.11 Outside Counsel of Record: attorneys who are not employees
4 of a party to this Action but are retained to represent or advise a party to
5 this Action and have appeared in this Action on behalf of that party or
6 are affiliated with a law firm which has appeared on behalf of that party,
7 and includes support staff.
8
2.12 Party: any party to this Action, including all of its officers,
9
directors, employees, consultants, retained experts, and Outside Counsel
10
of Record (and their support staffs).
11
2.13 Producing Party: a Party or Non-Party that produces
12
Disclosure or Discovery Material in this Action.
13
2.14 Professional Vendors: persons or entities that provide
14
litigation- support services (e.g., photocopying, videotaping, translating,
15
preparing exhibits or demonstrations, and organizing, storing, or
16
retrieving data in any form or medium) and their employees and
17
subcontractors.
18
2.15 Protected Material: any Disclosure or Discovery Material that
19
is designated as “CONFIDENTIAL.”
20
2.16 Receiving Party: a Party that receives Disclosure or Discovery
21
22 Material from a Producing Party.
23
24 3. SCOPE
25 The protections conferred by this Stipulation and Order cover not
26 only Protected Material (as defined above), but also (1) any information
27
copied or extracted from Protected Material; (2) all copies, excerpts,
1 summaries, or compilations of Protected Material; and (3) any
2 testimony, conversations, or presentations by Parties or their Counsel
3 that might reveal Protected Material.
4 Any use of Protected Material at trial shall be governed by the
5 orders of the trial judge. This Stipulated Protective Order does not
6 govern the use of Protected Material at trial.
7
8
4. TRIAL AND DURATION
9
The terms of this Stipulated Protective Order apply through Final
10
Disposition of the Action.
11
Once a case proceeds to trial, information that was designated as
12
CONFIDENTIAL or maintained pursuant to this Stipulated Protective
13
14 Order and used or introduced as an exhibit at trial becomes public and
15 will be presumptively available to all members of the public, including
16 the press, unless compelling reasons supported by specific factual
17 findings to proceed otherwise are made to the trial judge in advance of
18 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good
19 cause” showing for sealing documents produced in discovery from
20 “compelling reasons” standard when merits-related documents are part
21 of court record). Accordingly, for such materials, the terms of this
22 Stipulated Protective Order do not extend beyond the commencement of
23
the trial.
24
Even after Final Disposition of this litigation, the confidentiality
25
obligations imposed by this Stipulated Protective Order shall remain in
26
effect until a Designating Party agrees otherwise in writing or a court
27
order otherwise directs.
1 5. DESIGNATING PROTECTED MATERIAL
2 5.1 Exercise of Restraint and Care in Designating Material for
3 Protection. Each Party or Non-Party that designates information or
4
items for protection under this Order must take care to limit any such
5
designation to specific material that qualifies under the appropriate
6
standards. The Designating Party must designate for protection only
7
those parts of material, documents, items, or oral or written
8
communications that qualify so that other portions of the material,
9
documents, items, or communications for which protection is not
10
warranted are not swept unjustifiably within the ambit of this Order.
11
Mass, indiscriminate, or routinized designations are prohibited.
12
Designations that are shown to be clearly unjustified or that have been
13
made for an improper purpose (e.g., to unnecessarily encumber the case
14
development process or to impose unnecessary expenses and burdens on
15
other parties) may expose the Designating Party to sanctions.
16
If it comes to a Designating Party’s attention that information or
17
18 items that it designated for protection do not qualify for protection, that
19 Designating Party must promptly notify all other Parties that it is
20 withdrawing the inapplicable designation.
21 5.2 Manner and Timing of Designations. Except as otherwise
22 provided in this Stipulated Protective Order (see, e.g., second paragraph
23
of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
24
or Discovery Material that qualifies for protection under this Stipulated
25
Protective Order must be clearly so designated before the material is
26
disclosed or produced.
27
Designation in conformity with this Stipulated Protective Order
1 requires:
2 (a) for information in documentary form (e.g., paper or electronic
3 documents, but excluding transcripts of depositions or other pretrial or
4 trial proceedings), that the Producing Party affix at a minimum, the
5 legend “CONFIDENTIAL” to each page that contains protected
6 material. If only a portion or portions of the material on a page
7 qualifies for protection, the Producing Party also must clearly identify
8
the protected portion(s) (e.g., by making appropriate markings in the
9
margins).
10
A Party or Non-Party that makes original documents available for
11
inspection need not designate them for protection until after the
12
inspecting Party has indicated which documents it would like copied
13
and produced. During the inspection and before the designation, all of
14
the material made available for inspection shall be deemed
15
CONFIDENTIAL. After the inspecting Party has identified the
16
documents it wants copied and produced, the Producing Party must
17
determine which documents, or portions thereof, qualify for protection
18
under this Stipulated Protective Order. Then, before producing the
19
specified documents, the Producing Party must affix the
20
21 “CONFIDENTIAL” legend to each page that contains Protected
22 Material. If only a portion or portions of the material on a page
23 qualifies for protection, the Producing Party also must clearly identify
24 the protected portion(s) (e.g., by making appropriate markings in the
25 margins).
26 (b) for testimony given in depositions that the Designating Party
27 identify the Disclosure or Discovery Material on the record, before the
1 (c) for information produced in some form other than
2 documentary and for any other tangible items, that the Producing Party
3 affix in a prominent place on the exterior of the container or containers
4 in which the information is stored the “CONFIDENTIAL” legend. If only
5 a portion or portions of the information warrants protection, the
6 Producing Party, to the extent practicable, shall identify the protected
7 portion(s).
8
5.3 Inadvertent Failures to Designate. If timely corrected, an
9
inadvertent failure to designate qualified information or items does not,
10
standing alone, waive the Designating Party’s right to secure protection
11
under this Order for such material. Upon timely correction of a
12
designation, the Receiving Party must make reasonable efforts to assure
13
that the material is treated in accordance with the provisions of this
14
Stipulated Protective Order.
15

16
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
17
18 6.1 Timing of Challenges. Any Party or Non-Party may
19 challenge a designation of confidentiality at any time that is consistent
20 with the court’s Scheduling Order.
21 6.2 Meet and Confer. The Challenging Party shall initiate the
22 dispute resolution process under Local Rule 37.1 et seq. and with
23
Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-
24
Discovery Motion Conference.”2
25
6.3 The burden of persuasion in any such challenge proceeding
26

27
2 Judge Christensen’s Procedures are available at
1 shall be on the Designating Party. Frivolous challenges, and those
2 made for an improper purpose (e.g., to harass or impose unnecessary
3 expenses and burdens on other parties) may expose the Challenging
4 Party to sanctions. Unless the Designating Party has waived or
5 withdrawn the confidentiality designation, all parties shall continue to
6 afford the material in question the level of protection to which it is
7 entitled under the Producing Party’s designation until the court rules on
8
the challenge.
9

10
7. ACCESS TO AND USE OF PROTECTED MATERIAL
11
7.1 Basic Principles. A Receiving Party may use Protected
12
Material that is disclosed or produced by another Party or by a Non-
13
Party in connection with this Action only for prosecuting, defending, or
14
attempting to settle this Action. Such Protected Material may be
15
disclosed only to the categories of persons and under the conditions
16
17 described in this Order. When the Action reaches a Final Disposition, a
18 Receiving Party must comply with the provisions of section 13 below.
19 Protected Material must be stored and maintained by a Receiving
20 Party at a location and in a secure manner that ensures that access is
21 limited to the persons authorized under this Stipulated Protective
22 Order.
23 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
24 Unless otherwise ordered by the court or permitted in writing by the
25 Designating Party, a Receiving Party may disclose any information or
26
item designated “CONFIDENTIAL” only:
27
(a) to the Receiving Party’s Outside Counsel of Record in this
1 Action, as well as employees of said Outside Counsel of Record to whom
2 it is reasonably necessary to disclose the information for this Action;
3 (b) to the officers, directors, and employees (including House
4 Counsel) of the Receiving Party to whom disclosure is reasonably
5 necessary for this Action;
6 (c) to Experts (as defined in this Order) of the Receiving Party to
7 whom disclosure is reasonably necessary for this Action and who have
8
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9
(d) to the court and its personnel;
10
(e) to court reporters and their staff;
11
(f) to professional jury or trial consultants, mock jurors, and
12
Professional Vendors to whom disclosure is reasonably necessary for
13
this Action and who have signed the “Acknowledgment and Agreement
14
to Be Bound” (Exhibit A);
15
(g) to the author or recipient of a document containing the
16
information or a custodian or other person who otherwise possessed or
17
knew the information;
18
(h) during their depositions, to witnesses, and attorneys for
19
witnesses, in the Action to whom disclosure is reasonably necessary,
20
provided: (1) the deposing party requests that the witness sign the
21
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
23 witness will not be permitted to keep any confidential information
24 unless they sign the “Acknowledgment and Agreement to Be Bound”
25 (Exhibit A), unless otherwise agreed by the Designating Party or
26 ordered by the court. Pages of transcribed deposition testimony or
27 exhibits to depositions that reveal Protected Material may be separately
1 as permitted under this Stipulated Protective Order; and
2 (i) to any mediator or settlement officer, and their supporting
3 personnel, mutually agreed upon by any of the parties engaged in
4 settlement discussions.
5
6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
7 PRODUCED IN OTHER LITIGATION
8
If a Party is served with a subpoena or a court order issued in
9
other litigation that compels disclosure of any information or items
10
designated in this Action as “CONFIDENTIAL,” that Party must:
11
(a) promptly notify in writing the Designating Party. Such
12
notification shall include a copy of the subpoena or court order;
13
(b) promptly notify in writing the party who caused the
14
subpoena or order to issue in the other litigation that some or all of the
15
material covered by the subpoena or order is subject to this Protective
16
Order. Such notification shall include a copy of this Stipulated
17
18 Protective Order; and
19 (c) cooperate with respect to all reasonable procedures sought to
20 be pursued by the Designating Party whose Protected Material may be
21 affected.
22 If the Designating Party timely seeks a protective order, the
23 Party served with the subpoena or court order shall not produce any
24 information designated in this action as “CONFIDENTIAL” before a
25 determination by the court from which the subpoena or order issued,
26 unless the Party has obtained the Designating Party’s permission. The
27
Designating Party shall bear the burden and expense of seeking
1 protection in that court of its confidential material and nothing in these
2 provisions should be construed as authorizing or encouraging a
3 Receiving Party in this Action to disobey a lawful directive from another
4 court.
5
6 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
7 PRODUCED IN THIS LITIGATION
8
9.1 Application. The terms of this Stipulated Protective Order
9
are applicable to information produced by a Non-Party in this Action and
10
designated as “CONFIDENTIAL.” Such information produced by Non-
11
Parties in connection with this litigation is protected by the remedies
12
and relief provided by this Order. Nothing in these provisions should be
13
construed as prohibiting a Non-Party from seeking additional
14
protections.
15
9.2 Notification. In the event that a Party is required, by a valid
16
discovery request, to produce a Non-Party’s confidential information in
17
its possession, and the Party is subject to an agreement with the Non-
18
Party not to produce the Non-Party’s confidential information, then the
19
Party shall:
20
21 (a) promptly notify in writing the Requesting Party and the
22 Non-Party that some or all of the information requested is subject to a
23 confidentiality agreement with a Non-Party;
24 (b) make the information requested available for inspection by
25 the Non-Party, if requested.
26 9.3 Conditions of Production. If the Non-Party fails to seek a
27 protective order from this court within 14 days of receiving the notice
1 Non-Party’s confidential information responsive to the discovery request.
2 If the Non-Party timely seeks a protective order, the Receiving Party
3 shall not produce any information in its possession or control that is
4 subject to the confidentiality agreement with the Non-Party before a
5 determination by the court. Absent a court order to the contrary, the
6 Non-Party shall bear the burden and expense of seeking protection in
7 this court of its Protected Material.
8

9
10. UNAUTHORIZED DISCLOSURE OF PROTECTED
10
MATERIAL
11
If a Receiving Party learns that, by inadvertence or otherwise, it
12
has disclosed Protected Material to any person or in any circumstance
13
not authorized under this Stipulated Protective Order, the Receiving
14
Party must immediately (a) notify in writing the Designating Party of
15
the unauthorized disclosures, (b) use its best efforts to retrieve all
16
17 unauthorized copies of the Protected Material, (c) inform the person or
18 persons to whom unauthorized disclosures were made of all the terms of
19 this Order, and (d) request such person or persons to execute the
20 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
21
22
11. INADVERTENT PRODUCTION OF PRIVILEGED OR
23
OTHERWISE PROTECTED MATERIAL
24
When a Producing Party gives notice to Receiving Parties that
25
certain inadvertently produced material is subject to a claim of privilege
26
or other protection, the obligations of the Receiving Parties are those set
27
1 provision is not intended to modify whatever procedure may be
2 established in an e-discovery order that provides for production without
3 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
4 Rules of Evidence, insofar as the parties reach an agreement on the
5 effect of disclosure of a communication or information covered by the
6 attorney-client privilege or work product protection, the parties may
7 incorporate their agreement in the stipulated protective order
8
submitted to the court.
9

10
12. MISCELLANEOUS
11
12.1 Right to Further Relief. Nothing in this Stipulated
12
Protective Order abridges the right of any person to seek its
13
modification by the court in the future.
14
12.2 Right to Assert Other Objections. By stipulating to the entry
15
of this Stipulated Protective Order no Party waives any right it
16
17 otherwise would have to object to disclosing or producing any
18 information or item on any ground not addressed in this Stipulated
19 Protective Order. Similarly, no Party waives any right to object on any
20 ground to use in evidence of any of the material covered by this
21 Stipulated Protective Order.
22 12.3 Filing Protected Material. A Party that seeks to file under
23 seal any Protected Material must comply with Local Rule 79-5.
24 Protected Material may only be filed under seal pursuant to a court
25 order authorizing the sealing of the specific Protected Material at issue.
26
If a Party's request to file Protected Material under seal is denied by the
27
court, then the Receiving Party may file the information in the public
1 record unless otherwise instructed by the court.
2
3 13. FINAL DISPOSITION
4
After the Final Disposition of this Action, as defined in paragraph
5
4, within 60 days of a written request by the Designating Party, each
6
Receiving Party must return all Protected Material to the Producing
7
Party or destroy such material. As used in this subdivision, “all
8
Protected Material” includes all copies, abstracts, compilations,
9
summaries, and any other format reproducing or capturing any of the
10
Protected Material. Whether the Protected Material is returned or
11
destroyed, the Receiving Party must submit a written certification to
12
the Producing Party (and, if not the same person or entity, to the
13
Designating Party) by the 60 day deadline that (1) identifies (by
14
category, where appropriate) all the Protected Material that was
15
returned or destroyed and (2) affirms that the Receiving Party has not
16
retained any copies, abstracts, compilations, summaries or any other
17
18 format reproducing or capturing any of the Protected Material.
19 Notwithstanding this provision, Counsel is entitled to retain an archival
20 copy of all pleadings, motion papers, trial, deposition, and hearing
21 transcripts, legal memoranda, correspondence, deposition and trial
22 exhibits, expert reports, attorney work product, and consultant and
23 expert work product, even if such materials contain Protected Material.
24 Any such archival copies that contain or constitute Protected Material
25 remain subject to this Protective Order as set forth in Section 4.
26

27
1 || 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished
3 || by any and all appropriate measures including, without limitation,
4 || contempt proceedings and/or monetary sanctions.
5
6 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8 DATED: February 24, 2026 /s/ Jay Rahimi
° Attorney(s) for Plaintiff(s)
10
1]
DATED: February 24, 2026 /s/ Monique Matar
3 Attorney(s) for Defendant(s)
14
15
16 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
17
ig || DATED: February 25, 2026
19 STEPHANIE S. CHRISTENSEN
50 United States Magistrate Judge
21
22
23
24
25
26
27
28

1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2

3
I, ________________________ [print or type full name], of
4
_________________ [print or type full address], declare under
5
penalty of perjury that I have read in its entirety and understand the
6
Stipulated Protective Order that was issued by the United States
7
District Court for the Central District of California on [date] in the
8
case of __________ [insert formal name of the case and the
9
number and initials assigned to it by the court]. I agree to
10
comply with and to be bound by all the terms of this Stipulated
11
Protective Order and I understand and acknowledge that failure to so
12
comply could expose me to sanctions and punishment in the nature of
13
14 contempt. I solemnly promise that I will not disclose in any manner
15 any information or item that is subject to this Stipulated Protective
16 Order to any person or entity except in strict compliance with the
17 provisions of this Order.
18 I further agree to submit to the jurisdiction of the United States
19 District Court for the Central District of California for the purpose of
20 enforcing the terms of this Stipulated Protective Order, even if such
21 enforcement proceedings occur after termination of this action. I
22 hereby appoint ________________________ [print or type full name]
23
of _________ [print or type full address and telephone number] as
24
25
26
27
1 my California agent for service of process in connection with this action
2 or any proceedings related to enforcement of this Stipulated Protective
3 Order.
4
5 Date: ___________________________
6 City and State where sworn and
7 signed: ___________________________
8
Printed name: ___________________________
9
Signature: ___________________________
10

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11367641. Public record. Not legal advice.