distinguishing “good cause” showing for sealing documents 21 produced in discovery from “compelling reasons” standard when merits-related 22 documents are part of court record
How later courts described this case
- distinguishing “good cause” showing for sealing documents 21 produced in discovery from “compelling reasons” standard when merits-related 22 documents are part of court record
Written by the judges who cited it.
The opinion
Case 5:2 1-cv-00454-JWH-KK Document 28 Filed 02/02/22 Page 1 of 16 Page ID #:145
LAW OFFICES OF DALE K. GALIPO
1 Dale K. Galipo, Esq. (SBN 144074)
dalekgalipo@yahoo.com
2 Marcel F. Sincich, Esq. (SBN 319508)
msincich@galipolaw.com
3 21800 Burbank Boulevard, Suite 310
Woodland Hills, CA 91367
4 Telephone: (818) 347-3333
Facsimile: (818) 347-4118
5
THE DOMINGUEZ FIRM
6 Scott D. Peebles, Esq. (Bar No. 227493)
scott.peebles@dominguezfirm.com
7 3250 Wilshire Blvd., Suite 2200
San Bernardino, CA 90010
8 Phone: (213) 235-2460 | Fax: (213) 388-9540
9 Attorneys for Plaintiffs CARLOS TORRES
10 Paul B. Beach, Esq. [State Bar No. 166265]
E-Mail: pbeach@lbaclaw.com
11 Aamir Raza, Esq. [State Bar No. 223530]
E-Mail: araza@lbaclaw.com
12 LAWRENCE BEACH ALLEN & CHOI, PC
E-Mail: courtemails@lbaclaw.com
13 2677 North Main Street, Suite 370
Santa Ana, California 92705
14 Telephone No.: (714) 479-0180
Facsimile No.: (714) 479-0181
15
Attorneys for Defendants, CITY OF SAN BERNARDINO, IRMAN AHMED
16 And MARTIN HYSEN
17
UNITED STATES DISTRICT COURT
18
CENTRAL DISTRICT OF CALIFORNIA
19
20
CARLOS TORRES, CASE No.: 5:21-cv-00454-JWH-KKx
Plaintiff, [Honorable John W. Holcomb]
21
22 vs. STIPULATED PROTECTIVE
CITY OF SAN BERNARDINO; ORDER
23 IRMAN AHMED; MARTIN
HYSEN; and DOES 1-10, inclusive, [[Proposed] Protective Order filed
24 concurrently herewith]
25 Defendants.
DISCOVERY DOCUMENT:
26 REFERRED TO MAGISTRATE
JUDGE KENLY KIYA KATO
27
28
1 Case No. 5:21-CV-00454-JWH-KK
STIPULATED PROTECTIVE ORDER
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1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary, or private information for which special protection from public
4 disclosure and from use for any purpose other than prosecuting this litigation may
5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court
6 to enter the following Stipulated Protective Order. The parties acknowledge that
7 this Order does not confer blanket protections on all disclosures or responses to
8 discovery and that the protection it affords from public disclosure and use extends
9 only to the limited information or items that are entitled to confidential treatment
10 under the applicable legal principles. The parties further acknowledge, as set forth
11 in Section 12.3, below, that this Stipulated Protective Order does not entitle them
12 to file confidential information under seal; Civil Local Rule 79-5 sets forth the
13 procedures that must be followed and the standards that will be applied when a
14 party seeks permission from the court to file material under seal.
15
16 B. GOOD CAUSE STATEMENT
17 This action involves the use of use of force against Carlos Torres by
18 members of the City of San Bernardino Police Department. Plaintiff is seeking
19 materials and information that Defendant City of San Bernardino (“City”)
20 maintains as confidential, such as personnel files of the police officers involved in
21 this incident, Internal Affairs materials and information, Force Investigation
22 Division materials and information and other administrative materials and
23 information currently in the possession of the City and which the City believes
24 needs special protection from public disclosure. Further, Plaintiff’s medical
25 records including photographs of his injuries, and other personal or financial
26 information also needs special protection from public disclosure.
27 Special protection of these documents from public disclosure and from use
28 for any purpose other than the prosecution, defense, and attempted settlement of
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1 this action may be warranted. Public disclosures of such confidential and
2 proprietary materials and information, information otherwise generally
3 unavailable to the public, may be privileged or otherwise protected from
4 disclosure under state or federal statutes, court rules, case decisions, or common
5 law. Accordingly, to expedite the flow of information, to facilitate the prompt
6 resolution of disputes over confidentiality of discovery materials, to adequately
7 protect information the parties are entitled to keep confidential, to ensure that the
8 parties are permitted reasonable necessary uses of such material in preparation for
9 and in the conduct of trial, to address their handling at the end of the litigation,
10 and serve the ends of justice, a protective order for such information is justified in
11 this matter. It is the intent of the parties that information will not be designated as
12 confidential for tactical reasons and that nothing be so designated without a good
13 faith belief that it has been maintained in a confidential, non-public manner, and
14 there is good cause why it should not be part of the public record of this case.
15
16 2. DEFINITIONS
17 2.1 Action: This pending federal lawsuit entitled Torres v. City of San
18 Bernardino, Case No. 5:21-CV-00454-JWH-KK.
19 2.2 Challenging Party: a Party or Non-Party that challenges the
20 designation of information or items under this Order.
21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
22 how it is generated, stored or maintained) or tangible things that qualify for
23 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
24 the Good Cause Statement.
25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
26 their support staff).
27 2.5 Designating Party: a Party or Non-Party that designates information
28 or items that it produces in disclosures or in responses to discovery as
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1 “CONFIDENTIAL.”
2 2.6 Disclosure or Discovery Material: all items or information, regardless
3 of the medium or manner in which it is generated, stored, or maintained
4 (including, among other things, testimony, transcripts, and tangible things), that
5 are produced or generated in disclosures or responses to discovery in this matter.
6 2.7 Expert: a person with specialized knowledge or experience in a
7 matter pertinent to the litigation who has been retained by a Party or its counsel to
8 serve as an expert witness or as a consultant in this Action.
9 2.8 House Counsel: attorneys who are employees of a party to this
10 action. House Counsel does not include Outside Counsel of Record or any other
11 outside counsel.
12 2.9 Non-Party: any natural person, partnership, corporation, association,
13 or other legal entity not named as a Party to this action.
14 2.10 Outside Counsel of Record: attorneys who are not employees of a
15 party to this action but are retained to represent or advise a party to this action and
16 have appeared in this action on behalf of that party or are affiliated with a law firm
17 which has appeared on behalf of that party, and includes support staff.
18 2.11 Party: any party to this action, including all of its officers, directors,
19 employees, consultants, retained experts, and Outside Counsel of Record (and
20 their support staffs).
21 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
22 Discovery Material in this action.
23 2.13 Professional Vendors: persons or entities that provide litigation
24 support services (e.g., photocopying, videotaping, translating, preparing exhibits
25 or demonstrations, and organizing, storing, or retrieving data in any form or
26 medium) and their employees and subcontractors.
27 2.14 Protected Material: any Disclosure or Discovery Material that is
28 designated as “CONFIDENTIAL.”
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1 2.15 Receiving Party: a Party that receives Disclosure or Discovery
2 Material from a Producing Party.
3
4 3. SCOPE
5 The protections conferred by this Stipulation and Order cover not only
6 Protected Material (as defined above), but also (1) any information copied or
7 extracted from Protected Material; (2) all copies, excerpts, summaries, or
8 compilations of Protected Material; and (3) any testimony, conversations, or
9 presentations by Parties or their Counsel that might reveal Protected Material.
10 Any use of Protected Material at trial shall be governed by the orders of the
11 trial judge. This Order does not govern the use of Protected Materials at trial.
12
13 4. DURATION
14 Once a case proceeds to trial, all of the information that was designated as
15 confidential or maintained pursuant to this protective order that was presented at
16 trial becomes public and will be presumptively available to all members of the
17 public, including the press, unless compelling reasons supported by specific
18 factual findings to proceed otherwise are made to the trial judge in advance of the
19 trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81
20 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents
21 produced in discovery from “compelling reasons” standard when merits-related
22 documents are part of court record). Any information designated as confidential
23 or maintained pursuant to this protective order that was not presented at trial shall
24 maintain its confidentiality as described below.
25
26 5. DESIGNATING PROTECTED MATERIAL
27 5.1 Exercise of Restraint and Care in Designating Material for Protection.
28 Each Party or Non-Party that designates information or items for protection
5 Case No. 5:21-CV-00454-JWH-KK
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1 under this Order must take care to limit any such designation to specific material
2 that qualifies under the appropriate standards. The Designating Party must
3 designate for protection only those parts of material, documents, items, or oral or
4 written communications that qualify so that other portions of the material,
5 documents, items, or communications for which protection is not warranted are
6 not swept unjustifiably within the ambit of this Order.
7 Mass, indiscriminate, or routinized designations are prohibited.
8 Designations that are shown to be clearly unjustified or that have been made for
9 an improper purpose (e.g., to unnecessarily encumber or retard the case
10 development process or to impose unnecessary expenses and burdens on other
11 parties) expose the Designating Party to sanctions.
12 If it comes to a Designating Party’s attention that information or items that
13 it designated for protection do not qualify for protection, that Designating Party
14 must promptly notify all other Parties that it is withdrawing the inapplicable
15 designation.
16
17 5.2 Manner and Timing of Designations.
18 Except as otherwise provided in this Order (see, e.g., second paragraph of
19 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or
20 Discovery Material that qualifies for protection under this Order must be clearly
21 so designated before the material is disclosed or produced.
22 Designation in conformity with this Order requires:
23 (a) for information in documentary form (e.g., paper or electronic
24 documents, but excluding transcripts of depositions or other pretrial or trial
25 proceedings), that the Producing Party affix the legend “CONFIDENTIAL”
26 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected
27 material. If only a portion or portions of the material on a page qualifies for
28 protection, the Producing Party also must clearly identify the protected portion(s)
6 Case No. 5:21-CV-00454-JWH-KK
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1 (e.g., by making appropriate markings in the margins).
2 A Party or Non-Party that makes original documents available for
3 inspection need not designate them for protection until after the inspecting Party
4 has indicated which documents it would like copied and produced. During the
5 inspection and before the designation, all of the material made available for
6 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
7 identified the documents it wants copied and produced, the Producing Party must
8 determine which documents, or portions thereof, qualify for protection under this
9 Order. Then, before producing the specified documents, the Producing Party must
10 affix the “CONFIDENTIAL legend” to each page that contains Protected
11 Material. If only a portion of the material on a page qualifies for protection, the
12 Producing Party also must clearly identify the protected portion(s) (e.g., by
13 making appropriate markings in the margins).
14 (b) for testimony given in depositions that the Designating Party identify
15 the Disclosure or Discovery Material on the record, before the close of the
16 deposition all protected testimony.
17 (c) for information produced in some form other than documentary and for
18 any other tangible items, that the Producing Party affix in a prominent place on
19 the exterior of the container or containers in which the information is stored the
20 legend “CONFIDENTIAL.” If only a portion or portions of the information
21 warrants protection, the Producing Party, to the extent practicable, shall identify
22 the protected portion(s).
23
24 5.3 Inadvertent Failures to Designate.
25 If timely corrected, an inadvertent failure to designate qualified information
26 or items does not, standing alone, waive the Designating Party’s right to secure
27 protection under this Order for such material. Upon timely correction of a
28 designation, the Receiving Party must make reasonable efforts to assure that the
7 Case No. 5:21-CV-00454-JWH-KK
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1 material is treated in accordance with the provisions of this Order.
2
3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4 6.1 Timing of Challenges.
5 Any Party or Non-Party may challenge a designation of confidentiality at
6 any time consistent with the Court’s Scheduling Order.
7 6.2 Meet and Confer.
8 The Challenging Party shall initiate the dispute resolution process under
9 Local Rule 37.1 et seq.
10 6.3 Judicial Intervention.
11 The burden of persuasion in any such challenge proceeding shall be on the
12 Designating Party. Frivolous challenges, and those made for an improper purpose
13 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
14 expose the Challenging Party to sanctions. Unless the Designating Party has
15 waived or withdrawn the confidentiality designation, all parties shall continue to
16 afford the material in question the level of protection to which it is entitled under
17 the Producing Party’s designation until the Court rules on the challenge.
18
19 7. ACCESS TO AND USE OF PROTECTED MATERIAL
20 7.1 Basic Principles.
21 A Receiving Party may use Protected Material that is disclosed or produced
22 by another Party or by a Non-Party in connection with this case only for
23 prosecuting, defending, or attempting to settle this Action. Such Protected
24 Material may be disclosed only to the categories of persons and under the
25 conditions described in this Order. When the Action has been terminated, a
26 Receiving Party must comply with the provisions of section 13 below (FINAL
27 DISPOSITION).
28 Protected Material must be stored and maintained by a Receiving Party at a
8 Case No. 5:21-CV-00454-JWH-KK
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1 location and in a secure manner that ensures that access is limited to the persons
2 authorized under this Order.
3 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
4 Unless otherwise ordered by the court or permitted in writing by the
5 Designating Party, a Receiving Party may disclose any information or item
6 designated “CONFIDENTIAL” only to:
7 (a) the Receiving Party’s Outside Counsel of Record in this action, as
8 well as employees of said Outside Counsel of Record to whom it is reasonably
9 necessary to disclose the information for this Action;
10 (b) the officers, directors, and employees (including House Counsel) of
11 the Receiving Party to whom disclosure is reasonably necessary for this Action;
12 (c) Experts (as defined in this Order) of the Receiving Party to whom
13 disclosure is reasonably necessary for this litigation and who have signed the
14 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
15 (d) the Court and its personnel;
16 (e) court reporters and their staff;
17 (f) professional jury or trial consultants, mock jurors, and Professional
18 Vendors to whom disclosure is reasonably necessary for this litigation and who
19 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20 (g) the author or recipient of a document containing the information or a
21 custodian or other person who otherwise possessed or knew the information;
22 (h) during their depositions, witnesses ,and attorneys for witnesses, in the
23 Action to whom disclosure is reasonably necessary provided: (1) the deposing
24 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2)
25 they will not be permitted to keep any confidential information unless they sign
26 the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
27 otherwise agreed by the Designating Party or ordered by the court. Pages of
28 transcribed deposition testimony or exhibits to depositions that reveal Protected
9 Case No. 5:21-CV-00454-JWH-KK
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1 Material may be separately bound by the court reporter and may not be disclosed
2 to anyone except as permitted under this Stipulated Protective Order; and
3 (i) any mediator or settlement officer, and their supporting personnel,
4 mutually agreed upon by any of the parties engaged in settlement discussions.
5
6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
7 PRODUCED IN OTHER LITIGATION
8 If a Party is served with a subpoena or a court order issued in other
9 litigation that compels disclosure of any information or items designated in this
10 action as “CONFIDENTIAL,” that Party must:
11 (a) promptly notify in writing the Designating Party. Such notification
12 shall include a copy of the subpoena or court order;
13 (b) promptly notify in writing the party who caused the subpoena or
14 order to issue in the other litigation that some or all of the material covered by the
15 subpoena or order is subject to this Protective Order. Such notification shall
16 include a copy of this Stipulated Protective Order; and
17 (c) cooperate with respect to all reasonable procedures sought to be
18 pursued by the Designating Party whose Protected Material may be affected.
19 If the Designating Party timely seeks a protective order, the Party served
20 with the subpoena or court order shall not produce any information designated in
21 this action as “CONFIDENTIAL” before a determination by the court from which
22 the subpoena or order issued, unless the Party has obtained the Designating
23 Party’s permission. The Designating Party shall bear the burden and expense of
24 seeking protection in that court of its confidential material and nothing in these
25 provisions should be construed as authorizing or encouraging a Receiving Party in
26 this Action to disobey a lawful directive from another court.
27
28 / / /
10 Case No. 5:21-CV-00454-JWH-KK
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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.” Such information
5 produced by Non-Parties in connection with this litigation is protected by the
6 remedies and relief provided by this Order. Nothing in these provisions should be
7 construed as prohibiting a Non-Party from seeking additional protections.
8 (b) In the event that a Party is required, by a valid discovery request, to
9 produce a Non-Party’s confidential information in its possession, and the Party is
10 subject to an agreement with the Non-Party not to produce the Non-Party’s
11 confidential information, then the Party shall:
12 1) promptly notify in writing the Requesting Party and the Non-
13 Party that some or all of the information requested is subject to a confidentiality
14 agreement with a Non-Party;
15 2) promptly provide the Non-Party with a copy of the Stipulated
16 Protective Order in this litigation, the relevant discovery request(s), and a
17 reasonably specific description of the information requested; and
18 3) make the information requested available for inspection by the
19 Non-Party.
20 (c) If the Non-Party fails to seek a protective order from this court within
21 14 days of receiving the notice and accompanying information, the Receiving
22 Party may produce the Non-Party’s confidential information responsive to the
23 discovery request. If the Non-Party timely seeks a protective order, the Receiving
24 Party shall not produce any information in its possession or control that is subject
25 to the confidentiality agreement with the Non-Party before a determination by the
26 court. Absent a court order to the contrary, the Non-Party shall bear the burden
27 and expense of seeking protection in this court of its Protected Material.
28
11 Case No. 5:21-CV-00454-JWH-KK
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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)
7 inform the person or persons to whom unauthorized disclosures were made of all
8 the terms of this Order, and (d) request such person or persons to execute the
9 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
10 A.
11
12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
13 OTHERWISE PROTECTED MATERIAL
14 When a Producing Party gives notice to Receiving Parties that certain
15 inadvertently produced material is subject to a claim of privilege or other
16 protection, the obligations of the Receiving Parties are those set forth in Federal
17 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
18 whatever procedure may be established in an e-discovery order that provides for
19 production without prior privilege review. Pursuant to Federal Rule of Evidence
20 502(d) and (e), insofar as the parties reach an agreement on the effect of
21 disclosure of a communication or information covered by the attorney-client
22 privilege or work product protection, the parties may incorporate their agreement
23 in the stipulated protective order submitted to the court.
24
25 12. MISCELLANEOUS
26 12.1 Right to Further Relief.
27 Nothing in this Order abridges the right of any person to seek its
28 modification by the Court in the future.
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1 12.2 Right to Assert Other Objections.
2 By stipulating to the entry of this Protective Order no Party waives any
3 right it otherwise would have to object to disclosing or producing any information
4 or item on any ground not addressed in this Stipulated Protective Order.
5 Similarly, no Party waives any right to object on any ground to use in evidence of
6 any of the material covered by this Protective Order.
7
8 12.3 Filing Protected Material.
9 A Party that seeks to file under seal any Protected Material must comply
10 with Civil Local Rule 79-5. Protected Material may only be filed under seal
11 pursuant to a court order authorizing the sealing of the specific Protected Material
12 at issue. If a Party's request to file Protected Material under seal is denied by the
13 court, then the Receiving Party may file the information in the public record
14 unless otherwise instructed by the court.
15
16 13. FINAL DISPOSITION
17 After the final disposition of this Action, as defined in paragraph 4, within
18 60 days of a written request by the Designating Party, each Receiving Party must
19 return all Protected Material to the Producing Party or destroy such material. As
20 used in this subdivision, “all Protected Material” includes all copies, abstracts,
21 compilations, summaries, and any other format reproducing or capturing any of
22 the Protected Material. Whether the Protected Material is returned or destroyed,
23 the Receiving Party must submit a written certification to the Producing Party
24 (and, if not the same person or entity, to the Designating Party) by the 60 day
25 deadline that (1) identifies (by category, where appropriate) all the Protected
26 Material that was returned or destroyed and (2) affirms that the Receiving Party
27 has not retained any copies, abstracts, compilations, summaries or any other
28 format reproducing or capturing any of the Protected Material. Notwithstanding
13 Case No. 5:21-CV-00454-JWH-KK
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1 this provision, Counsel are entitled to retain an archival copy of all pleadings,
2 motion papers, trial, deposition, and hearing transcripts, legal memoranda,
3 correspondence, deposition and trial exhibits, expert reports, attorney work
4 product, and consultant and expert work product, even if such materials contain
5 Protected Material. Any such archival copies that contain or constitute Protected
6 Material remain subject to this Protective Order as set forth in Section 4
7 (DURATION).
8
9 14. VIOLATION
10 Any violation of this Order may be punished by any and all appropriate
11 measures including, without limitation, contempt proceedings and/or monetary
12 sanctions.
13
14 / / /
15
16 / / /
17
18 / / /
19
20 / / /
21
22 / / /
23
24 / / /
25
26 / / /
27
28 / / /
14 Case No. 5:21-CV-00454-JWH-KK
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1 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
3 || Dated: January 31, 2022 THE LAW OFFICES OF DALE K. GALIPO
4 THE DOMINGUEZ FIRM
5 /s/__ Marcel F. Sincich
6 Dale K. Galipo, Esp.
Scott D. Peebles, Esq.
7 Marcel F. Sincich, Esq.
8 Attorney for Plaintiff CARLOS TORRES
9 ||Dated: January 31, 2022 LAWRENCE BEACH ALLEN & CHOI, PC
10
/s/_ Aamir Raza
11 Paul B. Beach
2 Aamir Raza. !
Attorneys for Defendant, CITY OF SAN
13 BERNARDINO, IRMAN AHMED and MARTIN
14 HYSEN
15
16 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
17 Com ny WwW
18 || DATED: February 2, 2022
19 Honorable Kenly Kiya Kato
United States Magistrate Judge
20
21
22
23
24
25
26
27 | AA
'], Aamir Raza, hereby concur in the content of this Stipulated Protective Order and have
28 authorized its filing.
15 Case No. 5:21-CV-00454-JWH-KK
— FIPULATED PROTECTIVE ORDER—“‘O □□□□□□□□□□□□□□□□□□□□□□□□□□
Case 5:21 -cv-00454-JWH-KK Document 28 Filed 02/02/22 Page 16 of 16 Page ID #:160
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of
5 ____________________________________ [print or type full address], declare
6 under penalty of perjury that I have read in its entirety and understand the
7 Stipulated Protective Order that was issued by the United States District Court for
8 the Central District of California on ________________[date] in the case of
9 Torres v. City of San Bernardino, et al., Case No. 5:21-CV-00454-JWH-KK. I
10 agree to comply with and to be bound by all the terms of this Stipulated Protective
11 Order and I understand and acknowledge that failure to so comply could expose
12 me to sanctions and punishment in the nature of contempt. I solemnly promise
13 that I will not disclose in any manner any information or item that is subject to this
14 Stipulated Protective Order to any person or entity except in strict compliance
15 with the provisions of this Order.
16 I further agree to submit to the jurisdiction of the United States District
17 Court for the Central District of California for the purpose of enforcing the terms
18 of this Stipulated Protective Order, even if such enforcement proceedings occur
19 after termination of this action. I hereby appoint __________________________
20 [print or type full name] of _______________________________________ [print
21 or type full address and telephone number] as my California agent for service of
22 process in connection with this action or any proceedings related to enforcement
23 of this Stipulated Protective Order.
24
25 Date: _____________________ Signature: ______________________________
26 Printed Name: ______________________________
27
28 City and State where sworn and signed: _________________________________
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