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.
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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
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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