Opinion

Court: District Court, C.D. California
Filed: Jun 30, 2026
Cited by: 0 cases
Authority: More cited than 41.6%

The opinion

1 HYDEE FELDSTEIN SOTO, City Attorney (SBN 106866)

DENISE C. MILLS, Chief Deputy City Attorney (SBN 191992)

2 KATHLEEN KENEALY, Chief Assistant City Attorney (SBN 212289)

CHRISTIAN R. BOJORQUEZ, Deputy City Attorney (SBN 192872)

3 CHRISTINA ISAGHOLIAN, Deputy City Attorney (SBN 340430)

200 North Main Street, 6th Floor, City Hall East

4 Los Angeles, CA 90012

Phone No.: (213) 978-6900

5 Fax No.: (213) 978-8785

Email: christina.isagholian@lacity.org

Attorneys for Defendants, CITY OF LOS ANGELES, EGON PONCE, JUAN GONZALEZ and CHRISTOPHER

7 MENCHACA

8 Andrew M. Stein, SBN 82963

Joseph A. Markus, SBN 113802

9 LAW OFFICES OF STEIN AND MARKUS, PLC

9944 Flower Street

10 Bellflower, CA 90706

Telephone: (562) 866-9762

11 Email: astein.steinandmarkus@gmail.com

Email: jmarkus.steinandmarkus@gmail.com

Gregory Peacock, Esq. (SBN. 277669)

13 LAW OFFICE OF GREGORY PEACOCK

4063 Birch Street, Suite 100

14 Newport Beach, CA 92660

Telephone: (949) 292-7478

15 Email: gregorypeacockesq@gmail.com

16 Attorneys for Plaintiff Donna Simms

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

DONNA SIMMS,

Case No. 2:25-cv-08222-SSC

21 Plaintiff,

v. STIPULATED PROTECTIVE

22 ORDER1

23 CITY OF LOS ANGELES; EGON

PONCE; CHRISTOPHER

MENCHACA; JUAN

1 This Stipulated Protective Order is substantially based on the model

protective order provided under Magistrate Judge Stephanie S.

1 GONZALEZ; DOES 1 through 10,

inclusive,

Defendants.

8 1. INTRODUCTION

9 1.1 Purposes and Limitations. Discovery in this action is likely to

10 involve production of confidential, proprietary, or private information for

11 which special protection from public disclosure and from use for any

12 purpose other than prosecuting this litigation may be warranted.

13 Accordingly, the parties hereby stipulate to and petition the court to

14 enter the following Stipulated Protective Order. The parties

15 acknowledge that this Order does not confer blanket protections on all

16 disclosures or responses to discovery and that the protection it affords

from public disclosure and use extends only to the limited information or

items that are entitled to confidential treatment under the applicable

legal principles.

1.2 Good Cause Statement. [*The “Good Cause Statement”

should be edited to include or exclude specific information that

applies to the particular case, i.e., what harm will result from the

disclosure of the confidential information likely to be produced

in this case? Below is an example]:

This action is likely to involve trade secrets, customer and pricing

lists and other valuable research, development, commercial, financial,

1 from public disclosure and from use for any purpose other than

2 prosecution of this action is warranted. Such confidential and

3 proprietary materials and information consist of, among other things,

4 confidential business or financial information, information regarding

5 confidential business practices, or other confidential research,

6 development, or commercial information (including information

7 implicating privacy rights of third parties), information otherwise

generally unavailable to the public, or which may be privileged or

otherwise protected from disclosure under state or federal statutes, court

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

information, to facilitate the prompt resolution of disputes over

confidentiality of discovery materials, to adequately protect information

the parties are entitled to keep confidential, to ensure that the parties

are permitted reasonable necessary uses of such material in preparation

for and in the conduct of trial, to address their handling at the end of the

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

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

information will not be designated as confidential for tactical reasons

and that nothing be so designated without a good faith belief that it has

been maintained in a confidential, non-public manner, and there is good

22 cause why it should not be part of the public record of this case.

23 1.3 Acknowledgment of Procedure for Filing Under Seal. The

24 parties further acknowledge, as set forth in Section 12.3, below, that this

25 Stipulated Protective Order does not entitle them to file confidential

26 information under seal; Local Rule 79-5 sets forth the procedures that

27 must be followed and the standards that will be applied when a party

1 There is a strong presumption that the public has a right of access

2 to judicial proceedings and records in civil cases. In connection with

3 non-dispositive motions, good cause must be shown to support a filing

4 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d

5 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors

6 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony

7 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

protective orders require good cause showing), and a specific showing of

good cause or compelling reasons with proper evidentiary support and

legal justification, must be made with respect to Protected Material that

a party seeks to file under seal. The parties’ mere designation of

Disclosure or Discovery Material as CONFIDENTIAL does not—

without the submission of competent evidence by declaration,

establishing that the material sought to be filed under seal qualifies as

confidential, privileged, or otherwise protectable—constitute good cause.

Further, if a party requests sealing related to a dispositive motion

or trial, then compelling reasons, not only good cause, for the sealing

must be shown, and the relief sought shall be narrowly tailored to serve

the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,

605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of

22 information, document, or thing sought to be filed or introduced under

23 seal in connection with a dispositive motion or trial, the party seeking

24 protection must articulate compelling reasons, supported by specific

25 facts and legal justification, for the requested sealing order. Again,

26 competent evidence supporting the application to file documents under

27 seal must be provided by declaration.

1 protectable in its entirety will not be filed under seal if the confidential

2 portions can be redacted. If documents can be redacted, then a redacted

3 version for public viewing, omitting only the confidential, privileged, or

4 otherwise protectable portions of the document, shall be filed. Any

5 application that seeks to file documents under seal in their entirety

6 should include an explanation of why redaction is not feasible.

2. DEFINITIONS

2.1 Action: [this pending federal lawsuit]. [*Option: consolidated

or related actions.]

2.2 Challenging Party: a Party or Non-Party that challenges the

designation of information or items under this Order.

2.3 “CONFIDENTIAL” Information or Items: information

(regardless of how it is generated, stored or maintained) or tangible

things that qualify for protection under Rule 26(c) of the Federal Rules of

Civil Procedure, and as specified above in the Good Cause Statement.

18 2.4 Counsel: Outside Counsel of Record and House Counsel (as

19 well as their support staff).

20 2.5 Designating Party: a Party or Non-Party that designates

21 information or items that it produces in disclosures or in responses to

22 discovery as “CONFIDENTIAL.”

23 2.6 Disclosure or Discovery Material: all items or information,

24 regardless of the medium or manner in which it is generated, stored, or

25 maintained (including, among other things, testimony, transcripts, and

26 tangible things), that are produced or generated in disclosures or

responses to discovery in this matter.

1 2.7 Expert: a person with specialized knowledge or experience in

2 a matter pertinent to the litigation who has been retained by a Party or

3 its counsel to serve as an expert witness or as a consultant in this Action.

4 2.8 Final Disposition: the later of (1) dismissal of all claims and

5 defenses in this Action, with or without prejudice; and (2) final judgment

6 herein after the completion and exhaustion of all appeals, rehearings,

7 remands, trials, or reviews of this Action, including the time limits for

filing any motions or applications for extension of time pursuant to

applicable law.

2.9 In-House Counsel: attorneys who are employees of a party to

this Action. In-House Counsel does not include Outside Counsel of

Record or any other outside counsel.

2.10 Non-Party: any natural person, partnership, corporation,

association, or other legal entity not named as a Party to this action.

2.11 Outside Counsel of Record: attorneys who are not employees

of a party to this Action but are retained to represent or advise a party to

this Action and have appeared in this Action on behalf of that party or

are affiliated with a law firm which has appeared on behalf of that party,

and includes support staff.

2.12 Party: any party to this Action, including all of its officers,

22 directors, employees, consultants, retained experts, and Outside Counsel

23 of Record (and their support staffs).

24 2.13 Producing Party: a Party or Non-Party that produces

25 Disclosure or Discovery Material in this Action.

26 2.14 Professional Vendors: persons or entities that provide

27 litigation- support services (e.g., photocopying, videotaping, translating,

1 retrieving data in any form or medium) and their employees and

2 subcontractors.

3 2.15 Protected Material: any Disclosure or Discovery Material that

4 is designated as “CONFIDENTIAL.”

5 2.16 Receiving Party: a Party that receives Disclosure or Discovery

6 Material from a Producing Party.

3. SCOPE

The protections conferred by this Stipulation and Order cover not

only Protected Material (as defined above), but also (1) any information

copied or extracted from Protected Material; (2) all copies, excerpts,

summaries, or compilations of Protected Material; and (3) any

testimony, conversations, or presentations by Parties or their Counsel

that might reveal Protected Material.

Any use of Protected Material at trial shall be governed by the

orders of the trial judge. This Stipulated Protective Order does not

18 govern the use of Protected Material at trial.

20 4. TRIAL AND DURATION

21 The terms of this Stipulated Protective Order apply through Final

22 Disposition of the Action.

Once a case proceeds to trial, information that was designated as

CONFIDENTIAL or maintained pursuant to this Stipulated Protective

Order and used or introduced as an exhibit at trial becomes public and

will be presumptively available to all members of the public, including

1 findings to proceed otherwise are made to the trial judge in advance of

2 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good

3 cause” showing for sealing documents produced in discovery from

4 “compelling reasons” standard when merits-related documents are part

5 of court record). Accordingly, for such materials, the terms of this

6 Stipulated Protective Order do not extend beyond the commencement of

7 the trial.

[Optional addition:]

Even after Final Disposition of this litigation, the confidentiality

obligations imposed by this Stipulated Protective Order shall remain in

effect until a Designating Party agrees otherwise in writing or a court

order otherwise directs.

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for

Protection. Each Party or Non-Party that designates information or

18 items for protection under this Order must take care to limit any such

19 designation to specific material that qualifies under the appropriate

20 standards. The Designating Party must designate for protection only

21 those parts of material, documents, items, or oral or written

22 communications that qualify so that other portions of the material,

23 documents, items, or communications for which protection is not

24 warranted are not swept unjustifiably within the ambit of this Order.

25 Mass, indiscriminate, or routinized designations are prohibited.

26 Designations that are shown to be clearly unjustified or that have been

made for an improper purpose (e.g., to unnecessarily encumber the case

1 development process or to impose unnecessary expenses and burdens on

2 other parties) may expose the Designating Party to sanctions.

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

4 items that it designated for protection do not qualify for protection, that

5 Designating Party must promptly notify all other Parties that it is

6 withdrawing the inapplicable designation.

5.2 Manner and Timing of Designations. Except as otherwise

provided in this Stipulated Protective Order (see, e.g., second paragraph

of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure

or Discovery Material that qualifies for protection under this Stipulated

Protective Order must be clearly so designated before the material is

disclosed or produced.

Designation in conformity with this Stipulated Protective Order

requires:

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

17 documents, but excluding transcripts of depositions or other pretrial or

18 trial proceedings), that the Producing Party affix at a minimum, the

19 legend “CONFIDENTIAL” to each page that contains protected

20 material. If only a portion or portions of the material on a page

21 qualifies for protection, the Producing Party also must clearly identify

22 the protected portion(s) (e.g., by making appropriate markings in the

23 margins).

24 A Party or Non-Party that makes original documents available for

25 inspection need not designate them for protection until after the

inspecting Party has indicated which documents it would like copied

and produced. During the inspection and before the designation, all of

1 the material made available for inspection shall be deemed

2 CONFIDENTIAL. After the inspecting Party has identified the

3 documents it wants copied and produced, the Producing Party must

4 determine which documents, or portions thereof, qualify for protection

5 under this Stipulated Protective Order. Then, before producing the

6 specified documents, the Producing Party must affix the

7 “CONFIDENTIAL” legend to each page that contains Protected

Material. If only a portion or portions of the material on a page

qualifies for protection, the Producing Party also must clearly identify

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

margins).

(b) for testimony given in depositions that the Designating Party

identify the Disclosure or Discovery Material on the record, before the

close of the deposition all protected testimony.

documentary and for any other tangible items, that the Producing Party

affix in a prominent place on the exterior of the container or containers

in which the information is stored the “CONFIDENTIAL” legend. If only

a portion or portions of the information warrants protection, the

Producing Party, to the extent practicable, shall identify the protected

22 portion(s).

23 5.3 Inadvertent Failures to Designate. If timely corrected, an

24 inadvertent failure to designate qualified information or items does not,

25 standing alone, waive the Designating Party’s right to secure protection

26 under this Order for such material. Upon timely correction of a

designation, the Receiving Party must make reasonable efforts to assure

1 that the material is treated in accordance with the provisions of this

2 Stipulated Protective Order.

4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

6.1 Timing of Challenges. Any Party or Non-Party may

challenge a designation of confidentiality at any time that is consistent

with the court’s Scheduling Order.

6.2 Meet and Confer. The Challenging Party shall initiate the

dispute resolution process under Local Rule 37.1 et seq. and with

Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-

Discovery Motion Conference.”2

6.3 The burden of persuasion in any such challenge proceeding

shall be on the Designating Party. Frivolous challenges, and those

made for an improper purpose (e.g., to harass or impose unnecessary

expenses and burdens on other parties) may expose the Challenging

Party to sanctions. Unless the Designating Party has waived or

18 withdrawn the confidentiality designation, all parties shall continue to

19 afford the material in question the level of protection to which it is

20 entitled under the Producing Party’s designation until the court rules on

21 the challenge.

23 7. ACCESS TO AND USE OF PROTECTED MATERIAL

7.1 Basic Principles. A Receiving Party may use Protected

Material that is disclosed or produced by another Party or by a Non-

2 Judge Christensen’s Procedures are available at

1 Party in connection with this Action only for prosecuting, defending, or

2 attempting to settle this Action. Such Protected Material may be

3 disclosed only to the categories of persons and under the conditions

4 described in this Order. When the Action reaches a Final Disposition, a

5 Receiving Party must comply with the provisions of section 13 below.

6 Protected Material must be stored and maintained by a Receiving

7 Party at a location and in a secure manner that ensures that access is

limited to the persons authorized under this Stipulated Protective

Order.

7.2 Disclosure of “CONFIDENTIAL” Information or Items.

Unless otherwise ordered by the court or permitted in writing by the

Designating Party, a Receiving Party may disclose any information or

item designated “CONFIDENTIAL” only:

(a) to the Receiving Party’s Outside Counsel of Record in this

Action, as well as employees of said Outside Counsel of Record to whom

it is reasonably necessary to disclose the information for this Action;

(b) to the officers, directors, and employees (including House

Counsel) of the Receiving Party to whom disclosure is reasonably

necessary for this Action;

22 whom disclosure is reasonably necessary for this Action and who have

23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

24 (d) to the court and its personnel;

25 (e) to court reporters and their staff;

26 (f) to professional jury or trial consultants, mock jurors, and

27 Professional Vendors to whom disclosure is reasonably necessary for

1 to Be Bound” (Exhibit A);

2 (g) to the author or recipient of a document containing the

3 information or a custodian or other person who otherwise possessed or

4 knew the information;

5 (h) during their depositions, to witnesses, and attorneys for

6 witnesses, in the Action to whom disclosure is reasonably necessary,

7 provided: (1) the deposing party requests that the witness sign the

“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the

witness will not be permitted to keep any confidential information

unless they sign the “Acknowledgment and Agreement to Be Bound”

(Exhibit A), unless otherwise agreed by the Designating Party or

ordered by the court. Pages of transcribed deposition testimony or

exhibits to depositions that reveal Protected Material may be separately

bound by the court reporter and may not be disclosed to anyone except

as permitted under this Stipulated Protective Order; and

(i) to any mediator or settlement officer, and their supporting

personnel, mutually agreed upon by any of the parties engaged in

settlement discussions.

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

23 If a Party is served with a subpoena or a court order issued in

24 other litigation that compels disclosure of any information or items

25 designated in this Action as “CONFIDENTIAL,” that Party must:

26 (a) promptly notify in writing the Designating Party. Such

notification shall include a copy of the subpoena or court order;

1 (b) promptly notify in writing the party who caused the

2 subpoena or order to issue in the other litigation that some or all of the

3 material covered by the subpoena or order is subject to this Protective

4 Order. Such notification shall include a copy of this Stipulated

5 Protective Order; and

6 (c) cooperate with respect to all reasonable procedures sought to

7 be pursued by the Designating Party whose Protected Material may be

affected.

If the Designating Party timely seeks a protective order, the

Party served with the subpoena or court order shall not produce any

information designated in this action as “CONFIDENTIAL” before a

determination by the court from which the subpoena or order issued,

unless the Party has obtained the Designating Party’s permission. The

Designating Party shall bear the burden and expense of seeking

protection in that court of its confidential material and nothing in these

provisions should be construed as authorizing or encouraging a

Receiving Party in this Action to disobey a lawful directive from another

court.

21 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

22 PRODUCED IN THIS LITIGATION

23 9.1 Application. The terms of this Stipulated Protective Order

24 are applicable to information produced by a Non-Party in this Action and

25 designated as “CONFIDENTIAL.” Such information produced by Non-

26 Parties in connection with this litigation is protected by the remedies

27 and relief provided by this Order. Nothing in these provisions should be

1 protections.

2 9.2 Notification. In the event that a Party is required, by a valid

3 discovery request, to produce a Non-Party’s confidential information in

4 its possession, and the Party is subject to an agreement with the Non-

5 Party not to produce the Non-Party’s confidential information, then the

6 Party shall:

7 (a) promptly notify in writing the Requesting Party and the

Non-Party that some or all of the information requested is subject to a

confidentiality agreement with a Non-Party;

(b) make the information requested available for inspection by

the Non-Party, if requested.

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

protective order from this court within 14 days of receiving the notice

and accompanying information, the Receiving Party may produce the

Non-Party’s confidential information responsive to the discovery request.

If the Non-Party timely seeks a protective order, the Receiving Party

shall not produce any information in its possession or control that is

subject to the confidentiality agreement with the Non-Party before a

determination by the court. Absent a court order to the contrary, the

Non-Party shall bear the burden and expense of seeking protection in

22 this court of its Protected Material.

24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED

25 MATERIAL

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

has disclosed Protected Material to any person or in any circumstance

1 not authorized under this Stipulated Protective Order, the Receiving

2 Party must immediately (a) notify in writing the Designating Party of

3 the unauthorized disclosures, (b) use its best efforts to retrieve all

4 unauthorized copies of the Protected Material, (c) inform the person or

5 persons to whom unauthorized disclosures were made of all the terms of

6 this Order, and (d) request such person or persons to execute the

7 “Acknowledgment and Agreement to Be Bound” (Exhibit A).

11. INADVERTENT PRODUCTION OF PRIVILEGED OR

OTHERWISE PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that

certain inadvertently produced material is subject to a claim of privilege

14 or other protection, the obligations of the Receiving Parties are those set

15 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This

16 provision is not intended to modify whatever procedure may be

17 established in an e-discovery order that provides for production without

18 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal

19 Rules of Evidence, insofar as the parties reach an agreement on the

20 effect of disclosure of a communication or information covered by the

21 attorney-client privilege or work product protection, the parties may

22 incorporate their agreement in the stipulated protective order

submitted to the court.

1 12. MISCELLANEOUS

2 12.1 Right to Further Relief. Nothing in this Stipulated

3 Protective Order abridges the right of any person to seek its

modification by the court in the future.

12.2 Right to Assert Other Objections. By stipulating to the entry

of this Stipulated Protective Order no Party waives any right it

otherwise would have to object to disclosing or producing any

information or item on any ground not addressed in this Stipulated

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

ground to use in evidence of any of the material covered by this

Stipulated Protective Order.

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

seal any Protected Material must comply with Local Rule 79-5.

Protected Material may only be filed under seal pursuant to a court

order authorizing the sealing of the specific Protected Material at issue.

If a Party's request to file Protected Material under seal is denied by the

18 court, then the Receiving Party may file the information in the public

19 record unless otherwise instructed by the court.

21 13. FINAL DISPOSITION

22 After the Final Disposition of this Action, as defined in paragraph

4, within 60 days of a written request by the Designating Party, each

Receiving Party must return all Protected Material to the Producing

Party or destroy such material. As used in this subdivision, “all

Protected Material” includes all copies, abstracts, compilations,

summaries, and any other format reproducing or capturing any of the

1 Protected Material. Whether the Protected Material is returned or

2 destroyed, the Receiving Party must submit a written certification to

3 the Producing Party (and, if not the same person or entity, to the

4 Designating Party) by the 60 day deadline that (1) identifies (by

5 category, where appropriate) all the Protected Material that was

6 returned or destroyed and (2) affirms that the Receiving Party has not

7 retained any copies, abstracts, compilations, summaries or any other

format reproducing or capturing any of the Protected Material.

Notwithstanding this provision, Counsel is entitled to retain an archival

copy of all pleadings, motion papers, trial, deposition, and hearing

transcripts, legal memoranda, correspondence, deposition and trial

exhibits, expert reports, attorney work product, and consultant and

expert work product, even if such materials contain Protected Material.

Any such archival copies that contain or constitute Protected Material

remain subject to this Protective Order as set forth in Section 4.

///

18 ///

///

23 ///

24 ///

///

1 || 14. VIOLATION

2 Any violation of this Stipulated Protective Order may be punished

3 || by any and all appropriate measures including, without limitation,

4 || contempt proceedings and/or monetary sanctions.

6 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

8 || Dated: June 29, 2026 HYDEE FELDSTEIN SOTO, City Attorney

9 DENISE C. MILLS, Chief Deputy City Attorney

KATHLEEN KENEALY, Chief Assistant City Atty

10 CHRISTIAN R. BOJORQUEZ, Deputy City Atty.

3 CHRISTINA ISAGHOLIAN, Deputy City At

Attorneys for Defendants, CITY OF LOS ANGELES, JUAN

14 GONZALEZ and CHRISTOPHER MENCHACA

6 Dated: June 29, 2026 LAW OFFICE OF GREGORY PEACOCK

By: s/ Gregory Peacock

18 Gregory Peacock, Lawyer for Plaintiff

|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: June 30, 2026 Zz

STEPHANIE 8. CHRISTENSEN

24 United States Magistrate Judge

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ________________________ [print or type full name], of

_________________ [print or type full address], declare under

penalty of perjury that I have read in its entirety and understand the

Stipulated Protective Order that was issued by the United States

District Court for the Central District of California on [date] in the

case of __________ [insert formal name of the case and the

number and initials assigned to it by the court]. I agree to

comply with and to be bound by all the terms of this Stipulated

Protective Order and I understand and acknowledge that failure to so

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

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

15 any information or item that is subject to this Stipulated Protective

16 Order to any person or entity except in strict compliance with the

17 provisions of this Order.

18 I further agree to submit to the jurisdiction of the United States

19 District Court for the Central District of California for the purpose of

20 enforcing the terms of this Stipulated Protective Order, even if such

21 enforcement proceedings occur after termination of this action. I

22 hereby appoint ________________________ [print or type full name]

of _________ [print or type full address and telephone number] as

1 my California agent for service of process in connection with this action

2 or any proceedings related to enforcement of this Stipulated Protective

3 Order.

5 Date: ___________________________

6 City and State where sworn and

7 signed: ___________________________

Printed name: ___________________________

Signature: ___________________________

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.