The opinion
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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
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11 EARL J. WASHINGTON and LOLA CASE NO. 2:25-cv-09036-JAK-MBK
MITSUK, Hon.John A. Kronstadt –Ctrm. 10C
12 Hon.Michael B. Kauffman – Ctrm. 550 Roybal
Plaintiffs,
Complaint filed 9-22-2025
13
v.
14 STIPULATED [xPxRxOxxPxOxxSxExDx]
KYLE RYAN JAMES, an individual; PROTECTIVE ORDER
15 PATRICK LOUIS TOPACIO, an
individual; ZACHERY S. TOTTEN, an
16 individual; ASHLEY Y. MARTINEZ, an
individual; JUAN D. MEJIA-
17 HERNANDEZ, an individual; CITY OF
LOS ANGELES,
18 a municipal corporation; and LOS
ANGELES POLICE DEPARTMENT,
19 a public entity, and DOES 1 through
10, inclusive,
20
Defendants.
21
22
23 1. GENERAL
24 1.1 Purposes and Limitations. Discovery in this action is likely to involve
25 production of confidential, proprietary, or private information for which special
26 protection from public disclosure and from use for any purpose other than prosecuting
27 this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition
1 that this Order does not confer blanket protections on all disclosures or responses to
2 discovery and that the protection it affords from public disclosure and use extends only
3 to the limited information or items that are entitled to confidential treatment under the
4 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3,
5 below, that this Stipulated Protective Order does not entitle them to file confidential
6 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
7 followed and the standards that will be applied when a party seeks permission from the
8 court to file material under seal.
9 1.2 Good Cause Statement.
10 This action involves the City of Los Angeles and members of the Los Angeles
11 Police Department. Plaintiff is seeking materials and information that Defendants the City
12 of Los Angeles et al. (“City”) maintains as confidential, such as information that contains
13 third-party information, personnel files of the police officers involved in this incident,
14 Internal Affairs materials and information, video recordings (including Body-Worn Video
15 recordings and Digital In-Car Video recordings), audio recordings (including 911 calls),
16 and information and other administrative materials and information currently in the
17 possession of the City and which the City believes need special protection from public
18 disclosure and from use for any purpose other than prosecuting this litigation. Plaintiff is
19 also seeking official information contained in the personnel files of the police officers
20 involved in the subject incident, which the City maintains as strictly confidential and
21 which the City believes need special protection from public disclosure and from use for
22 any purpose other than prosecuting this litigation.
23 The City asserts that the confidentiality of the materials and information sought by
24 Plaintiff is recognized by California and federal law, as evidenced inter alia by California
25 Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., 511 F.2d 192,
26 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City has not publicly released the
27 materials and information referenced above except under protective order or pursuant to
1 to initiate disciplinary action against Los Angeles Police Department (“LAPD”) officers,
2 and has been used as evidence in disciplinary proceedings, where the officers’ conduct
3 was considered to be contrary to LAPD policy. The City contends that absent a protective
4 order delineating the responsibilities of nondisclosure on the part of the parties hereto,
5 there is a specific risk of unnecessary and undue disclosure by one or more of the many
6 attorneys, secretaries, law clerks, paralegals and expert witnesses involved in this case, as
7 well as the corollary risk of embarrassment, harassment and professional and legal harm
8 on the part of the LAPD officers referenced in the materials and information.
9 The City also contends that the unfettered disclosure of the materials and
10 information, absent a protective order, would allow the media to share this information
11 with potential jurors in the area, impacting the rights of the City herein to receive a fair
12 trial. Accordingly, to expedite the flow of information, to facilitate the prompt resolution
13 of disputes over confidentiality of discovery materials, to adequately protect information
14 the parties are entitled to keep confidential, to ensure that the parties are permitted
15 reasonably necessary uses of such material in preparation for and in the conduct of trial,
16 to address their handling at the end of the litigation, and serve the ends of justice, a
17 protective order for such information is justified in this matter. It is the intent of the parties
18 that information will not be designated as confidential for tactical reasons and that nothing
19 be so designated without a good faith belief that it has been maintained in a confidential,
20 non-public manner, and there is good cause why it should not be part of the public record
21 of this case.
22 Plaintiffs assert information produced in response to discovery requests to other
23 parties may contain confidential or proprietary information or may disclose information
24 concerning highly sensitive and confidential financial information or other confidential
25 materials, including the sensitive information of third parties. These records include, but
26 are not limited to the following:
27 (a) Video and Audio Records Depicting Plaintiffs’ Private Home and Curtilage
1 CONFIDENTIAL. This includes video and audio records of (i) Plaintiffs’ private home
2 and curtilage recorded February 25, 2025; (ii) the center courtyard of the residential
3 complex containing Plaintiffs’ private home; (iii) any hallway or common space of the
4 residential complex containing Plaintiffs’ private home; and (iv) the garage of the
5 residential complex containing Plaintiffs’ private home. Private residences are places in
6 which the individual normally expects privacy free of governmental intrusion. U.S. v.
7 Struckman (9th Cir. 2010) 603 F.3d 731, 738. This expectation extends to outdoor areas
8 traditionally known as curtilage or privately controlled exterior areas that harbor the
9 intimate activity associated with the sanctity of a person’s home and the privacies of life.
10 Id.
11 (b) This action is likely to involve the exchange of protected health information
12 (“PHI”) of Plaintiffs for which special protection from public disclosure and from use for
13 any purpose other than prosecution of this action is warranted. Such confidential materials
14 and information consist of, among other things, medical records containing PHI,
15 deposition transcripts of expert witnesses, deposition transcripts of Plaintiffs, mental
16 health examination reports or all documents identified as confidential. Accordingly, to
17 expedite the flow of information, to facilitate the prompt resolution of disputes over
18 confidentiality of discovery materials, to adequately protect information the parties are
19 entitled to keep confidential, to ensure that the parties are permitted reasonable necessary
20 uses of such material in preparation for and in the conduct of trial, to address their
21 handling at the end of the litigation, and serve the ends of justice, a protective order for
22 such information is justified in this matter.
23
24 2. DEFINITIONS
25 2.1 Action: This pending federal lawsuit, Earl. J. Washington, et. al v. City of
26 Los Angeles, et. al, 2:25-cv-09036-JAK-MBK.
27 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
1 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
2 it is generated, stored or maintained) or tangible things that qualify for protection under
3 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
4 Statement.
5 2.4 Counsel: Counsel of Record, Outside Counsel of Record and House Counsel
6 (as well as their support staff).
7 2.5 Designating Party: a Party or Non-Party that designates information or items
8 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
9 2.6 Disclosure or Discovery Material: all items or information, regardless of the
10 medium or manner in which it is generated, stored, or maintained (including, among other
11 things, testimony, transcripts, and tangible things), that are produced or generated in
12 disclosures or responses to discovery in this matter.
13 2.7 Expert: a person with specialized knowledge or experience in a matter
14 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
15 expert witness or as a consultant in this Action.
16 2.8 House Counsel: attorneys who are employees of a party to this Action.
17 House Counsel does not include Outside Counsel of Record or any other outside counsel.
18 2.9 Non-Party: any natural person, partnership, corporation, association, or
19 other legal entity not named as a Party to this action.
20 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
21 this Action but are retained to represent or advise a party to this Action and have appeared
22 in this Action on behalf of that party or are affiliated with a law firm that has appeared on
23 behalf of that party, including support staff.
24 2.11 Party: any party to this Action, including all of its officers, directors,
25 employees, consultants, retained experts, and Outside Counsel of Record (and their
26 support staffs).
27 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
1 2.13 Professional Vendors: persons or entities that provide litigation support
2 services (e.g., photocopying, videotaping, translating, preparing exhibits or
3 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
4 their employees and subcontractors.
5 2.14 Protected Material: any Disclosure or Discovery Material that is designated
6 as “CONFIDENTIAL.”
7 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
8 from a Producing Party.
9
10 3. SCOPE
11 The protections conferred by this Stipulation and Order cover not only Protected
12 Material (as defined above), but also (1) any information copied or extracted from
13 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
14 Material; and (3) any testimony, conversations, or presentations by Parties or their
15 Counsel that might reveal Protected Material.
16 Any use of Protected Material at trial shall be governed by the orders of the trial
17 judge. This Order does not govern the use of Protected Material at trial.
18
19 4. DURATION
20 Once a case proceeds to trial, all of the court-filed information to be introduced that
21 was previously designated as confidential or maintained pursuant to this protective order
22 becomes public and will be presumptively available to all members of the public,
23 including the press, unless compelling reasons supported by specific factual findings to
24 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v.
25 City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good
26 cause” showing for sealing documents produced in discovery from “compelling reasons”
27 standard when merits-related documents are part of court record). Accordingly, the terms
1 5. DESIGNATING PROTECTED MATERIAL
2 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
3 Party or Non-Party that designates information or items for protection under this Order
4 must take care to limit any such designation to specific material that qualifies under the
5 appropriate standards. The Designating Party must designate for protection only those
6 parts of material, documents, items, or oral or written communications that qualify so that
7 other portions of the material, documents, items, or communications for which protection
8 is not warranted are not swept unjustifiably within the ambit of this Order.
9 Mass, indiscriminate, or routinized designations are prohibited. Designations that
10 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
11 to unnecessarily encumber the case development process or to impose unnecessary
12 expenses and burdens on other parties) may expose the Designating Party to sanctions.
13 If it comes to a Designating Party’s attention that information or items that it
14 designated for protection do not qualify for protection, that Designating Party must
15 promptly notify all other Parties that it is withdrawing the inapplicable designation.
16 5.2 Manner and Timing of Designations. Except as otherwise provided in this
17 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
18 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
19 must be clearly so designated before the material is disclosed or 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 proceedings),
23 that the Producing Party affix, at a minimum, the legend “CONFIDENTIAL” (hereinafter
24 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
25 portion or portions of the material on a page qualifies for protection, the Producing Party
26 also must clearly identify the protected portion(s) (e.g., by making appropriate markings
27 in the margins).
1 A Party or Non-Party that makes original documents available for inspection need
2 not designate them for protection until after the inspecting Party has indicated which
3 documents it would like copied and produced. During the inspection and before the
4 designation, all of the material made available for inspection shall be deemed
5 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
6 copied and produced, the Producing Party must determine which documents, or portions
7 thereof, qualify for protection under this Order. Then, before producing the specified
8 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
9 that contains Protected Material. If only a portion or portions of the material on a page
10 qualifies for protection, the Producing Party, also must clearly identify the protected
11 portion(s) (e.g., by making appropriate markings in the margins).
12 (b) for testimony given in depositions that the Designating Party identify the
13 Disclosure or Discovery Material on the record, before the close of the deposition.
14 (c) for information produced in some form other than documentary and for
15 any other tangible items, that the Producing Party affix in a prominent place on the
16 exterior of the container or containers in which the information is stored the legend
17 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,
18 the Producing Party, to the extent practicable, shall identify the protected portion(s).
19 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
20 to designate qualified information or items does not, standing alone, waive the
21 Designating Party’s right to secure protection under this Order for such material. Upon
22 timely correction of a designation, the Receiving Party must make reasonable efforts to
23 assure that the material is treated in accordance with the provisions of this Order.
24
25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
26 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation
27 of confidentiality at any time that is consistent with the Court’s Scheduling Order.
1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
2 process under Local Rule 37-1, et seq, as modified by Judge Kaufman’s Procedures. See
3 https://www.cacd.uscourts.gov/honorable-michael-b-kaufman. Any discovery motion
4 must strictly comply with these procedures. The parties may satisfy the meet and confer
5 requirements of Local Rule 37-1 by videoconference of counsel and need not meet in
6 person.
7 6.3 Burden. The burden of persuasion in any such challenge proceeding shall
8 be on the Designating Party. Frivolous challenges, and those made for an improper
9 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
10 may expose the Challenging Party to sanctions. Unless the Designating Party has waived
11 or withdrawn the confidentiality designation, all parties shall continue to afford the
12 material in question the level of protection to which it is entitled under the Producing
13 Party’s designation until the Court rules on the challenge.
14
15 7. ACCESS TO AND USE OF PROTECTED MATERIAL
16 7.1 Basic Principles. A Receiving Party may use Protected Material that is
17 disclosed or produced by another Party or by a Non-Party in connection with this Action
18 only for prosecuting, defending, or attempting to settle this Action. Such Protected
19 Material may be disclosed only to the categories of persons and under the conditions
20 described in this Order. When the Action has been terminated, a Receiving Party must
21 comply with the provisions of section 13 below (FINAL DISPOSITION).
22 Protected Material must be stored and maintained by a Receiving Party at a location
23 and in a secure manner that ensures that access is limited to the persons authorized under
24 this Order.
25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
26 ordered by the Court or permitted in writing by the Designating Party, a Receiving Party
27 may disclose any information or item designated “CONFIDENTIAL” only to:
1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
2 as employees of said Outside Counsel of Record to whom it is reasonably necessary to
3 disclose the information for this Action;
4 (b) the officers, directors, and employees (including House Counsel) of the
5 Receiving Party to whom disclosure is reasonably necessary for this Action;
6 (c) Experts (as defined in this Order) of the Receiving Party to whom
7 disclosure is reasonably necessary for this Action and who have signed the
8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (d) the Court and its personnel;
10 (e) court reporters and their staff;
11 (f) Trial consultants and Professional Vendors to whom disclosure is
12 reasonably necessary for this Action and who have signed the “Acknowledgment and
13 Agreement to Be Bound” (Exhibit A);
14 (g) the author or recipient of a document containing the information or a
15 custodian or other person who otherwise possessed or knew the information;
16 (h) during their depositions, witnesses, and attorneys for witnesses, in the
17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
18 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not
19 be permitted to keep any confidential information unless they sign the “Acknowledgment
20 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
21 Party or ordered by the Court. Pages of transcribed deposition testimony or exhibits to
22 depositions that reveal Protected Material may be separately bound by the court reporter
23 and may not be disclosed to anyone except as permitted under this Stipulated Protective
24 Order; and
25 (i) any mediator or settlement officer, and their supporting personnel,
26 mutually agreed upon by any of the parties engaged in settlement discussions.
27
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
2 IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation that
4 compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification shall
7 include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order to issue
9 in the other litigation that some or all of the material covered by the subpoena or order is
10 subject to this Protective Order. Such notification shall include a copy of this Stipulated
11 Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
13 Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with the
15 subpoena or court order shall not produce any information designated in this action as
16 “CONFIDENTIAL” before a determination by the court from which the subpoena or
17 order issued, unless the Party has obtained the Designating Party’s permission. The
18 Designating Party shall bear the burden and expense of seeking protection in that court of
19 its confidential material and nothing in these provisions should be construed as
20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
21 from another court.
22
23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
24 PRODUCED IN THIS LITIGATION
25 (a) The terms of this Order are applicable to information produced by a Non-Party
26 in this Action and designated as “CONFIDENTIAL.” Such information produced by
27 Non-Parties in connection with this litigation is protected by the remedies and relief
1 provided by this Order. Nothing in these provisions should be construed as prohibiting a
2 Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to produce a
4 Non-Party’s confidential information in its possession, and the Party is subject to an
5 agreement with the Non-Party not to produce the Non-Party’s confidential information,
6 then the Party shall:
7 (1) promptly notify in writing the Requesting Party and the Non-Party that
8 some or all of the information requested is subject to a confidentiality agreement with a
9 Non-Party;
10 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
11 Order in this Action, the relevant discovery request(s), and a reasonably specific
12 description of the information requested; and
13 (3) make the information requested available for inspection by the Non-
14 Party, if requested.
15 (c) If the Non-Party fails to seek a protective order from this Court within 14 days
16 of receiving the notice and accompanying information, the Receiving Party may produce
17 the Non-Party’s confidential information responsive to the discovery request. If the Non-
18 Party timely seeks a protective order, the Receiving Party shall not produce any
19 information in its possession or control that is subject to the confidentiality agreement
20 with the Non-Party before a determination by the Court. Absent a court order to the
21 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
22 Court of its Protected Material.
23
24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
26 Protected Material to any person or in any circumstance not authorized under this
27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
1 all unauthorized copies of the Protected Material, (c) inform the person or persons to
2 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
3 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
4 that is attached hereto as Exhibit A.
5
6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
7 PROTECTED MATERIAL
8 When a Producing Party gives notice to Receiving Parties that certain inadvertently
9 produced material is subject to a claim of privilege or other protection, the obligations of
10 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
11 This provision is not intended to modify whatever procedure may be established in an e-
12 discovery order that provides for production without prior privilege review. Pursuant to
13 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the
14 effect of disclosure of a communication or information covered by the attorney-client
15 privilege or work product protection, the parties may incorporate their agreement in the
16 stipulated protective order submitted to the Court.
17
18 12. MISCELLANEOUS
19 12.1 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 12.2 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 disclosing
23 or producing any information or item on any ground not addressed in this Stipulated
24 Protective Order. Similarly, no Party waives any right to object on any ground to use in
25 evidence of any of the material covered by this Protective Order.
26 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
27 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
1 Material at issue; good cause must be shown in the request to file under seal. If a Party’s
2 request to file Protected Material under seal is denied by the Court, then the Receiving
3 Party may file the information in the public record unless otherwise instructed by the
4 Court.
5 13. FINAL DISPOSITION
6 After the final disposition of this Action, within 60 days of a written request by the
7 Designating Party, each Receiving Party must return all Protected Material to the
8 Producing Party or destroy such material. As used in this subdivision, “all Protected
9 Material” includes all copies, abstracts, compilations, summaries, and any other format
10 reproducing or capturing any of the Protected Material. Whether the Protected Material
11 is returned or destroyed, the Receiving Party must submit a written certification to the
12 Producing Party (and, if not the same person or entity, to the Designating Party) by the
13 60 day deadline that (1) identifies (by category, where appropriate) all the Protected
14 Material that was returned or destroyed, and (2) affirms that the Receiving Party has not
15 retained any copies, abstracts, compilations, summaries or any other format reproducing
16 or capturing any of the Protected Material. Notwithstanding this provision, counsel are
17 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and
18 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,
19 expert reports, attorney work product, and consultant and expert work product, even if
20 such materials contain Protected Material. Any such archival copies that contain or
21 constitute Protected Material remain subject to this Protective Order as set forth in Section
22 4 (DURATION).
23 / / /
24 / / /
25 / / /
26 / / /
27 / / /
1 VIOLATION OF ORDER
2 Any violation of this Order may be punished by any and all appropriate measures
3 || including, without limitation, contempt proceedings and/or monetary sanctions.
4
5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
7
g Dated: May 14, 2026 EARL J. WASHINGTON, Attorney at Law
9
10 By:___is/Harl J. Washington
EARL J. WASHINGTON
11 Plaintiff in Pro Se
12
13 ||Dated: May 14, 2026 HYDEE FELDSTEIN SOTO, City Attorney
14 DENISE C. MILLS, Chief Deputy City Attorney
KATHLEEN KENEALY, Chief Asst. City Attorney
15 CHRISTIAN R. BOJORQUEZ, Deputy City Attorney
16
M7 SHANT TASLAKIAN
18 Deputy City Attorney
19 Attorneys for Defendants, CITY OF LOS ANGELES,
et al.
20
21
22 ISSO ORDERED.
23
24 |lDated: May 15, 2026 LALEY) Ne
5 HON. MICHAEL B: KAUFMAN
UNITED STATES MAGISTRATE JUDGE
26
27
28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [full name], of
4 [address], declare under penalty of perjury that I have
5 read in its entirety and understand the Stipulated Protective Order that was issued by the
6 United States District Court for the Central District of California on
7 [date] in the case of Earl. J. Washington, et. al v. City of Los Angeles, et. al, 2:25-cv-
8 09036-JAK-MBK. I agree to comply with and to be bound by all the terms of this
9 Stipulated Protective Order, and I understand and acknowledge that failure to so comply
10 could expose me to sanctions and punishment in the nature of contempt. I solemnly
11 promise that I will not disclose in any manner any information or item that is subject to
12 this Stipulated Protective Order to any person or entity except in strict compliance with
13 the provisions of this Stipulated Protective
14 Order.
15 I further agree to submit to the jurisdiction of the United States District Court for
16 the Central District of California for the purpose of enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of this
18 action. I hereby appoint [full name] of
19 [address and telephone number] as my
20 California agent for service of process in connection with this action or any proceedings
21 related to enforcement of this Stipulated Protective Order.
22
23 Signature:
24
Printed Name:
25
Date:
26
27 City and State Where Sworn and Signed: