even 13 stipulated protective orders require good cause showing
How later courts described this case
- even 13 stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 1 of 16 Page ID #:137
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8 UNITED STATES DISTRICT COURT
9
CENTRAL DISTRICT OF CALIFORNIA
10
SOUTHERN DIVISION
11
12
VERONICA RIVERA, an individual, Case No. 8:21-cv-01431-DOC-JDE
13
Plaintiff, STIPULATED PROTECTIVE
14 ORDER
v.
15
MEDTRONIC USA, INC., a Trial Date: N/A
16 corporation; and DOES 1 through 50, Complaint Filed: July 30, 2021
17 Defendants.
18
19
20 Pursuant to the parties’ Stipulation (Dkt. 19), and for good cause shown, the
21 Court finds and orders as follows.
22 1. PURPOSES AND LIMITATIONS
23 Discovery in this action is likely to involve production of confidential,
24 proprietary or private information for which special protection from public
25
disclosure and from use for any purpose other than pursuing this litigation may be
26
warranted. Accordingly, the parties hereby stipulate to and petition the Court to
27
enter the following Stipulated Protective Order. The parties acknowledge that this
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Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 2 of 16 Page ID #:138
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Order does not confer blanket protections on all disclosures or responses to
2
discovery and that the protection it affords from public disclosure and use extends
3
only to the limited information or items that are entitled to confidential treatment
4
under the applicable legal principles.
5
2. GOOD CAUSE STATEMENT
6
This action is likely to involve confidential, non-public, sensitive, and/or
7
proprietary trade secrets, business, employment, tax, financial, and personally
8
identifiable information, documents and other materials for which special
9
protection from public disclosure and from use for any purpose other than
10
prosecution of this action is warranted. Such confidential and proprietary materials
11
and information consist of, among other things, confidential business or financial
12
information, information regarding confidential business practices, or other
13
confidential research, development, or commercial information (including
14
information implicating privacy rights of third parties), information otherwise
15
generally unavailable to the public, or which may be privileged or otherwise
16
protected from disclosure under state or federal statutes, court rules, case decisions,
17
or common law. Accordingly, to expedite the flow of information, to facilitate the
18
19 prompt resolution of disputes over confidentiality of discovery materials, to
20 adequately protect information the parties are entitled to keep confidential, to
21 ensure that the parties are permitted reasonable necessary uses of such material in
22 preparation for and in the conduct of trial, to address their handling at the end of
23 the litigation, and serve the ends of justice, a protective order for such information
24 is justified in this matter. It is the intent of the parties that information will not be
25 designated as confidential for tactical reasons and that nothing be so designated
26 without a good faith belief that it has been maintained in a confidential, non-public
27 manner, and there is good cause why it should not be part of the public record of
28 this case.
2
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 3 of 16 Page ID #:139
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3. ACKNOWLEDGMENT OF UNDER SEAL FILING
2
PROCEDURE
3
The parties further acknowledge, as set forth in Section 14.3, below, that this
4
Stipulated Protective Order does not entitle them to file confidential information
5
under seal; Local Civil 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. There is a strong presumption that the public has a right
8
of access to judicial proceedings and records in civil cases. In connection with non-
9
dispositive motions, good cause must be shown to support a filing under seal. See
10
Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
11
Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
12
Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
13
stipulated protective orders require good cause showing), and a specific showing of
14
good cause or compelling reasons with proper evidentiary support and legal
15
justification, must be made with respect to Protected Material that a party seeks to
16
file under seal. The parties’ mere designation of Disclosure or Discovery Material
17
as CONFIDENTIAL does not— without the submission of competent evidence by
18
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, the party seeking protection must articulate compelling
27 reasons, supported by specific facts and legal justification, for the requested sealing
28
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Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 4 of 16 Page ID #:140
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order. Again, competent evidence supporting the application to file documents
2
under seal must be provided by declaration.
3
Any document that is not confidential, privileged, or otherwise protectable
4
in its entirety will not be filed under seal if the confidential portions can be
5
redacted. If documents can be redacted, then a redacted version for public viewing,
6
omitting only the confidential, privileged, or otherwise protectable portions of the
7
document, shall be filed. Any application that seeks to file documents under seal in
8
their entirety should include an explanation of why redaction is not feasible.
9
4. DEFINITIONS
10
4.1 Action: Veronica Rivera v. Medtronic USA, Inc., and Does 1 through
11
50, inclusive, Case No. 8:21-cv-01431-DOC-JDE.
12
4.2 Challenging Party: a Party or Non-Party that challenges the
13
designation of information or items under this Order.
14
4.3 “CONFIDENTIAL” Information or Items: information (regardless of
15
how it is generated, stored or maintained) or tangible things that qualify for
16
protection under Federal Rule of Civil Procedure 26(c), and as specified above in
17
the Good Cause Statement.
18
19 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
20 their support staff).
21 4.5 Designating Party: a Party or Non-Party that designates information or
22 items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL.”
24 4.6 Disclosure or Discovery Material: all items or information, regardless
25 of the medium or manner in which it is generated, stored, or maintained (including,
26 among other things, testimony, transcripts, and tangible things), that are produced
27 or generated in disclosures or responses to discovery.
28
4
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 5 of 16 Page ID #:141
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4.7 Expert: a person with specialized knowledge or experience in a matter
3
pertinent to the litigation who has been retained by a Party or its counsel to serve
4
as an expert witness or as a consultant in this Action.
5
4.8 In House Counsel: attorneys who are employees of a party to this
6
Action. House Counsel does not include Outside Counsel of Record or any other
7
outside counsel.
8
4.9 Non-Party: any natural person, partnership, corporation, association or
9
other legal entity not named as a Party to this action.
10
4.10 Outside Counsel of Record: attorneys who are not employees of a
11
party to this Action but are retained to represent a party to this Action and have
12
appeared in this Action on behalf of that party or are affiliated with a law firm that
13
has appeared on behalf of that party, and includes support staff.
14
4.11 Party: any party to this Action, including all of its officers, directors,
15
employees, consultants, retained experts, and Outside Counsel of Record (and their
16
support staffs).
17
4.12 Producing Party: a Party or Non-Party that produces Disclosure or
18
19 Discovery Material in this Action.
20 4.13 Professional Vendors: persons or entities that provide litigation
21 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium)
23 and their employees and subcontractors.
24 4.14 Protected Material: any Disclosure or Discovery Material that is
25 designated as “CONFIDENTIAL.”
26 4.15 Receiving Party: a Party that receives Disclosure or Discovery
27 Material from a Producing Party.
28
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Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 6 of 16 Page ID #:142
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5. SCOPE
2
The protections conferred by this Stipulation and Order cover not only
3
Protected Material (as defined above), but also (1) any information copied or
4
extracted from Protected Material; (2) all copies, excerpts, summaries, or
5
compilations of Protected Material; and (3) any testimony, conversations, or
6
presentations by Parties or their Counsel that might reveal Protected Material.
7
Any use of Protected Material at trial shall be governed by the orders of the
8
trial judge and other applicable authorities. This Order does not govern the use of
9
Protected Material at trial.
10
6. DURATION
11
Even after final disposition of this litigation, the confidentiality
12
obligations imposed by this Stipulated Protective Order shall remain in effect until
13
a Designating Party agrees otherwise in writing or a court order otherwise directs.
14
Final disposition shall be deemed to be the later of (1) dismissal of all claims and
15
defenses in this Action, with or without prejudice; and (2) final judgment herein
16
after the completion and exhaustion of all appeals, rehearings, remands, trials, or
17
reviews of this Action, including the time limits for filing any motions or
18
19 applications for extension of time pursuant to applicable law.
20 7. DESIGNATING PROTECTED MATERIAL
21 7.1 Exercise of Restraint and Care in Designating Material for
22 Protection. Each Party or Non-Party that designates information or
23 items for protection under this Order must take care to limit any such designation
24 to specific material that qualifies under the appropriate standards. The Designating
25 Party must designate for protection only those parts of material, documents, items
26 or oral or written communications that qualify so that other portions of the
27 material, documents, items or communications for which protection is not
28 warranted are not swept unjustifiably within the ambit of this Order.
6
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 7 of 16 Page ID #:143
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Mass, indiscriminate or routinized designations are prohibited. Designations
2
that are shown to be clearly unjustified or that have been made for an improper
3
purpose (e.g., to unnecessarily encumber the case development process or to
4
impose unnecessary expenses and burdens on other parties) may expose the
5
Designating Party to sanctions.
6
If it comes to a Designating Party’s attention that information or items that it
7
designated for protection do not qualify for protection, that Designating Party must
8
promptly notify all other Parties that it is withdrawing the inapplicable designation.
9
7.2 Manner and Timing of Designations. Except as otherwise provided in
10
this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
11
that qualifies for protection under this Order must be clearly so designated before
12
the material is disclosed or produced.
13
Designation in conformity with this Order requires:
14
(a) for information in documentary form (e.g., paper or electronic
15
documents, but excluding transcripts of depositions or other pretrial or trial
16
proceedings), that the Producing Party affix at a minimum, the legend
17
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
18
19 contains protected material. If only a portion of the material on a page qualifies for
20 protection, the Producing Party also must clearly identify the protected portion(s)
21 (e.g., by making appropriate markings in the margins).
22 A Party or Non-Party that makes original documents available for inspection
23 need not designate them for protection until after the inspecting Party has indicated
24 which documents it would like copied and produced. During the inspection and
25 before the designation, all of the material made available for inspection shall be
26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
27 documents it wants copied and produced, the Producing Party must determine
28 which documents, or portions thereof, qualify for protection under this Order.
7
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 8 of 16 Page ID #:144
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Then, before producing the specified documents, the Producing Party must affix
2
the “CONFIDENTIAL legend” to each page that contains Protected Material. If
3
only a portion of the material on a page qualifies for protection, the Producing
4
Party also must clearly identify the protected portion(s) (e.g., by making
5
appropriate markings in the margins).
6
(b) for testimony given in depositions that the Designating Party
7
identifies the Disclosure or Discovery Material on the record, before the close of
8
the deposition all protected testimony.
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(c) for information produced in some form other than documentary
10
and for any other tangible items, that the Producing Party affix in a prominent
11
place on the exterior of the container or containers in which the information is
12
stored the legend “CONFIDENTIAL.” If only a portion or portions of the
13
information warrants protection, the Producing Party, to the extent practicable,
14
shall identify the protected portion(s).
15
7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
16
failure to designate qualified information or items does not, standing alone, waive
17
the Designating Party’s right to secure protection under this Order for such
18
19 material. Upon timely correction of a designation, the Receiving Party must make
20 reasonable efforts to assure that the material is treated in accordance with the
21 provisions of this Order.
22 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
23 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
24 designation of confidentiality at any time that is consistent with the Court’s
25 Scheduling Order.
26 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
27 resolution process under Local Rule 37-1 et seq.
28
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Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 9 of 16 Page ID #:145
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8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
2
joint stipulation pursuant to Local Rule 37-2.
3
8.4 The burden of persuasion in any such challenge proceeding shall be on
4
the Designating Party. Frivolous challenges, and those made for an improper
5
purpose (e.g., to harass or impose unnecessary expenses and burdens on other
6
parties) may expose the Challenging Party to sanctions. Unless the Designating
7
Party has waived or withdrawn the confidentiality designation, all parties shall
8
continue to afford the material in question the level of protection to which it is
9
entitled under the Producing Party’s designation until the Court rules on the
10
challenge.
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9. ACCESS TO AND USE OF PROTECTED MATERIAL
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9.1 Basic Principles. A Receiving Party may use Protected Material that is
13
disclosed or produced by another Party or by a Non-Party in connection with this
14
Action only for prosecuting, defending or attempting to settle this Action. Such
15
Protected Material may be disclosed only to the categories of persons and under
16
the conditions described in this Order. When the Action has been terminated, a
17
Receiving Party must comply with the provisions of section 15 below (FINAL
18
19 DISPOSITION).
20 Protected Material must be stored and maintained by a Receiving Party at a
21 location and in a secure manner that ensures that access is limited to the persons
22 authorized under this Order.
23 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
24 otherwise ordered by the court or permitted in writing by the Designating Party, a
25 Receiving Party may disclose any information or item designated
26 “CONFIDENTIAL” only to:
27 / / /
28 / / /
9
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 10 of 16 Page ID #:146
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(a) the Receiving Party’s Outside Counsel of Record in this Action, as
2
well as employees of said Outside Counsel of Record to whom it is reasonably
3
necessary to disclose the information for this Action;
4
(b) the officers, directors, and employees (including In-House
5
Counsel) of the Receiving Party to whom disclosure is reasonably necessary for
6
this Action;
7
(c) Experts (as defined in this Order) of the Receiving Party to whom
8
disclosure is reasonably necessary for this Action and who have signed the
9
“Acknowledgment and Agreement to Be Bound” (Exhibit A):
10
(d) the court and its personnel;
11
(e) court reporters and their staff;
12
(f) professional jury or trial consultants, mock jurors, and Professional
13
Vendors to whom disclosure is reasonably necessary for this Action and who have
14
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
15
(g) the author or recipient of a document containing the information or
16
a custodian or other person who otherwise possessed or knew the information;
17
(h) during their depositions, witnesses, and attorneys for witnesses, in
18
19 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
20 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
21 they will not be permitted to keep any confidential information unless they sign the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
23 agreed by the Designating Party or ordered by the court. Pages of transcribed
24 deposition testimony or exhibits to depositions that reveal Protected Material may
25 be separately bound by the court reporter and may not be disclosed to anyone
26 except as permitted under this Stipulated Protective Order; and
27 (i) any mediators or settlement officers and their supporting personnel,
28 mutually agreed upon by any of the parties engaged in settlement discussions.
10
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 11 of 16 Page ID #:147
1
10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2
PRODUCED IN OTHER LITIGATION
3
If a Party is served with a subpoena or a court order issued in other litigation
4
that compels disclosure of any information or items designated in this Action as
5
“CONFIDENTIAL,” that Party must:
6
(a) promptly notify in writing the Designating Party. Such notification
7
shall include a copy of the subpoena or court order;
8
(b) promptly notify in writing the party who caused the subpoena or
9
order to issue in the other litigation that some or all of the material covered by the
10
subpoena or order is subject to this Protective Order. Such notification shall
11
include a copy of this Stipulated Protective Order; and
12
(c) cooperate with respect to all reasonable procedures sought to be
13
pursued by the Designating Party whose Protected Material may be affected. If the
14
Designating Party timely seeks a protective order, the Party served with the
15
subpoena or court order shall not produce any information designated in this action
16
as “CONFIDENTIAL” before a determination by the court from which the
17
subpoena or order issued, unless the Party has obtained the Designating Party’s
18
19 permission. The Designating Party shall bear the burden and expense of seeking
20 protection in that court of its confidential material and nothing in these provisions
21 should be construed as authorizing or encouraging a Receiving Party in this Action
22 to disobey a lawful directive from another court.
23 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
24 BE PRODUCED IN THIS LITIGATION
25 (a) The terms of this Order are applicable to information produced by
26 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
27 information produced by Non-Parties in connection with this litigation is protected
28 by the remedies and relief provided by this Order. Nothing in these provisions
11
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 12 of 16 Page ID #:148
1
should be construed as prohibiting a Non-Party from seeking additional
2
protections.
3
(b) In the event that a Party is required, by a valid discovery request,
4
to produce a Non-Party’s confidential information in its possession, and the Party
5
is subject to an agreement with the Non-Party not to produce the Non-Party’s
6
confidential information, then the Party shall:
7
(1) promptly notify in writing the Requesting Party and the
8
Non-Party that some or all of the information requested is subject to a
9
confidentiality agreement with a Non-Party;
10
(2) promptly provide the Non-Party with a copy of the
11
Stipulated Protective Order in this Action, the relevant discovery request(s), and a
12
reasonably specific description of the information requested; and
13
(3) make the information requested available for inspection by
14
the Non-Party, if requested.
15
(c) If the Non-Party fails to seek a protective order from this court
16
within 14 days of receiving the notice and accompanying information, the
17
Receiving Party may produce the Non-Party’s confidential information responsive
18
19 to the discovery request. If the Non-Party timely seeks a protective order, the
20 Receiving Party shall not produce any information in its possession or control that
21 is subject to the confidentiality agreement with the Non-Party before a
22 determination by the court. Absent a court order to the contrary, the Non-Party
23 shall bear the burden and expense of seeking protection in this court of its
24 Protected Material.
25 12. UNAUTHORIZED DISCLOSURE OF PROTECTED
26 MATERIAL
27 If a Receiving Party learns that, by inadvertence or otherwise, it has
28 disclosed Protected Material to any person or in any circumstance not authorized
12
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 13 of 16 Page ID #:149
1
under this Stipulated Protective Order, the Receiving Party must immediately (a)
2
notify in writing the Designating Party of the unauthorized disclosures, (b) use its
3
best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
4
the person or persons to whom unauthorized disclosures were made of all the terms
5
of this Order, and (d) request such person or persons to execute the
6
“Acknowledgment an Agreement to Be Bound” attached hereto as Exhibit A.
7
13. INADVERTENT PRODUCTION OF PRIVILEGED OR
8
OTHERWISE PROTECTED MATERIAL
9
When a Producing Party gives notice to Receiving Parties that certain
10
inadvertently produced material is subject to a claim of privilege or other
11
protection, the obligations of the Receiving Parties are those set forth in Federal
12
Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to modify
13
whatever procedure may be established in an e-discovery order that provides for
14
production without prior privilege review. Pursuant to Federal Rule of Evidence
15
502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
16
of a communication or information covered by the attorney-client privilege or
17
work product protection, the parties may incorporate their agreement in the
18
19 stipulated protective order submitted to the court.
20 14. MISCELLANEOUS
21 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
22 person to seek its modification by the Court in the future.
23 14.2 Right to Assert Other Objections. By stipulating to the entry of this
24 Protective Order, no Party waives any right it otherwise would have to object to
25 disclosing or producing any information or item on any ground not addressed in
26 this Stipulated Protective Order. Similarly, no Party waives any right to object on
27 any ground to use in evidence of any of the material covered by this Protective
28 Order.
13
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 14 of 16 Page ID #:150
1
14.3 Filing Protected Material. A Party that seeks to file under seal any
2
Protected Material must comply with Local Civil Rule 79-5. Protected Material
3
may only be filed under seal pursuant to a court order authorizing the sealing of the
4
specific Protected Material. If a Party’s request to file Protected Material under
5
seal is denied by the court, then the Receiving Party may file the information in the
6
public record unless otherwise instructed by the court.
7
15. FINAL DISPOSITION
8
After the final disposition of this Action, as defined in paragraph 6, within
9
60 days of a written request by the Designating Party, each Receiving Party must
10
return all Protected Material to the Producing Party or destroy such material. As
11
used in this subdivision, “all Protected Material” includes all copies, abstracts,
12
compilations, summaries, and any other format reproducing or capturing any of the
13
Protected Material. Whether the Protected Material is returned or destroyed, the
14
Receiving Party must submit a written certification to the Producing Party (and, if
15
not the same person or entity, to the Designating Party) by the 60-day deadline that
16
(1) identifies (by category, where appropriate) all the Protected Material that was
17
returned or destroyed and (2) affirms that the Receiving Party has not retained any
18
19 copies, abstracts, compilations, summaries or any other format reproducing or
20 capturing any of the Protected Material. Notwithstanding this provision, Counsel
21 are entitled to retain an archival copy of all pleadings, motion papers, trial,
22 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
23 and trial exhibits, expert reports, attorney work product, and consultant and expert
24 work product, even if such materials contain Protected Material. Any such archival
25 copies that contain or constitute Protected Material remain subject to this
26 Protective Order as set forth in Section 6 (DURATION).
27 16. VIOLATION
28 Any violation of this Order may be punished by appropriate measures
14
Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page150f16 Page ID #:151
I including, without limitation, contempt proceedings and/or monetary sanctions.
> || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: March 18, 2022
/
xh bp ee
9 ited States Magistrate Judge
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28
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Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 16 of 16 Page ID #:152
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [full name], of
4 [address], declare under penalty of perjury that I have read in its
5 entirety and understand the Stipulated Protective Order that was issued by the United
6 States District Court for the Central District of California on March 18, 2022, in the
7
case of Veronica Rivera v. Medtronic USA, Inc., Does 1-50, Case No. 8:21-cv-
8
01431-DOC-JDE. I agree to comply with and to be bound by all the terms of this
9
Stipulated Protective Order, and I understand and acknowledge that failure to so
10
comply could expose me to sanctions and punishment in the nature of contempt. I
11
solemnly promise that I will not disclose in any manner any information or item that
12
is subject to this Stipulated Protective Order to any person or entity except in strict
13
compliance with the provisions of this Stipulated Protective Order.
14
I further agree to submit to the jurisdiction of the United States District Court
15
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint [full name]
19 of [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
24 Signature:
25 Printed Name:
26 Date:
27 City and State Where Sworn and Signed:
28
16