Opinion

Opinion

Court
District Court, C.D. California
Filed
May 13, 2026
Cited by
0 cases
Authority
More cited than 41.5%

The opinion

1 REEDER MCCREARY, LLP

Mark D. Passin, Bar No. 101195

2 mar k@reedermecreary. com

11766 Wilshire Blvd., Suite 1470

3 Los Angeles, CA 90025

Telephone: 310-861-2470

4

Attorneys for Defendant

5 MAN-KEN MUSIC, INC. and Defendant

and Counterclaimant HARVEY LISBERG

6

7

g UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 EASTERN DIVISION

1]

12

GRAHAM GOULDMAN, an Case No. 5:25-cv-3311-KK-DTB

3 individual,

14 y. Plaintiff, STIPULATED PROTECTIVE ORDER

15 qe

HARVEY LISBERG, an individual; .

California corporation and First Amended Complaint filed: 04/28/2026

California corporation; and DOES |_| Fst Amended Complaint Iled:

through 10, inclusive, Trial Date: 03/29/2027

18 Defendants.

19

20 | 1. INTRODUCTION

21 1.1. Purposes and Limitations. Discovery in this action is likely to involve production

22 || of confidential, proprietary, or private information for which special protection from public

23 || disclosure and from use for any purpose other than prosecuting this litigation may be warranted.

24 || Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated

25 || Protective Order. The parties acknowledge that this Order does not confer blanket protections on all

26 || disclosures or responses to discovery and that the protection it affords from public disclosure and use

27 || extends only to the limited information or items that are entitled to confidential treatment under the

28 || applicable legal principles. Civil Local Rule 79-5 sets forth the procedures that must be followed and

1 | the standards that will be applied when a party seeks permission from the court to file material under

2 || seal.

3 1.2. Good Cause Statement. This action is likely to involve confidential

4 | financial information and/or proprietary information for which special protection from

5 | public disclosure and from use for any purpose other than prosecution of this action is

6 | warranted. Such confidential and proprietary materials and information consist of,

7 || among other things, confidential business or financial information, information

8 | regarding confidential business practices, or other confidential commercial

9 | information, information otherwise generally unavailable to the public, or which may

10 | be privileged or otherwise protected from disclosure under state or federal statutes,

11 | court rules, case decisions, or common law. Accordingly, to expedite the flow of

12 | information, to facilitate the prompt resolution of disputes over confidentiality of

13 || discovery materials, to adequately protect information the parties are entitled to keep

14 | confidential, to ensure that the parties are permitted reasonable necessary uses of such

15 | material in preparation for and in the conduct of trial, to address their handling at the

16 | end of the litigation, and serve the ends of justice, a protective order for such

17 | information is justified in this matter. It is the intent of the parties that information will

18 | not be designated as confidential for tactical reasons and that nothing be so designated

19 | without a good faith belief that it has been maintained in a confidential, non-public

20 | manner, and there is good cause why it should not be part of the public record of this

21 || case.

22 1.3. Acknowledgment of Procedure for Filing Under Seal. The parties further

23 | acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order

24 | does not entitle them to file confidential information under seal; Local Rule 79-5 sets

25 | forth the procedures that must be followed and the standards that will be applied when

26 || a party seeks permission from the court to file material under seal.

27 There is a strong presumption that the public has a right of access to judicial

28 | proceedings and records in civil cases. In connection with non-dispositive motions,

1 | good cause must be shown to support a filing under seal. See Kamakana vy. City and

2 | Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v.

3 | Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir_2002), Makar-Welbon v. Sony

4] Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

5 || require good cause showing), and a specific showing of good cause or compelling

6 || reasons with proper evidentiary support and legal justification, must be made with

7 || respect to Protected Material that a party seeks to file under seal. The parties’ mere

8 | designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

9 | without the submission of competent evidence by declaration, establishing that the

10 | material sought to be filed under seal qualifies as confidential, privileged, or otherwise

11 | protectable—constitute good cause.

12 Further, if a party requests sealing related to a dispositive motion or trial, then

13 || compelling reasons, not only good cause, for the sealing must be shown, and the relief

14 | sought shall be narrowly tailored to serve the specific interest to be protected. See

15 | Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir_2010). For each item or

16 | type of information, document, or thing sought to be filed or introduced under seal in

17 | connection with a dispositive motion or trial, the party seeking protection must

18 | articulate compelling reasons, supported by specific facts and legal justification, for the

19 || requested sealing order. Again, competent evidence supporting the application to file

20 | documents under seal must be provided by declaration.

21 Any document that is not confidential, privileged, or otherwise protectable in its

22 | entirety will not be filed under seal if the confidential portions can be redacted. If

23 | documents can be redacted, then a redacted version for public viewing, omitting only

24 | the confidential, privileged, or otherwise protectable portions of the document, shall be

25 | filed. Any application that seeks to file documents under seal in their entirety should

26 | include an explanation of why redaction is not feasible.

27 | ///

28 | ///

1} 2. DEFINITIONS

2 2.1 Action: This pending federal lawsuit.

3 2.2 Challenging Party: A Party or Non-Party that challenges the designation

4 | of information or items under this Order.

5 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of how

6 | itis generated, stored or maintained) or tangible things that qualify for protection

7 | under 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 In-House Counsel (as well as

10 | their support staff).

11 2.5 Designating Party: A Party or Non-Party that designates information or

12 | 1tems that it produces in disclosures or in responses to discovery as

13 | “CONFIDENTIAL.”

14 2.6 Disclosure or Discovery Material: All items or information, regardless of

15 | the medium or manner in which it is generated, stored, or maintained (including,

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

17 | generated in disclosures or responses to discovery in this matter,

18 2.7 Expert: A person with specialized knowledge or experience in a matter

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

20 || expert witness or as a consultant in this Action.

21 2.8 In-House Counsel: Attorneys who are employees of a party to this Action.

22 | In-House Counsel does not include Outside Counsel of Record or any other outside

23 | counsel.

24 2.9 Non-Party: Any natural person, partnership, corporation, association, or

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

26 2.10 Outside Counsel of Record: Attorneys who are not employees of a party

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

28

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

2 | has appeared on behalf of that party, and includes support staff.

3 2.11 Party or Parties: Any party to this Action, and in the case of a corporate

4 | party, including all of its officers, directors and employees.

5 2.12 Producing Party: A Party or Non-Party that produces Disclosure or

6 || Discovery Material in this Action.

7 2.13 Professional Vendors: Persons or entities that provide litigation support

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

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

10 | their employees and subcontractors.

11 2.14 Protected Material: Any Disclosure or Discovery Material that is

12 | designated as “CONFIDENTIAL.”

13 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material

14 | from a Producing Party.

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.

23 | 4. DURATION

24 Once a case proceeds to trial, all of the information that was designated as

25 | confidential or maintained pursuant to this protective order becomes public and will be

26 | presumptively available to all members of the public, including the press, unless

27 || compelling reasons supported by specific factual findings to proceed otherwise are

28 | made to the trial judge in advance of the trial. See Kamakana v. City and County of

1 | Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”

2 | showing for sealing documents produced in discovery from “compelling reasons”

3 | standard when merits-related documents are part of court record). Accordingly, the

4 | terms of this protective order do not extend beyond the commencement of the trial.

5 | 5. DESIGNATING PROTECTED MATERIAL

6 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

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

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

11 | qualify so that other portions of the material, documents, items, or communications for

12 | which protection is not warranted are not swept unjustifiably within the ambit of this

13 | Order.

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

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

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

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

18 || to sanctions.

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

20 | designated for protection do not qualify for protection, that Designating Party must

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

22 5.2 Manner and Timing of Designations. Except as otherwise provided in this

23 | Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated

24 | or ordered, Disclosure or Discovery Material that qualifies for protection under this

25 | Order must be clearly so designated before the material is disclosed or produced.

26 Designation in conformity with this Order requires:

27 (a) For information in documentary form (e.g., paper or electronic

28 | documents, but excluding transcripts of depositions or other pretrial or trial

1 | proceedings), that the Producing Party affix at a minimum, the legend

2 | “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

3 || contains protected material. If only a portion or portions of the material on a page

4 | qualifies for protection, the Producing Party also must clearly identify the protected

5 || portion(s) (e.g., by making appropriate markings in the margins).

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

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

8 | which documents it would like copied and produced. During the inspection and before

g | the designation, all of the material made available for inspection shall be deemed

10 | “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

11 | copied and produced, the Producing Party must determine which documents, or

12 || portions thereof, qualify for protection under this Order. Then, before producing the

13 | specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to

14 | cach page that contains Protected Material. If only a portion or portions of the material

15 | ona page qualifies for protection, the Producing Party also must clearly identify the

16 | protected portion(s) (e.g., by making appropriate markings in the margins).

17 (b) For testimony given in depositions that the Designating Party identify the

18 | Disclosure or Discovery Material on the record, before the close of the deposition all

19 | protected testimony.

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

21 | any other tangible items, that the Producing Party affix in a prominent place on the

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

23 | “CONFIDENTIAL.” [f only a portion or portions of the information warrants

24 | protection, the Producing Party, to the extent practicable, shall identify the protected

25 || portion(s).

26 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

28 | Designating Party’s right to secure protection under this Order for such material. Upon

1 | timely correction of a designation, the Receiving Party must make reasonable efforts to

2 | assure that the material is treated in accordance with the provisions of this Order.

3 | 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

5 | designation of confidentiality at any time that is consistent with the Court’s Scheduling

6 | Order.

7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

8 || resolution process under Local Rule 37.1 et seq.

9 6.3 The burden of persuasion in any such challenge proceeding shall be on the

10 | Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

11 | to harass or impose unnecessary expenses and burdens on other parties) may expose

12 | the Challenging Party to sanctions. Unless the Designating Party has waived or

13 | withdrawn the confidentiality designation, all parties shall continue to afford the

14 | material in question the level of protection to which it is entitled under the Producing

15 | Party’s designation until the Court rules on the challenge.

16] 7. ACCESS TO AND USE OF PROTECTED MATERIAL

17 7.1. Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

22 | Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

23 | Protected Material must be stored and maintained by a Receiving Party at a location

24 | and in a secure manner that ensures that access is limited to the persons authorized

25 | under this Order,

26 72 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

27 | ordered by the court or permitted in writing by the Designating Party, a Receiving

28 | Party may disclose any information or item designated “CONFIDENTIAL” only to:

1 (a) The Parties to the action;

2 (b) The employees and agents of the Parties, provided that such disclosure 1s

3 | needed to assist in the prosecution or defense of this action;

4 (c) The Parties’ Outside Counsel of Record in this Action, as well as

5 | employees of said Outside Counsel of Record to whom it is reasonably necessary to

6 || disclose the information for this Action;

7 (d) As to any document. the author, its addressee, any other person shown on

8 | the face of the document as having received a copy and a recipient of a document

9 | containing the information or a custodian or other person who otherwise possessed or

10 | knew the information;

11 (e) Any witness (other than persons who already qualify under sub-

12 | paragraphs 7.2(a) through (d) whose counsel for a party in good faith believes may be

13 | called to testify at trial or deposition in this action, provided that they are advised of

14 | the existence of this Stipulated Protective Order and that the °>CONFIDENTIAL “

15 | Information or Items are subject to the terms of this Order;

16 (f) | Experts (as defined in this Order) of a Party who have signed the

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

18 (g) The court and its personnel;

19 (h) Court reporters and video technicians engaged to transcribe or record

20 | depositions or trial testimony in this Action and their staff;

21 (i) 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 (j) During their depositions, witnesses, and attorneys for witnesses, in the

25 | Action to whom disclosure is reasonably necessary provided: (1) the deposing party

26 | requests that the witness and his attorney sign the form attached as Exhibit A hereto;

27 | and (2) they will not be permitted to keep any confidential information unless they sign

28 | the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

1 | agreed by the Designating Party or ordered by the court. For the avoidance of doubt,

2 | the witness and his counsel may be allowed during the deposition to review any

3 | “CONFIDENTIAL” Information or Item whether or not the witness and/or his attorney

4 | sign the “Acknowledgment and Agreement to Be Bound. Pages of transcribed

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

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

7 || permitted under this Stipulated Protective Order;

8 (k) | Any mediator or settlement officer, and their supporting personnel,

9 | engaged by the parties or assigned by the Court;

10 (1) The party’s attorneys other than Outside Counsel of Record in this Action,

11 | as well as employees of said attorneys to whom it is reasonably necessary to disclose

12 | the information for this Action;

13 (1) — Any other person whom the Designating Party agrees in writing may have

14 || access to such Confidential Information or Items provided that such person has first

15 | executed an Acknowledgment and Agreement to Be Bound (Exhibit “A”’); and

16 (m) Paul Lisberg, Philip Lisberg and Louis Bloom.

17 | 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

18 IN OTHER LITIGATION

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

20 || compels disclosure of any information or items designated in this Action as

21 | “CONFIDENTIAL,” that Party must:

22 (a) Promptly notify in writing the Designating Party. Such notification shall

23 || include a copy of the subpoena or court order;

24 (b) Promptly notify in writing the party who caused the subpoena or order to

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

26 | order is subject to this Protective Order. Such notification shall include a copy of this

27 | Stipulated Protective Order; and

28

10

1 (c) Cooperate with respect to all reasonable procedures sought to be pursued

2 | by the Designating Party whose Protected Material may be affected.

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

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

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

6 | or order issued, unless the Party has obtained the Designating Party’s permission. The

7 | Designating Party shall bear the burden and expense of seeking protection in that court

8 | of its confidential material and nothing in these provisions should be construed as

9 | authorizing or encouraging a Receiving Party in this Action to disobey a lawful

10 | directive from another court.

11] 9. $ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO

12 BEPRODUCED IN THIS LITIGATION

13 9.1 Application. The terms of this Order are applicable to information

14 | produced by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such

15 | information produced by Non-Parties in connection with this litigation is protected by

16 | the remedies and relief provided by this Order. Nothing in these provisions should be

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

18 9.2. Notification. In the event that a Party is required, by a valid discovery

19 || request, to produce a Non-Party’s confidential information in its possession, and the

20 | Party is subject to an agreement with the Non-Party not to produce the Non-Party’s

21 | confidential information, then the Party shall:

22 (a) Promptly notify in writing the Requesting Party and the Non-Party that some

23 | or all of the information requested is subject to a confidentiality agreement with a Non-

24 | Party;

25 (b) promptly provide the Non-Party with a copy of the Stipulated Protective

26 | Order in this Action, the relevant discovery request(s), and a reasonably specific

27 | description of the information requested; and

28

11

1 (c) make the information requested available for inspection by the Non-Party, if

2 | requested.

3 9.3 Conditions of Production. If the Non-Party fails to seek a protective order

4 | from this court within 14 days of receiving the notice and accompanying information,

5 | the Receiving Party may produce the Non-Party’s confidential information responsive

6 || to the discovery request. If the Non-Party timely seeks a protective order, the

7 | Receiving Party shall not produce any information in its possession or control that is

8 | subject to the confidentiality agreement with the Non-Party before a determination by

g | the court. Absent a court order to the contrary, the Non-Party shall bear the burden and

10 | expense of seeking protection in this court of its Protected Material.

11 | 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

14 | Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

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

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

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

18 || request such person or persons to execute the “Acknowledgment and Agreement to Be

19 | Bound” that is attached hereto as Exhibit A.

20 | 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

21 PROTECTED MATERIAL

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

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

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

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

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

27 | privilege review pursuant to Federal Rule of Evidence 502(d) and (e).

28 | ///

12

1] 12. MISCELLANEOUS

2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

3 | person to seek its modification by the Court in the future.

4 12.2 Right to Assert Other Objections. By stipulating to the entry of this

5 | Protective Order no Party waives any right it otherwise would have to object to

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

7 | Stipulated Protective Order. Similarly, no Party waives any right to object on any

8 | ground to use in evidence of any of the material covered by this Protective Order.

9 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

11 | only be filed under seal pursuant to a court order authorizing the sealing of the specific

12 | Protected Material at issue. If a Party's request to file Protected Material under seal is

13 | denied by the court, then the Receiving Party may file the information in the public

14 || record unless otherwise instructed by the court.

15 | 13. FINAL DISPOSITION

16 This Order shall survive the termination of this litigation. A Party may seek the

17 | written permission of the Designating Party or may move the Court for relief from the

18 | provisions of this Order. To the extent permitted by law, the Court shall retain

19 | jurisdiction to enforce, modify, or reconsider this Order, even after the Proceeding is

20 | terminated.

21 | 14. VIOLATION

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

23 | measures including, without limitation, contempt proceedings and/or monetary

24 || sanctions.

25

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1 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2

3 BYRNES HIRSCH P.C.

4

; DATED: May 7, 2026 /s/ Bridget B. Hirsch

Bridget B. Hirsch

6

Attorneys for Plaintiff GRAHAM

’ GOULDMAN

8

9

10 COHEN MUSIC LAW

'l | DATED: May 7, 2026 /s/ Evan □□ Cohen

12 Evan S. Cohen

13 Attorneys for Plaintiff GRAHAM

14 GOULDMAN

i

REEDER MCCREARY, LLP

17

DATED: May 7, 2026 /s/ Mark D. Passin

18 Mark D. Passin

19

Attorneys for Defendants HARVEY LISBERG

20 and MAN-KEN MUSIC, INC.

21

SIGNATURE ATTESTATION

22

33 Pursuant to Local Rule 5-4.3.4, I hereby attest that all signatories listed, and on

whose behalf the filing is submitted, concur in the filing’s content and have authorized

24 | the filing.

25

26 | DATED: May 7, 2026 /s/ Mark D. Passin

27 Mark D. Passin

28

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1

| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

3

; | DATED: May 19. 2026

David T. Bristow

6 United States Magistrate Judge

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1 EXHIBIT A

2

GRAHAM GOULDMAN, an Case No. 5:25-cv-3311-KK-DTB

3 individual,

4 Plaintiff,

V. ACKNOWLEDGEMENT AND

5

HARVEY LISBERG, an individual; AGREEMENT TO BE BOUND

6 | MAN-KEN MUSIC, INC., a

California corporation; and DOES 1

7 | through 10, inclusive,

8 Defendants.

9

I, [print or type full name],

10

[print or type full address], declare under penalty of perjury

11

that I have read in its entirety and understand the Stipulated Protective Order that was

12

issued by the United States District Court for the Central District of California on

13

[date] in the in the above referenced action. I agree to comply with and to be bound

14

by all the terms of this Stipulated Protective Order and I understand and acknowledge

15

that failure to so comply could expose me to sanctions and punishment in the nature of

16

contempt. I solemnly promise that I will not disclose in any manner any information or

17

item that is subject to this Stipulated Protective Order to any person or entity except in

18

strict compliance with the provisions of this Order.

19

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

20

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

21

Stipulated Protective Order, even if such enforcement proceedings occur after

22

termination of this action.

23

I declare under penalty of perjury that the foregoing is true and correct.

24

Dated:

City and State :

26

Printed name:

Signature:

28

16

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

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