The opinion
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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11 GIOVANNI HERNANDEZ CASE NO. 2:25-CV-05372-MRA-KS
Hon. Monica Ramirez Almadani Ctrm. 9B
12 Hon. Karen Stevenson Ctrm. 580
Plaintiff(s),
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v.
14 STIPULATED PROTECTIVE ORDER
CITY OF LOS ANGELES, JOE
15 LUMBRERAS, BLANCA LOPEZ,
AUGUSTIN LOPEZ, JEROME
16 MICHALEZAK, N. MAGPOC, M.
DEPASQUALE, OFFICER
17 REYNOLDS, B. BERT, and
UNIDENTIFIED EMPLOYEES of the
18 LOS ANGELES POLICE
DEPARTMENT,
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Defendant(s).
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1. A. PURPOSES AND LIMITATIONS
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Discovery in this action is likely to involve production of confidential, proprietary,
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or private information for which special protection from public disclosure and from use
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for any purpose other than prosecuting this litigation may be warranted. Accordingly, the
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parties hereby stipulate to and petition the Court to enter the following Stipulated
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Protective Order. The parties acknowledge that this Order does not confer blanket
1 from public disclosure and use extends only to the limited information or items that are
2 entitled to confidential treatment under the applicable legal principles. The parties further
3 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order
4 does not entitle them to file confidential information under seal; Civil Local Rule 79-5
5 sets forth the procedures that must be followed and the standards that will be applied
6 when a party seeks permission from the court to file material under seal.
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8 B. GOOD CAUSE STATEMENT
9 This action involves employees of the City of Los Angeles (the City) which
10 include members of the Citys Los Angeles Police Department (LAPD). The nature of
11 the incident that gives rise to Plaintiffs suit and Plaintiffs claims and allegations, will
12 result in discovery production that includes: police reports and evidence; investigation
13 reports and evidence; peace officer personnel materials; and information that may
14 implicate the privacy rights of third parties (i.e., bystander witnesses, emergency
15 personnel information).
16 Specifically, Plaintiff is seeking materials and information that Defendant
17 maintains as confidential which may include personnel files of the police and/or sworn
18 officers involved in this incident, Internal Affairs materials and information, video
19 recordings, audio recordings, photographs, and information and other administrative
20 materials and information currently in the possession of the City and which Defendant
21 believes need special protection from public disclosure and from use for any purpose
22 other than prosecuting this litigation. Defendants also anticipate that Plaintiff will also
23 seek information contained in the personnel files of the police and/or sworn officers
24 involved in the subject incident, which the City maintained as confidential and which
25 Defendants believe need special protection from public disclosure and from use for any
26 purpose other than prosecuting this litigation.
27 The parties do not agree about the propriety of keeping all of this information
1 hand, Defendants assert that the confidentiality of the materials and information sought
2 by Plaintiff is recognized by California and federal law, as evidenced inter alia by
3 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal.,
4 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). Defendant has not publicly
5 released the materials and information referenced above except under protective order or
6 pursuant to a court order, if at all. Defendants contend the personnel materials and
7 information are of the type that has been used to initiate disciplinary action against the
8 Citys respective employees, and has been used as evidence in disciplinary proceedings,
9 where the employee conduct was considered to be contrary to policy.
10 Defendants contend that absent a protective order delineating the responsibilities
11 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary
12 and undue disclosure by one or more of the many attorneys, secretaries, law clerks,
13 paralegals and expert witnesses involved in this case, as well as the corollary risk of
14 embarrassment, harassment and professional and legal harm on the part of the Citys
15 employees referenced in the materials and information.
16 Defendants also contend that the unfettered disclosure of the materials and
17 information, absent a protective order, would allow the media to share this information
18 with potential jurors in the area, impacting the rights of Defendant herein to receive a fair
19 trial.
20 On the other hand, Plaintiff disagrees with Defendants contentions about the need
21 for privacy over all police documents. Plaintiff disagrees that state-law privileges or
22 statutes are relevant to discovery in this matter. See, e.g., Moore v. Gonzalez, 2013 WL
23 3816012, at *5 (E.D. Cal. July 22, 2013). Even putting that to the side, Plaintiff contends
24 that internal affairs documentswhich can reveal systemic police misconductshould
25 not be strictly confidential under Californias Public Records Act. Defendants view of
26 absolute or strict privacy is anathema to transparency and was rejected in 2018 by the
27 passage of the Right to Know Act. Indeed, online databases now exist that include some
1 However, documents available under the Public Records Act must be redacted,
2 which poses a burden on Defendnats and may lead to disputes about what should or
3 should not be redacted. To expedite matters, and to ensure that discovery can be fulsome,
4 Plaintiff agrees that there is Good Cause for a Protective Order so as to preserve the
5 respective interests of the parties while streamlining the process of resolving any
6 disagreements.
7 Accordingly, to expedite the flow of information, to facilitate the prompt resolution
8 of disputes over confidentiality of discovery materials, to adequately protect information
9 the parties are entitled to keep confidential, to ensure that the parties are permitted
10 reasonable necessary uses of such material in preparation for and in the conduct of trial,
11 to address their handling at the end of the litigation, and serve the ends of justice, a
12 protective order for such information is justified in this matter. It is the intent of the
13 parties that information will not be designated as confidential for tactical reasons and that
14 nothing be so designated without a good faith belief that it has been maintained in a
15 confidential, non-public manner, and there is good cause why it should not be part of the
16 public record of this case.
17 The parties therefore stipulate that there is Good Cause for, and hereby jointly
18 request that the honorable Court issue a Protective Order regarding confidential
19 documents consistent with the terms and provisions of this Stipulation. However, the
20 entry of a Protective Order by the Court pursuant to this Stipulation shall not be construed
21 as any ruling by the Court on the aforementioned legal statements or privilege claims in
22 this section, no shall this section be construed as part of any such Court Order.
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27 2. DEFINITIONS
1 2.1 Action: [ Giovanni Hernandez v. City of Los Angeles, et al., case no. 2:25-
2 CV-05372-MRA-KS.
3 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
4 information or items under this Order.
5 2.3 CONFIDENTIAL Information or Items: information (regardless of how
6 it is generated, stored or maintained) or tangible things that qualify for protection under
7 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
8 Statement.
9 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
10 support staff).
11 2.5 Designating Party: a Party or Non-Party that designates information or items
12 that it produces in disclosures or in responses to discovery as CONFIDENTIAL.
13 2.6 Disclosure or Discovery Material: all items or information, regardless of the
14 medium or manner in which it is generated, stored, or maintained (including, among other
15 things, testimony, transcripts, and tangible things), that are produced or generated in
16 disclosures or responses to discovery in this matter.
17 2.7 Expert: a person with specialized knowledge or experience in a matter
18 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
19 expert witness or as a consultant in this Action.
20 2.8 House Counsel: attorneys who are employees of a party to this Action.
21 House Counsel does not include Outside Counsel of Record or any other outside counsel.
22 2.9 Non-Party: any natural person, partnership, corporation, association, or
23 other legal entity not named as a Party to this action.
24 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
25 this Action but are retained to represent or advise a party to this Action and have appeared
26 in this Action on behalf of that party or are affiliated with a law firm which has appeared
27 on behalf of that party, and includes support staff.
1 2.11 Party: any party to this Action, including all of its officers, directors,
2 employees, consultants, retained experts, and Outside Counsel of Record (and their
3 support staffs).
4 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
5 Discovery Material in this Action.
6 2.13 Professional Vendors: persons or entities that provide litigation support
7 services (e.g., photocopying, videotaping, translating, preparing exhibits or
8 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
9 their employees and subcontractors.
10 2.14 Protected Material: any Disclosure or Discovery Material that is designated
11 as CONFIDENTIAL.
12 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from
13 a Producing Party.
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15 3. SCOPE
16 The protections conferred by this Stipulation and Order cover not only Protected
17 Material (as defined above), but also (1) any information copied or extracted from
18 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
19 Material; and (3) any testimony, conversations, or presentations by Parties or their
20 Counsel that might reveal Protected Material.
21 Any use of Protected Material at trial shall be governed by the orders of the trial
22 judge. This Order does not govern the use of Protected Material at trial.
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24 4. DURATION
25 Once a case proceeds to trial, all of the information that was designated as
26 confidential or maintained pursuant to this protective order becomes public and will be
27 presumptively available to all members of the public, including the press, unless
1 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu,
2 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing good cause showing for sealing
3 documents produced in discovery from compelling reasons standard when merits-
4 related documents are part of court record). Accordingly, the terms of this protective
5 order do not extend beyond the commencement of the trial.
6 After final disposition of this litigation, the confidentiality obligations imposed by
7 this Stipulated Protective Order shall remain in effect for items not considered by the
8 Court in adjudicating any motion or dispute (for items not submitted under seal) and not
9 published to the jury or entered into evidence at trial until a Designating Party agrees
10 otherwise in writing or a court order otherwise directs. Final disposition shall be pursuant
11 to Section 13 below.
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13 5. DESIGNATING PROTECTED MATERIAL
14 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
15 Party or Non-Party that designates information or items for protection under this Order
16 must take care to limit any such designation to specific material that qualifies under the
17 appropriate standards. The Designating Party must designate for protection only those
18 parts of material, documents, items, or oral or written communications that qualify so that
19 other portions of the material, documents items, or communications for which protection
20 is not warranted are not swept unjustifiably within the ambit of this Order.
21 Mass, indiscriminate, or routinized designations are prohibited. Designations that
22 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
23 to unnecessarily encumber the case development process or to impose unnecessary
24 expenses and burdens on other parties) may expose the Designating Party to sanctions.
25 If it comes to a Designating Partys attention that information or items that it
26 designated for protection do not qualify for protection, that Designating Party must
27 promptly notify all other Parties that it is withdrawing the inapplicable designation.
1 5.2 Manner and Timing of Designations. Except as otherwise provided in this
2 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
3 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
4 must be clearly so designated before the material is disclosed or produced.
5 Designation in conformity with this Order requires:
6 (a) for information in documentary form (e.g., paper or electronic documents, but
7 excluding transcripts of depositions or other pretrial or trial proceedings), that the
8 Producing Party affix at a minimum, the legend CONFIDENTIAL (hereinafter
9 CONFIDENTIAL legend), to each page that contains protected material. If only a
10 portion or portions of the material on a page qualifies for protection, the Producing Party
11 also must clearly identify the protected portion(s) (e.g., by making appropriate markings
12 in the margins).
13 A Party or Non-Party that makes original documents available for inspection need
14 not designate them for protection until after the inspecting Party has indicated which
15 documents it would like copied and produced. During the inspection and before the
16 designation, all of the material made available for inspection shall be deemed
17 CONFIDENTIAL. After the inspecting Party has identified the documents it wants
18 copied and produced, the Producing Party must determine which documents, or portions
19 thereof, qualify for protection under this Order. Then, before producing the specified
20 documents, the Producing Party must affix the CONFIDENTIAL legend to each page
21 that contains Protected Material. If only a portion or portions of the material on a page
22 qualifies for protection, the Producing Party also must clearly identify the protected
23 portion(s) (e.g., by making appropriate markings in the margins).
24 (b) for testimony given in depositions that the Designating Party identify the
25 Disclosure or Discovery Material on the record, before the close of the deposition all
26 protected testimony.
27 (c) for information produced in some form other than documentary and for any
1 of the container or containers in which the information is stored the legend
2 CONFIDENTIAL. If only a portion or portions of the information warrants protection,
3 the Producing Party, to the extent practicable, shall identify the protected portion(s).
4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
5 to designate qualified information or items does not, standing alone, waive the
6 Designating Partys right to secure protection under this Order for such material. Upon
7 timely correction of a designation, the Receiving Party must make reasonable efforts to
8 assure that the material is treated in accordance with the provisions of this Order.
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10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
11 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation
12 of confidentiality at any time that is consistent with the Courts Scheduling Order.
13 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
14 process under Local Rule 37.1 et seq.
15 6.3 The burden of persuasion in any such challenge proceeding shall be on the
16 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
17 to harass or impose unnecessary expenses and burdens on other parties) may expose the
18 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
19 the confidentiality designation, all parties shall continue to afford the material in question
20 the level of protection to which it is entitled under the Producing Partys designation until
21 the Court rules on the challenge.
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23 7. ACCESS TO AND USE OF PROTECTED MATERIAL
24 7.1 Basic Principles. A Receiving Party may use Protected Material that is
25 disclosed or produced by another Party or by a Non-Party in connection with this Action
26 only for prosecuting, defending, or attempting to settle this Action. Such Protected
27 Material may be disclosed only to the categories of persons and under the conditions
1 described in this Order. When the Action has been terminated, a Receiving Party must
2 comply with the provisions of section 13 below (FINAL DISPOSITION).
3 Protected Material must be stored and maintained by a Receiving Party at a
4 location and in a secure manner that ensures that access is limited to the persons
5 authorized under this Order.
6 7.2 Disclosure of CONFIDENTIAL Information or Items. Unless otherwise
7 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
8 may disclose any information or item designated CONFIDENTIAL only to:
9 (a) the Receiving Partys Outside Counsel of Record in this Action, as well as
10 employees of said Outside Counsel of Record to whom it is reasonably necessary to
11 disclose the information for this Action;
12 (b) the officers, directors, and employees (including House Counsel) of the
13 Receiving Party to whom disclosure is reasonably necessary for this Action;
14 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
15 reasonably necessary for this Action and who have signed the Acknowledgment and
16 Agreement to Be Bound (Exhibit A);
17 (d) the court and its personnel;
18 (e) court reporters and their staff;
19 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to
20 whom disclosure is reasonably necessary for this Action and who have signed the
21 Acknowledgment and Agreement to Be Bound (Exhibit A);
22 (g) the author or recipient of a document containing the information or a custodian
23 or other person who otherwise possessed or knew the information;
24 (h) during their depositions, witnesses ,and attorneys for witnesses, in the Action
25 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that
26 the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be permitted
27 to keep any confidential information unless they sign the Acknowledgment and
1 or ordered by the court. Pages of transcribed deposition testimony or exhibits to
2 depositions that reveal Protected Material may be separately bound by the court reporter
3 and may not be disclosed to anyone except as permitted under this Stipulated Protective
4 Order; and
5 (i) any mediator or settlement officer, and their supporting personnel, mutually
6 agreed upon by any of the parties engaged in settlement discussions.
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8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
9 OTHER LITIGATION
10 If a Party is served with a subpoena or a court order issued in other litigation that
11 compels disclosure of any information or items designated in this Action as
12 CONFIDENTIAL, that Party must:
13 (a) promptly notify in writing the Designating Party. Such notification shall
14 include a copy of the subpoena or court order;
15 (b) promptly notify in writing the party who caused the subpoena or order to
16 issue in the other litigation that some or all of the material covered by the subpoena or
17 order is subject to this Protective Order. Such notification shall include a copy of this
18 Stipulated Protective Order; and
19 (c) cooperate with respect to all reasonable procedures sought to be pursued by
20 the Designating Party whose Protected Material may be affected.
21 If the Designating Party timely seeks a protective order, the Party served with the
22 subpoena or court order shall not produce any information designated in this action as
23 CONFIDENTIAL before a determination by the court from which the subpoena or
24 order issued, unless the Party has obtained the Designating Partys permission. The
25 Designating Party shall bear the burden and expense of seeking protection in that court
26 of its confidential material and nothing in these provisions should be construed as
27 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
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2 9. A NON-PARTYS PROTECTED MATERIAL SOUGHT TO BE PRODUCED
3 IN THIS LITIGATION
4 (a) The terms of this Order are applicable to information produced by a Non-
5 Party in this Action and designated as CONFIDENTIAL. Such information produced
6 by Non-Parties in connection with this litigation is protected by the remedies and relief
7 provided by this Order. Nothing in these provisions should be construed as prohibiting a
8 Non-Party from seeking additional protections.
9 (b) In the event that a Party is required, by a valid discovery request, to produce
10 a Non-Partys confidential information in its possession, and the Party is subject to an
11 agreement with the Non-Party not to produce the Non-Partys confidential information,
12 then the Party shall:
13 (1) promptly notify in writing the Requesting Party and the Non-Party
14 that some or all of the information requested is subject to a confidentiality agreement with
15 a Non-Party;
16 (2) promptly provide the Non-Party with a copy of the Stipulated
17 Protective Order in this Action, the relevant discovery request(s), and a reasonably
18 specific description of the information requested; and
19 (3) make the information requested available for inspection by the Non-
20 Party, if requested.
21 (c) If the Non-Party fails to seek a protective order from this court within 14 days
22 of receiving the notice and accompanying information, the Receiving Party may produce
23 the Non-Partys confidential information responsive to the discovery request. If the Non-
24 Party timely seeks a protective order, the Receiving Party shall not produce any
25 information in its possession or control that is subject to the confidentiality agreement
26 with the Non-Party before a determination by the court. Absent a court order to the
27 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
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2 10. 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 writing
6 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
7 all unauthorized copies of the Protected Material, (c) inform the person or persons to
8 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
9 such person or persons to execute the Acknowledgment and Agreement to Be Bound
10 that is attached hereto as Exhibit A.
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12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
13 PROTECTED MATERIAL
14 When a Producing Party gives notice to Receiving Parties that certain inadvertently
15 produced material is subject to a claim of privilege or other protection, the obligations of
16 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
17 This provision is not intended to modify whatever procedure may be established in an e-
18 discovery order that provides for production without prior privilege review. Pursuant to
19 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the
20 effect of disclosure of a communication or information covered by the attorney-client
21 privilege or work product protection, the parties may incorporate their agreement in the
22 stipulated protective order submitted to the court.
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24 12. MISCELLANEOUS
25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
26 person to seek its modification by the Court in the future.
27 12.2 Right to Assert Other Objections. By stipulating to the entry of this
1 or producing any information or item on any ground not addressed in this Stipulated
2 Protective Order. Similarly, no Party waives any right to object on any ground to use in
3 evidence of any of the material covered by this Protective Order.
4 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
5 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
6 under seal pursuant to a court order authorizing the sealing of the specific Protected
7 Material at issue. If a Party's request to file Protected Material under seal is denied by the
8 court, then the Receiving Party may file the information in the public record unless
9 otherwise instructed by the court.
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11 13. FINAL DISPOSITION
12 After the final disposition of this Action, as defined in paragraph 4, within 60 days
13 of a written request by the Designating Party, each Receiving Party must return all
14 Protected Material to the Producing Party or destroy such material. As used in this
15 subdivision, all Protected Material includes all copies, abstracts, compilations,
16 summaries, and any other format reproducing or capturing any of the Protected Material.
17 Whether the Protected Material is returned or destroyed, the Receiving Party must submit
18 a written certification to the Producing Party (and, if not the same person or entity, to the
19 Designating Party) by the 60 day deadline that (1) identifies (by category, where
20 appropriate) all the Protected Material that was returned or destroyed and (2)affirms that
21 the Receiving Party has not retained any copies, abstracts, compilations, summaries or
22 any other format reproducing or capturing any of the Protected Material. Notwithstanding
23 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion
24 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
25 deposition and trial exhibits, expert reports, attorney work product, and consultant and
26 expert work product, even if such materials contain Protected Material. Any such archival
27 copies that contain or constitute Protected Material remain subject to this Protective Order
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2 14. Any violation of this Order may be punished by any and all appropriate measures
3 including, without limitation, contempt proceedings and/or monetary sanctions.
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5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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7 Dated: April 6, 2026
8 By: /s/David B. Owens
9 David B. Owens, Cal. Bar No. 275030
Loevy & Loevy
10
333 S Grand Ave
11 Suite 3310
Los Angeles, CA 90071
12
13 Elizabeth Wang*
Loevy & Loevy
14
2060 Broadway, Ste 260
15 Boulder, CO 80302
*admitted pro hac vice
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Attorneys for Plaintiff
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18 Dated: April 3, 2026
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20 HYDEE FELDSTEIN SOTO, City Attorney
DENISE C. MILLS, Chief Deputy City Attorney
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KATHLEEN KENEALY, Chief Assistant City Attorney
22 CHRISTIAN R. BOJORQUEZ, Deputy City Attorney
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By: /s/ exuxvvt XA [âÇàxÜ
24
REBECCA E. HUNTER, Deputy City Attorney
25 Attorneys for Defendants, CITY OF LOS ANGELES,
KEVIN REYNOLDS, NOEL MAGPOC, JOE
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LUMBRERAS, MICHAEL DEPASQUALE,
27 JEFFREY BERT, JEROME MICHALCZAK,
AGUSTIN LOPEZ and BLANCA LOPEZ
I FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
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4 || DATED: April 27, 2026 TS win f- hos Lus7n
> HON. KAREN L. STEVENSON
6 CHIEF U.S. MAGISTRATE JUDGE
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of _________________
4 [print or type full address], declare under penalty of perjury that I have read in its entirety
5 and understand the Stipulated Protective Order that was issued by the United States
6 District Court for the Central District of California on [date] in the case of ___________
7 Giovanni Hernandez v. City of Los Angeles, et al., case no. 2:25-CV-05372-MRA-KS. I
8 agree to comply with and to be bound by all the terms of this Stipulated Protective Order
9 and I understand and acknowledge that failure to so comply could expose me to sanctions
10 and punishment in the nature of contempt. I solemnly promise that I will not disclose in
11 any manner any information or item that is subject to this Stipulated Protective Order to
12 any person or entity except in strict compliance with the provisions of this Order.
13 I further agree to submit to the jurisdiction of the United States District Court for the
14 Central District of California for the purpose of enforcing the terms of this Stipulated
15 Protective Order, even if such enforcement proceedings occur after termination of this
16 action. I hereby appoint __________________________ [print or type full name] of
17 _______________________________________ [print or type full address and telephone
18 number] as my California agent for service of process in connection with this action or
19 any proceedings related to enforcement of this Stipulated Protective Order.
20
21 Date: ______________________________________
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23 City and State where sworn and signed: _________________________________
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25 Printed name: _______________________________
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27 Signature: __________________________________