The opinion
1 Rick Richmond (SBN 194962)
rrichmond@larsonllp.com
2 Andrew E. Calderón (SBN 316673)
acalderon@larsonllp.com
3 Jina Yoon (SBN 331948)
jyoon@larsonllp.com
4 LARSON LLP
555 South Flower Street, 30th Floor
5 Los Angeles, California 90071
Telephone: (213) 436-4888
6 Facsimile: (213) 623-2000
7 Attorneys for Defendant The Church of
Jesus Christ of Latter-day Saints
8
9 Sara D. Beller (SBN 316210) Kevin E. Monson (SBN 89785)
sara.beller@dolmanlaw.com kevinemonson@hotmail.com
10 Matthew A. Dolman LAW OFFICES OF KEVIN E. MONSON
(pro hac vice forthcoming) 184 Brookhurst Street, Suite 202N
11 matt@dolmanlaw.com Fountain Valley, CA 92709
R. Stanley Gipe
12 (pro hac vice forthcoming) Attorneys for Defendant Daren Francom
stan.gipe@dolmanlaw.com
13 Kendall Follert (SBN 367201)
Kendall.follert@dolmanlaw.com
14 DOLMAN LAW GROUP
361 Central Ave., Suite 400
15 Riverside, CA 92506
Telephone: (727) 451-6900
16 Facsimile (727) 451-6907
17 Attorneys for Plaintiff Jane AC Doe
18
UNITED STATES DISTRICT COURT
19
CENTRAL DISTRICT OF CALIFORNIA
20
JOHN DOE A.W., an individual, Case No. 2:26-cv-02389-RAO
21
Plaintiff, STIPULATED PROTECTIVE
22 ORDER1
vs.
23
THE CHURCH OF JESUS CHRIST
24 OF LATTER-DAY SAINTS, a Utah
Corporation; DAREN FRANCOM, an
25 individual; and DOES 3-25, inclusive,,
26 Defendant.
27
1 This Stipulated Protective Order is substantially based on the model protective
1
1. A. PURPOSES AND LIMITATIONS
2
Discovery in this action is likely to involve production of confidential,
3
proprietary or private information for which special protection from public
4
disclosure and from use for any purpose other than prosecuting this litigation may
5
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
6
enter the following Stipulated Protective Order. The parties acknowledge that this
7
Order does not confer blanket protections on all disclosures or responses to
8
discovery and that the protection it affords from public disclosure and use extends
9
only to the limited information or items that are entitled to confidential treatment
10
under the applicable legal principles.
11
B. GOOD CAUSE STATEMENT
12
This Action arises from allegations of childhood sexual abuse and is likely to
13
involve medical records, psychiatric records, confidential church membership
14
records, and other private information implicating the privacy rights of third parties
15
for which special protection from public disclosure and from use for any purpose
16
other than prosecution of this action is warranted. Accordingly, to expedite the flow
17
of information, to facilitate the prompt resolution of disputes over confidentiality of
18
discovery materials, to adequately protect information the parties are entitled to keep
19
confidential, to ensure that the parties are permitted reasonable necessary uses of
20
such material in preparation for and in the conduct of trial, to address their handling
21
at the end of the litigation, and serve the ends of justice, a protective order for such
22
information is justified in this matter. It is the intent of the parties that information
23
will not be designated as confidential for tactical reasons and that nothing be so
24
designated without a good faith belief that it has been maintained in a confidential,
25
non-public manner, and there is good cause why it should not be part of the public
26
record of this case.
27
C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
1 The parties further acknowledge, as set forth in Section 12.3, below, that this
2 Stipulated Protective Order does not entitle them to file confidential information
3 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
4 and the standards that will be applied when a party seeks permission from the Court
5 to file material under seal.
6 There is a strong presumption that the public has a right of access to judicial
7 proceedings and records in civil cases. In connection with non-dispositive motions,
8 good cause must be shown to support a filing under seal. See Kamakana v. City and
9 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
10 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,
11 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
12 require good cause showing), and a specific showing of good cause or compelling
13 reasons with proper evidentiary support and legal justification, must be made with
14 respect to Protected Material that a party seeks to file under seal. The parties’ mere
15 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
16 without the submission of competent evidence by declaration, establishing that the
17 material sought to be filed under seal qualifies as confidential, privileged, or
18 otherwise protectable—constitute good cause.
19 Further, if a party requests sealing related to a dispositive motion or trial, then
20 compelling reasons, not only good cause, for the sealing must be shown, and the
21 relief sought shall be narrowly tailored to serve the specific interest to be protected.
22 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
23 each item or type of information, document, or thing sought to be filed or introduced
24 under seal in connection with a dispositive motion or trial, the party seeking
25 protection must articulate compelling reasons, supported by specific facts and legal
26 justification, for the requested sealing order. Again, competent evidence supporting
27 the application to file documents under seal must be provided by declaration.
1 its entirety will not be filed under seal if the confidential portions can be redacted. If
2 documents can be redacted, then a redacted version for public viewing, omitting
3 only the confidential, privileged, or otherwise protectable portions of the document
4 shall be filed. Any application that seeks to file documents under seal in their
5 entirety should include an explanation of why redaction is not feasible.
6 2. DEFINITIONS
7 2.1 Action: John Doe A.W. v. The Church of Jesus Christ of Latter-day
8 Saints, et. al., 2:26-cv-02389-RA (C.D. Cal.)
9 2.2 Challenging Party: a Party or Non-Party that challenges the designation
10 of information or items under this Order.
11 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
12 how it is generated, stored or maintained) or tangible things that qualify for
13 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
14 the Good Cause Statement.
15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
16 their support staff).
17 2.5 Designating Party: a Party or Non-Party that designates information or
18 items that it produces in disclosures or in responses to discovery as
19 “CONFIDENTIAL.”
20 2.6 Disclosure or Discovery Material: all items or information, regardless
21 of the medium or manner in which it is generated, stored, or maintained (including,
22 among other things, testimony, transcripts, and tangible things) that are produced or
23 generated in disclosures or responses to discovery in this matter.
24 2.7 Expert: a person with specialized knowledge or experience in a matter
25 pertinent to the litigation who has been retained by a Party or its counsel to serve as
26 an expert witness or as a consultant in this Action.
27 2.8 House Counsel: attorneys who are employees of a party to this Action,
1 House Counsel does not include Outside Counsel of Record or any other outside
2 counsel.
3 2.9 Non-Party: any natural person, partnership, corporation, association or
4 other legal entity not named as a Party to this action.
5 2.10 Outside Counsel of Record: attorneys who are not employees of a party
6 to this Action but are retained to represent or advise a party to this Action and have
7 appeared in this Action on behalf of that party or are affiliated with a law firm that
8 has appeared on behalf of that party, and includes support staff.
9 2.11 Party: any party to this Action, including all of its officers, directors,
10 employees, consultants, retained experts, and Outside Counsel of Record (and their
11 support staffs).
12 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
13 Discovery Material in this Action.
14 2.13 Professional Vendors: persons or entities that provide litigation support
15 services (e.g., photocopying, videotaping, translating, preparing exhibits or
16 demonstrations, and organizing, storing, or retrieving data in any form or medium)
17 and their employees and subcontractors.
18 2.14 Protected Material: any Disclosure or Discovery Material that is
19 designated as “CONFIDENTIAL.”
20 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
21 from a Producing Party.
22 3. SCOPE
23 The protections conferred by this Stipulation and Order cover not only
24 Protected Material (as defined above), but also (1) any information copied or
25 extracted from Protected Material; (2) all copies, excerpts, summaries, or
26 compilations of Protected Material; and (3) any testimony, conversations, or
27 presentations by Parties or their Counsel that might reveal Protected Material.
1 trial judge. This Order does not govern the use of Protected Material at trial.
2
3 4. DURATION
4 Once a case proceeds to trial, information that was designated as
5 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
6 as an exhibit at trial becomes public and will be presumptively available to all
7 members of the public, including the press, unless compelling reasons supported by
8 specific factual findings to proceed otherwise are made to the trial judge in advance
9 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
10 showing for sealing documents produced in discovery from “compelling reasons”
11 standard when merits-related documents are part of court record). Accordingly, the
12 terms of this protective order do not extend beyond the commencement of the trial
13 in this matter as to the Protected Material that is admitted into evidence or otherwise
14 made part of the public trial record, unless the Court orders otherwise.
15 Information that remains confidential and is not made available to the public
16 at trial shall remain subject to the confidentiality obligations imposed by this Order
17 until a Designating Party agrees otherwise in writing or a court order otherwise
18 directs, even after final disposition of this litigation. Even after final disposition of
19 this litigation, the confidentiality obligations imposed by this Order shall remain in
20 effect until a Designating Party agrees otherwise in writing or a court order
21 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal
22 of all claims and defenses in this Action, with or without prejudice; and (2) final
23 judgment herein after the completion and exhaustion of all appeals, rehearings,
24 remands, trials, or reviews of this Action, including the time limits for filing any
25 motions or applications for extension of time pursuant to applicable law.
26 5. DESIGNATING PROTECTED MATERIAL
27 5.1 Exercise of Restraint and Care in Designating Material for Protection.
1 this Order must take care to limit any such designation to specific material that
2 qualifies under the appropriate standards. The Designating Party must designate for
3 protection only those parts of material, documents, items or oral or written
4 communications that qualify so that other portions of the material, documents, items
5 or communications for which protection is not warranted are not swept unjustifiably
6 within the ambit of this Order.
7 Mass, indiscriminate or routinized designations are prohibited. Designations
8 that are shown to be clearly unjustified or that have been made for an improper
9 purpose (e.g., to unnecessarily encumber the case development process or to impose
10 unnecessary expenses and burdens on other parties) may expose the Designating
11 Party to sanctions.
12 If it comes to a Designating Party’s attention that information or items that it
13 designated for protection do not qualify for protection, that Designating Party must
14 promptly notify all other Parties that it is withdrawing the inapplicable designation.
15 5.2 Manner and Timing of Designations. Except as otherwise provided in
16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
18 under this Order must be clearly so designated before the material is disclosed or
19 produced.
20 Designation in conformity with this Order requires:
21 (a) for information in documentary form (e.g., paper or electronic
22 documents, but excluding transcripts of depositions or other pretrial or trial
23 proceedings), that the Producing Party affix at a minimum, the legend
24 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
25 contains protected material. If only a portion of the material on a page qualifies for
26 protection, the Producing Party also must clearly identify the protected portion(s)
27 (e.g., by making appropriate markings in the margins).
1 need not designate them for protection until after the inspecting Party has indicated
2 which documents it would like copied and produced. During the inspection and
3 before the designation, all of the material made available for inspection shall be
4 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
5 documents it wants copied and produced, the Producing Party must determine which
6 documents, or portions thereof, qualify for protection under this Order. Then, before
7 producing the specified documents, the Producing Party must affix the
8 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
9 portion of the material on a page qualifies for protection, the Producing Party also
10 must clearly identify the protected portion(s) (e.g., by making appropriate markings
11 in the margins).
12 (b) for testimony given in depositions that the Designating Party identifies
13 the Disclosure or Discovery Material on the record, before the close of the
14 deposition all protected testimony.
15 (c) for information produced in some form other than documentary and
16 for any other tangible items, that the Producing Party affix in a prominent place on
17 the exterior of the container or containers in which the information is stored the
18 legend “CONFIDENTIAL.” If only a portion or portions of the information
19 warrants protection, the Producing Party, to the extent practicable, shall identify the
20 protected portion(s).
21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
22 failure to designate qualified information or items does not, standing alone, waive
23 the Designating Party’s right to secure protection under this Order for such material.
24 Upon timely correction of a designation, the Receiving Party must make reasonable
25 efforts to assure that the material is treated in accordance with the provisions of this
26 Order.
27 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
1 designation of confidentiality at any time that is consistent with the Court’s
2 Scheduling Order.
3 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
4 resolution process under Local Rule 37.1 et seq.
5 6.3 Burden. The burden of persuasion in any such challenge proceeding
6 shall be on the Designating Party. Frivolous challenges, and those made for an
7 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
8 other parties) may expose the Challenging Party to sanctions. Unless the
9 Designating Party has waived or withdrawn the confidentiality designation, all
10 parties shall continue to afford the material in question the level of protection to
11 which it is entitled under the Producing Party’s designation until the Court rules on
12 the challenge.
13 7. ACCESS TO AND USE OF PROTECTED MATERIAL
14 7.1 Basic Principles. A Receiving Party may use Protected Material that is
15 disclosed or produced by another Party or by a Non-Party in connection with this
16 Action only for prosecuting, defending or attempting to settle this Action. Such
17 Protected Material may be disclosed only to the categories of persons and under the
18 conditions described in this Order. When the Action has been terminated, a
19 Receiving Party must comply with the provisions of section 13 below (FINAL
20 DISPOSITION).
21 Protected Material must be stored and maintained by a Receiving Party at a
22 location and in a secure manner that ensures that access is limited to the persons
23 authorized under this Order.
24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
25 otherwise ordered by the court or permitted in writing by the Designating Party, a
26 Receiving Party may disclose any information or item designated
27 “CONFIDENTIAL” only to:
1 well as employees of said Outside Counsel of Record to whom it is reasonably
2 necessary to disclose the information for this Action;
3 (b) the officers, directors, and employees (including House Counsel) of
4 the Receiving Party to whom disclosure is reasonably necessary for this Action;
5 (c) Experts (as defined in this Order) of the Receiving Party to whom
6 disclosure is reasonably necessary for this Action and who have signed the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
8 (d) the court and its personnel;
9 (e) court reporters and their staff;
10 (f) professional jury or trial consultants, mock jurors, and Professional
11 Vendors to whom disclosure is reasonably necessary for this Action and who have
12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13 (g) the author or recipient of a document containing the information or a
14 custodian or other person who otherwise possessed or knew the information;
15 (h) during their depositions, witnesses, and attorneys for witnesses, in the
16 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
17 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
18 will not be permitted to keep any confidential information unless they sign the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
20 agreed by the Designating Party or ordered by the court. Pages of transcribed
21 deposition testimony or exhibits to depositions that reveal Protected Material may
22 be separately bound by the court reporter and may not be disclosed to anyone except
23 as permitted under this Stipulated Protective Order; and
24 (i) any mediator or settlement officer, and their supporting personnel,
25 mutually agreed upon by any of the parties engaged in settlement discussions.
26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
27 IN OTHER LITIGATION
1 that compels disclosure of any information or items designated in this Action as
2 “CONFIDENTIAL,” that Party must:
3 (a) promptly notify in writing the Designating Party. Such notification
4 shall include a copy of the subpoena or court order;
5 (b) promptly notify in writing the party who caused the subpoena or order
6 to issue in the other litigation that some or all of the material covered by the
7 subpoena or order is subject to this Protective Order. Such notification shall include
8 a copy of this Stipulated Protective Order; and
9 (c) cooperate with respect to all reasonable procedures sought to be
10 pursued by the Designating Party whose Protected Material may be affected.
11 If the Designating Party timely seeks a protective order, the Party served with
12 the subpoena or court order shall not produce any information designated in this
13 action as “CONFIDENTIAL” before a determination by the court from which the
14 subpoena or order issued, unless the Party has obtained the Designating Party’s
15 permission. The Designating Party shall bear the burden and expense of seeking
16 protection in that court of its confidential material and nothing in these provisions
17 should be construed as authorizing or encouraging a Receiving Party in this Action
18 to disobey a lawful directive from another court.
19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
20 PRODUCED IN THIS LITIGATION
21 (a) The terms of this Order are applicable to information produced by a
22 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
23 produced by Non-Parties in connection with this litigation is protected by the
24 remedies and relief provided by this Order. Nothing in these provisions should be
25 construed as prohibiting a Non-Party from seeking additional protections.
26 (b) In the event that a Party is required, by a valid discovery request, to
27 produce a Non-Party’s confidential information in its possession, and the Party is
1 confidential information, then the Party shall:
2 (1) promptly notify in writing the Requesting Party and the Non-Party
3 that some or all of the information requested is subject to a confidentiality
4 agreement with a Non-Party;
5 (2) promptly provide the Non-Party with a copy of the Stipulated
6 Protective Order in this Action, the relevant discovery request(s), and a reasonably
7 specific description of the information requested; and
8 (3) make the information requested available for inspection by the
9 Non-Party, if requested.
10 (c) If the Non-Party fails to seek a protective order from this court within
11 14 days of receiving the notice and accompanying information, the Receiving Party
12 may produce the Non-Party’s confidential information responsive to the discovery
13 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
14 not produce any information in its possession or control that is subject to the
15 confidentiality agreement with the Non-Party before a determination by the court.
16 Absent a court order to the contrary, the Non-Party shall bear the burden and
17 expense of seeking protection in this court of its Protected Material.
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 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
22 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
23 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
24 persons to whom unauthorized disclosures were made of all the terms of this Order,
25 and (d) request such person or persons to execute the “Acknowledgment and
26 Agreement to Be Bound” that is attached hereto as Exhibit A.
27 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
1 When a Producing Party gives notice to Receiving Parties that certain
2 inadvertently produced material is subject to a claim of privilege or other protection,
3 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
4 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
5 may be established in an e-discovery order that provides for production without
6 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
7 as the parties reach an agreement on the effect of disclosure of a communication or
8 information covered by the attorney-client privilege or work product protection, the
9 parties may incorporate their agreement in the stipulated protective order submitted
10 to the court.
11 12. MISCELLANEOUS
12 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
13 person to seek its modification by the Court in the future.
14 12.2 Right to Assert Other Objections. By stipulating to the entry of this
15 Protective Order, no Party waives any right it otherwise would have to object to
16 disclosing or producing any information or item on any ground not addressed in this
17 Stipulated Protective Order. Similarly, no Party waives any right to object on any
18 ground to use in evidence of any of the material covered by this Protective Order.
19 12.3 Filing Protected Material. A Party that seeks to file under seal any
20 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
21 only be filed under seal pursuant to a court order authorizing the sealing of the
22 specific Protected Material at issue. If a Party’s request to file Protected Material
23 under seal is denied by the court, then the Receiving Party may file the information
24 in the public record unless otherwise instructed by the court.
25 13. FINAL DISPOSITION
26 After the final disposition of this Action, as defined in paragraph 4, within 60
27 days of a written request by the Designating Party, each Receiving Party must return
1 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
2 summaries, and any other format reproducing or capturing any of the Protected
3 Material. Whether the Protected Material is returned or destroyed, the Receiving
4 Party must submit a written certification to the Producing Party (and, if not the same
5 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
6 (by category, where appropriate) all the Protected Material that was returned or
7 destroyed and (2) affirms that the Receiving Party has not retained any copies,
8 abstracts, compilations, summaries or any other format reproducing or capturing any
9 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
10 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
11 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
12 reports, attorney work product, and consultant and expert work product, even if such
13 materials contain Protected Material. Any such archival copies that contain or
14 constitute Protected Material remain subject to this Protective Order as set forth in
15 Section 4 (DURATION).
16 14. VIOLATION
17 Any violation of this Order may be punished by appropriate measures
18 including, without limitation, contempt proceedings and/or monetary sanctions.
19
20 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
21
22 Dated: May 6, 2026 DOLMAN LAW GROUP
23
24 By: /s/ Sara D. Beller
Sara D. Beller
25
Matthew A. Dolman
26 Stanley R. Gipe
27 Attorneys for Plaintiff JOHN DOE A.W.
1 || Dated: May 6, 2026 LARSON LLP
2
3 By: /s/ Rick Richmond
4 Rick Richmond?
Andrew E. Calderon
5 Jina Yoon
6 Attorneys for Defendant The Church of Jesus
4 Christ of Latter-day Saints
Dated: May 6, 2026 LAW OFFICES OF KEVIN E. MONSON
9
10
By: /s/ Kevin E. Monson
11 Kevin E. Monson
12 Attorney for Defendant Daren Francom
13
14 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
15
16 || DATED:05/07/2026
,|Re a. OC
AYRES A, COW
HON. ROZELLA A. OLIVER
19 || United States Magistrate Judge
20
21
22
23
24
25
26 * Pursuant to Local Rule PAA), filer hereby attests that all signatories
97 || listed, and on whose behalf the filing is submitted, concur in the filing’s content and
have authorized the filing.
28
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
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on [date] in the case of John Doe A.W. v. The Church of Jesus Christ of Latter-day
8 Saints, et. al., 2:26-cv-02389-RA (C.D. Cal.). I agree to comply with and to be
9 bound by all the terms of this Stipulated Protective Order and I understand and
10 acknowledge that failure to so comply could expose me to sanctions and punishment
11 in the nature of contempt. I solemnly promise that I will not disclose in any manner
12 any information or item that is subject to this Stipulated Protective Order to any
13 person or entity except in strict compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court for the
15 Central District of California for enforcing the terms of this Stipulated Protective
16 Order, even if such enforcement proceedings occur after termination of this action.
17 I hereby appoint __________________________ [print or type full name] of
18 _______________________________________ [print or type full address and
19 telephone number] as my California agent for service of process in connection with
20 this action or any proceedings related to enforcement of this Stipulated Protective
21 Order.
22 Date: ______________________________________
23 City and State where sworn and signed: _________________________________
24
25 Printed name: _______________________________
26
27 Signature: __________________________________