The opinion
1 Sophia M. Rios (SBN 305801)
srios@bergermontague.com
2 BERGER MONTAGUE PC
8241 La Mesa Blvd., Suite A
3
La Mesa, CA 91942
4 Telephone: (619) 489-0300
5 [Additional Counsel Appear on Signature Page]
Attorneys for Plaintiff
6
Alex Terepka (SBN 288243)
7
alex@wtlaw.com
8 John Mittelbach (SBN 284088)
jmittelbach@wtlaw.com
9 WATSTEIN TEREPKA, LLP
515 South Flower Street, 19th Floor
10
Los Angeles, California 90071
11 Telephone: (213) 839-3317
12 Attorneys for Defendant
13
UNITED STATES DISTRICT COURT
14
FOR THE CENTRAL DISTRICT OF CALIFORNIA
15
ROBERT TRUSTY, on behalf of No. 5:25-cv-03318-KK-DTB
16
himself and all others similarly situated,
17 [PROPOSED] STIPULATED
Plaintiff, PROTECTIVE ORDER
18
19 v. Hon. David T. Bristow, M.J.
20
COMERICA BANK,
21
Defendant.
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23
24
25
26
27
1 Pursuant to the agreement between Plaintiff Robert Trusty (“Plaintiff”) and
2 Defendant Comerica Bank (“Defendant” or “Comerica” or “Comerica Bank”) (taken
3 together, the “Parties”), the Court hereby enters this Stipulated Protective Order
4 (“Order”) in the above-captioned action (the “Action”):
5 1. PURPOSES AND LIMITATIONS
6 Disclosure and discovery activity in this action are likely to involve
7 production of confidential or private information for which special protection from
8 public disclosure and from use for any purpose other than prosecuting this litigation
9 may be warranted. Accordingly, the Parties stipulate to and petition the Court to
10 enter the following Stipulated Protective Order. The Parties acknowledge that this
11 Order does not confer blanket protections on all disclosures or responses to
12 discovery and that the protection it affords from public disclosure and use extends
13 only to the limited information or items that are entitled to confidential treatment
14 under the applicable legal principles.
15 2. GOOD CAUSE STATEMENT
16 This action is likely to involve customer lists, commercial, and/or financial,
17 information for which special protection from public disclosure and from use for any
18 purpose other than prosecution of this action is warranted. Such confidential
19 materials and information consist of, among other things, confidential business or
20 financial information, information regarding confidential business practices, or other
21 commercial information (including information implicating privacy rights of third
22 parties), information otherwise generally unavailable to the public, or which may be
23 privileged or otherwise protected from disclosure under state or federal statutes,
24 court rules, case decisions, or common law. Accordingly, to expedite the flow of
25 information, to facilitate the prompt resolution of disputes over confidentiality of
26 discovery materials, to adequately protect information the parties are entitled to keep
27 confidential, to ensure that the Parties are permitted reasonable necessary uses of
1 at the end of the litigation, and serve the ends of justice, a protective order for such
2 information is justified in this matter. It is the intent of the Parties that information
3 will not be designated as confidential for tactical reasons and that nothing be so
4 designated without a good faith belief that it has been maintained in a confidential,
5 non-public manner, and there is good cause why it should not be part of the public
6 record of this case.
7 3. ACKNOWLEDGEMENT OF UNDER SEAL FILING PROCEDURE
8 The Parties further acknowledge, as set forth in Section 14.3, below, that this
9 Stipulated Protective Order does not entitle them to file confidential information
10 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
11 and the standards that will be applied when a party seeks permission from the court
12 to file material under seal. There is a strong presumption that the public has a right
13 of access to judicial proceedings and records in civil cases. In connection with non-
14 dispositive motions, good cause must be shown to support a filing under seal. See
15 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006);
16 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-
17 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
18 stipulated protective orders require good cause showing). A specific showing of
19 good cause or compelling reasons with proper evidentiary support and legal
20 justification, must be made with respect to Protected Material that a party seeks to
21 file under seal. The Parties’ mere designation of Disclosure or Discovery Material
22 as CONFIDENTIAL does not—without the submission of competent evidence by
23 declaration, establishing that the material sought to be filed under seal qualifies as
24 confidential, privileged, or otherwise protectable—constitute good cause.
25 Further, if a party requests sealing related to a dispositive motion or trial, then
26 compelling reasons, not only good cause, for the sealing must be shown, and the
27 relief sought shall be narrowly tailored to serve the specific interest to be protected.
1 each item or type of information, document, or thing sought to be filed or introduced
2 under seal, the party seeking protection must articulate compelling reasons,
3 supported by specific facts and legal justification, for the requested sealing order.
4 Again, competent evidence supporting the application to file documents under seal
5 must be provided by declaration. Any document that is not confidential, privileged,
6 or otherwise protectable in its entirety will not be filed under seal if the confidential
7 portions can be redacted. If documents can be redacted, then a redacted version for
8 public viewing, omitting only the confidential, privileged, or otherwise protectable
9 portions of the document, shall be filed. Any application that seeks to file documents
10 under seal in their entirety should include an explanation of why redaction is not
11 feasible.
12 4. DEFINITIONS
13 4.1 Action: this pending federal lawsuit, Trusty v. Comerica Bank, Case
14 No. 25-cv-03318-KK-DTB (C.D. Cal.).
15 4.2 Challenging Party: a Party or Non-Party that challenges the designation
16 of information or items under this Order.
17 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
18 how it is generated, stored or maintained) or tangible things that qualify
19 for protection under Federal Rule of Civil Procedure 26(c), and as
20 specified above in the Good Cause Statement.
21 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
22 their support staff).
23 4.5 Designating Party: a Party or Non-Party that designates information or
24 items that it produces in disclosures or in responses to discovery as
25 “CONFIDENTIAL.”
26 4.6 Disclosure or Discovery Material: all items or information, regardless
27 of the medium or manner in which it is generated, stored, or maintained
1 things), that are produced or generated in disclosures or responses to
2 discovery.
3 4.7 Expert: a person with specialized knowledge or experience in a matter
4 pertinent to the litigation who has been retained by a Party or its counsel
5 to serve as an expert witness or as a consultant in this Action.
6 4.8 House Counsel: attorneys who are employees of a party to this Action.
7 House Counsel does not include Outside Counsel of Record or any
8 other outside counsel.
9 4.9 Non-Party: any natural person, partnership, corporation, association or
10 other legal entity not named as a Party to this action.
11 4.10 Outside Counsel of Record: attorneys who are not employees of a party
12 to this Action but are retained to represent a party to this Action and
13 have appeared in this Action on behalf of that party or are affiliated
14 with a law firm that has appeared on behalf of that party, and includes
15 support staff.
16 4.11 Party: any party to this Action, including all of its officers, directors,
17 employees, consultants, retained experts, and Outside Counsel of
18 Record (and their support staff).
19 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
20 Discovery Material in this Action.
21 4.13 Professional Vendors: persons or entities that provide litigation support
22 services (e.g., photocopying, videotaping, translating, preparing
23 exhibits or demonstrations, and organizing, storing, or retrieving data
24 in any form or medium) and their employees and subcontractors.
25 4.14 Protected Material: any Disclosure or Discovery Material that is
26 designated as “CONFIDENTIAL.”
27 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material
1 5. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material. Any
7 use of Protected Material at trial shall be governed by the orders of the trial judge
8 and other applicable authorities. This Order does not govern the use of Protected
9 Material at trial.
10 6. DURATION
11 Once a case proceeds to trial, information that was designated as
12 “CONFIDENTIAL” or maintained pursuant to this protective order used or
13 introduced as an exhibit at trial becomes public and will be presumptively available
14 to all members of the public, including the press, unless compelling reasons
15 supported by specific factual findings to proceed otherwise are made to the trial
16 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing
17 “good cause” showing for sealing documents produced in discovery from
18 “compelling reasons” standard when merits-related documents are part of court
19 record). Accordingly, the terms of this protective order do not extend beyond the
20 commencement of the trial.
21 7. DESIGNATING PROTECTED MATERIAL
22 7.1 Exercise of Restraint and Care in Designating Material for Protection.
23 Each Party or Non-Party that designates information or items for protection under
24 this Order must take care to limit any such designation to specific material that
25 qualifies under the appropriate standards. The Designating Party must designate for
26 protection only those parts of material, documents, items or oral or written
27 communications that qualify so that other portions of the material, documents, items
1 within the ambit of this Order.
2 Mass, indiscriminate, or routinized designations are prohibited. Designations
3 that are shown to be clearly unjustified or that have been made for an improper
4 purpose (e.g., to unnecessarily encumber the case development process or to impose
5 unnecessary expenses and burdens on other parties) may expose the Designating
6 Party to sanctions.
7 If it comes to a Designating Party’s attention that information or items that it
8 designated for protection do not qualify for protection, that Designating Party must
9 promptly notify all other Parties that it is withdrawing the inapplicable designation.
10 7.2 Manner and Timing of Designations. Except as otherwise provided in
11 this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material
12 that qualifies for protection under this Order must be clearly so designated before
13 the material is disclosed or 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 or other pretrial or trial
17 proceedings), that the Producing Party affix at a minimum, the legend
18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
19 contains protected material.
20 A Party or Non-Party that makes original documents available for
21 inspection need not designate them for protection until after the inspecting Party has
22 indicated which documents it would like copied and produced. During the inspection
23 and before the designation, all of the material made available for inspection shall be
24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
25 documents it wants copied and produced, the Producing Party must determine which
26 documents, or portions thereof, qualify for protection under this Order. Then, before
27 producing the specified documents, the Producing Party must affix the
1 portion of the material on a page qualifies for protection, the Producing Party also
2 must clearly identify the protected portion(s) (e.g., by making appropriate markings
3 in the margins).
4 (b) for testimony given in depositions, that the Designating Party
5 identifies the Disclosure or Discovery Material either (i) on the record, before the
6 close of the deposition, or (ii) by notifying all parties in writing within thirty (30)
7 days after receipt of the final certified deposition transcript, specifying the particular
8 pages and lines of the transcript designated “CONFIDENTIAL.” Pending any
9 written designation within such thirty (30)-day period, the entire deposition
10 transcript and all exhibits thereto shall be treated as “CONFIDENTIAL” by all
11 Receiving Parties. If no written designation is served within thirty (30) days of
12 receipt of the final transcript, the transcript shall no longer be subject to the
13 protections of this Order unless designated on the record during the deposition.
14 (c) for information produced in some form other than documentary and
15 for any other tangible items, that the Producing Party affix in a prominent place on
16 the exterior of the container or containers in which the information is stored the
17 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants
18 protection, the Producing Party, to the extent practicable, shall identify the protected
19 portion(s).
20 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
21 failure to designate qualified information or items does not, standing alone, waive
22 the Designating Party’s right to secure protection under this Order for such material.
23 For purposes of this Section, “timely” means within thirty (30) days after the
24 Designating Party discovers that the information or items were not properly
25 designated. Upon timely correction of a designation, the Receiving Party must make
26 reasonable efforts to assure that the material is treated in accordance with the
27 provisions of this Order.
1 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 8.1 Timing of Challenges. Any Party or Non-Party may challenge a
3 designation of confidentiality at any time that is consistent with the Court’s
4 Scheduling Order.
5 8.2 Pre-Challenge Notice. Before initiating the dispute resolution process
6 under Local Civil Rule 37-1, the Challenging Party shall first serve written notice
7 on the Designating Party identifying the specific designation(s) being challenged
8 and the grounds for each challenge. The Designating Party shall respond in writing
9 within fourteen (14) days of receipt of such notice, either (a) withdrawing the
10 challenged designation(s) in full or in part, or (b) providing a written explanation of
11 the factual and legal basis for maintaining such designation(s). If the parties are
12 unable to resolve the dispute through this exchange, the Challenging Party may then
13 initiate the dispute resolution process set forth in Local Civil Rule 37-1.
14 8.3 Meet and Confer. The Challenging Party shall initiate the dispute
15 resolution process under Local Civil Rule 37-1 et seq.
16 8.4 Joint Stipulation. Any challenge submitted to the Court shall be via a
17 joint stipulation pursuant to Local Civil Rule 37-2.
18 8.5 The burden of persuasion in any such challenge proceeding shall be on
19 the Designating Party. Frivolous challenges, and those made for an improper
20 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
21 parties) may expose the Challenging Party to sanctions. Unless the Designating Party
22 has waived or withdrawn the confidentiality designation, all parties shall continue to
23 afford the material in question the level of protection to which it is entitled under the
24 Producing Party’s designation until the Court rules on the challenge.
25 9. ACCESS TO AND USE OF PROTECTED MATERIAL
26 9.1 Basic Principles. A Receiving Party may use Protected Material that is
27 disclosed or produced by another Party or by a Non-Party in connection with this
1 Protected Material may be disclosed only to the categories of persons and under the
2 conditions described in this Order. When the Action has been terminated, a
3 Receiving Party must comply with the provisions of Section 15 below (FINAL
4 DISPOSITION). Protected Material must be stored and maintained by a Receiving
5 Party at a location and in a secure manner that ensures that access is limited to the
6 persons authorized under this Order.
7 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
8 otherwise ordered by the court or permitted in writing by the Designating Party, a
9 Receiving Party may disclose any information or item designated
10 “CONFIDENTIAL” only to:
11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
12 well as employees of said Outside Counsel of Record to whom it is reasonably
13 necessary to disclose the information for this Action;
14 (b) the officers, directors, and employees (including House Counsel) of
15 the Receiving Party to whom disclosure is reasonably necessary for this Action;
16 (c) Experts (as defined in this Order) of the Receiving Party to whom
17 disclosure is reasonably necessary for this Action and who have signed the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
19 (d) the court and its personnel;
20 (e) court reporters and their staff;
21 (f) professional jury or trial consultants, mock jurors, and Professional
22 Vendors to whom disclosure is reasonably necessary for this Action and who have
23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
24 (g) the author or recipient of a document containing the information or
25 a custodian or other person who otherwise possessed or knew the information;
26 (h) during their depositions, witnesses, and attorneys for witnesses, in
27 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
1 they will not be permitted to keep any confidential information unless they sign the
2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
3 agreed by the Designating Party or ordered by the court. Pages of transcribed
4 deposition testimony or exhibits to depositions that reveal Protected Material may
5 be separately bound by the court reporter and may not be disclosed to anyone except
6 as permitted under this Stipulated Protective Order; and
7 (i) any mediators or settlement officers and their supporting personnel,
8 mutually agreed upon by any of the parties engaged in settlement discussions.
9 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
10 PRODUCED IN OTHER LITIGATION
11 If a Party is served with a subpoena or a court order issued in other litigation
12 that compels disclosure of any information or items designated in this Action as
13 “CONFIDENTIAL,” that Party must:
14 (a) promptly notify in writing the Designating Party. Such notification
15 shall include a copy of the subpoena or court order;
16 (b) promptly notify in writing the party who caused the subpoena or
17 order to issue in the other litigation that some or all of the material covered by the
18 subpoena or order is subject to this Protective Order. Such notification shall include
19 a copy of this Stipulated Protective Order; and
20 (c) cooperate with respect to all reasonable procedures sought to be
21 pursued by the Designating Party whose Protected Material may be affected. If the
22 Designating Party timely seeks a protective order, the Party served with the
23 subpoena or court order shall not produce any information designated in this action
24 as “CONFIDENTIAL” before a determination by the court from which the subpoena
25 or order issued, unless the Party has obtained the Designating Party’s permission.
26 The Designating Party shall bear the burden and expense of seeking protection in
27 that court of its confidential material and nothing in these provisions should be
1 construed as authorizing or encouraging a Receiving Party in this Action to disobey
2 a lawful directive from another court.
3 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 (a) The terms of this Order are applicable to information produced by a
6 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
7 produced by Non-Parties in connection with this litigation is protected by the
8 remedies and relief provided by this Order. Nothing in these provisions should be
9 construed as prohibiting a Non-Party from seeking additional protections.
10 (b) In the event that a Party is required, by a valid discovery request, to
11 produce a Non-Party’s confidential information in its possession, and the Party is
12 subject to an agreement with the Non-Party not to produce the Non-Party’s
13 confidential information, then the Party shall:
14 (1) promptly notify in writing the Requesting Party and the Non-
15 Party that some or all of the information requested is subject to a confidentiality
16 agreement with a Non-Party;
17 (2) promptly provide the Non-Party with a copy of the Stipulated
18 Protective Order in this Action, the relevant discovery request(s), and a reasonably
19 specific description of the information requested; and
20 (3) make the information requested available for inspection by the
21 Non-Party, if requested.
22 (c) If the Non-Party fails to seek a protective order from this court
23 within 14 days of receiving the notice and accompanying information, the Receiving
24 Party may produce the Non-Party’s confidential information responsive to the
25 discovery request. If the Non-Party timely seeks a protective order, the Receiving
26 Party shall not produce any information in its possession or control that is subject to
27 the confidentiality agreement with the Non-Party before a determination by the
1 court. Absent a court order to the contrary, the Non-Party shall bear the burden and
2 expense of seeking protection in this court of its Protected Material.
3 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
5 Protected Material to any person or in any circumstance not authorized under this
6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
9 or persons to whom unauthorized disclosures were made of all the terms of this
10 Order, and (d) request such person or persons to execute the “Acknowledgment and
11 Agreement to Be Bound” attached hereto as Exhibit A.
12 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
13 PROTECTED MATERIAL
14 When a Producing Party gives notice to Receiving Parties that certain
15 inadvertently produced material is subject to a claim of privilege or other protection,
16 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
17 Procedure 26(b)(5)(B).
18 14. MISCELLANEOUS
19 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
20 person to seek its modification by the Court in the future.
21 14.2 Right to Assert Other Objections. By stipulating to the entry of this
22 Protective Order, no Party waives any right it otherwise would have to object to
23 disclosing or producing any information or item on any ground not addressed in this
24 Stipulated Protective Order. Similarly, no Party waives any right to object on any
25 ground to use in evidence of any of the material covered by this Protective Order.
26 14.3 Filing Protected Material. A Party that seeks to file under seal any
27 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
1 specific Protected Material. If a Party’s request to file Protected Material under seal
2 is denied by the court, then the Receiving Party may file the information in the public
3 record unless otherwise instructed by the court.
4 14.4 Use of Generative Artificial Intelligence (“GenAI”). The Receiving
5 Party shall not load, import, submit, or otherwise transfer Discovery Material
6 produced by the Producing Party to any public, non-confidential, and non-secure
7 Large Language Model (“LLM”) or other GenAI platform, and shall not use data
8 produced by the Producing Party to train AI systems or platforms.
9 15. FINAL DISPOSITION
10 After the final disposition of this Action, within 60 days of a written request
11 by the Designating Party, each Receiving Party must return all Protected Material to
12 the Producing Party or destroy such material. As used in this subdivision, “all
13 Protected Material” includes all copies, abstracts, compilations, summaries, and any
14 other format reproducing or capturing any of the Protected Material. Whether the
15 Protected Material is returned or destroyed, the Receiving Party must submit a
16 written certification to the Producing Party (and, if not the same person or entity, to
17 the Designating Party) by the 60-day deadline that (1) identifies (by category, where
18 appropriate) all the Protected Material that was returned or destroyed and (2) affirms
19 that the Receiving Party has not retained any copies, abstracts, compilations,
20 summaries or any other format reproducing or capturing any of the Protected
21 Material. Notwithstanding this provision, Counsel are entitled to retain an archival
22 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
23 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
24 work product, and consultant and expert work product, even if such materials contain
25 Protected Material. Any such archival copies that contain or constitute Protected
26 Material remain subject to this Protective Order as set forth in Section 6
27 (DURATION).
1 16. VIOLATION
2 Any violation of this Order may be punished by appropriate measures
3 including, without limitation, contempt proceedings and/or monetary sanctions.
4
5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
Date: May 7, 2026 /s/ Sophia M. Rios
7 Sophia M. Rios, SBN 305801
srios@bergermontague.com
8
BERGER MONTAGUE PC
9 8241 La Mesa Blvd., Suite A
La Mesa, CA 91942
10
Telephone: (619) 489-0300
11
Marika K. O’Connor Grant, SBN 334469
12
moconnorgrant@bergermontague.com
13 BERGER MONTAGUE PC
1229 Tyler Street NE, Suite 205
14
Minneapolis, MN 55413
15 Telephone: (612) 268-0311
16
Beth E. Terrell, SBN 178181
17 Blythe H. Chandler, pro hac vice
TERRELL MARSHALL
18
LAW GROUP PLLC
19 1700 Westlake Avenue North, Suite 300
Seattle, WA 98109
20
Tel: (206) 816-6603
21 bterrell@terrellmarshall.com
bchandler@terrellmarshall.com
22
23 Matthew M. Loker (SBN 279939)
LOKER LAW, APC
24
132 Bridge Street
25 Arroyo Grande, CA 93420
Tel: (805) 468-8181
26
matt.loker@loker.law
27
1
Date: May 7, 2026 /s/ John Mittelbach
2 Alex Terepka (SBN 288243)
3 alex@wtlaw.com
John Mittelbach (SBN 284088)
4 jmittelbach@wtlaw.com
5 WATSTEIN TEREPKA, LLP
515 South Flower Street, 19th Floor
6 Los Angeles, California 90071
7 Telephone: (213) 839-3317
8 Attorneys for Defendant
9
10
1]
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16 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
” 7 Hata
18 | Dated: May 8, 2026
19 David T. Bristow
United States Magistrate Judge
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ORME TT ATED DDATECTIVE OPDEDP
1 Exhibit A: Acknowledgment and Agreement to Be Bound
2 I, _____________________________ [print or type full name], of
3 _________________ [print or type full address], declare under penalty of perjury
4 that I have read in its entirety and understand the Stipulated Protective Order that
5 was issued by the United States District Court for the Central District of California
6 on [date] in the case of Trusty v. Comerica Bank, Case No. 25-cv-03318-KK-
7 DTB (C.D. Cal.). I agree to comply with and to be bound by all the terms of this
8 Stipulated Protective Order and I understand and acknowledge that failure to so
9 comply could expose me to sanctions and punishment in the nature of contempt. I
10 solemnly promise that I will not disclose in any manner any information or item
11 that is subject to this Stipulated Protective Order to any person or entity except in
12 strict compliance with the provisions of this Order.
13 I further agree to submit to the jurisdiction of the United States District Court
14 for the Central District of California for the purpose of enforcing the terms of this
15 Stipulated Protective Order, even if such enforcement proceedings occur after
16 termination of this action.
17 I hereby appoint __________________________ [print or type full name]
18 of _______________________________________ [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 Printed name: _______________________________
25 Signature: __________________________________
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