The opinion
1 Christopher M. Engels, Esq (Bar No. 304855)
Sean B. Janzen, Esq. (SBN 293426)
2 Sarah O’Brien, Esq. (SBN 299408)
ENGELS LAW APC
3 2900 Bristol St., Ste. G205
Costa Mesa CA 92626
4 (949) 269-7709
chris@engelslaw.com
5 sean@engelslaw.com
sarah@engelslaw.com
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Attorneys for Plaintiff Sonia Lozano
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Hardy Ray Murphy CA Bar No. 187149
8 hardy.murphy@ogletree.com
OGLETREE, DEAKINS, NASH,
9 SMOAK & STEWART, P.C.
400 South Hope Street, Suite 1200
10 Los Angeles, CA 90071
Telephone: 213-239-9800
11 Facsimile: 213-239-9045
12 Attorneys for Defendants
Arthur J. Gallagher & Co.; Arthur J. Gallagher
13 Service Company, LLC; Arthur J. Gallagher, LLC;
Arthur J. Gallagher Real Estate Risk Purchasing
14 Group, LLC; and Arthur J. Gallagher Financial
Services Professionals Risk Purchasing Group, LLC
15 [Additional Attorneys on following page]
16
17 UNITED STATES DISTRICT COURT
18 CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION
19 SONIA LOZANO, an individual; Case No. 2:25-cv-09666-JLS (AJR)
20 Plaintiff, STIPULATION AND PROPOSED
PROTECTIVE ORDER
21 v.
Complaint Filed: August 25, 2025
22 ARTHUR J. GALLAGHER & CO., Trial Date: None Set
an unknown entity; ARTHUR J. District Judge: Hon. Josephine L.
23 GALLAGHER SERVICE COMPANY, Staton
LLC, a Delaware Limited Liability Magistrate Judge: Hon. A. Joel Richlin
24 Company; ARTHUR J. GALLAGHER,
LLC, an Illinois Limited Liability
25 Company; et al.
26 Defendants.
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1 Omar F. Hassan CA Bar No. 322034
omar.hassan@ogletree.com
2 OGLETREE, DEAKINS, NASH,
SMOAK & STEWART, P.C.
3 Park Tower, Fifteenth Floor
695 Town Center Drive
4 Costa Mesa, CA 92626
Telephone: 714-800-7900
5 Facsimile: 714-754-1298
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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 disclosure
4 and from use for any purpose other than pursuing this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 following Stipulated Protective Order (also, the “Order” or “Protective Order”). The
7 parties acknowledge that this Order does not confer blanket protections on all
8 disclosures or responses to discovery and that the protection it affords from public
9 disclosure and use extends only to the limited information or items that are entitled to
10 confidential treatment under the applicable legal principles.
11 2. GOOD CAUSE STATEMENT
12 This action is likely to involve financial, commercial, private, and/or proprietary
13 information for which special protection from public disclosure and from use for any
14 purpose other than prosecution of this action is warranted. Such confidential and
15 proprietary materials and information consist of, among other things, confidential
16 business or financial information, information implicating privacy rights of third
17 parties and/or Plaintiff, information generally unavailable to the public, or which may
18 be privileged or otherwise protected from disclosure under state or federal statutes,
19 court rules, case decisions, or common law. Accordingly, to expedite the flow of
20 information, to facilitate the prompt resolution of disputes over confidentiality or
21 privacy of discovery materials, to adequately protect information the parties are
22 entitled to keep confidential and/or private, to ensure that the parties are permitted to
23 reasonable necessary uses of such material in preparation for and in conduct of trial,
24 to address their handling at the end of litigation, and to serve the ends of justice, a
25 protective order for such information is justified in this matter. It is the intent of the
26 parties that information will not be designated as confidential for tactical reasons and
27 that nothing be so designated without a good faith belief that it has been maintained in
28 a confidential, non-public manner, and there is good cause why it should not be part
1 of the public record of this case.
2 3. ACKNOWLEDGMENT OF UNDER SEAL FILING
3 PROCEDURE
4 The parties further acknowledge, as set forth in Section 14.3, below, that this
5 Stipulated Protective Order does not entitle them to file confidential information under
6 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
7 standards that will be applied when a party seeks permission from the court to file
8 material under seal. There is a strong presumption that the public has a right of access
9 to judicial proceedings and records in civil cases. In connection with non-dispositive
10 motions, good cause must be shown to support a filing under seal. See Kamakana v.
11 City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.
12 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony
13 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective
14 orders require good cause showing), and a specific showing of good cause or
15 compelling reasons with proper evidentiary support and legal justification, must be
16 made with respect to Protected Material that a party seeks to file under seal. The
17 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL
18 does not— without the submission of competent evidence by declaration, establishing
19 that the material sought to be filed under seal qualifies as confidential, privileged, or
20 otherwise protectable—constitute good cause.
21 Further, if a party requests sealing related to a dispositive motion or trial, then
22 compelling reasons, not only good cause, for the sealing must be shown, and the relief
23 sought shall be narrowly tailored to serve the specific interest to be protected. See
24 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
25 or type of information, document, or thing sought to be filed or introduced under seal,
26 the party seeking protection must articulate compelling reasons, supported by specific
27 facts and legal justification, for the requested sealing order. Again, competent
28 evidence supporting the application to file documents under seal must be provided by
1 declaration.
2 Any document that is not confidential, privileged, or otherwise protectable in
3 its entirety will not be filed under seal if the confidential portions can be redacted. If
4 documents can be redacted, then a redacted version for public viewing, omitting only
5 the confidential, privileged, or otherwise protectable portions of the document, shall
6 be filed. Any application that seeks to file documents under seal in their entirety
7 should include an explanation of why redaction is not feasible.
8 4. DEFINITIONS
9 4.1 Action: Sonia Lozano v. Arthur J. Gallagher & Co., et al., United States
10 District Court Case No. 2:25-cv-09666-JLS (AJR).
11 4.2 Challenging Party: a Party or Non-Party that challenges the designation
12 of information or items under this Order.
13 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
14 how it is generated, stored or maintained) or tangible things that qualify for protection
15 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
16 Statement. [Note: any request for a two-tiered, attorney-eyes-only protective order
17 that designates certain material as “Highly Confidential” will require a separate and
18 detailed showing of need.]
19 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
20 support staff).
21 4.5 Designating Party: a Party or Non-Party that designates information or
22 items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL.”
24 4.6 Disclosure or Discovery Material: all items or information, regardless of
25 the medium or manner in which it is generated, stored, or maintained (including,
26 among other things, testimony, transcripts, and tangible things), that are produced or
27 generated in disclosures or responses to discovery in this matter.
28 4.7 Expert: a person with specialized knowledge or experience in a matter
1 pertinent to the litigation who has been retained by a Party or its counsel to serve as
2 an expert witness or as a consultant in this Action.
3 4.8 House Counsel: attorneys who are employees of a Party to this Action.
4 House Counsel does not include Outside Counsel of Record or any other outside
5 counsel.
6 4.9 Non-Party: any natural person, partnership, corporation, association, or
7 other legal entity not named as a Party to this action.
8 4.10 Outside Counsel of Record: attorneys who are not employees of a Party
9 to this Action but are retained to represent or advise a Party to this Action and have
10 appeared in this Action on behalf of that Party or are affiliated with a law firm which
11 has appeared on behalf of that Party, and includes support staff.
12 4.11 Party: any Party to this Action, including all of its officers, directors,
13 employees, consultants, retained experts, and Outside Counsel of Record (and their
14 support staffs).
15 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
16 Discovery Material in this Action.
17 4.13 Professional Vendors: persons or entities that provide litigation support
18 services (e.g., photocopying, videotaping, translating, preparing exhibits or
19 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
20 their employees and subcontractors.
21 4.14 Protected Material: any Disclosure or Discovery Material that is
22 designated as “CONFIDENTIAL.”
23 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material
24 from a Producing Party.
25 5. SCOPE
26 The protections conferred by this Stipulation and Order cover not only Protected
27 Material (as defined above), but also (1) any information copied or extracted from
28 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
1 Material; and (3) any testimony, conversations, or presentations by Parties or their
2 Counsel that might reveal Protected Material.
3 Any use of Protected Material at trial will be governed by the orders of the trial
4 judge. This Order does not govern the use of Protected Material at trial.
5 6. DURATION
6 Once a case proceeds to trial, all of the information that was designated as
7 confidential or maintained pursuant to this protective order becomes public and will
8 be presumptively available to all members of the public, including the press, unless
9 compelling reasons supported by specific factual findings to proceed otherwise are
10 made to the trial judge in advance of the trial. See Kamakana v. City and County of
11 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
12 showing for sealing documents produced in discovery from “compelling reasons”
13 standard when merits-related documents are part of court record). Accordingly, the
14 terms of this Protective Order do not extend beyond the commencement of the trial.
15 7. DESIGNATING PROTECTED MATERIAL
16 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each
17 Party or Non-Party that designates information or items for protection under this Order
18 must take care to limit any such designation to specific material that qualifies under
19 the appropriate standards. The Designating Party must designate for protection only
20 those parts of material, documents, items or oral or written communications that
21 qualify so that other portions of the material, documents, items or communications for
22 which protection is not warranted are not swept unjustifiably within the ambit of this
23 Order. Mass, indiscriminate or routinized designations are prohibited. Designations
24 that are shown to be clearly unjustified or that have been made for an improper purpose
25 (e.g., to unnecessarily encumber the case development process or to impose
26 unnecessary expenses and burdens on other parties) may expose the Designating Party
27 to sanctions.
28 If it comes to a Designating Party’s attention that information or items that it
1 designated for protection do not qualify for protection, that Designating Party must
2 promptly notify all other Parties that it is withdrawing the inapplicable designation.
3 7.2 Manner and Timing of Designations. Except as otherwise provided in this
4 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that
5 qualifies for protection under this Order must be clearly so designated before the
6 material is disclosed or produced.
7 Designation in conformity with this Order requires:
8 (a) for information in documentary form (e.g., paper or electronic
9 documents, but excluding transcripts of depositions or other pretrial or trial
10 proceedings), that the Producing Party affix at a minimum, the legend
11 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
12 contains protected material. If only a portion of the material on a page qualifies for
13 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
14 by making appropriate markings in the margins).
15 A Party or Non-Party that makes original documents available for inspection
16 need not designate them for protection until after the inspecting Party has indicated
17 which documents it would like copied and produced.
18 During the inspection and before the designation, all of the material made
19 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting
20 Party has identified the documents it wants copied and produced, the Producing Party
21 must determine which documents, or portions thereof, qualify for protection under this
22 Order. Then, before producing the specified documents, the Producing Party must
23 affix the “CONFIDENTIAL legend” to each page that contains Protected Material. If
24 only a portion of the material on a page qualifies for protection, the Producing Party
25 also must clearly identify the protected portion(s) (e.g., by making appropriate
26 markings in the margins).
27 (b) for testimony given in depositions that the Designating Party
28 identifies the Disclosure or Discovery Material on the record, before the close of the
1 deposition all protected testimony.
2 (c) for information produced in some form other than documentary and
3 for any other tangible items, that the Producing Party affix in a prominent place on the
4 exterior of the container or containers in which the information is stored the legend
5 “CONFIDENTIAL.” If only a portion or portions of the information warrants
6 protection, the Producing Party, to the extent practicable, shall identify the protected
7 portion(s).
8 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
9 to designate qualified information or items does not, standing alone, waive the
10 Designating Party’s right to secure protection under this Order for such material. Upon
11 timely correction of a designation, the Receiving Party must make reasonable efforts
12 to assure that the material is treated in accordance with the provisions of this Order.
13 8. CHALLENGING CONFIDENTIAL DESIGNATIONS
14 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation
15 of confidentiality at any time that is consistent with the Court’s Scheduling Order.
16 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
17 process under Local Rule 37-1 et seq.
18 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
19 stipulation pursuant to Local Rule 37-2.
20 8.4 The burden of persuasion in any such challenge proceeding shall be on the
21 Designating Party. Frivolous challenges, and those made for an improper purpose
22 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
23 expose the Challenging Party to sanctions. Unless the Designating Party has waived
24 or withdrawn the confidentiality designation, all parties shall continue to afford the
25 material in question the level of protection to which it is entitled under the Producing
26 Party’s designation until the Court rules on the challenge.
27 9. ACCESS TO AND USE OF PROTECTED MATERIAL
28 9.1 Basic Principles. A Receiving Party may use Protected Material that is
1 disclosed or produced by another Party or by a Non-Party in connection with this
2 Action only for prosecuting, defending or attempting to settle this Action. Such
3 Protected Material may be disclosed only to the categories of persons and under the
4 conditions described in this Order. When the Action has been terminated, a Receiving
5 Party must comply with the provisions of section 15 below (FINAL DISPOSITION).
6 Protected Material must be stored and maintained by a Receiving Party at a
7 location and in a secure manner that ensures that access is limited to the persons
8 authorized under this Order.
9 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
10 ordered by the court or permitted in writing by the Designating Party, a Receiving
11 Party may disclose any information or item designated “CONFIDENTIAL” only to:
12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
13 well as employees of said Outside Counsel of Record to whom it is reasonably
14 necessary to disclose the information for this Action;
15 (b) the officers, directors, and employees (including House Counsel) of
16 the Receiving Party to whom disclosure is reasonably necessary for this Action;
17 (c) Experts (as defined in this Order) of the Receiving Party to whom
18 disclosure is reasonably necessary for this Action and who have signed the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20 (d) the court and its personnel;
21 (e) court reporters and their staff;
22 (f) professional jury or trial consultants, mock jurors, and Professional
23 Vendors to whom disclosure is reasonably necessary for this Action and who have
24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (g) the author or recipient of a document containing the information or a
26 custodian or other person who otherwise possessed or knew the information;
27 (h) during their depositions, witnesses, and attorneys for witnesses, in the
28 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
1 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
2 not be permitted to keep any confidential information unless they sign the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
4 by the Designating Party or ordered by the court.
5 Pages of transcribed deposition testimony or exhibits to depositions that reveal
6 Protected Material may be separately bound by the court reporter and may not be
7 disclosed to anyone except as permitted under this Stipulated Protective Order; and
8 (i) any mediators or settlement officers and their supporting personnel,
9 mutually agreed upon by any of the parties engaged in settlement discussions.
10 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
11 PRODUCED IN OTHER LITIGATION
12 If a Party is served with a subpoena or a court order issued in other litigation
13 that compels disclosure of any information or items designated in this Action as
14 “CONFIDENTIAL,” that Party must:
15 (a) promptly notify in writing the Designating Party. Such notification
16 shall include a copy of the subpoena or court order;
17 (b) promptly notify in writing the party who caused the subpoena or order
18 to issue in the other litigation that some or all of the material covered by the subpoena
19 or order is subject to this Protective Order. Such notification shall include a copy of
20 this Stipulated Protective Order; and
21 (c) cooperate with respect to all reasonable procedures sought to be
22 pursued by the Designating Party whose Protected Material may be affected. If the
23 Designating Party timely seeks a protective order, the Party served with the subpoena
24 or court order shall not produce any information designated in this action as
25 “CONFIDENTIAL” before a determination by the court from which the subpoena or
26 order issued, unless the Party has obtained the Designating Party’s permission. The
27 Designating Party shall bear the burden and expense of seeking protection in that court
28 of its confidential material and nothing in these provisions should be construed as
1 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
2 directive from another court.
3 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 (a) The terms of this Order are applicable to information produced by a
6 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
7 produced by Non-Parties in connection with this litigation is protected by the remedies
8 and relief provided by this Order. Nothing in these provisions should be construed as
9 prohibiting a Non-Party from seeking additional protections.
10 (b) In the event that a Party is required, by a valid discovery request, to
11 produce a Non-Party’s confidential information in its possession, and the Party is
12 subject to an agreement with the Non-Party not to produce the Non-Party’s
13 confidential information, then the Party shall:
14 (1) promptly notify in writing the Requesting Party and the Non-Party
15 that some or all of the information requested is subject to a confidentiality agreement
16 with a Non-Party;
17 (2) promptly provide the Non-Party with a copy of the Stipulated
18 Protective Order in this Action, the relevant discovery request(s), and a reasonably
19 specific description of the information requested; and
20 (3) make the information requested available for inspection by the Non-
21 Party, if requested.
22 (c) If the Non-Party fails to seek a protective order from this court within
23 14 days of receiving the notice and accompanying information, the Receiving Party
24 may produce the Non-Party’s confidential information responsive to the discovery
25 request. If the Non-Party timely seeks a protective order, the Receiving Party will not
26 produce any information in its possession or control that is subject to the
27 confidentiality agreement with the Non-Party before a determination by the court.
28 Absent a court order to the contrary, the Non-Party will bear the burden and expense
1 of seeking protection in this court of its Protected Material.
2 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
4 Protected Material to any person or in any circumstance not authorized under this
5 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
6 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
7 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
8 persons to whom unauthorized disclosures were made of all the terms of this Order,
9 and (d) request such person or persons to execute the “Acknowledgment and
10 Agreement to Be Bound” attached hereto as Exhibit A.
11 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
12 OTHERWISE PROTECTED MATERIAL
13 When a Producing Party gives notice to Receiving Parties that certain
14 inadvertently produced material is subject to a claim of privilege or other protection,
15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil\
16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
17 may be established in an e-discovery order that provides for production without prior
18 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
19 parties reach an agreement on the effect of disclosure of a communication or
20 information covered by the attorney-client privilege or work product protection, the
21 parties may incorporate their agreement in the stipulated protective order submitted to
22 the court.
23 14. MISCELLANEOUS
24 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
25 person to seek its modification by the Court in the future.
26 14.2 Right to Assert Other Objections. By stipulating to the entry of this
27 Protective Order, no Party waives any right it otherwise would have to object to
28 disclosing or producing any information or item on any ground not addressed in this
1 Stipulated Protective Order. Similarly, no Party waives any right to object on any
2 ground to use in evidence of any of the material covered by this Protective Order.
3 14.3 Filing Protected Material. A Party that seeks to file under seal any
4 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
5 only be filed under seal pursuant to a court order authorizing the sealing of the specific
6 Protected Material. If a Party’s request to file Protected Material under seal is denied
7 by the court, then the Receiving Party may file the information in the public record
8 unless otherwise instructed by the court.
9 15. FINAL DISPOSITION
10 After the final disposition of this Action, as defined in paragraph 4, within 60
11 days of a written request by the Designating Party, each Receiving Party must return
12 all Protected Material to the Producing Party or destroy such material. As used in this
13 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
14 summaries, and any other format reproducing or capturing any of the Protected
15 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
16 must submit a written certification to the Producing Party (and, if not the same person
17 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
18 category, where appropriate) all the Protected Material that was returned or destroyed
19 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
20 compilations, summaries or any other format reproducing or capturing any of the
21 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
22 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
23 legal memoranda, correspondence, deposition and trial exhibits, expert reports,
24 attorney work product, and consultant and expert work product, even if such materials
25 contain Protected Material. Any such archival copies that contain or constitute
26 Protected Material remain subject to this Protective Order as set forth in Section 6
27 (DURATION).
28 / / / /
1 16. VIOLATION
2 Any violation of this Order may be punished by appropriate measures including,
3 || without limitation, contempt proceedings and/or monetary sanctions.
4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5
6 |] DATED: March 10, 2026 ENGELS LAW, APC
7 By: /s/ Sean B. Janzen
8 Christopher M. Engels
Sean B. Janzen, Esq.
9 Sarah O’Brien, Esq.
10 Attorneys for Plaintiff
Sonia Lozano
12 |, DATED: March 4, 2026 OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
13
14
15 By: /s/ Omar F. Hassan
Hardy Ray Murphy
16 Omar F. Hassan
17 Attomeys for Defendants
Arthur J. Gallagher & Co.; Arthur J. Gallagher
18 Service Company. LLC; Arthur J. Gallagher,
LLC; Arthur J. allagher Real Estate Risk
19 Purchasing Group, LLC; and Arthur J.
Gallagher inancial Services Professionals
20 Risk Purchasing Group, LLC
21 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22
93 || DATED: March 11, 2026
24 .
ANDel Richlin
26 United States Magistrate Judge
27
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13 Case No. 2:25-cv-09666-JLS (AJR
OQTIPTIT ATION ANT) PROPOSED PROTECTIVE ORDER
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [full name], of _________________ [full
5 address], declare under penalty of perjury that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States District
7 Court for the Central District of California on [date] in the case of ___________
8 [insert case name and number]. I agree to comply with and to be bound by all the
9 terms of this Stipulated Protective Order and I understand and acknowledge that failure
10 to so comply could expose me to sanctions and punishment in the nature of contempt.
11 I solemnly promise that I will not disclose in any manner any information or item that
12 is subject to this Stipulated Protective Order to any person or entity except in strict
13 compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court for the
15 Central District of California for the purpose of enforcing the terms of this Stipulated
16 Protective Order, even if such enforcement proceedings occur after termination of this
17 action. I hereby appoint __________________________ [full name] of
18 _______________________________________ [full address and telephone
19 number] as my California agent for service of process in connection with this action
20 or any proceedings related to enforcement of this Stipulated Protective Order.
21
22 Date: ______________________________________
23 City and State where signed: _________________________________
24 Printed name: _______________________________
25
26 Signature: __________________________________
27
28