The opinion
]
3
5
6 UNITED STATES DISTRICT COURT
7 FOR THE EASTERN DISTRICT OF CALIFORNIA
° GROWER DIRECT NUT COMPANY, Case No. 2:24-CV-03468-DJC-CSK
INC» ORDER GRANTING MODIFIED
11 Plaintiff, STIPULATED PROTECTIVE ORDER
12 Vv. (ECF No. 18)
13 || INDEMNITY INSURANCE COMPANY
OF NORTH AMERICA,
"4 Defendant.
15
16 The Court has reviewed the parties’ stipulated protective order below (ECF No.
17 || 18), 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: February 3, 2026
27 Ch Spo \
GHI 500 KIM
28 |} 4 grows468.24 UNITED STATES MAGISTRATE JUDGE
1 Jonathan Gross, State Bar No. 122010
jgross@moundcotton.com
2 Megan Wendell, State Bar No. 238423
mwendell@moundcotton.com
3
MOUND COTTON WOLLAN & GREENGRASS LLP
4 2200 Powell Street, Suite 1050
Emeryville, California 94608
5 Telephone: (510) 900-9371
Facsimile: (510) 900-9381
6
Attorneys for Defendant
7
INDEMNITY INSURANCE COMPANY
OF NORTH AMERICA
8
9
10 UNITED STATES DISTRICT COURT
11 EASTERN DISTRICT OF CALIFORNIA
12 GROWER DIRECT NUT COMPANY, INC., Case No. 2:24-cv-03468-DJC-CSK
a California corporation,
13
Plaintiff, STIPULATION FOR MODIFIED
14 [PROPOSED] PROTECTIVE ORDER
v.
15
INDEMNITY INSURANCE COMPANY OF Judge: Hon. Daniel J. Calabretta
16 NORTH AMERICA, a Pennsylvania Complaint Filed: 10/10/2024
Corporation,
17
Defendants.
18
19
20
21
22
23
24
25
26
27
1 WHEREAS, Plaintiff GROWER DIRECT NUT COMPANY and Defendant INDEMNITY
2 INSURANCE COMPANY OF NORTH AMERICAN (collectively, the "PARTIES") believe that
3 confidential, private and/or proprietary information may be requested by the PARTIES in discovery
4 in the course of this litigation by way of document requests and deposition testimony; and
5 WHEREAS, discovery in this action is expected to involve production of limited categories
6 of information that constitute confidential business, financial, proprietary, or private information,
7 the disclosure of which could reasonably be expected to cause competitive harm, invade privacy, or
8 otherwise result in prejudice, including, to the extent such information is maintained as confidential
9 in the ordinary course of business and is not publicly available.
10 For its part, Plaintiff contends that the following categories of documents may be eligible
11 for protection:
12 (a) Competitively sensitive sales, pricing and customer or vendor information reflecting
13 negotiated terms, margins, discounts, or non-public business strategies, the disclosure of which
14 would reasonably be expected to cause competitive harm.
15 (b) Non-public shipping, logistics and inventory records only to the extent they reveal
16 proprietary operational methods, security-sensitive information, or confidential vendor relationships
17 and not routine transactional documents produced in the ordinary course of business, except to the
18 extent that such documents reflect non-public pricing, volumes, customer identifies, or routing
19 information not generally disclosed outside the business relationship.
20 (d) Non-public financial information, including internal financial statements, profit and loss
21 reports, projections and business interruption or lost profits analyses, prepared for internal
22 management, regulatory or litigation purposes and the disclosure of which would reveal sensitive
23 financial performance or strategy.
24 (e) Internal policies, procedures, manuals or process documents that are not publicly
25 disseminated and that disclose proprietary methods, internal controls, or confidential operational
26 practices, excluding high-level policies or procedures made available to employees or the public.
27 (f) Commercially sensitive information regarding the development, production, marketing,
1 of causing harm to the competitive position of the person or entity from which the information is
2 obtained.
3 (g) Personal identifying information of employees, customers or third parties protected by
4 privacy interests or applicable law, including Social Security numbers, financial account
5 information, or personal contact information.
6 For its part, Defendant contends that the following categories of documents may be eligible
7 for protection:
8 (a) Policies and procedures for claims and underwriting.
9 (b) Underwriting information.
10 WHEREAS, the PARTIES desire to avoid controversy regarding the potential disclosure of
11 such confidential information,
12 IT IS HEREBY STIPULATED by and among the PARTIES, through their respective
13 counsel of record, that they will comply with the following terms and the Court may enter an
14 order establishing the following:
15 1. PURPOSES AND LIMITATIONS
16 Disclosure and discovery activity in this action are likely to involve production of
17 confidential, proprietary, or private information for which special protection from public disclosure
18 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly,
19 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective
20 Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures
21 or responses to discovery and that the protection it affords from public disclosure and use extends
22 only to the limited information or items that are entitled to confidential treatment under the
23 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, below, that
24 this Stipulated Protective Order does not entitle them to file confidential information under seal;
25 Local Rule 141 sets forth the procedures that must be followed and the standards that will be applied
26 when a party seeks permission from the court to file material under seal.
27 2. DEFINITIONS
1 information or items under this Order.
2 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is
3 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule
4 of Civil Procedure 26(c), including, without limitation, the categories of information described in
5 the recitals to this Stipulated Protective Order.
6 2.3 Counsel (without qualifier): Outside Counsel of Record and In-House Counsel (as
7 well as their support staff).
8 2.4 Designating Party: a Party or Non-Party that designates information or items that it
9 produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
10 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium
11 or manner in which it is generated, stored, or maintained (including, among other things, testimony,
12 transcripts, and tangible things), that are produced or generated in disclosures or responses to
13 discovery in this matter.
14 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to
15 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
16 consultant in this action.
17 2.7 In-House Counsel: attorneys who are employees of a party to this action. In-House
18 Counsel does not include Outside Counsel of Record or any other outside counsel.
19 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal
20 entity not named as a Party to this action.
21 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action
22 but are retained to represent or advise a party to this action and have appeared in this action on
23 behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
24 2.10 Party: any party to this action, including all of its officers, directors, employees,
25 consultants, retained experts, and Outside Counsel of Record (and their support staffs).
26 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
27 Material in this action.
1 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing,
2 storing, or retrieving data in any form or medium) and their employees and subcontractors.
3 2.13 Protected Material: any Disclosure or Discovery Material that is designated as
4 “CONFIDENTIAL.”
5 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a
6 Producing Party.
7 3. SCOPE
8 The protections conferred by this Stipulation and Order cover not only Protected Material
9 (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all
10 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
11 conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
12 However, the protections conferred by this Stipulation and Order do not cover the following
13 information: (a) any information that is in the public domain at the time of disclosure to a Receiving
14 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of
15 publication not involving a violation of this Order, including becoming part of the public record
16 through trial or otherwise; and (b) any information known to the Receiving Party prior to the
17 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the
18 information lawfully and under no obligation of confidentiality to the Designating Party. Any use
19 of Protected Material at trial shall be governed by a separate agreement or order.
20 4. DURATION
21 Even after final disposition of this litigation, the confidentiality obligations imposed by this
22 Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order
23 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and
24 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion
25 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the
26 time limits for filing any motions or applications for extension of time pursuant to applicable law.
27 5. DESIGNATING PROTECTED MATERIAL
1 Non-Party that designates information or items for protection under this Order must take care to
2 limit any such designation to specific material that qualifies under the appropriate standards. The
3 Designating Party must designate for protection only those parts of material, documents, items, or
4 oral or written communications that qualify – so that other portions of the material, documents,
5 items, or communications for which protection is not warranted are not swept unjustifiably within
6 the ambit of this Order.
7 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown
8 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily
9 encumber or retard the case development process or to impose unnecessary expenses and burdens
10 on other parties) expose the Designating Party to sanctions.
11 If it comes to a Designating Party’s attention that information or items that it designated for
12 protection do not qualify for protection, that Designating Party must promptly notify all other Parties
13 that it is withdrawing the mistaken designation.
14 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see,
15 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or
16 Discovery Material that qualifies for protection under this Order must be clearly so designated
17 before the material is disclosed or produced.
18 Designation in conformity with this Order requires:
19 (a) For information in documentary form (e.g., paper or electronic documents, but
20 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party
21 affix the legend “CONFIDENTIAL” to each page that contains protected material.
22 (b) For testimony given in deposition or in other pretrial or trial proceedings, that the
23 Designating Party identify on the record, before the close of the deposition, hearing, or other
24 proceeding, all protected testimony, with an exception that the. Parties retain the right to designate
25 confidential material in a deposition thirty (30) days after the final deposition transcript is made
26 available.
27 (c) For information produced in some form other than documentary and for any other
1 or containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a
2 portion or portions of the information or item warrant protection, the Producing Party, to the extent
3 practicable, shall identify the protected portion(s).
4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
5 designate qualified information or items does not, standing alone, waive the Designating Party’s
6 right to secure protection under this Order for such material. Upon timely correction of a
7 designation, the Receiving Party must make reasonable efforts to assure the Producing Party that
8 the material is treated in accordance with the provisions of this Order.
9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
11 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
12 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic
13 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to
14 challenge a confidentiality designation by electing not to mount a challenge promptly after the
15 original designation is disclosed.
16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process
17 by providing written notice of each designation it is challenging and describing the basis for each
18 challenge . To avoid ambiguity as to whether a challenge has been made, the written notice must
19 recite that the challenge to confidentiality is being made in accordance with this specific paragraph
20 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must
21 begin the process by conferring directly (in voice to voice dialogue; other forms of communication
22 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging
23 Party must explain the basis for its belief that the confidentiality designation was not proper and
24 must give the Designating Party an opportunity to review the designated material, to reconsider the
25 circumstances, and, if no change in designation is offered, to explain the basis for the chosen
26 designation. A Challenging Party may proceed to the next stage of the challenge process only if it
27 has engaged in this meet and confer process first or establishes that the Designating Party is
1 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court
2 intervention, the Designating Party shall file and serve a motion to retain confidentiality under Local
3 Rule 230 (and in compliance with Local Rule 141, if applicable) within 21 days of the initial notice
4 of challenge or within 14 days of the parties agreeing that the meet and confer process will not
5 resolve their dispute, whichever is earlier. Each such motion must be accompanied by a competent
6 declaration affirming that the movant has complied with the meet and confer requirements imposed
7 in the preceding paragraph. Failure by the Designating Party to make such a motion including the
8 required declaration within 21 days (or 14 days, if applicable) shall automatically waive the
9 confidentiality designation for each challenged designation. In addition, the Challenging Party may
10 file a motion challenging a confidentiality designation at any time if there is good cause for doing
11 so, including a challenge to the designation of a deposition transcript or any portions thereof. Any
12 motion brought pursuant to this provision must be accompanied by a competent declaration
13 affirming that the movant has complied with the meet and confer requirements imposed by the
14 preceding paragraph.
15 The burden of persuasion in any such challenge proceeding shall be on the Designating
16 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
17 unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions.
18 Unless the Designating Party has waived the confidentiality designation by failing to file a motion
19 to retain confidentiality as described above, all parties shall continue to afford the material in
20 question the level of protection to which it is entitled under the Producing Party’s designation until
21 the court rules on the challenge.
22 7. ACCESS TO AND USE OF PROTECTED MATERIAL
23 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or
24 produced by another Party or by a Non-Party in connection with this case only for prosecuting,
25 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to
26 the categories of persons and under the conditions described in this Order. When the litigation has
27 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
1 Protected Material must be stored and maintained by a Receiving Party at a location and in
2 a secure manner that ensures that access is limited to the persons authorized under this Order.
3 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered
4 by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
5 information or item designated “CONFIDENTIAL” only to:
6 (a) the parties;
7 (b) the Receiving Party’s Outside Counsel of Record in this action, as well as employees
8 of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information
9 for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is
10 attached hereto as Exhibit A;
11 (c) the officers, directors, and employees (including In-House Counsel) of the Receiving
12 Party to whom disclosure is reasonably necessary for this litigation and who have signed the
13 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14 (d) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
15 reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement
16 to Be Bound” (Exhibit A);
17 (e) the court, court personnel, and court appointed or party agreed upon mediators;
18 (f) court reporters and their staff, professional jury or trial consultants, mock jurors, and
19 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have
20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
21 (g) during their depositions, witnesses in the action to whom disclosure is reasonably
22 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
23 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed
24 deposition testimony or exhibits to depositions that reveal Protected Material must be separately
25 bound by the court reporter and may not be disclosed to anyone except as permitted under this
26 Stipulated Protective Order.
27 (h) the author or recipient of a document containing the information or a custodian or
1 (i) as necessary, to reinsurers, auditors, and regulators.
2 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
3 LITIGATION
4 If a Party is served with a subpoena or a court order issued in other litigation that compels
5 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
6 must:
7 (a) promptly notify in writing the Designating Party. Such notification shall include a
8 copy of the subpoena or court order;
9 (b) Upon receipt of this notice, the Designating Party may, in its sole discretion and at
10 its own cost, move to quash or limit the Subpoena or Order, otherwise oppose
11 production of the Confidential or Protected Material, and/or seek to obtain
12 confidential treatment of such Confidential or Protected Material from the
13 subpoenaing or ordering person or entity to the fullest extent available under law.
14 (c) The recipient of the Subpoena may not produce any documents, testimony or
15 information relating to the Confidential or Protected Material pursuant to the
16 Subpoena prior to the date specified for production on the Subpoena.
17
18 If the Designating Party timely seeks a protective order, the Party served with the subpoena
19 or court order shall not produce any information designated in this action as “CONFIDENTIAL”
20 before a determination by the court from which the subpoena or order issued, unless the Party has
21 obtained the Designating Party’s permission. The Designating Party shall bear the burden and
22 expense of seeking protection in that court of its confidential material – and nothing in these
23 provisions should be construed as authorizing or encouraging a Receiving Party in this action to
24 disobey a lawful directive from another court.
25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
26 LITIGATION
27 (a) The terms of this Order are applicable to information produced by a Non-Party in this
1 connection with this litigation is protected by the remedies and relief provided by this Order.
2 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional
3 protections.
4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
6 Material to any person or in any circumstance not authorized under this Stipulated Protective Order,
7 the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized
8 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c)
9 inform the person or persons to whom unauthorized disclosures were made of all the terms of this
10 Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to
11 Be Bound” that is attached hereto as Exhibit A.
12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
13 MATERIAL
14 The production of a privileged or work-product-protected document, whether inadvertent or
15 otherwise, is not a waiver of privilege or protection from discovery in this case or in any other
16 federal or state proceeding. Any documents subject to a claim of privilege or of protection as trial
17 preparation material that are inadvertently produced shall be handled in the same manner as the
18 production of a privileged or work-product protected document. Within a reasonable time after the
19 discovery of an inadvertent disclosure of Protective Material (including but not limited to the
20 production of privileged or work-product protected document), the party that disclosed the
21 Protective Material must (1) notify the Producing Party promptly and (2) diligently attempt to
22 recover the Protective Material (including but not limited to the production of privileged or work-
23 product protected document) that was inadvertently disclosed, including but not limited to involving
24 the applicable court to retrieve the inadvertently disclosed information.
25 12. MISCELLANEOUS
26 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek
27 its modification by the court in the future.
1 no Party waives any right it otherwise would have to object to disclosing or producing any
2 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
3 Party waives any right to object on any ground to use in evidence of any of the material covered by
4 this Protective Order.
5 12.3 Filing Protected Material. Without written permission from the Designating Party or
6 a court order secured after appropriate notice to all interested persons, a Party may not file in the
7 public record in this action any Protected Material. A Party that seeks to file under seal any Protected
8 Material must comply with Local Rule 141. Protected Material may only be filed under seal pursuant
9 to a court order authorizing the sealing of the specific Protected Material at issue. Pursuant to Local
10 Rule 141, a sealing order will issue only upon a request establishing that the Protected Material at
11 issue is privileged, protectable as a trade secret, or otherwise entitled to protection under the law. If
12 a Receiving Party’s request to file Protected Material under seal pursuant to Local Rule 141 is denied
13 by the court, then the Receiving Party may file the information in the public record unless otherwise
14 instructed by the court.
15 13. FINAL DISPOSITION
16 Within 60 days after the final disposition of this action, as defined in paragraph 4, each
17 Receiving Party must return all Protected Material to the Producing Party or destroy such material.
18 The Receiving Party that is an insurance company may keep and maintain Protected Material as
19 strictly confidential or redacted. The Protected Material will become part of the insurance
20 company’s claim file that cannot be destroyed pursuant to the Insurance Code and Regulations
21 imposed by California. As used in this subdivision, “all Protected Material” includes all copies,
22 abstracts, compilations, summaries, and any other format reproducing or capturing any of the
23 Protected Material. Whether the Protected Material is returned, destroyed, or maintained as
24 confidential or redacted, the Receiving Party must submit a written certification to the Producing
25 Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline that (1)
26 identifies (by category, where appropriate) all the Protected Material that was returned, destroyed,
27 maintained as confidential, or maintained as confidential and redacted and (2) except as permitted
1 compilations, summaries or any other format reproducing or capturing any of the Protected Material.
2 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings,
3 motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
4 deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work
5 product, even if such materials contain Protected Material. Any such archival copies that contain or
6 constitute Protected Material remain subject to this Protective Order as set forth in Section 4
7 (DURATION).
8 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
9 Dated: January 30, 2026 DOWNEY BRAND
10
11 By: /s/ Norik Naraghi
Anthony L. Vignolo
12 Norik Naraghi
13 Attorneys for Plaintiff
GROWER DIRECT NUT COMPANY
14
15 Dated: January 30, 2026 MOUND COTTON WOLLAN & GREENGRASS
LLP
16
17
By: /s/ Megan Wendell (as authorized on 1/3/26)
18 Jonathan Gross
Megan Wendell
19
Attorneys for Defendants
INDEMNITY INSURANCE COMPANY OF
20
NORTH AMERICA
21
22
23
24
25
26
27
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of _________________
5 [print or type full 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 Court for
7 Eastern District on ____________ in the case of Grower Direct Nut Company, Inc. v. Indemnity
8 Insurance Company of North America, case no. 2:24-cv-03468-DJC-CSK. I have been given a copy
9 of the Stipulated Protective Order; I have read it, and I agree to be bound by its terms. I agree to
10 comply with and to be bound by all the terms of this Stipulated Protective Order and I understand
11 and acknowledge that failure to so comply could expose me to sanctions and punishment in the
12 nature of contempt. I solemnly promise that I will not disclose in any manner any information or
13 item that is subject to this Stipulated Protective Order to any person or entity except in strict
14 compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for the Eastern
16 District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even
17 if such enforcement proceedings occur after termination of this action.
18
19 Date: ______________________________________
20 City and State where sworn and signed: _________________________________
21 Printed name: _______________________________
22 Signature: __________________________________
23
24
25
26
27