The opinion
1 TROUTMAN AMIN, LLP
Puja J. Amin (State Bar # 299547)
2 Brittany A. Andres (State Bar # 340856)
400 Spectrum Center Drive, Suite 1450
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Irvine, California 92618
4 Telephone: +1 949 350 3663
Facsimile: +1 949 203 8689
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troutman@troutmanamin.com
6 amin@troutmanamin.com
brittany@troutmanamin.com
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8 Attorneys for Plaintiffs ERIC J. TROUTMAN
and TROUTMAN AMIN, LLP
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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13 ERIC J. TROUTMAN and Case No. 8:25-CV-1181-JVS-KES
TROUTMAN AMIN, LLP,
14 STIPULATED PROTECTIVE
Plaintiffs, ORDER
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VS.
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17 SYMPLE LENDING LLC,
18 Defendant.
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22 1. PURPOSES AND LIMITATIONS
23 Discovery in this action is likely to involve production of confidential,
24 proprietary or private information for which special protection from public disclosure
25 and from use for any purpose other than pursuing this litigation may be warranted.
26 Accordingly, the parties hereby stipulate to and petition the Court to enter the
27 following Stipulated Protective Order. The parties acknowledge that this Order does
1 the protection it affords from public disclosure and use extends only to the limited
2 information or items that are entitled to confidential treatment under the applicable
3 legal principles.
4 2. GOOD CAUSE STATEMENT
5 This action is likely to involve: (i) personal identifying information pertaining
6 to the parties; (ii) non-public, proprietary company information including policies,
7 contracts with third party vendors, and other information, the disclosure of which
8 could compromise Defendant’s competitive position; (iii) personal identifying
9 information of individuals; and (iv) other trade secrets and intellectual property
10 belonging to the parties. These confidential, private, and proprietary materials consist
11 of confidential business information, personal identifying information, confidential
12 business transactions, and other confidential information that would otherwise be
13 unavailable to the public, or which may be privileged or otherwise protected from
14 disclosure under state or federal statutes, court rules, case decisions, or common law.
15 To expedite the flow of information, to facilitate the prompt resolution of
16 disputes over confidentiality of discovery materials, to adequately protect
17 information that the parties are entitled to keep confidential, to ensure that the parties
18 are permitted reasonable necessary uses of such material in preparation for and in the
19 conduct of trial, to address their handling at the end of the litigation, and to serve the
20 ends of justice, a protective order for such information is justified in this matter. It is
21 the intent of the parties that information will not be designated as confidential for
22 tactical reasons and that nothing be so designated without a good faith belief that it
23 has been maintained in a confidential, non-public manner, and there is good cause
24 why it should not be part of the public record of this case.
25 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
26 The parties further acknowledge, as set forth in Section 14.3, below, that this
27 Stipulated Protective Order does not entitle them to file confidential information
1 the standards that will be applied when a party seeks permission from the court to
2 file material under seal. There is a strong presumption that the public has a right of
3 access to judicial proceedings and records in civil cases. In connection with non-
4 dispositive motions, good cause must be shown to support a filing under seal. See
5 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
6 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
7 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
8 protective orders require good cause showing), and a specific showing of good cause
9 or compelling reasons with proper evidentiary support and legal justification, must
10 be made with respect to Protected Material that a party seeks to file under seal. The
11 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL
12 does not— without the submission of competent evidence by declaration,
13 establishing that the material sought to be filed under seal qualifies as confidential,
14 privileged, or otherwise protectable—constitute good cause.
15 Further, if a party requests sealing related to a dispositive motion or trial, then
16 compelling reasons, not only good cause, for the sealing must be shown, and the
17 relief sought shall be narrowly tailored to serve the specific interest to be protected.
18 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each
19 item or type of information, document, or thing sought to be filed or introduced under
20 seal, the party seeking protection must articulate compelling reasons, supported by
21 specific facts and legal justification, for the requested sealing order. Again,
22 competent evidence supporting the application to file documents under seal must be
23 provided by declaration.
24 Any document that is not confidential, privileged, or otherwise protectable in
25 its entirety will not be filed under seal if the confidential portions can be redacted. If
26 documents can be redacted, then a redacted version for public viewing, omitting only
27 the confidential, privileged, or otherwise protectable portions of the document, shall
1 be filed. Any application that seeks to file documents under seal in their entirety
2 should include an explanation of why redaction is not feasible.
3 4. DEFINITIONS
4 4.1 Action: this pending federal lawsuit.
5 4.2 Challenging Party: a Party or Non-Party that challenges the
6 designation of information or items under this Order.
7 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
8 how it is generated, stored or maintained) or tangible things that qualify for protection
9 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
10 Cause Statement.
11 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
12 their support staff).
13 4.5 Designating Party: a Party or Non-Party that designates information or
14 items that it produces in disclosures or in responses to discovery as
15 “CONFIDENTIAL.”
16 4.6 Disclosure or Discovery Material: all items or information, regardless
17 of the medium or manner in which it is generated, stored, or maintained (including,
18 among other things, testimony, transcripts, and tangible things), that are produced or
19 generated in disclosures or responses to discovery.
20 4.7 Expert: a person with specialized knowledge or experience in a matter
21 pertinent to the litigation who has been retained by a Party or its counsel to serve as
22 an expert witness or as a consultant in this Action.
23 4.8 House Counsel: attorneys who are employees of a party to this Action.
24 House Counsel does not include Outside Counsel of Record or any other outside
25 counsel.
26 4.9 Non-Party: any natural person, partnership, corporation, association or
27 other legal entity not named as a Party to this action.
1 4.10 Outside Counsel of Record: attorneys who are not employees of a party
2 to this Action but are retained to represent a party to this Action and have appeared
3 in this Action on behalf of that party or are affiliated with a law firm that has appeared
4 on behalf of that party, and includes support staff.
5 4.11 Party: any party to this Action, including all of its officers, directors,
6 employees, consultants, retained experts, and Outside Counsel of Record (and their
7 support staffs).
8 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
9 Discovery Material in this Action.
10 4.13 Professional Vendors: persons or entities that provide litigation support
11 services (e.g., photocopying, videotaping, translating, preparing exhibits or
12 demonstrations, and organizing, storing, or retrieving data in any form or medium)
13 and their employees and subcontractors.
14 4.14 Protected Material: any Disclosure or Discovery Material that is
15 designated as “CONFIDENTIAL.”
16 4.15 Receiving Party: a Party that receives Disclosure or Discovery
17 Material from a Producing Party.
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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.
7 Any use of Protected Material at trial shall be governed by the orders of the
8 trial judge and other applicable authorities. This Order does not govern the use of
9 Protected Material at trial.
10 6. DURATION
11 Even after final disposition of this litigation, the confidentiality obligations
12 imposed by this Order shall remain in effect until a Designating Party agrees
13 otherwise in writing or a court order otherwise directs. Final disposition shall be
14 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
15 or without prejudice; and (2) final judgment herein after the completion and
16 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
17 including the time limits for filing any motions or applications for extension of time
18 pursuant to applicable law.
19 7. DESIGNATING PROTECTED MATERIAL
20 7.1 Exercise of Restraint and Care in Designating Material for
21 Protection. Each Party or Non-Party that designates information or items
22 for protection under this Order must take care to limit any such designation to specific
23 material that qualifies under the appropriate standards. The Designating Party must
24 designate for protection only those parts of material, documents, items or oral or
25 written communications that qualify so that other portions of the material,
26 documents, items or communications for which protection is not warranted are not
27 swept unjustifiably within the ambit of this Order.
1 Mass, indiscriminate or routinized designations are prohibited. Designations
2 that are shown to be clearly unjustified or that have been made for an improper
3 purpose (e.g., to unnecessarily encumber the case development process or to impose
4 unnecessary expenses and burdens on other parties) may expose the Designating
5 Party to sanctions.
6 If it comes to a Designating Party’s attention that information or items that it
7 designated for protection do not qualify for protection, that Designating Party must
8 promptly notify all other Parties that it is withdrawing the inapplicable designation.
9 7.2 Manner and Timing of Designations. Except as otherwise provided in
10 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
11 that qualifies for protection under this Order must be clearly so designated before the
12 material is disclosed or produced.
13 Designation in conformity with this Order requires:
14 (a) for information in documentary form (e.g., paper or electronic
15 documents, but excluding transcripts of depositions or other pretrial or trial
16 proceedings), that the Producing Party affix at a minimum, the legend
17 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
18 contains protected material. If only a portion of the material on a page qualifies for
19 protection, the Producing Party also must clearly identify the protected portion(s)
20 (e.g., by making appropriate markings in the margins).
21 A Party or Non-Party that makes original documents available for inspection
22 need not designate them for protection until after the inspecting Party has indicated
23 which documents it would like copied and produced. During the inspection and
24 before the designation, all of the material made available for inspection shall be
25 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
26 it wants copied and produced, the Producing Party must determine which documents,
27 or portions thereof, qualify for protection under this Order. Then, before producing
1 legend” to each page that contains Protected Material. If only a portion of the material
2 on a page qualifies for protection, the Producing Party also must clearly identify the
3 protected portion(s) (e.g., by making appropriate markings in the margins).
4 (b) for testimony given in depositions that the Designating Party
5 identifies the Disclosure or Discovery Material on the record, before the close of the
6 deposition all protected testimony or no later than 30 days after the deposition
7 concludes.
8 (c) for information produced in some form other than documentary and
9 for any other tangible items, that the Producing Party affix in a prominent place on
10 the exterior of the container or containers in which the information is stored the
11 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants
12 protection, the Producing Party, to the extent practicable, shall identify the protected
13 portion(s).
14 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
15 failure to designate qualified information or items does not, standing alone, waive
16 the Designating Party’s right to secure protection under this Order for such material.
17 Upon timely correction of a designation, the Receiving Party must make reasonable
18 efforts to assure that the material is treated in accordance with the provisions of this
19 Order.
20 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
21 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
22 designation of confidentiality at any time that is consistent with the Court’s
23 Scheduling Order.
24 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
25 resolution process under Local Rule 37-1 et seq.
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8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
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stipulation pursuant to Local Rule 37-2.
1 8.4 The burden of persuasion in any such challenge proceeding shall be on the
2 Designating Party. Frivolous challenges, and those made for an improper purpose
3 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
4 expose the Challenging Party to sanctions. Unless the Designating Party has waived
5 or withdrawn the confidentiality designation, all parties shall continue to afford the
6 material in question the level of protection to which it is entitled under the Producing
7 Party’s designation until the Court rules on the challenge.
8 9. ACCESS TO AND USE OF PROTECTED MATERIAL
9 9.1 Basic Principles. A Receiving Party may use Protected Material that is
10 disclosed or produced by another Party or by a Non-Party in connection with this
11 Action only for prosecuting, defending or attempting to settle this Action. Such
12 Protected Material may be disclosed only to the categories of persons and under the
13 conditions described in this Order. When the Action has been terminated, a Receiving
14 Party must comply with the provisions of section 15 below (FINAL DISPOSITION).
15 Protected Material must be stored and maintained by a Receiving Party at a
16 location and in a secure manner that ensures that access is limited to the persons
17 authorized under this Order.
18 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
19 otherwise ordered by the court or permitted in writing by the Designating Party, a
20 Receiving Party may disclose any information or item designated
21 “CONFIDENTIAL” only to:
22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
23 well as employees of said Outside Counsel of Record to whom it is reasonably
24 necessary to disclose the information for this Action;
25 (b) the officers, directors, and employees (including House Counsel) of
26 the Receiving Party to whom disclosure is reasonably necessary for this Action;
27 (c) Experts (as defined in this Order) of the Receiving Party to whom
1 disclosure is reasonably necessary for this Action and who have signed the
2 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
3 (d) the court and its personnel;
4 (e) court reporters and their staff;
5 (f) professional jury or trial consultants, mock jurors, and Professional
6 Vendors to whom disclosure is reasonably necessary for this Action and who have
7 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
8 (g) the author or recipient of a document containing the information or
9 a custodian or other person who otherwise possessed or knew the information;
10 (h) during their depositions, witnesses, and attorneys for witnesses, in
11 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
12 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
13 they will not be permitted to keep any confidential information unless they sign the
14 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
15 agreed by the Designating Party or ordered by the court. Pages of transcribed
16 deposition testimony or exhibits to depositions that reveal Protected Material may be
17 separately bound by the court reporter and may not be disclosed to anyone except as
18 permitted under this Stipulated Protective Order; and
19 (i) any mediators or settlement officers and their supporting personnel,
20 mutually agreed upon by any of the parties engaged in settlement discussions.
21 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
22 PRODUCED IN OTHER LITIGATION
23 If a Party is served with a subpoena or a court order issued in other litigation
24 that compels disclosure of any information or items designated in this Action as
25 “CONFIDENTIAL,” that Party must:
26 (a) promptly notify in writing the Designating Party. Such notification
27 shall include a copy of the subpoena or court order;
1 order to issue in the other litigation that some or all of the material covered by the
2 subpoena or order is subject to this Protective Order. Such notification shall include
3 a copy of this Stipulated Protective Order; and
4 (c) cooperate with respect to all reasonable procedures sought to be
5 pursued by the Designating Party whose Protected Material may be affected. If the
6 Designating Party timely seeks a protective order, the Party served with the subpoena
7 or court order shall not produce any information designated in this action as
8 “CONFIDENTIAL” before a determination by the court from which the subpoena or
9 order issued, unless the Party has obtained the Designating Party’s permission. The
10 Designating Party shall bear the burden and expense of seeking protection in that
11 court of its confidential material and nothing in these provisions should be construed
12 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful
13 directive from another court.
14 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
15 PRODUCED IN THIS LITIGATION
16 (a) The terms of this Order are applicable to information produced by a
17 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
18 produced by Non-Parties in connection with this litigation is protected by the
19 remedies and relief provided by this Order. Nothing in these provisions should be
20 construed as prohibiting a Non-Party from seeking additional protections.
21 (b) In the event that a Party is required, by a valid discovery request, to
22 produce a Non-Party’s confidential information in its possession, and the Party is
23 subject to an agreement with the Non-Party not to produce the Non-Party’s
24 confidential information, then the Party shall:
25 (1) promptly notify in writing the Requesting Party and the Non-Party
26 that some or all of the information requested is subject to a confidentiality agreement
27 with a Non-Party;
1 (2) promptly provide the Non-Party with a copy of the Stipulated
2 Protective Order in this Action, the relevant discovery request(s), and a reasonably
3 specific description of the information requested; and
4 (3) make the information requested available for inspection by the Non-
5 Party, if requested.
6 (c) If the Non-Party fails to seek a protective order from this court within
7 14 days of receiving the notice and accompanying information, the Receiving Party
8 may produce the Non-Party’s confidential information responsive to the discovery
9 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
10 not produce any information in its possession or control that is subject to the
11 confidentiality agreement with the Non-Party before a determination by the court.
12 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
13 of seeking protection in this court of its Protected Material.
14 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
16 Protected Material to any person or in any circumstance not authorized under this
17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
18 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
19 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
20 persons to whom unauthorized disclosures were made of all the terms of this Order,
21 and (d) request such person or persons to execute the “Acknowledgment an
22 Agreement to Be Bound” attached hereto as Exhibit A.
23 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
24 OTHERWISE PROTECTED MATERIAL
25 When a Producing Party gives notice to Receiving Parties that certain inadvertently
26 produced material is subject to a claim of privilege or other protection, the obligations
27 of the Receiving Parties are those set forth in Federal Rule of Civil Procedure
1 established in an e-discovery order that provides for production without prior
2 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
3 parties reach an agreement on the effect of disclosure of a communication or
4 information covered by the attorney-client privilege or work product protection, the
5 parties may incorporate their agreement in the stipulated protective order submitted
6 to the court.
7 14. MISCELLANEOUS
8 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
9 person to seek its modification by the Court in the future.
10 14.2 Right to Assert Other Objections. By stipulating to the entry of this
11 Protective Order, no Party waives any right it otherwise would have to object to
12 disclosing or producing any information or item on any ground not addressed in this
13 Stipulated Protective Order. Similarly, no Party waives any right to object on any
14 ground to use in evidence of any of the material covered by this Protective Order.
15 14.3 Filing Protected Material. A Party that seeks to file under seal any
16 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
17 only be filed under seal pursuant to a court order authorizing the sealing of the
18 specific Protected Material. If a Party’s request to file Protected Material under seal
19 is denied by the court, then the Receiving Party may file the information in the public
20 record unless otherwise instructed by the court.
21 15. FINAL DISPOSITION
22 After the final disposition of this Action, as defined in paragraph 6, within 60
23 days of a written request by the Designating Party, each Receiving Party must return
24 all Protected Material to the Producing Party or destroy such material. As used in this
25 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
26 summaries, and any other format reproducing or capturing any of the Protected
27 Material. Whether the Protected Material is returned or destroyed, the Receiving
1 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies
2 (by category, where appropriate) all the Protected Material that was returned or
3 destroyed and (2) affirms that the Receiving Party has not retained any copies,
4 abstracts, compilations, summaries or any other format reproducing or capturing any
5 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
6 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
7 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
8 reports, attorney work product, and consultant and expert work product, even if such
9 materials contain Protected Material. Any such archival copies that contain or
10 constitute Protected Material remain subject to this Protective Order as set forth in
11 Section 6 (DURATION).
12 16. VIOLATION
13 Any violation of this Order may be punished by appropriate measures
14 including, without limitation, contempt proceedings and/or monetary sanctions.
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, || TPIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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3 Dated: June 12, 2026 TROUTMAN AMIN, LLP
4 By: /s/ Brittany A. Andres
5 Puja J. Amin
Brittany A. Andres
6 Attorneys for Plainiigs Eric J. Troutman ana
Troutman Amin, LL
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g ANGELO & WHITE
9 By: /s/ Alyssa Milman White, Esq.
yssa Milman White
10 Sara Escalante
Attorneys for Defendant Symple Lending,
11 LLC
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5 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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7 DATED: June 15, 2026
OS
19 [0nm) U2. colt
50 KAREN E. SCOTT
United States Magistrate Judge
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CERTIFICATE OF SERVICE
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I hereby certify that on June 12, 2026, a copy of the foregoing was served by
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electronic mail to counsel of record.
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/s/ Brittany A. Andres
5 Brittany A. Andres
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [______________________] [print or type full name], of
4 [__________________] [print or type full address], declare under penalty of perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that was
6 issued by the United States District Court for the Central District of California on
7 [date] in the case of Eric J. Troutman, et al. v. Symple Lending, LLC, Case No. 8:25-
8 cv-1181-JVS-KES (C.D. Cal.), filed on May 30, 2025. I agree to comply with and to
9 be 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
15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint [________________________] [print or
18 type full name] 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.
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23 Date: ________________________________
24 City and State where sworn and signed: ____________________________
25 Printed Name: _________________________
26 Signature: _____________________________
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