The opinion
1 MITCHELL SILBERBERG & KNUPP LLP
BRADLEY J. MULLINS (SBN 274219)
2 bym@msk.com
GABRIELLA N. ISMAJ (SBN 301594)
3 gan@msk.com
2049 Century Park East, 18th Floor
4 Los Angeles, CA 90067-3120
Telephone: (310) 312-2000
5 Facsimile: (310) 312-3100
6 Attorneys for Defendant and
Counter-Claimant Guns N’ Roses
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 ALAN G. NIVEN, an individual, CASE NO. 2:26-cv-06571-SB-DSR
12 Plaintiff, Judge Stanley Blumenfeld, Jr.
13 v. [PROPOSED] STIPULATED
PROTECTIVE ORDER
14 GUNS N’ ROSES, a California
partnership, and DOES 1-10, inclusive, [Discovery Document submitted to
15 Hon. Daniel S. Roberts]
Defendant.
16 File Date: 11/04/25
Trial Date: Not set
17 GUNS N’ ROSES, a California
partnership, NOTE MODIFICATIONS BY THE
18 COURT SHOWN IN RED TYPE IN
Counter-Claimant, PARTS 2 AND 4
19
v.
20
ALAN G. NIVEN, an individual,
21
Counterclaim-Defendant.
22
23
24
25
26
27
28
1 1. GENERAL
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 production of confidential, proprietary, or private information for which special
4 protection from public disclosure and from use for any purpose other than
5 prosecuting this litigation may be warranted. Accordingly, the parties hereby
6 stipulate to and petition the Court to enter the following Stipulated Protective
7 Order. The parties acknowledge that this Order does not confer blanket protections
8 on all disclosures or responses to discovery and that the protection it affords from
9 public disclosure and use extends only to the limited information or items that are
10 entitled to confidential treatment under the applicable legal principles. The parties
11 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
12 Protective Order does not entitle them to file confidential information under seal;
13 Civil Local Rule 79-5 sets forth the procedures that must be followed and the
14 standards that will be applied when a party seeks permission from the court to file
15 material under seal.
16 1.2 Good Cause Statement. This action is likely to involve trade secrets
17 and other valuable research, personal information, development, commercial,
18 financial, technical and/or proprietary information for which special protection
19 from public disclosure and from use for any purpose other than prosecution of this
20 action is warranted. Such confidential and proprietary materials and information
21 consist of, among other things, confidential personal, business or financial
22 information, information regarding confidential business practices, or other
23 confidential research, development, or commercial information (including
24 information implicating privacy rights of third parties), information otherwise
25 generally unavailable to the public, or which may be privileged or otherwise
26 protected from disclosure under state or federal statutes, court rules, case decisions,
27 or common law. Accordingly, to expedite the flow of information, to facilitate the
28 prompt resolution of disputes over confidentiality of discovery materials, to
1 adequately protect information the parties are entitled to keep confidential, to
2 ensure that the parties are permitted reasonable necessary uses of such material in
3 preparation for and in the conduct of trial, to address their handling at the end of
4 the litigation, and serve the ends of justice, a protective order for such information
5 is justified in this matter. It is the intent of the parties that information will not be
6 designated as confidential for tactical reasons and that nothing be so designated
7 without a good faith belief that it has been maintained in a confidential, non-public
8 manner, and there is good cause why it should not be part of the public record of
9 this case.
10 2. DEFINITIONS
11 2.1 Action: the instant action, Alan G. Niven v. Guns N’ Roses, C.D. Cal.
12 Case No. 2:26-cv-06571-SB-DSR.
13 2.2 Challenging Party: a Party or Non-Party that challenges the
14 designation of information or items under this Order.
15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
16 how it is generated, stored or maintained) or tangible things that qualify for
17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
18 the Good Cause Statement.
19 2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
20 Information or Items: extremely sensitive “CONFIDENTIAL” Information or
21 Items, the disclosure of which to another Party or Non-Party would create a
22 substantial risk of serious harm that could not be avoided by less restrictive means.
23 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as
24 their support staff).
25 2.6 Designating Party: a Party or Non-Party that designates information
26 or items that it produces in disclosures or in responses to discovery as
27 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
28 ONLY.”
1 2.7 Disclosure or Discovery Material: all items or information, regardless
2 of the medium or manner in which it is generated, stored, or maintained (including,
3 among other things, testimony, transcripts, and tangible things), that are produced
4 or generated in disclosures or responses to discovery in this matter.
5 2.8 Expert: a person with specialized knowledge or experience in a
6 matter pertinent to the litigation who has been retained by a Party or its counsel to
7 serve as an expert witness or as a consultant in this Action.
8 2.9 House Counsel: attorneys who are employees of a party to this
9 Action. House Counsel does not include Outside Counsel of Record or any other
10 outside counsel.
11 2.10 Non-Party: any natural person, partnership, corporation, association,
12 or other legal entity not named as a Party to this action.
13 2.11 Outside Counsel of Record: attorneys who are not employees of a
14 party to this Action but are retained to represent or advise a party to this Action
15 and have appeared in this Action on behalf of that party or are affiliated with a law
16 firm that has appeared on behalf of that party, including support staff.
17 2.12 Party: any party to this Action, including all of its officers, directors,
18 employees, consultants, retained experts, and Outside Counsel of Record (and their
19 support staffs).
20 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
21 Discovery Material in this Action.
22 2.14 Professional Vendors: persons or entities that provide litigation
23 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
24 demonstrations, and organizing, storing, or retrieving data in any form or medium)
25 and their employees and subcontractors.
26 2.15 Protected Material: any Disclosure or Discovery Material that is
27 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
28 ATTORNEYS’ EYES ONLY.”
1 2.16 Receiving Party: a Party that receives Disclosure or Discovery
2 Material from a Producing Party.
3 3. SCOPE
4 The protections conferred by this Stipulation and Order cover not only
5 Protected Material (as defined above), but also (1) any information copied or
6 extracted from Protected Material; (2) all copies, excerpts, summaries, or
7 compilations of Protected Material; and (3) any testimony, conversations, or
8 presentations by Parties or their Counsel that might reveal Protected Material.
9 Any use of Protected Material at trial shall be governed by the orders of the
10 trial judge. This Order does not govern the use of Protected Material at trial.
11 4. DURATION
12 Even after final disposition of this litigation, the confidentiality obligations
13 imposed by this Order will remain in effect until a Designating Party agrees
14 otherwise in writing or a court order otherwise directs. Final disposition shall be
15 deemed to be the later of (1) dismissal of all claims and defenses in this Action,
16 with or without prejudice; and (2) final judgment herein after the completion and
17 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
18 including the time limits for filing any motions or applications for extension of
19 time pursuant to applicable law.
20 Notwithstanding the immediately preceding paragraph, once a case proceeds
21 to trial, all of the court-filed information to be introduced that was previously
22 designated as confidential or maintained pursuant to this protective order becomes
23 public and will be presumptively available to all members of the public, including
24 the press, unless compelling reasons supported by specific factual findings to
25 proceed otherwise are made to the trial judge in advance of the trial. See
26 Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006)
27 (distinguishing “good cause” showing for sealing documents produced in
28 discovery from “compelling reasons” standard when merits-related documents are
1 part of court record). Accordingly, the terms of this protective order do not extend
2 beyond the commencement of the trial.
3 5. DESIGNATING PROTECTED MATERIAL
4 5.1 Exercise of Restraint and Care in Designating Material for Protection.
5 Each Party or Non-Party that designates information or items for protection under
6 this Order must take care to limit any such designation to specific material that
7 qualifies under the appropriate standards. The Designating Party must designate
8 for protection only those parts of material, documents, items, or oral or written
9 communications that qualify so that other portions of the material, documents,
10 items, or communications for which protection is not warranted are not swept
11 unjustifiably within the ambit of this Order.
12 Mass, indiscriminate, or routinized designations are prohibited.
13 Designations that are shown to be clearly unjustified or that have been made for an
14 improper purpose (e.g., to unnecessarily encumber the case development process
15 or to impose unnecessary expenses and burdens on other parties) may expose the
16 Designating Party to sanctions.
17 If it comes to a Designating Party’s attention that information or items that it
18 designated for protection do not qualify for protection, that Designating Party must
19 promptly notify all other Parties that it is withdrawing the inapplicable designation.
20 5.2 Manner and Timing of Designations. Except as otherwise provided in
21 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
22 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
23 under this Order must be clearly so designated before the material is disclosed or
24 produced.
25 Designation in conformity with this Order requires:
26 (a) for information in documentary form (e.g., paper or electronic
27 documents, but excluding transcripts of depositions or other pretrial or trial
28 proceedings), that the Producing Party affix, at a minimum, the legend
1 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
2 ONLY” to each page that contains protected material. If the information is
3 contained in a file format that does not reasonably allow for the affixing of such
4 legend, then the Producing Party may designate for the protection the information
5 within such file by stating such designation via the transmittal e-mail or letter, or
6 by producing a slip sheet in its production which identifies the bates number of the
7 file in question and the confidentiality designation for that file. If only a portion or
8 portions of the material on a page qualifies for protection, the Producing Party also
9 must clearly identify the protected portion(s) (e.g., by making appropriate
10 markings in the margins).
11 A Party or Non-Party that makes original documents available for
12 inspection need not designate them for protection until after the inspecting Party
13 has indicated which documents it would like copied and produced. During the
14 inspection and before the designation, all of the material made available for
15 inspection shall be deemed “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
16 ONLY.” After the inspecting Party has identified the documents it wants copied
17 and produced, the Producing Party must determine which documents, or portions
18 thereof, qualify for protection under this Order. Then, before producing the
19 specified documents, the Producing Party must affix the “CONFIDENTIAL”
20 legend or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” legend to
21 each page that contains Protected Material. If only a portion or portions of the
22 material on a page qualifies for protection, the Producing Party also must clearly
23 identify the protected portion(s) (e.g., by making appropriate markings in the
24 margins).
25 (b) for testimony given in depositions that the Designating Party identify
26 the Disclosure or Discovery Material on the record, before the close of the
27 deposition. In the event that the parties fail to designate testimony as
28 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
1 ONLY” prior to the close of the deposition, the deposition transcript shall be
2 presumptively deemed “CONFIDENTIAL” for twenty-one (21) days after the
3 receipt of the official transcript. If neither Party designates the deposition (or
4 portions thereof) as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
5 ATTORNEYS’ EYES ONLY” during the twenty-one (21) day period, the
6 deposition will be deemed not to be confidential.
7 (c) for information produced in some form other than documentary and
8 for any other tangible items, that the Producing Party affix in a prominent place on
9 the exterior of the container or containers in which the information is stored the
10 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
11 EYES ONLY.” If only a portion or portions of the information warrants
12 protection, the Producing Party, to the extent practicable, shall identify the
13 protected portion(s).
14 5.3 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
17 material. Upon timely correction of a designation, the Receiving Party must make
18 reasonable efforts to assure that the material is treated in accordance with the
19 provisions of this Order.
20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
21 6.1 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 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
25 resolution process under Local Rule 37-1, et seq. Any discovery motion must
26 strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
27 6.3 Burden. The burden of persuasion in any such challenge proceeding
28 shall be on the Designating Party. Frivolous challenges, and those made for an
1 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
2 other parties) may expose the Challenging Party to sanctions. Unless the
3 Designating Party has waived or withdrawn the confidentiality designation, all
4 parties shall continue to afford the material in question the level of protection to
5 which it is entitled under the Producing Party’s designation until the Court rules on
6 the challenge.
7 7. ACCESS TO AND USE OF PROTECTED MATERIAL
8 7.1 Basic Principles. A Receiving Party may use Protected Material that
9 is disclosed or produced by another Party or by a Non-Party in connection with this
10 Action only for prosecuting, defending, or attempting to settle this Action. Such
11 Protected Material may be disclosed only to the categories of persons and under
12 the conditions described in this Order. When the Action has been terminated, a
13 Receiving Party must comply with the provisions of section 13 below (FINAL
14 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 7.2 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
28
1 (c) Experts (as defined in this Order) of the Receiving Party to whom
2 disclosure is reasonably necessary for this Action and who have signed the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (d) the Court and its personnel;
5 (e) court reporters and their staff;
6 (f) professional jury or trial consultants, mock jurors, and Professional
7 Vendors to whom disclosure is reasonably necessary for this Action and who have
8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (g) the author or recipient of a document containing the information or a
10 custodian or other person who otherwise possessed or knew the information;
11 (h) during their depositions, witnesses, and attorneys for witnesses, in the
12 Action to whom disclosure is reasonably necessary provided: (1) the deposing
13 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
14 they will not be permitted to keep any confidential information, 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
17 be separately bound by the court reporter and may not be disclosed to anyone
18 except as permitted under this Stipulated Protective Order; and
19 (i) any mediator or settlement officer, and their supporting personnel,
20 mutually agreed upon by any of the parties engaged in settlement discussions.
21 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
22 ONLY” Information or Items. Unless otherwise ordered by the Court or permitted
23 in writing by the Designating Party, any information or item designated as
24 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” may only be
25 disclosed to the people listed above in paragraphs 7.2(a), (c)-(g), (i).
26 Nothing in this Order shall preclude any Parties or their attorneys from
27 disclosing or using any material or documents from that Party’s own files which
28 the Party itself has designated as Protected Material; however, neither Party shall
1 be permitted to disclose material or documents that both Parties have designated as
2 Protected Material. No information that is in the public domain shall be subject to
3 this Order.
4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
5 PRODUCED IN OTHER LITIGATION
6 If a Party is served with a subpoena or a court order issued in other litigation
7 that compels disclosure of any information or items designated in this Action as
8 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
9 ONLY,” that Party must:
10 (a) promptly notify in writing the Designating Party. Such notification
11 shall include a copy of the subpoena or court order;
12 (b) promptly notify in writing the party who caused the subpoena or order
13 to issue in the other litigation that some or all of the material covered by the
14 subpoena or order is subject to this Protective Order. Such notification shall
15 include a copy of this Stipulated Protective Order; and
16 (c) cooperate with respect to all reasonable procedures sought to be
17 pursued by the Designating Party whose Protected Material may be affected.
18 If the Designating Party timely seeks a protective order, the Party served
19 with the subpoena or court order shall not produce any information designated in
20 this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
21 ATTORNEYS’ EYES ONLY” before a determination by the court from which the
22 subpoena or order issued, unless the Party has obtained the Designating Party’s
23 permission. The Designating Party shall bear the burden and expense of seeking
24 protection in that court of its confidential material and nothing in these provisions
25 should be construed as authorizing or encouraging a Receiving Party in this Action
26 to disobey a lawful directive from another court.
27
28
1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by a
4 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
5 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced
6 by Non-Parties in connection with this litigation is protected by the remedies and
7 relief provided by this Order. Nothing in these provisions should be construed as
8 prohibiting a Non-Party from seeking additional protections.
9 (b) In the event that a Party is required, by a valid discovery request, to
10 produce a Non-Party’s confidential information in its possession, and the Party is
11 subject to an agreement with the Non-Party not to produce the Non-Party’s
12 confidential information, then the Party shall:
13 (1) promptly notify in writing the Requesting Party and the Non-
14 Party that some or all of the information requested is subject to a confidentiality
15 agreement with a Non-Party;
16 (2) promptly provide the Non-Party with a copy of the Stipulated
17 Protective Order in this Action, the relevant discovery request(s), and a reasonably
18 specific description of the information requested; and
19 (3) make the information requested available for inspection by the
20 Non-Party, if requested.
21 (c) If the Non-Party fails to seek a protective order from this Court within
22 14 days of receiving the notice and accompanying information, the Receiving
23 Party may produce the Non-Party’s confidential information responsive to the
24 discovery request. If the Non-Party timely seeks a protective order, the Receiving
25 Party shall not produce any information in its possession or control that is subject
26 to the confidentiality agreement with the Non-Party before a determination by the
27 Court. Absent a court order to the contrary, the Non-Party shall bear the burden
28 and expense of seeking protection in this Court of its Protected Material.
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has
3 disclosed Protected Material to any person or in any circumstance not authorized
4 under this Stipulated Protective Order, the Receiving Party must immediately (a)
5 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
6 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
7 the person or persons to whom unauthorized disclosures were made of all the terms
8 of this Order, and (d) request such person or persons to execute the
9 “Acknowledgment and Agreement to Be Bound” attached hereto as Exhibit A.
10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
11 OTHERWISE PROTECTED MATERIAL
12 When a Producing Party gives notice to Receiving Parties that certain
13 inadvertently produced material is subject to a claim of privilege or other
14 protection, the obligations of the Receiving Parties are those set forth in Federal
15 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
16 whatever procedure may be established in an e-discovery order that provides for
17 production without prior privilege review. Pursuant to Federal Rule of Evidence
18 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
19 of a communication or information covered by the attorney-client privilege or
20 work product protection, the parties may incorporate their agreement in the
21 stipulated protective order submitted to the Court.
22 12. MISCELLANEOUS
23 12.1 Right to Further Relief. Nothing in this Order abridges the right of
24 any person to seek its modification by the Court in the future.
25 12.2 Right to Assert Other Objections. By stipulating to the entry of this
26 Protective Order, no Party waives any right it otherwise would have to object to
27 disclosing or producing any information or item on any ground not addressed in
28 this Stipulated Protective Order. Similarly, no Party waives any right to object on
1 any ground to use in evidence of any of the material covered by this Protective
2 Order.
3 12.3 Filing Protected Material. A Party that seeks to file under seal any
4 Protected Material must comply with Civil Local Rule 79-5. Protected Material
5 may only be filed under seal pursuant to a court order authorizing the sealing of the
6 specific Protected Material at issue; good cause must be shown in the request to
7 file under seal. If a Party’s request to file Protected Material under seal is denied
8 by the Court, then the Receiving Party may file the information in the public record
9 unless otherwise instructed by the Court.
10 13. FINAL DISPOSITION
11 After the final disposition of this Action, as defined in paragraph 4, within
12 60 days of a written request by the Designating Party, each Receiving Party must
13 return all Protected Material to the Producing Party or destroy such material. As
14 used in this subdivision, “all Protected Material” includes all copies, abstracts,
15 compilations, summaries, and any other format reproducing or capturing any of the
16 Protected Material. Whether the Protected Material is returned or destroyed, the
17 Receiving Party must submit a written certification to the Producing Party (and, if
18 not the same person or entity, to the Designating Party) by the 60 day deadline that
19 (1) identifies (by category, where appropriate) all the Protected Material that was
20 returned or destroyed, and (2) affirms that the Receiving Party has not retained any
21 copies, abstracts, compilations, summaries or any other format reproducing or
22 capturing any of the Protected Material. Notwithstanding this provision, counsel
23 are entitled to retain an archival copy of all pleadings, motion papers, trial,
24 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
25 and trial exhibits, expert reports, attorney work product, and consultant and expert
26 work product, even if such materials contain Protected Material. Any such
27 archival copies that contain or constitute Protected Material remain subject to this
28 Protective Order as set forth in Section 4 (DURATION).
1|14. VIOLATION OF ORDER
2 Any violation of this Order may be punished by any and all appropriate
3 | measures including, without limitation, contempt proceedings and/or monetary
4 | sanctions.
5 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6 | DATED: JULY 24, 2026 A. ERIC BJORGUN
BJORGUM LAW, PC
7
8
By: /s/ A. Eric Bjorgum
9 A. Eric Bjorgum
10 Attorneys for Plaintiff Alan G. Niven
11
DATED: JULY 24, 2026 BRADLEY J. MULLINS
12 GABRIELLA N. ISMAJ
B MITCHELL SILBERBERG & KNUPP LLP
14
15 By:_/s/ Gabriella N. Ismaj
Bradley J. Mullins
16 Gabriella N. Iemaj
Attorneys for Defendant and
17 Counter-Claimant Guns N’ Roses
Attestation Regarding Signatures: I, Gabriella N. Ismay, attest that all signatories
19 | listed, and on whose behalf the filing is submitted, concur in the filing’s content
20 and have authorized the filing.
DATED: July 24, 2026
22
By: /s/ Gabriella N. Ismaj
23 Gabriella N. Ismay
24
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
25
26
DATED: July 27, 2026
27 hn. Daniel 8. Koberts
United States Magistrate Judge
2
berberg &
LLP 1 5
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [full name], of _________________
5 [full address], declare under penalty of perjury that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States
7 District Court for the Central District of California on ____________ [date] in the
8 case of Alan G. Niven v. Guns N’ Roses, C.D. Cal. Case No. 2:26-cv-06571-SB-
9 DSR. I agree to comply with and to be bound by all the terms of this Stipulated
10 Protective Order and I understand and acknowledge that failure to so comply could
11 expose me to sanctions and punishment in the nature of contempt. I solemnly
12 promise that I will not disclose in any manner any information or item that is
13 subject to this Stipulated Protective Order to any person or entity except in strict
14 compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District
16 Court for the Central District of California for the purpose of enforcing the terms
17 of this Stipulated Protective Order, even if such enforcement proceedings occur
18 after termination of this action. I hereby appoint __________________________
19 [full name] of _______________________________________ [full address and
20 telephone number] as my California agent for service of process in connection
21 with this action or any proceedings related to enforcement of this Stipulated
22 Protective Order.
23 Date: ______________________________________
24 City and State where signed: _________________________________
25
26 Printed name: _______________________________
27
28 Signature: __________________________________