Opinion

Opinion

Court
District Court, C.D. California
Filed
Apr 17, 2026
Cited by
0 cases
Authority
More cited than 41.5%

The opinion

1 DENISE C. MILLS, Chief Deputy City Attorney

KATHLEEN KENEALY, Chief Assistant City Attorney

2

CHRISTIAN R. BOJORQUEZ, Deputy City Attorney

3 ERIN CHOI, Deputy City Attorney (SBN 342323)

200 North Main Street, 6th Floor, City Hall East

4 Los Angeles, CA 90012

Phone No.: (213) 202-5429 | Fax No.: (213) 978-8785

5 Email: erin.choi@lacity.org

6

Attorneys for Defendant, CITY OF LOS ANGELES

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10

11

KELLY OCAMPO, an individual;

Case No. 2:26-cv-01874-SB-AJR

12

Plaintiff,

v. [PROPOSED] STIPULATED

13 PROTECTIVE ORDER

CITY OF LOS ANGELES, a

14

California public entity; and DOES 1-

20, inclusive;

15

Defendant.

16

17 1. GENERAL

18 1.1 Purposes and Limitations. Discovery in this action is likely to involve

19 production of confidential or private information for which special protection from

20 public disclosure and from use for any purpose other than pursuing this litigation may

21 be warranted. Accordingly, the parties hereby stipulate to and petition this Court to

22 enter the following Protective Order. This Order does not confer blanket protections

23 on all disclosures or responses to discovery; the protection it affords from public

24 disclosure and use extends only to the limited information or items that are entitled to

25 confidential treatment under the applicable legal principles. Further, as set forth in

26 Section 12.3, below, that this Protective Order does not entitle the parties to file

27 confidential information under seal. Civil Local Rule 79-5 sets forth the procedures

28 that must be followed and the standards that will be applied when a party seeks

1 permission from the court to file material under seal.

2 1.2 Good Cause Statement. In light of the nature of the claims and

3 allegations in this case and the parties’ representations that discovery in this case may

4 involve the production of confidential records, and including but not limited to

5 employment/personnel records, information of individually named Defendants and/or

6 other employees of the City, information otherwise generally unavailable to the

7 public, or which may be privileged or otherwise protected from disclosure under state

8 or federal statutes, court rules, case decisions, or common law.

9 Defendants maintain as confidential such as personnel files of the peace

10 officer(s) involved in this incident, Internal Affairs materials and information, video

11 recordings, audio recordings, photographs, and information and other administrative

12 materials and information currently in the possession of Defendant City of Los

13 Angeles (“City”), and the City believes need special protection from public

14 disclosure and from use for any purpose other than pursuing this litigation. To the

15 extent personnel files of peace officers involved in the subject incident are sought

16 in discovery, personnel files are maintained as strictly confidential and need special

17 protection from public disclosure and from use for any purpose other than

18 prosecuting this litigation.

19 The confidentiality of the materials and information is recognized by

20 California and federal law, as evidenced inter alia by California Penal Code §§

21 832.5, 832.7 and 832.8; Kerr v. United States Dist. Ct. for N.D. Cal., 511 F.2d 192,

22 198 (9th Cir. Cal. 1975); California Evidence Code §§ 1040 and 1043 et. seq; the

23 Privacy Act of 1974, 5 U.S.C. § 552; the right to privacy; decisional law relating to

24 such provisions; official information privilege1; state or federal statutes, court rules,

25 case decisions, or common law.

26

27 1 Sanchez v. City of Santa Ana, 936 F.2d 1027, 1033 (9th Cir. Cal.1990); see

also Kerr v. United States Dist. Ct. for N.D. Cal., 511 F.2d 192, 198 (9th Cir. Cal.

28

1975), aff’d, 426 U.S. 394, 96 S. Ct. 3229, 48 L.Ed.2d 725 (1976).

1 Further, discovery may require depositions, written discovery and/or the

2 production of certain information the public disclosure of which could compromise

3 officer safety, and/or raise security issues. Additionally, public disclosure of such

4 information poses a substantial risk of embarrassment, oppression, and/or physical

5 harm to peace officers whose confidential information is disclosed. The risk of harm

6 to peace officers is greater than with other government employees due to the nature

7 of their profession. The benefit of public disclosure of confidential information is

8 minimal while the potential disadvantages are great. Defendants also contend that the

9 unfettered disclosure of the materials and information, absent a Protective Order,

10 would allow the media to share this information with potential jurors in the area,

11 impacting the rights of Defendants herein to receive a fair trial.

12 Accordingly, to expedite the flow of information, facilitate the prompt

13 resolution of disputes over confidentiality of discovery materials, adequately protect

14 information the parties are entitled to keep confidential, ensure that the parties are

15 permitted reasonable necessary uses of such material in connection with this action,

16 address their handling at the end of the litigation, and serve the ends of justice, a

17 protective order for such information is justified in this matter. It is the intent of the

18 parties that information will not be designated as confidential for tactical reasons and

19 that nothing be so designated without a good faith belief that it has been maintained

20 in a confidential, non-public manner, and there is good cause why it should not be

21 part of the public record of this case.

22 2. DEFINITIONS

23 2.1 Action: Kailey Ocampo v. City of Los Angeles, Case No. 2:26-cv-01874-

24 SB-AJR.

25 2.2 Challenging Party: a Party or Non-Party that challenges the designation

26 of information or items under this Order.

27 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

28 how it is generated, stored or maintained) or tangible things that qualify for protection

1 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good

2 Cause Statement.

3 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

4 support staff).

5 2.5 Designating Party: a Party or Non-Party that designates information or

6 items that it produces in disclosures or in responses to discovery as

7 “CONFIDENTIAL.”

8 2.6 Disclosure or Discovery Material: all items or information, regardless

9 of the medium or manner in which it is generated, stored, or maintained (including,

10 among other things, testimony, transcripts, and tangible things), that are produced or

11 generated in disclosures or responses to discovery in this matter.

12 2.7 Expert: a person with specialized knowledge or experience in a matter

13 pertinent to the litigation who has been retained by a Party or its counsel to serve as

14 an expert witness or as a consultant in this Action.

15 2.8 House Counsel: attorneys who are employees of a party to this Action.

16 House Counsel does not include Outside Counsel of Record or any other outside

17 counsel.

18 2.9 Non-Party: any natural person, partnership, corporation, association, or

19 other legal entity not named as a Party to this action.

20 2.10 Outside Counsel of Record: attorneys who are not employees of a party

21 to this Action but are retained to represent or advise a party to this Action and have

22 appeared in this Action on behalf of that party or are affiliated with a law firm that

23 has appeared on behalf of that party, including support staff.

24 2.11 Party: any party to this Action, including all of its officers, directors,

25 employees, consultants, retained experts, and Outside Counsel of Record (and their

26 support staffs).

27 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

28 Discovery Material in this Action.

1 2.13 Professional Vendors: persons or entities that provide litigation support

2 services (e.g., photocopying, videotaping, translating, preparing exhibits or

3 demonstrations, and organizing, storing, or retrieving data in any form or medium)

4 and their employees and subcontractors.

5 2.14 Protected Material: any Disclosure or Discovery Material that is

6 designated as “CONFIDENTIAL.”

7 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

8 from a Producing Party.

9

10 3. SCOPE

11 The protections conferred by this Order cover not only Protected Material (as

12 defined above), but also (1) any information copied or extracted from Protected

13 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;

14 and (3) any testimony, conversations, or presentations by Parties or their Counsel that

15 might reveal Protected Material, other than during a court hearing or at trial.

16 Any use of Protected Material during a court hearing or at trial shall be

17 governed by the orders of the presiding judge. This Order does not govern the use of

18 Protected Material during a court hearing or at trial.

19

20 4. DURATION

21 Even after final disposition of this litigation, the confidentiality obligations

22 imposed by this Order shall remain in effect until a Designating Party agrees

23 otherwise in writing or a court order otherwise directs. Final disposition shall be

24 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with

25 or without prejudice; or (2) final judgment herein after the completion and exhaustion

26 of all appeals, rehearings, remands, trials, or reviews of this Action, including the time

27 limits for filing any motions or applications for extension of time pursuant to

28 applicable law.

1 Any protection sought for documents that are presented at trial shall be

2 governed by order of the judge presiding over the trial. Should any Protected

3 Material become part of the public record at trial or otherwise (such as where the

4 Court denies the request to file under seal), this Protective Order shall no longer

5 apply to the portions which became part of the public record at trial with the

6 exception that any such material must still be returned in compliance with Section

7 13 FINAL DISPOSITION.

8 Should any portion of the Protected Material remain confidential during any

9 portion of the trial of this action which could entail the discussion or disclosure of

10 confidential information, that Designating Party may request the opportunity to

11 show compelling reasons to the Court as to why access to the courtroom should be

12 limited to parties, their counsel and other designated representative, experts or

13 consultants who agreed to be bound by this stipulation/protective order, and court

14 personnel. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81

15 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents

16 produced in discovery from “compelling reasons” standard when merits-related

17 documents are part of court record).

18

19 5. DESIGNATING PROTECTED MATERIAL

20 5.1 Exercise of Restraint and Care in Designating Material for Protection.

21 Each Party or Non-Party that designates information or items for protection under this

22 Order must take care to limit any such designation to specific material that qualifies

23 under the appropriate standards. The Designating Party must designate for protection

24 only those parts of material, documents, items, or oral or written communications that

25 qualify so that other portions of the material, documents, items, or communications

26 for which protection is not warranted are not swept unjustifiably within the ambit of

27 this Order.

28

1 Mass, indiscriminate, or routinized designations are prohibited. Designations

2 that are shown to be clearly unjustified or that have been made for an improper

3 purpose (e.g., to unnecessarily encumber the case development process or to impose

4 unnecessary expenses and burdens on other parties) may expose the Designating Party

5 to sanctions.

6 If it comes to a Designating Party’s attention that information or items that it

7 designated for protection do not qualify for protection, that Designating Party must

8 promptly notify all other Parties that it is withdrawing the inapplicable designation.

9 5.2 Manner and Timing of Designations. Except as otherwise provided in

10 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise

11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

12 under this Order must be clearly so designated before the material is disclosed or

13 produced.

14 Designation in conformity with this Order requires:

15 (a) for information in documentary form (e.g., paper or electronic

16 documents, but excluding transcripts of depositions), that the Producing Party affix,

17 at a minimum, the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL

18 legend”), to each page that contains protected material. If only a portion or portions

19 of the material on a page qualifies for protection, the Producing Party also must clearly

20 identify the protected portion(s) (e.g., by making appropriate markings in the

21 margins).

22 A Party or Non-Party that makes original documents available for inspection

23 need not designate them for protection until after the inspecting Party has indicated

24 which documents it would like copied and produced. During the inspection and

25 before the designation, all of the material made available for inspection shall be

26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

27 it wants copied and produced, the Producing Party must determine which documents,

28 or portions thereof, qualify for protection under this Order. Then, before producing

1 the specified documents, the Producing Party must affix the “CONFIDENTIAL

2 legend” to each page that contains Protected Material. If only a portion or portions

3 of the material on a page qualifies for protection, the Producing Party also must clearly

4 identify the protected portion(s) (e.g., by making appropriate markings in the

5 margins).

6 (b) for testimony given in depositions that the Designating Party identify

7 the Disclosure or Discovery Material on the record, before the close of the deposition.

8 (c) for information produced in some form other than documentary and

9 for any other tangible items, that the Producing Party affix in a prominent place on

10 the exterior of the container or containers in which the information is stored the legend

11 “CONFIDENTIAL.” If only a portion or portions of the information warrants

12 protection, the Producing Party, to the extent practicable, shall identify the protected

13 portion(s).

14 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

15 failure to designate qualified information or items does not, standing alone, waive the

16 Designating Party’s right to secure protection under this Order for such material.

17 Upon timely correction of a designation, the Receiving Party must make reasonable

18 efforts to assure that the material is treated in accordance with the provisions of this

19 Order.

20

21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

23 designation of confidentiality at any time that is consistent with the Court’s

24 Scheduling Order.

25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

26 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly

27 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.

28

1 6.3 Burden. The burden of persuasion in any such challenge proceeding

2 shall be on the Designating Party. Frivolous challenges, and those made for an

3 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on

4 other parties) may expose the Challenging Party to sanctions. Unless the Designating

5 Party has waived or withdrawn the confidentiality designation, all parties shall

6 continue to afford the material in question the level of protection to which it is entitled

7 under the Producing Party’s designation until the Court rules on the challenge.

8

9 7. ACCESS TO AND USE OF PROTECTED MATERIAL

10 7.1 Basic Principles. A Receiving Party may use Protected Material that is

11 disclosed or produced by another Party or by a Non-Party in connection with this

12 Action only for prosecuting, defending, or attempting to settle this Action. Such

13 Protected Material may be disclosed only to the categories of persons and under the

14 conditions described in this Order. When the Action has been terminated, a Receiving

15 Party must comply with the provisions of Section 13 below (FINAL DISPOSITION).

16 Protected Material must be stored and maintained by a Receiving Party at a

17 location and in a secure manner that ensures that access is limited to the persons

18 authorized under this Order.

19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

20 otherwise ordered by the Court or permitted in writing by the Designating Party, a

21 Receiving Party may disclose any information or item designated

22 “CONFIDENTIAL” only to:

23 (a) the Receiving Party’s Outside Counsel of Record in this Action, as

24 well as employees of said Outside Counsel of Record to whom it is reasonably

25 necessary to disclose the information for this Action;

26 (b) the officers, directors, and employees (including House Counsel) of

27 the Receiving Party to whom disclosure is reasonably necessary for this Action;

28

1 (c) Experts (as defined in this Order) of the Receiving Party to whom

2 disclosure is reasonably necessary for this Action and who have signed the

3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

4 (d) the Court and its personnel;

5 (e) court reporters and their staff;

6 (f) professional jury or trial consultants, mock jurors, and Professional

7 Vendors to whom disclosure is reasonably necessary for this Action and who have

8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

9 (g) the author or recipient of a document containing the information or

10 a custodian or other person who otherwise possessed or knew the information;

11 (h) during their depositions, witnesses, and attorneys for witnesses, in

12 the Action to whom disclosure is reasonably necessary provided: (1) the deposing

13 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they

14 will not be permitted to keep any confidential information unless they sign the

15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

16 agreed by the Designating Party or ordered by the Court. Pages of transcribed

17 deposition testimony or exhibits to depositions that reveal Protected Material may be

18 separately bound by the court reporter and may not be disclosed to anyone except as

19 permitted under this Protective Order; and

20 (i) any mediator or settlement officer, and their supporting personnel,

21 mutually agreed upon by any of the parties engaged in settlement discussions.

22

23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

24 PRODUCED IN OTHER LITIGATION

25 If a Party is served with a subpoena or a court order issued in other litigation

26 that compels disclosure of any information or items designated in this Action as

27 “CONFIDENTIAL,” that Party must:

28

1 (a) promptly notify in writing the Designating Party. Such notification shall

2 include a copy of the subpoena or court order;

3 (b) promptly notify in writing the party who caused the subpoena or order to

4 issue in the other litigation that some or all of the material covered by the subpoena

5 or order is subject to this Protective Order. Such notification shall include a copy of

6 this Protective Order; and

7 (c) cooperate with respect to all reasonable procedures sought to be pursued

8 by the Designating Party whose Protected Material may be affected.

9 If the Designating Party timely seeks a protective order, the Party served with

10 the subpoena or court order shall not produce any information designated in this action

11 as “CONFIDENTIAL” before a determination by the court from which the subpoena

12 or order issued, unless the Party has obtained the Designating Party’s permission or

13 unless otherwise required by law or court order. The Designating Party shall bear the

14 burden and expense of seeking protection in that court of its confidential material and

15 nothing in these provisions should be construed as authorizing or encouraging a

16 Receiving Party in this Action to disobey a lawful directive from another court.

17

18 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

19 PRODUCED IN THIS LITIGATION

20 (a) The terms of this Order are applicable to information produced by a Non-

21 Party in this Action and designated as “CONFIDENTIAL.” Such information

22 produced by Non-Parties in connection with this litigation is protected by the

23 remedies and relief provided by this Order. Nothing in these provisions should be

24 construed as prohibiting a Non-Party from seeking additional protections.

25 (b) In the event that a Party is required, by a valid discovery request, to produce

26 a Non-Party’s confidential information in its possession, and the Party is subject to an

27 agreement with the Non-Party not to produce the Non-Party’s confidential

28 information, then the Party shall:

1 (1) promptly notify in writing the Requesting Party and the Non-Party

2 that some or all of the information requested is subject to a confidentiality agreement

3 with a Non-Party;

4 (2) promptly provide the Non-Party with a copy of the Protective Order

5 in this Action, the relevant discovery request(s), and a reasonably specific description

6 of the information requested; and

7 (3) make the information requested available for inspection by the Non-

8 Party, if requested.

9 (c) If the Non-Party fails to seek a protective order from this Court within 14

10 days of receiving the notice and accompanying information, the Receiving Party may

11 produce the Non-Party’s confidential information responsive to the discovery request.

12 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

13 any information in its possession or control that is subject to the confidentiality

14 agreement with the Non-Party before a determination by the Court. Absent a court

15 order to the contrary, the Non-Party shall bear the burden and expense of seeking

16 protection in this Court of its Protected Material.

17

18 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

20 Protected Material to any person or in any circumstance not authorized under this

21 Protective Order, the Receiving Party must immediately (a) notify in writing the

22 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

23 all unauthorized copies of the Protected Material, (c) inform the person or persons to

24 whom unauthorized disclosures were made of all the terms of this Order, and (d)

25 request such person or persons to execute the “Acknowledgment and Agreement to

26 Be Bound” that is attached hereto as Exhibit A.

27

28

1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

2 PROTECTED MATERIAL

3 When a Producing Party gives notice to Receiving Parties that certain

4 inadvertently produced material is subject to a claim of privilege or other protection,

5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

7 may be established in an e-discovery order that provides for production without prior

8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

9 parties reach an agreement on the effect of disclosure of a communication or

10 information covered by the attorney-client privilege or work product protection, the

11 parties may incorporate their agreement in the Stipulated Protective Order submitted

12 to the Court.

13

14 12. MISCELLANEOUS

15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

16 person to seek its modification by the Court in the future.

17 12.2 Right to Assert Other Objections. By stipulating to the entry of this

18 Protective Order, no Party waives any right it otherwise would have to object to

19 disclosing or producing any information or item on any ground not addressed in this

20 Protective Order. Similarly, no Party waives any right to object on any ground to use

21 in evidence of any of the material covered by this Protective Order.

22 12.3 Filing Protected Material. A Party that seeks to file under seal any

23 Protected Material must comply with Civil Local Rule 79-5. Protected Material may

24 only be filed under seal pursuant to a Court Order authorizing the sealing of the

25 specific Protected Material at issue; good cause must be shown in the request to file

26 under seal. 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 record unless

28 otherwise instructed by the Court.

1 13. FINAL DISPOSITION

2 After the final disposition of this Action, within 60 days of a written request by

3 the Designating Party, each Receiving Party must return all Protected Material to the

4 Producing Party or destroy such material. As used in this subdivision, “all Protected

5 Material” includes all copies, abstracts, compilations, summaries, and any other

6 format reproducing or capturing any of the Protected Material. Whether the Protected

7 Material is returned or destroyed, the Receiving Party must submit a written

8 certification to the Producing Party (and, if not the same person or entity, to the

9 Designating Party) by the 60 day deadline that (1) identifies (by category, where

10 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms

11 that the Receiving Party has not retained any copies, abstracts, compilations,

12 summaries or any other format reproducing or capturing any of the Protected Material.

13 Notwithstanding this provision, counsel are entitled to retain an archival copy of all

14 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

15 correspondence, deposition and trial exhibits, expert reports, attorney work product,

16 and consultant and expert work product, even if such materials contain Protected

17 Material. Any such archival copies that contain or constitute Protected Material

18 remain subject to this Protective Order as set forth in Section 4 (DURATION).

19

20 14. VIOLATION OF ORDER

21 Any violation of this Order may be punished by any and all appropriate

22 measures including, without limitation, contempt proceedings and/or monetary

23 sanctions.

///

24

25 ///

26

///

27

///

28

1 || fT ISSO STIPULATED, THROUGH COUNSEL OF RECORD.

2

Dated: April 16, 2026 POINTER & BUELNA, LLP

3 LAWYERS FOR THE PEOPLE

4

By: 4s/ Michael A, Slater

5 ADANTE POINTER

PATRICK BUELNA

6 MICHAEL A. SLATER

Counsel for Plaintiff

7 KAILEY OCAMPO

8

9

10 |! Dated: April 14, 2026 HYDEE FELDSTEIN SOTO, City Attorney

11 DENISE C. MILLS, Chief Deputy City Attorney

KATHLEEN KENEALY, Chief Assistant City Atty.

12 CHRISTIAN R. BOJORQUEZ, Deputy City Attorne

13 By: /s/ Erin Choi

14 ERIN CHOI, Deputy City Attorney

Attorneys for Defendant, CITY OF LOS ANGELES

15

16

17 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

18 -

19 || DATED: April 17, 2026

HON A. JOEL RICHLIN

20 United States Magistrate Judge

21

22

23

24

25

26

27

28

15

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

4 I, _____________________________ [full name], of _________________

5 [full address], declare under penalty of perjury that I have read in its entirety and

6 understand the Protective Order that was issued by the United States District Court

7 for the Central District of California on ____________ [date] in the case of Kailey

8 Ocampo v. City of Los Angeles, Case No. 2:26-cv-01874-SB-AJR. I agree to

9 comply with and to be bound by all the terms of this Protective Order and I

10 understand and acknowledge that failure to so comply could expose me to sanctions

11 and punishment in the nature of contempt. I solemnly promise that I will not

12 disclose in any manner any information or item that is subject to this Protective

13 Order to any person or entity except in strict compliance with the provisions of this

14 Order.

15 I further agree to submit to the jurisdiction of the United States District Court

16 for the Central District of California for the purpose of enforcing the terms of this

17 Protective Order, even if such enforcement proceedings occur after termination of

18 this action. I hereby appoint __________________________ [full name] of

19 _______________________________________ [full address and telephone

20 number] as my California agent for service of process in connection with this

21 action or any proceedings related to enforcement of this Protective Order.

22 Date: ______________________________________

23 City and State where signed: _________________________________

24

25 Printed name: _______________________________

26

27 Signature: __________________________________

28

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.