Jerry L. Cooch v. City of Covina

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8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

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11 || JERRY L. COOCH, an individual, Case No. 2:19-cv-00912-FMO-GJS

12 Plaintiff,

PROTECTIVE ORDER BASED ON

13 V. STIPULATION OF THE PARTIES

14 || JOSHUA TURNER, an individual and

employee of the City of Covina; IVAN Judge: Hon. Fernando M. Olguin

15 |] OSTARCEVIC, an individual and Magistrate Judge: Hon. Gail J. Standish

employee of the City of Covina, SAMER

16 || HATHOUT, an individual and employee Complaint Filed: February 6, 2019

of the County of Los Angeles; DOE-1, an FAC Filed: April 17, 2019

17 || individual and employee of County of Los | SAC Filed: May 8, 2019

Angeles; and DOES 2-20, inclusive,

18 Trial Date: May 19, 2020

Defendants.

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1. A. PURPOSES AND LIMITATIONS

33 Discovery in this action is likely to involve production of confidential,

44 proprietary or private information for which special protection from public

35 disclosure and from use for any purpose other than prosecuting this litigation may

46 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

enter the following Stipulated Protective Order. The parties acknowledge that this

38 Order does not confer blanket protections on all disclosures or responses to

1 || discovery and that the protection it affords from public disclosure and use extends

2 || only to the limited information or items that are entitled to confidential treatment

3 || under the applicable legal principles.

4 B. GOOD CAUSE STATEMENT

5 Discovery in this action is likely to involve production of City of Covina

6 || Police Department police investigation reports, and related documentation,

7 || regarding the investigation of an alleged underlying attempted murder, sexual

8 || battery, and residential robbery that occurred within the City of Covina, resulting

9 || arrests, and criminal prosecutions arising from the alleged incident. The

10 || documentation contains information implicating privacy rights of Party and non-

11 || Party individuals, including, but not limited to, the alleged victim, and alleged

12 || witnesses, which is otherwise generally unavailable to the public, or which may be

13 || privileged, or otherwise protected from disclosure, under state or federal statutes,

14 || court rules, case decisions, or common law.

15 Additionally, discovery in this action may involve production, if allowed, of

16 || certain City of Covina Police Department documents, records, tangible items, and

17 || information relating to police officer personnel files, and internal affairs files, to the

18 || extent such information is relevant to the claims asserted in this action. Such

19 || information may be protected by the official information privilege, law enforcement

20 || privilege, statutory and case law, and the right to privacy provided by both the

21 || California Constitution, and United States Constitution, when balanced with

22 || Plaintiff's right to discovery in this action.

23 Accordingly, to expedite the flow of information, to facilitate the prompt

24 || resolution of disputes over confidentiality of discovery materials, to adequately

25 || protect information the parties are entitled to keep confidential, to ensure that the

26 || Parties are permitted reasonable necessary uses of such material in preparation for

27 || and in the conduct of trial, to address their handling at the end of the litigation, and

28 || serve the ends of justice, a protective order for such information 1s justified in this

1 || matter. It is the intent of the Parties that information will not be designated as

2 || confidential for tactical reasons and that nothing be so designated without a good

3 || faith belief that it has been maintained in a confidential, non-public manner, and

4 || there is good cause why it should not be part of the public record of this case.

5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

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

7 || Stipulated Protective Order does not entitle them to file confidential information

8 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

9 || and the standards that will be applied when a party seeks permission from the court

10 || to file material under seal.

11 There is a strong presumption that the public has a right of access to judicial

12 || proceedings and records in civil cases. In connection with non-dispositive motions,

13 || good cause must be shown to support a filing under seal. See Kamakana v. City and

14 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

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

16 || Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

17 |)require good cause showing), and a specific showing of good cause or compelling

18 || reasons with proper evidentiary support and legal justification, must be made with

19 || respect to Protected Material that a party seeks to file under seal. The parties’ mere

20 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

21 |} without the submission of competent evidence by declaration, establishing that the

22 || material sought to be filed under seal qualifies as confidential, privileged, or

23 || otherwise protectable—constitute good cause.

24 Further, if a party requests sealing related to a dispositive motion or trial, then

25 || compelling reasons, not only good cause, for the sealing must be shown, and the

26 || relief sought shall be narrowly tailored to serve the specific interest to be protected.

27 || See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For

28 || each item or type of information, document, or thing sought to be filed or introduced

1 || under seal in connection with a dispositive motion or trial, the party seeking

2 || protection must articulate compelling reasons, supported by specific facts and legal

3 || justification, for the requested sealing order. Again, competent evidence supporting

4 || the application to file documents under seal must be provided by declaration.

5 Any document that is not confidential, privileged, or otherwise protectable in

6 || its entirety will not be filed under seal if the confidential portions can be redacted.

|| If documents can be redacted, then a redacted version for public viewing, omitting

8 || only the confidential, privileged, or otherwise protectable portions of the document,

9 || shall be filed. Any application that seeks to file documents under seal in their

10 || entirety should include an explanation of why redaction is not feasible.

DEFINITIONS

12 2.1 Action: Jerry L. Cooch v. Joshua Turner, et al., USDC Case No. 2:19-

13 || cv-00912-FMO-GJS.

14 2.2 Challenging Party: a Party or Non-Party that challenges the

15 || designation of information or items under this Order.

16 2.3. “CONFIDENTIAL” Information or Items: information (regardless of

17 || how it is generated, stored or maintained) or tangible things that qualify for

18 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in

19 || the Good Cause Statement.

20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

21 || their support staff).

22 2.5 Designating Party: a Party or Non-Party that designates information or

23 items that it produces in disclosures or in responses to discovery as

24 ||“CONFIDENTIAL.”

25 2.6 Disclosure or Discovery Material: all items or information, regardless

26 || of the medium or manner in which it is generated, stored, or maintained (including,

27 among other things, testimony, transcripts, and tangible things), that are produced or

28 || generated in disclosures or responses to discovery in this matter.

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

2 || pertinent to the litigation who has been retained by a Party or its counsel to serve as

3 ||an expert witness or as a consultant in this Action.

4 2.8 House Counsel: attorneys who are employees of a party to this Action.

5 || House Counsel does not include Outside Counsel of Record or any other outside counsel.

6 2.9 Non-Party: any natural person, partnership, corporation, association or other

7 || legal entity not named as a Party to this action.

8 2.10 Outside Counsel of Record: attorneys who are not employees of a party to

9 || this Action but are retained to represent or advise a party to this Action and have appeared

10 |] in this Action on behalf of that party or are affiliated with a law firm that has appeared on

11 || behalf of that party, and includes support staff.

12 2.11 Party: any party to this Action, including all of its officers, directors,

13 || employees, consultants, retained experts, and Outside Counsel of Record (and their support

14 || staffs).

15 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

16 || Discovery Material in this Action.

17 2.13 Professional Vendors: persons or entities that provide litigation support

18 || services (e.g., photocopying, videotaping, translating, preparing exhibits or

19 || demonstrations, and organizing, storing, or retrieving data in any form or medium) and

20 || their employees and subcontractors.

21 2.14 Protected Material: any Disclosure or Discovery Material that is designated

22 ||as “CONFIDENTIAL.”

23 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

24 || from a Producing Party.

25 □□ SCOPE

26 The protections conferred by this Stipulation and Order cover not only

27 || Protected Material (as defined above), but also (1) any information copied or

28 || extracted from Protected Material; (2) all copies, excerpts, summaries, or

1 || compilations of Protected Material; and (3) any testimony, conversations, or

2 || presentations by Parties or their Counsel that might reveal Protected Material.

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

trial judge. This Order does not govern the use of Protected Material at trial.

5 || 4. DURATION

6 FINAL DISPOSITION of the action is defined as the conclusion of any

7 || appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal

8 || has run. Except as set forth below, the terms of this protective order apply through

□□ FINAL DISPOSITION of the action. The parties may stipulate that the they will be

10 || contractually bound by the terms of this agreement beyond FINAL DISPOSITION,

11 |) but will have to file a separate action for enforcement of the agreement once all

12 || proceedings in this case are complete.

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

14 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced

15 an exhibit at trial becomes public and will be presumptively available to all

16 || members of the public, including the press, unless compelling reasons supported by

17 || specific factual findings to proceed otherwise are made to the trial judge in advance

18 || of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

19 || showing for sealing documents produced in discovery from “compelling reasons”

20 || standard when merits-related documents are part of court record). Accordingly, for

21 ||such materials, the terms of this protective order do not extend beyond the

22 || commencement of the trial.

23 ||5. DESIGNATING PROTECTED MATERIAL

24 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each

25 || Party or Non-Party that designates information or items for protection under this Order

26 || must take care to limit any such designation to specific material that qualifies under the

27 || appropriate standards. The Designating Party must designate for protection only those

28 || parts of material, documents, items or oral or written communications that qualify so that

1 || other portions of the material, documents, items or communications for which protection is

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

3 Mass, indiscriminate or routinized designations are prohibited. Designations

4 || that are shown to be clearly unjustified or that have been made for an improper

5 || purpose (e.g., to unnecessarily encumber the case development process or to impose

6 || unnecessary expenses and burdens on other parties) may expose the Designating

Party to sanctions.

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

9 || designated for protection do not qualify for protection, that Designating Party must

10 || promptly notify all other Parties that it is withdrawing the inapplicable designation.

1] 5.2 Manner and Timing of Designations. Except as otherwise provided in this

12 || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or

13 || ordered, Disclosure or Discovery Material that qualifies for protection under this Order

14 || must be clearly so designated before the material is disclosed or produced.

15 Designation in conformity with this Order requires:

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

17 |) but excluding transcripts of depositions or other pretrial or trial proceedings), that

18 || the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

19 || “CONFIDENTIAL legend”), to each page that contains protected material. If only a

20 || portion of the material on a page qualifies for protection, the Producing Party also

21 |} must clearly identify the protected portion(s) (e.g., by making appropriate markings

22 ||in the margins).

23 A Party or Non-Party that makes original documents available for inspection

24 || need not designate them for protection until after the inspecting Party has indicated

25 || which documents it would like copied and produced. During the inspection and

26 || before the designation, all of the material made available for inspection shall be

27 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

28 || documents it wants copied and produced, the Producing Party must determine which

1 || documents, or portions thereof, qualify for protection under this Order. Then,

2 || before producing the specified documents, the Producing Party must affix the

3 ||““CONFIDENTIAL legend” to each page that contains Protected Material. If only a

4 || portion of the material on a page qualifies for protection, the Producing Party also

5 || must clearly identify the protected portion(s) (e.g., by making appropriate markings

6 || in the margins).

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

8 || the Disclosure or Discovery Material on the record, before the close of the

9 || deposition all protected testimony.

10 (c) for information produced in some form other than documentary and for

11 □□ □□□ other tangible items, that the Producing Party affix in a prominent place on the

12 || exterior of the container or containers in which the information is stored the legend

13 || “CONFIDENTIAL.” If only a portion or portions of the information warrants

14 || protection, the Producing Party, to the extent practicable, shall identify the protected

15 || portion(s).

16 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

17 || to designate qualified information or items does not, standing alone, waive the Designating

18 || Party’s right to secure protection under this Order for such material. Upon timely

19 || correction of a designation, the Receiving Party must make reasonable efforts to assure

20 || that the material is treated in accordance with the provisions of this Order.

21/6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation

23 || of confidentiality at any time that is consistent with the Court’s Scheduling Order.

24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution

25 || process under Local Rule 37.1 et seq.

26 6.3. The burden of persuasion in any such challenge proceeding shall be on

27 || the Designating Party. Frivolous challenges, and those made for an improper

28 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other

1 || parties) may expose the Challenging Party to sanctions. Unless the Designating

2 || Party has waived or withdrawn the confidentiality designation, all parties shall

3 || continue to afford the material in question the level of protection to which it is

4 || entitled under the Producing Party’s designation until the Court rules on the

5 || challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

7 7.1 Basic Principles. A Receiving Party may use Protected Material that is

8 || disclosed or produced by another Party or by a Non-Party in connection with this Action

9 || only for prosecuting, defending or attempting to settle this Action. Such Protected

10 || Material may be disclosed only to the categories of persons and under the conditions

11 || described in this Order. When the Action has been terminated, a Receiving Party must

12 || comply with the provisions of section 13 below (FINAL DISPOSITION).

13 || Protected Material must be stored and maintained by a Receiving Party at a location and in

14 || a secure manner that ensures that access is limited to the persons authorized under this

15 || Order.

16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

17 || ordered by the court or permitted in writing by the Designating Party, a Receiving Party

18 || may disclose any information or item designated “CONFIDENTIAL” only to:

19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well

20 || as employees of said Outside Counsel of Record to whom it is reasonably necessary

21 || to disclose the information for this Action;

22 (b) the officers, directors, and employees (including House Counsel) of the

23 || Receiving Party to whom disclosure is reasonably necessary for this Action;

24 (c) Experts (as defined in this Order) of the Receiving Party to whom

25 || disclosure is reasonably necessary for this Action and who have signed the

26 || ““Acknowledgment and Agreement to Be Bound” (Exhibit A);

27 (d) the court and its personnel;

28 (e) court reporters and their staff;

1 (f) professional jury or trial consultants, mock jurors, and Professional

2 || Vendors to whom disclosure is reasonably necessary for this Action and who have

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

4 (g) the author or recipient of a document containing the information or a

5 || custodian or other person who otherwise possessed or knew the information;

6 (h) during their depositions, witnesses, and attorneys for witnesses, in the

|| Action to whom disclosure is reasonably necessary provided: (1) the deposing party

8 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

9 || not be permitted to keep any confidential information unless they sign the

10 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

11 ||agreed by the Designating Party or ordered by the court. Pages of transcribed

12 || deposition testimony or exhibits to depositions that reveal Protected Material may

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

14 || as permitted under this Stipulated Protective Order; and

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

16 || mutually agreed upon by any of the parties engaged in settlement discussions.

17]|8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

18 IN OTHER LITIGATION

19 If a Party is served with a subpoena or a court order issued in other litigation that

20 || compels disclosure of any information or items designated in this Action as

21 || “CONFIDENTIAL,” that Party must:

22 (a) promptly notify in writing the Designating Party. Such notification shall

23 || include a copy of the subpoena or court order;

24 (b) promptly notify in writing the party who caused the subpoena or order to

25 || issue in the other litigation that some or all of the material covered by the subpoena

26 || or order is subject to this Protective Order. Such notification shall include a copy of

27 || this Stipulated Protective Order; and

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1 (c) cooperate with respect to all reasonable procedures sought to be pursued

2 || by the Designating Party whose Protected Material may be affected.

3 If the Designating Party timely seeks a protective order, the Party served with the

4 || subpoena or court order shall not produce any information designated in this action as

5 || “CONFIDENTIAL” before a determination by the court from which the subpoena or order

6 || issued, unless the Party has obtained the Designating Party’s permission. The Designating

7 || Party shall bear the burden and expense of seeking protection in that court of its

8 || confidential material and nothing in these provisions should be construed as authorizing or

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

10 |] court.

11]}9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

12 PRODUCED IN THIS LITIGATION

13 (a) The terms of this Order are applicable to information produced by a Non-

14 Party in this Action and designated as “CONFIDENTIAL.” Such information

15 produced by Non-Parties in connection with this litigation is protected by the

16 remedies and relief provided by this Order. Nothing in these provisions

17 should be construed as prohibiting a Non-Party from seeking additional

18 protections.

19 (b) In the event that a Party is required, by a valid discovery request, to

20 produce a Non-Party’s confidential information in its possession, and the

21 Party is subject to an agreement with the Non-Party not to produce the Non-

22 Party’s confidential information, then the Party shall:

23 (1) promptly notify in writing the Requesting Party and the Non-Party that some or

24 || all of the information requested is subject to a confidentiality agreement with a Non-Party;

25 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order

26 |} in this Action, the relevant discovery request(s), and a reasonably specific description of

27 || the information requested; and

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1 (3) make the information requested available for inspection by the Non-Party, if

2 || requested.

3 (c) If the Non-Party fails to seek a protective order from this court within 14

4 || days of receiving the notice and accompanying information, the Receiving Party

5 produce the Non-Party’s confidential information responsive to the discovery

6 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall

7 || not produce any information in its possession or control that is subject to the

8 || confidentiality agreement with the Non-Party before a determination by the court.

9 || Absent a court order to the contrary, the Non-Party shall bear the burden and

10 || expense of seeking protection in this court of its Protected Material.

11)}10.. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

13 || Protected Material to any person or in any circumstance not authorized under this

14 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the

15 || Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all

16 || unauthorized copies of the Protected Material, (c) inform the person or persons to whom

17 || unauthorized disclosures were made of all the terms of this Order, and (d) request such

18 || person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is

19 || attached hereto as Exhibit A.

20)}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

21 PROTECTED MATERIAL

22 When a Producing Party gives notice to Receiving Parties that certain inadvertently

23 || produced material is subject to a claim of privilege or other protection, the obligations of

24 || the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).

25 || This provision is not intended to modify whatever procedure may be established in an e-

26 || discovery order that provides for production without prior privilege review. Pursuant to

27 || Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the

28 || effect of disclosure of a communication or information covered by the attorney-client

1 || privilege or work product protection, the parties may incorporate their agreement in the

2 || stipulated protective order submitted to the court.

3}}12. MISCELLANEOUS

4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

5 || person to seek its modification by the Court in the future.

6 12.2 Right to Assert Other Objections. By stipulating to the entry of this

7 || Protective Order, no Party waives any right it otherwise would have to object to

8 || disclosing or producing any information or item on any ground not addressed in this

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

10 || ground to use in evidence of any of the material covered by this Protective Order.

11 12.3. Filing Protected Material. A Party that seeks to file under seal any Protected

12 || Material must comply with Local Civil Rule 79-5. Protected Material may only be filed

13 || under seal pursuant to a court order authorizing the sealing of the specific Protected

14 || Material at issue. If a Party’s request to file Protected Material under seal is denied by the

15 || court, then the Receiving Party may file the information in the public record unless

16 || otherwise instructed by the court.

17|)}13. FINAL DISPOSITION

18 After the final disposition of this Action, as defined in paragraph 4, within 60 days

19 || of a written request by the Designating Party, each Receiving Party must return all

20 || Protected Material to the Producing Party or destroy such material. As used in this

21 |} subdivision, “all Protected Material” includes all copies, abstracts, compilations,

22 || summaries, and any other format reproducing or capturing any of the Protected Material.

23 || Whether the Protected Material is returned or destroyed, the Receiving Party must submit a

24 || written certification to the Producing Party (and, if not the same person or entity, to the

25 || Designating Party) by the 60 day deadline that (1) identifies (by category, where

26 || appropriate) all the Protected Material that was returned or destroyed and (2) affirms that

27 || the Receiving Party has not retained any copies, abstracts, compilations, summaries or any

28 || other format reproducing or capturing any of the Protected Material. Notwithstanding this

1 || provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers,

2 || trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and

3 || trial exhibits, expert reports, attorney work product, and consultant and expert work

4 || product, even if such materials contain Protected Material. Any such archival copies that

5 || contain or constitute Protected Material remain subject to this Protective Order as set forth

6 || in Section 4 (DURATION).

7\|14. MIOLATION

8 Any violation of this Order may be punished by appropriate measures

9 || including, without limitation, contempt proceedings and/or monetary sanctions.

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11 |} IT IS SO ORDERED.

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13 |} DATED: August 22, 2019

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16 GAIL’J. BJ ANDISH

UNITED*YSTATES MAGISTRATE JUDGE

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

41/1, [print or type full name], of

5 [print or type full address], declare under penalty of perjury

6 || that I have read in its entirety and understand the Stipulated Protective Order that

7 || was issued by the United States District Court for the Central District of California

8 || on [date] in the case of [insert formal name of the case and the

9 ||number and initials assigned to it by the court]. I agree to comply with and to be

10 || bound by all the terms of this Stipulated Protective Order and I understand and

11 |) acknowledge that failure to so comply could expose me to sanctions and punishment

12 |/in the nature of contempt. I solemnly promise that I will not disclose in any manner

13 || any information or item that is subject to this Stipulated Protective Order to any

14 || person or entity except in strict compliance with the provisions of this Order.

15 || I further agree to submit to the jurisdiction of the United States District Court for the

16 || Central District of California for enforcing the terms of this Stipulated Protective

17 || Order, even if such enforcement proceedings occur after termination of this action.

18 ||T hereby appoint [print or type full name] of

19 [print or type full address and

20 || telephone number] as my California agent for service of process in connection with

21 || this action or any proceedings related to enforcement of this Stipulated Protective

22 || Order.

23 || Date:

24 || City and State where sworn and signed:

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26 || Printed name:

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28 || Signature: