even stipulated protective 14 order require good cause showing
How later courts described this case
- even stipulated protective 14 order require good cause showing
Written by the judges who cited it.
The opinion
1 JOHN T. RICHARDS, ESQ. (SBN 159875)
John@jtrlaw1.com
2 EVAN WILLIS, ESQ. (SBN 314797)
evan@jtrlaw1.com
3 RICHARDS LAW FIRM, APLC
101 West Broadway, Suite 1950
4 San Diego, California 92101
Telephone: (619) 237-9800
5 Facsimile: (619) 238-9914
Attorneys for Plaintiff
6 LAMONTE GOODE
7 CRAIG J. MARIAM (SBN: 225280)
cmariam@grsm.com
8 HAZEL MAE B. PANGAN (SBN: 272657)
hpangan@grsm.com
9 GORDON REES SCULLY MANSUKHANI, LLP
633 West Fifth Street, 52nd floor
10 Los Angeles, CA 90071
Telephone: (213) 576-5000
11 Facsimile: (877) 306-0043
12 Attorneys for Defendant
DOLLAR TREE STORES, INC.
13
14 UNITED STATES DISTRICT COURT
15 CENTRAL DISTRICT OF CALIFORNIA
16 LAMONTE GOODE, an individual, ) CASE NO. 2:19-cv-2839 PA
) (RAOx)
17 Plaintiff, )
) Judge: Hon. Percy Anderson
18 vs. )
) Magistrate Judge: Hon. Rozella A.
19 DOLLAR TREE STORES, INC. and Oliver
)
DOES 1 through 20, inclusive,
20 )
)
Defendants. AMENDED STIPULATED
21 ) PROTECTIVE ORDER;
) [PROPOSED] ORDER
22 )
)
23
24 1. A. PURPOSES AND LIMITATIONS
25 Discovery in this action is likely to involve production of confidential,
26 proprietary, or private information for which special protection from public
27 disclosure and from use for any purpose other than prosecuting this litigation may
28 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
1 enter the following Stipulated Protective Order. The parties acknowledge that this
2 Order does not confer blanket protections on all disclosures or responses to
3 discovery and that the protection it affords from public disclosure and use extends
4 only to the limited information or items that are entitled to confidential treatment
5 under the applicable legal principles.
6 B. GOOD CAUSE STATEMENT
7 This action is likely to involve trade secrets, financial statements and pricing
8 lists and other valuable research, development, commercial, financial, technical
9 and/or proprietary information for which special protection from public disclosure
10 and from use for any purpose other than prosecution of this action is warranted.
11 Such confidential and proprietary materials and information consist of, among
12 other things, confidential business or financial information, information regarding
13 confidential business practices, or other confidential research, development, or
14 commercial information (including information implicating privacy rights of third
15 parties), information otherwise generally unavailable to the public, or which may
16 be privileged or otherwise protected from disclosure under state or federal statutes,
17 court rules, case decisions, or common law.
18 Accordingly, to expedite the flow of information, to facilitate the prompt
19 resolution of disputes over confidentiality of discovery materials, to adequately
20 protect information the parties are entitled to keep confidential, to ensure that the
21 parties are permitted reasonable necessary uses of such material in preparation for
22 and in the conduct of trial, to address their handling at the end of the litigation, and
23 serve the ends of justice, a protective order for such information is justified in this
24 matter. It is the intent of the parties that information will not be designated as
25 confidential for tactical reasons and that nothing be so designated without a good
26 faith belief that it has been maintained in a confidential, non-public manner, and
27 there is good cause why it should not be part of the public record of this case.
28 ///
1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING
2 UNDER SEAL
3 The parties further acknowledge, as set forth in Section 12.4, below, that this
4 Stipulated Protective Order does not entitle them to file confidential information
5 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed
6 and the standards that will be applied when a party seeks permission from the court
7 to file material under seal.
8 There is a strong presumption that the public has a right of access to judicial
9 proceedings and records in civil cases. In connection with non-dispositive motions,
10 good cause must be shown to support a filing under seal. See Kamakana v. City
11 and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.
12 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony
13 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective
14 order require good cause showing), and a specific showing of good cause or
15 compelling reasons with proper evidentiary support and legal justification, must be
16 made with respect to Protected Material that a party seeks to file under seal. The
17 parties’ mere designation of Disclosure or Discovery Material as
18 CONFIDENTIAL does not—without the submission of competent evidence by
19 declaration, establishing that the material sought to be filed under seal qualifies as
20 confidential, privileged, or otherwise protectable—constitute good cause.
21 Further, if a party requests sealing related to a dispositive motion or trial,
22 then compelling reasons, not only good cause, for the sealing must be shown, and
23 the relief sought shall be narrowly tailored to serve the specific interest to be
24 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.
25 2010). For each item or type of information, document, or thing sought to be filed
26 or introduced under seal in connection with a dispositive motion or trial, the party
27 seeking protection must articulate compelling reasons, supported by specific facts
28 and legal justification, for the requested sealing order. Again, competent evidence
1 supporting the application to file documents under seal must be provided by
2 declaration. Any document that is not confidential, privileged, or otherwise
3 protectable in its entirety will not be filed under seal if the confidential portions
4 can be redacted. If documents can be redacted, then a redacted version for public
5 viewing, omitting only the confidential, privileged, or otherwise protectable
6 portions of the document, shall be filed. Any application that seeks to file
7 documents under seal in their entirety should include an explanation of why
8 redaction is not feasible.
9 2. DEFINITIONS
10 2.1 Action: this pending federal law suit.
11 2.2 Challenging Party: a Party or Non-Party that challenges the
12 designation of information or items under this Order.
13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
14 how it is generated, stored or maintained) or tangible things that qualify for
15 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
16 the Good Cause Statement.
17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
18 their support staff).
19 2.5 Designating Party: a Party or Non-Party that designates information
20 or items that it produces in disclosures or in responses to discovery as
21 “CONFIDENTIAL.”
22 2.6 Disclosure or Discovery Material: all items or information, regardless
23 of the medium or manner in which it is generated, stored, or maintained (including,
24 among other things, testimony, transcripts, and tangible things), that are produced
25 or generated in disclosures or responses to discovery in this matter.
26 2.7 Expert: a person with specialized knowledge or experience in a
27 matter pertinent to the litigation who has been retained by a Party or its counsel to
28 serve as an expert witness or as a consultant in this Action.
1 2.8 House Counsel: attorneys who are employees of a party to this
2 Action. House Counsel does not include Outside Counsel of Record or any other
3 outside counsel.
4 2.9 Non-Party: any natural person, partnership, corporation, association,
5 or other legal entity not named as a Party to this action.
6 2.10 Outside Counsel of Record: attorneys who are not employees of a
7 party to this Action but are retained to represent or advise a party to this Action
8 and have appeared in this Action on behalf of that party or are affiliated with a law
9 firm which has appeared on behalf of that party, and includes support staff.
10 2.11 Party: any party to this Action, including all of its officers, directors,
11 employees, consultants, retained experts, and Outside Counsel of Record (and their
12 support staffs).
13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
14 Discovery Material in this Action.
15 2.13 Professional Vendors: persons or entities that provide litigation
16 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
17 demonstrations, and organizing, storing, or retrieving data in any form or medium)
18 and their employees and subcontractors.
19 2.14 Protected Material: any Disclosure or Discovery Material that is
20 designated as “CONFIDENTIAL.”
21 2.15 Receiving Party: a Party that receives Disclosure or Discovery
22 Material from a Producing Party.
23 3. SCOPE
24 The protections conferred by this Stipulation and Order cover not only
25 Protected Material (as defined above), but also (1) any information copied or
26 extracted from Protected Material; (2) all copies, excerpts, summaries, or
27 compilations of Protected Material; and (3) any testimony, conversations, or
28 presentations by Parties or their Counsel that might reveal Protected Material.
1 4. DURATION
2 Even after final disposition of this litigation, the confidentiality obligations
3 imposed by this Order shall remain in effect until a Designating Party agrees
4 otherwise in writing or a court order otherwise directs. Final disposition shall be
5 deemed to be the later of (1) dismissal of all claims and defenses in this Action,
6 with or without prejudice; and (2) final judgment herein after the completion and
7 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
8 including the time limits for filing any motions or applications for extension of
9 time pursuant to applicable law.
10 5. DESIGNATING PROTECTED MATERIAL
11 5.1 Exercise of Restraint and Care in Designating Material for Protection.
12 Each Party or Non-Party that designates information or items for protection under
13 this Order must take care to limit any such designation to specific material that
14 qualifies under the appropriate standards. The Designating Party must designate
15 for protection only those parts of material, documents, items, or oral or written
16 communications that qualify so that other portions of the material, documents,
17 items, or communications for which protection is not warranted are not swept
18 unjustifiably within the ambit of this Order.
19 Mass, indiscriminate, or routinized designations are prohibited.
20 Designations that are shown to be clearly unjustified or that have been made for an
21 improper purpose (e.g., to unnecessarily encumber the case development process
22 or to impose unnecessary expenses and burdens on other parties) may expose the
23 Designating Party to sanctions.
24 If it comes to a Designating Party’s attention that information or items that it
25 designated for protection do not qualify for protection, that Designating Party must
26 promptly notify all other Parties that it is withdrawing the inapplicable designation.
27 5.2 Manner and Timing of Designations. Except as otherwise provided in
28 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
1 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
2 under this Order must be clearly so designated before the material is disclosed or
3 produced.
4 Designation in conformity with this Order requires:
5 (a) for information in documentary form (e.g., paper or electronic
6 documents, but excluding transcripts of depositions or other pretrial or trial
7 proceedings), that the Producing Party affix at a minimum, the legend
8 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
9 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
11 protected portion(s) (e.g., by making appropriate markings in the margins).
12 A Party or Non-Party that makes original documents available for inspection
13 need not designate them for protection until after the inspecting Party has indicated
14 which documents it would like copied and produced. During the inspection and
15 before the designation, all of the material made available for inspection shall be
16 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
17 documents it wants copied and produced, the Producing Party must determine
18 which documents, or portions thereof, qualify for protection under this Order.
19 Then, before producing the specified documents, the Producing Party must affix
20 the “CONFIDENTIAL legend” to each page that contains Protected Material. If
21 only a portion or portions of the material on a page qualifies for protection, the
22 Producing Party also must clearly identify the protected portion(s) (e.g., by making
23 appropriate markings in the margins).
24 A Party or Non-Party whose Protected Material is sought in discovery,
25 including through a subpoena issued in this action to a Non-Party, may designate
26 the subpoenaed party’s production and/or disclosure as “CONFIDENTIAL” for
27 materials and/or documents, or portions thereof, that qualify for protection under
28 this Order.
1 (b) for testimony given in depositions that the Designating Party
2 identify the Disclosure or Discovery Material on the record, before the close of the
3 deposition all protected testimony. Deposition testimony may be treated as
4 “CONFIDENTIAL” during the deposition, as the Designating Party may direct,
5 and the transcript of the designated testimony shall be transcribed on separate
6 pages and so marked by the reporter. A Designating Party also may so designate
7 portions of the deposition after the transcription is produced and shall have twenty
8 (20) days after receipt of such deposition transcript to advise the Receiving Party,
9 in writing, of the portions of the deposition transcript that are to be designated as
10 “CONFIDENTIAL” after which period the right to make such designations shall
11 be waived.
12 (c) for information produced in some form other than documentary
13 and for any other tangible items, that the Producing Party affix in a prominent
14 place on the exterior of the container or containers in which the information is
15 stored the legend “CONFIDENTIAL.” If only a portion or portions of the
16 information warrants protection, the Producing Party, to the extent practicable,
17 shall identify the protected portion(s).
18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
19 failure to designate qualified information or items does not, standing alone, waive
20 the Designating Party’s right to secure protection under this Order for such
21 material. Upon timely correction of a designation, the Receiving Party must make
22 reasonable efforts to assure that the material is treated in accordance with the
23 provisions of this Order.
24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
26 designation of confidentiality at any time that is consistent with the Court’s
27 Scheduling Order.
28 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
1 resolution process under Local Rule 37.1 et seq.
2 6.3 The burden of persuasion in any such challenge proceeding shall be
3 on the Designating Party. Frivolous challenges, and those made for an improper
4 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
5 parties) may expose the Challenging Party to sanctions. Unless the Designating
6 Party has waived or withdrawn the confidentiality designation, all parties shall
7 continue to afford the material in question the level of protection to which it is
8 entitled under the Producing Party’s designation until the Court rules on the
9 challenge.
10 7. ACCESS TO AND USE OF PROTECTED MATERIAL
11 7.1 Basic Principles. A Receiving Party may use Protected Material that
12 is disclosed or produced by another Party or by a Non-Party in connection with this
13 Action only for prosecuting, defending, or attempting to settle this Action. Such
14 Protected Material may be disclosed only to the categories of persons and under
15 the conditions described in this Order. When the Action has been terminated, a
16 Receiving Party must comply with the provisions of section 13 below (FINAL
17 DISPOSITION).
18 Protected Material must be stored and maintained by a Receiving Party at a
19 location and in a secure manner that ensures that access is limited to the persons
20 authorized under this Order.
21 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
22 otherwise ordered by the court or permitted in writing by the Designating Party, a
23 Receiving Party may disclose any information or item designated
24 “CONFIDENTIAL” only to:
25 (a) the Receiving Party’s Outside Counsel of Record in this Action,
26 as well as employees of said Outside Counsel of Record to whom it is reasonably
27 necessary to disclose the information for this Action
28 (b) the officers, directors, and employees (including House
1 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for
2 this Action.
3 (c) Experts (as defined in this Order) of the Receiving Party to
4 whom disclosure is reasonably necessary for this Action and who have signed the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit A)
6 (d) the court and its personnel;
7 (e) court reporters and their staff;
8 (f) professional jury or trial consultants, mock jurors, and
9 Professional Vendors to whom disclosure is reasonably necessary for this Action
10 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
11 A);
12 (g) the author or recipient of a document containing the information or
13 a custodian or other person who otherwise possessed or knew the information;
14 (h) during their depositions, witnesses, and attorneys for witnesses, in
15 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
16 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2)
17 they will not be permitted to keep any confidential information unless they sign the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
19 agreed by the Designating Party or ordered by the court. Pages of transcribed
20 deposition testimony or exhibits to depositions that reveal Protected Material may
21 be separately bound by the court reporter and may not be disclosed to anyone
22 except as permitted under this Stipulated Protective Order; and
23 (i) any mediator or settlement officer, and their supporting personnel,
24 mutually agreed upon by any of the parties engaged in settlement discussions.
25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
26 PRODUCED IN OTHER LITIGATION
27 8.1 If a Party is served with a subpoena or a court order issued in other
28 litigation that compels disclosure of any information or items designated in this
1 Action as “CONFIDENTIAL,” that Party must:
2 (a) promptly notify in writing the Designating Party. Such
3 notification shall include a copy of the subpoena or court order;
4 (b) promptly notify in writing the party who caused the subpoena or
5 order to issue in the other litigation that some or all of the material covered by the
6 subpoena or order is subject to this Protective Order. Such notification shall
7 include a copy of this Stipulated Protective Order; and
8 (c) cooperate with respect to all reasonable procedures sought to be
9 pursued by the Designating Party whose Protected Material may be affected.
10 8.2 If the Designating Party timely seeks a protective order, the Party
11 served with the subpoena or court order shall not produce any information
12 designated in this action as “CONFIDENTIAL” before a determination by the
13 court from which the subpoena or order issued, unless the Party has obtained the
14 Designating Party’s permission. The Designating Party shall bear the burden and
15 expense of seeking protection in that court of its confidential material and nothing
16 in these provisions should be construed as authorizing or encouraging a Receiving
17 Party in this Action to disobey a lawful directive from another court.
18 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
19 PRODUCED IN THIS LITIGATION
20 9.1 The terms of this Order are applicable to information produced by a
21 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
22 produced by Non-Parties in connection with this litigation is protected by the
23 remedies and relief provided by this Order. Nothing in these provisions should be
24 construed as prohibiting a Non-Party from seeking additional protections.
25 9.2 In the event that a Party is required, by a valid discovery request, to
26 produce a Non-Party’s confidential information in its possession, and the Party is
27 subject to an agreement with the Non-Party not to produce the Non-Party’s
28 confidential information, then the Party shall:
1 (a) promptly notify in writing the Requesting Party and the Non-Party
2 that some or all of the information requested is subject to a confidentiality
3 agreement with a Non-Party;
4 (b) promptly provide the Non-Party with a copy of the Stipulated
5 Protective Order in this Action, the relevant discovery request(s), and a reasonably
6 specific description of the information requested; and
7 (c) make the information requested available for inspection by the
8 Non-Party, if requested.
9 9.3 If the Non-Party fails to seek a protective order from this court within
10 14 days of receiving the notice and accompanying information, the Receiving
11 Party may produce the Non-Party’s confidential information responsive to the
12 discovery request. If the Non-Party timely seeks a protective order, the Receiving
13 Party shall not produce any information in its possession or control that is subject
14 to the confidentiality agreement with the Non-Party before a determination by the
15 court. Absent a court order to the contrary, the Non-Party shall bear the burden
16 and expense of seeking protection in this court of its Protected Material.
17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
18 10.1 If a Receiving Party learns that, by inadvertence or otherwise, it has
19 disclosed Protected Material to any person or in any circumstance not authorized
20 under this Stipulated Protective Order, the Receiving Party must immediately (a)
21 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
22 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
23 the person or persons to whom unauthorized disclosures were made of all the terms
24 of this Order, and (d) request such person or persons to execute the
25 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
26 A.
27 / / /
28 / / /
1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
2 OTHERWISE PROTECTED MATERIAL
3 11.1 When a Producing Party gives notice to Receiving Parties that certain
4 inadvertently produced material is subject to a claim of privilege or other
5 protection, the obligations of the Receiving Parties are those set forth in Federal
6 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
7 whatever procedure may be established in an e-discovery order that provides for
8 production without prior privilege review.
9 Any inadvertent production of documents containing privileged information
10 shall not be deemed to be a waiver of the attorney-client privilege, work product
11 doctrine, or any other applicable privilege or doctrines. All parties specifically
12 reserve the right to demand the return of any privileged documents that it may
13 produce inadvertently during discovery if the producing party determines that such
14 documents contain privileged information. After receiving notice of such
15 inadvertent production by the producing party, the receiving party agrees to make
16 reasonable and good faith efforts to locate and return to the producing party all
17 such inadvertently produced documents.
18 12. MISCELLANEOUS
19 12.1 Right to Further Relief. Nothing in this Order abridges the right of
20 any 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
23 disclosing or producing any information or item on any ground not addressed in
24 this Stipulated Protective Order. Similarly, no Party waives any right to object on
25 any ground to use in evidence of any of the material covered by this Protective
26 Order.
27 12.3 Filing Protected Material. A Party that seeks to file under seal any
28 Protected Material must comply with Civil Local Rule 79-5. Protected Material
1 may only be filed under seal pursuant to a court order authorizing the sealing of the
2 specific Protected Material at issue. If a Party’s request to file Protected Material
3 under seal is denied by the court, then the Receiving Party may file the information
4 in the public record unless otherwise instructed by the court.
5 13. FINAL DISPOSITION
6 13.1 After the final disposition of this Action, as defined in paragraph 4,
7 within 60 days of a written request by the Designating Party, each Receiving Party
8 must return all Protected Material to the Producing Party or destroy such material.
9 As used in this subdivision, “all Protected Material” includes all copies, abstracts,
10 compilations, summaries, and any other format reproducing or capturing any of the
11 Protected Material. Whether the Protected Material is returned or destroyed, the
12 Receiving Party must submit a written certification to the Producing Party (and, if
13 not the same person or entity, to the Designating Party) by the 60 day deadline that
14 (1) identifies (by category, where appropriate) all the Protected Material that was
15 returned or destroyed and (2)affirms that the Receiving Party has not retained any
16 copies, abstracts, compilations, summaries or any other format reproducing or
17 capturing any of the Protected Material.
18 Notwithstanding this provision, Counsel are entitled to retain an archival
19 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
20 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
21 work product, and consultant and expert work product, even if such materials
22 contain Protected Material. Any such archival copies that contain or constitute
23 Protected Material remain subject to this Protective Order as set forth in Section 4
24 (DURATION).
25 ///
26 ///
27 ///
28 ///
1 ||14. VIOLATION
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.
7 Dated: August 20, 2019 RICHARDS LAW FIRM, APLC
8 By: /s/Evan Willis
9 John T. Richards
Evan Willis
10 Attorneys for Plaintiff Lamonte
11 Goode
3
3 Dated: August 20, 2019 GORDON REES SCULLY
14 MANSUKHANI, LLP
E
& 15
16 By: /s/ Hazel Mae B. Pangan
Craig J. Mariam
17 Hazel Mae B. Pangan
Attorneys for Defendant Dollar
18
Tree Stores, Inc.
19
20 [PROPOSED] ORDER
21 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22
93 || Dated: August 20, 2019
24 Rayelis,
25 |p
26 || HON. ROZELLA A. OLIVER
27 || United States Magistrate Judge
28
-15-
ANADCNITALCTY CTIDIIT ATELY DDOVTIOUS'TINV7C O\DIVLD- (TDDNDACLNy! □□□□□□□□□□
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
5
under penalty of perjury that I have read in its entirety and understand the
6
Stipulated Protective Order that was issued by the United States District Court for
7
the Central District of California in the case of Lamonte Goode v. Dollar Tree
8
Stores, Inc., Case No. 2:19-cv-2839 PA (RAOx). I agree to comply with and to be
9
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
11
punishment in the nature of contempt. I solemnly promise that I will not disclose
12
in any manner any information or item that is subject to this Stipulated Protective
13
Order to any person or entity except in strict compliance with the provisions of this
14
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.
19
I hereby appoint __________________________ [print or type full name] of
20
___________________________ [print or type full address and telephone number]
21
as my California agent for service of process in connection with this action or any
22
proceedings related to enforcement of this Stipulated Protective Order.
23
Date: ______________________________________
24
City and State where sworn and signed: _________________________________
25
Printed name: _______________________________
26
Signature: __________________________________
27
28