The opinion
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 1 of 24 Page ID #:214
1 Todd M. Friedman (SBN 216752)
Adrian R. Bacon (SBN 280332)
Meghan E. George (SBN 274525)
2
Thomas E. Wheeler (SBN 308789)
LAW OFFICES OF TODD M. FRIEDMAN, P.C.
3 21031 Ventura Blvd, Suite 340
Woodland Hills, CA 91364
4 Phone: 323-306-4234s
Fax: 866-633-0228
5 tfriedman@toddflaw.com
abacon@toddflaw.com
mgeorge@toddflaw.com
6 twheeler@toddflaw.com
Attorneys for Plaintiffs, and all others similarly situated
7
UNITED STATES DISTRICT COURT
8
9 CENTRAL DISTRICT OF CALIFORNIA
10
EDWIN BAZARGANFARD and Case No. 2:21-CV-02272-CBM-PLAx
11 B thA emR sA eK lv eG s O anL dA aN ll, oo tn h eb re sh sa il mf o ilf a rly
situated,
12
13 Plaintiffs, STIPULATED PROTECTIVE
v. ORDER
14
CLUB 360 LLC; ABC FINANCIAL
SERVICES, LLC; JEHANGIR
15 MEHER, and DOES 1 – 10,
16 Defendants,
17
18
I. PURPOSES AND LIMITATIONS
19
A. Discovery in this action is likely to involve production of
20
21 confidential, proprietary, or private information for which special
22 protection from public disclosure and from use for any purpose other
23
than prosecuting this litigation may be warranted. Accordingly, the
24
1
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 2 of 24 Page ID #:215
1 parties hereby stipulate to and petition the Court to enter the
2 following Stipulated Protective Order. The parties acknowledge that
3
this Order does not confer blanket protections on all disclosures or
4
responses to discovery and that the protection it affords from public
5
disclosure and use extends only to the limited information or items
6
7 that are entitled to confidential treatment under the applicable legal
8 principles. The parties further acknowledge, as set forth in Section
9 XIII(C), below, that this Stipulated Protective Order does not entitle
10
them to file confidential information under seal; Civil Local Rule 79-
11
5 sets forth the procedures that must be followed and the standards
12
that will be applied when a party seeks permission from the Court to
13
14 file material under seal.
15 II. GOOD CAUSE STATEMENT
16 A. This action is likely to involve trade secrets, customer and
17
pricing lists and other valuable research, development, commercial,
18
financial, technical and/or proprietary information for which special
19
protection from public disclosure and from use for any purpose other
20
21 than prosecution of this action is warranted. Such confidential and
22 proprietary materials and information consist of, among other
23 things, confidential business or financial information, information
24
2
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 3 of 24 Page ID #:216
1 regarding confidential business practices, or other confidential
2 research, development, or commercial information (including
3
information implicating privacy rights of third parties), information
4
otherwise generally unavailable to the public, or which may be
5
privileged or otherwise protected from disclosure under state or
6
7 federal statutes, court rules, case decisions, or common law.
8 Accordingly, to expedite the flow of information, to facilitate the
9 prompt resolution of disputes over confidentiality of discovery
10
materials, to adequately protect information the parties are entitled
11
to keep confidential, to ensure that the parties are permitted
12
reasonable necessary uses of such material in preparation for and in
13
14 the conduct of trial, to address their handling at the end of the
15 litigation, and serve the ends of justice, a protective order for such
16 information is justified in this matter. It is the intent of the parties
17
that information will not be designated as confidential for tactical
18
reasons and that nothing be so designated without a good faith belief
19
that it has been maintained in a confidential, non-public manner,
20
21 and there is good cause why it should not be part of the public record
22 of this case.
23
24
3
STIPULATED PROTECTIVE ORDER
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1 III. DEFINITIONS
2 A. Action: This pending federal lawsuit
3
B. Challenging Party: A Party or Non-Party that challenges the
4
designation of information or items under this Order.
5
C. “CONFIDENTIAL” Information or Items: Information
6
7 (regardless of how it is generated, stored or maintained) or tangible
8 things that qualify for protection under Federal Rule of Civil
9 Procedure 26(c), and as specified above in the Good Cause
10
Statement.
11
D. Counsel: Outside Counsel of Record and House Counsel (as
12
well as their support staff).
13
14 E. Designating Party: A Party or Non-Party that designates
15 information or items that it produces in disclosures or in responses
16 to discovery as “CONFIDENTIAL.”
17
F. Disclosure or Discovery Material: All items or information,
18
regardless of the medium or manner in which it is generated, stored,
19
or maintained (including, among other things, testimony,
20
21 transcripts, and tangible things), that are produced or generated in
22 disclosures or responses to discovery in this matter.
23
24
4
STIPULATED PROTECTIVE ORDER
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1 G. Expert: A person with specialized knowledge or experience in
2 a matter pertinent to the litigation who has been retained by a Party
3
or its counsel to serve as an expert witness or as a consultant in this
4
Action.
5
H. House Counsel: Attorneys who are employees of a party to this
6
7 Action. House Counsel does not include Outside Counsel of Record
8 or any other outside counsel.
9 I. Non-Party: Any natural person, partnership, corporation,
10
association, or other legal entity not named as a Party to this action.
11
J. Outside Counsel of Record: Attorneys who are not employees
12
of a party to this Action but are retained to represent or advise a
13
14 party to this Action and have appeared in this Action on behalf of
15 that party or are affiliated with a law firm which has appeared on
16 behalf of that party, and includes support staff.
17
K. Party: Any party to this Action, including all of its officers,
18
directors, employees, consultants, retained experts, and Outside
19
Counsel of Record (and their support staffs).
20
21 L. Producing Party: A Party or Non-Party that produces
22 Disclosure or Discovery Material in this Action.
23
24
5
STIPULATED PROTECTIVE ORDER
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1 M. Professional Vendors: Persons or entities that provide
2 litigation support services (e.g., photocopying, videotaping,
3
translating, preparing exhibits or demonstrations, and organizing,
4
storing, or retrieving data in any form or medium) and their
5
employees and subcontractors.
6
7 N. Protected Material: Any Disclosure or Discovery Material that
8 is designated as “CONFIDENTIAL.”
9 O. Receiving Party: A Party that receives Disclosure or Discovery
10
Material from a Producing Party.
11
IV. SCOPE
12
A. The protections conferred by this Stipulation and Order cover
13
14 not only Protected Material (as defined above), but also (1) any
15 information copied or extracted from Protected Material; (2) all
16 copies, excerpts, summaries, or compilations of Protected Material;
17
and (3) any testimony, conversations, or presentations by Parties or
18
their Counsel that might reveal Protected Material.
19
B. Any use of Protected Material at trial shall be governed by the
20
21 orders of the trial judge. This Order does not govern the use of Protected
22 Material at trial.
23
24
6
STIPULATED PROTECTIVE ORDER
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1 V. DURATION
2 A. Once a case proceeds to trial, all of the information that was
3
designated as confidential or maintained pursuant to this Protective
4
Order becomes public and will be presumptively available to all
5
members of the public, including the press, unless compelling
6
7 reasons supported by specific factual findings to proceed otherwise
8 are made to the trial judge in advance of the trial. See Kamakana v.
9 City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006)
10
(distinguishing “good cause” showing for sealing documents
11
produced in discovery from “compelling reasons” standard when
12
merits-related documents are part of court record). Accordingly, the
13
14 terms of this Protective Order do not extend beyond the
15 commencement of the trial.
16 VI. DESIGNATING PROTECTED MATERIAL
17
A. Exercise of Restraint and Care in Designating Material for
18
Protection
19
1. Each Party or Non-Party that designates information or
20
21 items for protection under this Order must take care to limit
22 any such designation to specific material that qualifies under
23 the appropriate standards. The Designating Party must
24
7
STIPULATED PROTECTIVE ORDER
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1 designate for protection only those parts of material,
2 documents, items, or oral or written communications that
3
qualify so that other portions of the material, documents,
4
items, or communications for which protection is not
5
warranted are not swept unjustifiably within the ambit of this
6
7 Order.
8 2. Mass, indiscriminate, or routinized designations are
9 prohibited. Designations that are shown to be clearly
10
unjustified or that have been made for an improper purpose
11
(e.g., to unnecessarily encumber the case development process
12
or to impose unnecessary expenses and burdens on other
13
14 parties) may expose the Designating Party to sanctions.
15 3. If it comes to a Designating Party’s attention that
16 information or items that it designated for protection do not
17
qualify for protection, that Designating Party must promptly
18
notify all other Parties that it is withdrawing the inapplicable
19
designation.
20
21 B. Manner and Timing of Designations
22 1. Except as otherwise provided in this Order (see, e.g.,
23 Section B(2)(b) below), or as otherwise stipulated or ordered,
24
8
STIPULATED PROTECTIVE ORDER
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1 Disclosure or Discovery Material that qualifies for protection
2 under this Order must be clearly so designated before the
3
material is disclosed or produced.
4
2. Designation in conformity with this Order requires the
5
following:
6
7 a. For information in documentary form (e.g., paper
8 or electronic documents, but excluding transcripts of
9 depositions or other pretrial or trial proceedings), that
10
the Producing Party affix at a minimum, the legend
11
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL
12
legend”), to each page that contains protected material.
13
14 If only a portion or portions of the material on a page
15 qualifies for protection, the Producing Party also must
16 clearly identify the protected portion(s) (e.g., by making
17
appropriate markings in the margins).
18
b. A Party or Non-Party that makes original
19
documents available for inspection need not designate
20
21 them for protection until after the inspecting Party has
22 indicated which documents it would like copied and
23 produced. During the inspection and before the
24
9
STIPULATED PROTECTIVE ORDER
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1 designation, all of the material made available for
2 inspection shall be deemed “CONFIDENTIAL.” After the
3
inspecting Party has identified the documents it wants
4
copied and produced, the Producing Party must
5
determine which documents, or portions thereof, qualify
6
7 for protection under this Order. Then, before producing
8 the specified documents, the Producing Party must affix
9 the “CONFIDENTIAL legend” to each page that contains
10
Protected Material. If only a portion or portions of the
11
material on a page qualifies for protection, the Producing
12
Party also must clearly identify the protected portion(s)
13
14 (e.g., by making appropriate markings in the margins).
15 c. For testimony given in depositions, that the
16 Designating Party identify the Disclosure or Discovery
17
Material on the record, before the close of the deposition
18
all protected testimony.
19
d. For information produced in form other than
20
21 document and for any other tangible items, that the
22 Producing Party affix in a prominent place on the
23 exterior of the container or containers in which the
24
10
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 11 of 24 Page ID #:224
1 information is stored the legend “CONFIDENTIAL.” If
2 only a portion or portions of the information warrants
3
protection, the Producing Party, to the extent practicable,
4
shall identify the protected portion(s).
5
C. Inadvertent Failure to Designate
6
7 1. If timely corrected, an inadvertent failure to designate
8 qualified information or items does not, standing alone, waive
9 the Designating Party’s right to secure protection under this
10
Order for such material. Upon timely correction of a
11
designation, the Receiving Party must make reasonable efforts
12
to assure that the material is treated in accordance with the
13
14 provisions of this Order.
15 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
16 A. Timing of Challenges
17
1. Any party or Non-Party may challenge a designation of
18
confidentiality at any time that is consistent with the Court’s
19
Scheduling Order.
20
21 B. Meet and Confer
22 1. The Challenging Party shall initiate the dispute
23 resolution process under Local Rule 37.1 et seq.
24
11
STIPULATED PROTECTIVE ORDER
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1 C. The burden of persuasion in any such challenge proceeding
2 shall be on the Designating Party. Frivolous challenges, and those
3
made for an improper purpose (e.g., to harass or impose unnecessary
4
expenses and burdens on other parties) may expose the Challenging
5
Party to sanctions. Unless the Designating Party has waived or
6
7 withdrawn the confidentiality designation, all parties shall continue
8 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
10
on the challenge.
11
VIII. ACCESS TO AND USE OF PROTECTED MATERIAL
12
A. Basic Principles
13
14 1. A Receiving Party may use Protected Material that is
15 disclosed or produced by another Party or by a Non-Party in
16 connection with this Action only for prosecuting, defending, or
17
attempting to settle this Action. Such Protected Material may
18
be disclosed only to the categories of persons and under the
19
conditions described in this Order. When the Action has been
20
21 terminated, a Receiving Party must comply with the provisions
22 of Section XIV below.
23
24
12
STIPULATED PROTECTIVE ORDER
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1 2. Protected Material must be stored and maintained by a
2 Receiving Party at a location and in a secure manner that
3
ensures that access is limited to the persons authorized under
4
this Order.
5
B. Disclosure of “CONFIDENTIAL” Information or Items
6
7 1. Unless otherwise ordered by the Court or permitted in
8 writing by the Designating Party, a Receiving Party may
9 disclose any information or item designated
10
“CONFIDENTIAL” only to:
11
a. The Receiving Party’s Outside Counsel of Record in
12
this Action, as well as employees of said Outside Counsel
13
14 of Record to whom it is reasonably necessary to disclose
15 the information for this Action;
16 b. The officers, directors, and employees (including
17
House Counsel) of the Receiving Party to whom
18
disclosure is reasonably necessary for this Action;
19
c. Experts (as defined in this Order) of the Receiving
20
21 Party to whom disclosure is reasonably necessary for this
22 Action and who have signed the “Acknowledgment and
23 Agreement to Be Bound” (Exhibit A);
24
13
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 14 of 24 Page ID #:227
1 d. The Court and its personnel;
2 e. Court reporters and their staff;
3
f. Professional jury or trial consultants, mock jurors,
4
and Professional Vendors to whom disclosure is
5
reasonably necessary or this Action and who have signed
6
7 the “Acknowledgment and Agreement to be Bound”
8 attached as Exhibit A hereto;
9 g. The author or recipient of a document containing
10
the information or a custodian or other person who
11
otherwise possessed or knew the information;
12
h. During their depositions, witnesses, and attorneys
13
14 for witnesses, in the Action to whom disclosure is
15 reasonably necessary provided: (i) the deposing party
16 requests that the witness sign the “Acknowledgment and
17
Agreement to Be Bound;” and (ii) they will not be
18
permitted to keep any confidential information unless
19
they sign the “Acknowledgment and Agreement to Be
20
21 Bound,” unless otherwise agreed by the Designating
22 Party or ordered by the Court. Pages of transcribed
23 deposition testimony or exhibits to depositions that
24
14
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 15 of 24 Page ID #:228
1 reveal Protected Material may be separately bound by the
2 court reporter and may not be disclosed to anyone except
3
as permitted under this Stipulated Protective Order; and
4
i. Any mediator or settlement officer, and their
5
supporting personnel, mutually agreed upon by any of
6
7 the parties engaged in settlement discussions.
8 IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED
9 PRODUCED IN OTHER LITIGATION
10
A. If a Party is served with a subpoena or a court order issued in
11
other litigation that compels disclosure of any information or items
12
designated in this Action as “CONFIDENTIAL,” that Party must:
13
14 1. Promptly notify in writing the Designating Party. Such
15 notification shall include a copy of the subpoena or court order;
16 2. Promptly notify in writing the party who caused the
17
subpoena or order to issue in the other litigation that some or
18
all of the material covered by the subpoena or order is subject
19
to this Protective Order. Such notification shall include a copy
20
21 of this Stipulated Protective Order; and
22
23
24
15
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 16 of 24 Page ID #:229
1 3. Cooperate with respect to all reasonable procedures
2 sought to be pursued by the Designating Party whose Protected
3
Material may be affected.
4
B. If the Designating Party timely seeks a protective order, the
5
Party served with the subpoena or court order shall not produce any
6
7 information designated in this action as “CONFIDENTIAL” before a
8 determination by the Court from which the subpoena or order
9 issued, unless the Party has obtained the Designating Party’s
10
permission. The Designating Party shall bear the burden and
11
expense of seeking protection in that court of its confidential
12
material and nothing in these provisions should be construed as
13
14 authorizing or encouraging a Receiving Party in this Action to
15 disobey a lawful directive from another court.
16 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
17
PRODUCED IN THIS LITIGATION
18
A. The terms of this Order are applicable to information produced
19
by a Non-Party in this Action and designated as “CONFIDENTIAL.”
20
21 Such information produced by Non-Parties in connection with this
22 litigation is protected by the remedies and relief provided by this
23
24
16
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 17 of 24 Page ID #:230
1 Order. Nothing in these provisions should be construed as
2 prohibiting a Non-Party from seeking additional protections.
3
B. In the event that a Party is required, by a valid discovery
4
request, to produce a Non-Party’s confidential information in its
5
possession, and the Party is subject to an agreement with the Non-
6
7 Party not to produce the Non-Party’s confidential information, then
8 the Party shall:
9 1. Promptly notify in writing the Requesting Party and the
10
Non-Party that some or all of the information requested is
11
subject to a confidentiality agreement with a Non-Party;
12
2. Promptly provide the Non-Party with a copy of the
13
14 Stipulated Protective Order in this Action, the relevant
15 discovery request(s), and a reasonably specific description of
16 the information requested; and
17
3. Make the information requested available for inspection
18
by the Non-Party, if requested.
19
C. If the Non-Party fails to seek a protective order from this court
20
21 within 14 days of receiving the notice and accompanying
22 information, the Receiving Party may produce the Non-Party’s
23 confidential information responsive to the discovery request. If the
24
17
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 18 of 24 Page ID #:231
1 Non-Party timely seeks a protective order, the Receiving Party shall
2 not produce any information in its possession or control that is
3
subject to the confidentiality agreement with the Non-Party before a
4
determination by the court. Absent a court order to the contrary, the
5
Non-Party shall bear the burden and expense of seeking protection
6
7 in this court of its Protected Material.
8 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED
9 MATERIAL
10
A. If a Receiving Party learns that, by inadvertence or otherwise, it
11
has disclosed Protected Material to any person or in any
12
circumstance not authorized under this Stipulated Protective Order,
13
14 the Receiving Party must immediately (1) notify in writing the
15 Designating Party of the unauthorized disclosures, (2) use its best
16 efforts to retrieve all unauthorized copies of the Protected Material,
17
(3) inform the person or persons to whom unauthorized disclosures
18
were made of all the terms of this Order, and (4) request such person
19
or persons to execute the “Acknowledgment and Agreement to be
20
21 Bound” that is attached hereto as Exhibit A.
22
23
24
18
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 19 of 24 Page ID #:232
1 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR
2 OTHERWISE PROTECTED MATERIAL
3
A. When a Producing Party gives notice to Receiving Parties that
4
certain inadvertently produced material is subject to a claim of
5
privilege or other protection, the obligations of the Receiving Parties
6
7 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
8 This provision is not intended to modify whatever procedure may be
9 established in an e-discovery order that provides for production
10
without prior privilege review. Pursuant to Federal Rule of Evidence
11
502(d) and (e), insofar as the parties reach an agreement on the
12
effect of disclosure of a communication or information covered by
13
14 the attorney-client privilege or work product protection, the parties
15 may incorporate their agreement in the Stipulated Protective Order
16 submitted to the Court.
17
XIII. MISCELLANEOUS
18
A. Right to Further Relief
19
1. Nothing in this Order abridges the right of any person to
20
21 seek its modification by the Court in the future.
22 B. Right to Assert Other Objections
23
24
19
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 20 of 24 Page ID #:233
1 1. By stipulating to the entry of this Protective Order, no
2 Party waives any right it otherwise would have to object to
3
disclosing or producing any information or item on any ground
4
not addressed in this Stipulated Protective Order. Similarly, no
5
Party waives any right to object on any ground to use in
6
7 evidence of any of the material covered by this Protective
8 Order.
9 C. Filing Protected Material
10
1. A Party that seeks to file under seal any Protected
11
Material must comply with Civil Local Rule 79-5. Protected
12
Material may only be filed under seal pursuant to a court order
13
14 authorizing the sealing of the specific Protected Material at
15 issue. If a Party's request to file Protected Material under seal
16 is denied by the Court, then the Receiving Party may file the
17
information in the public record unless otherwise instructed by
18
the Court.
19
XIV. FINAL DISPOSITION
20
21 A. After the final disposition of this Action, as defined in Section
22 V, within sixty (60) days of a written request by the Designating
23 Party, each Receiving Party must return all Protected Material to the
24
20
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 21 of 24 Page ID #:234
1 Producing Party or destroy such material. As used in this
2 subdivision, “all Protected Material” includes all copies, abstracts,
3
compilations, summaries, and any other format reproducing or
4
capturing any of the Protected Material. Whether the Protected
5
Material is returned or destroyed, the Receiving Party must submit a
6
7 written certification to the Producing Party (and, if not the same
8 person or entity, to the Designating Party) by the 60 day deadline
9 that (1) identifies (by category, where appropriate) all the Protected
10
Material that was returned or destroyed and (2) affirms that the
11
Receiving Party has not retained any copies, abstracts, compilations,
12
summaries or any other format reproducing or capturing any of the
13
14 Protected Material. Notwithstanding this provision, Counsel are
15 entitled to retain an archival copy of all pleadings, motion papers,
16 trial, deposition, and hearing transcripts, legal memoranda,
17
correspondence, deposition and trial exhibits, expert reports,
18
attorney work product, and consultant and expert work product,
19
even if such materials contain Protected Material. Any such archival
20
21 copies that contain or constitute Protected Material remain subject
22 to this Protective Order as set forth in Section V.
23
24
21
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 22 of 24 Page ID #:P35
1 B. — Any violation of this Order may be punished by any and all
2 appropriate measures including, without limitation, contempt
proceedings and/or monetary sanctions.
5
7 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated:_May 26, 2022 /s/ Todd M. Friedman
9 Todd M. Friedman
10 Attorneys for Plaintiffs
11
Dated: May 26, 2022 /s/ Hassan Elrakabawy
12 Attorneys for Defendants
13
14 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
15 Galex< - Marmot
Dated: May 31, 2022
16 HONORABLE PAUL L. ABRAMS
17 United States Magistrate Judge
18
19
20
21
29
23
24
22
STIPULATED PROTECTIVEORDER.
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 23 of 24 Page ID #:236
1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3
I, [print or type full name], of
4
[print or type full address], declare under penalty of
5
perjury that I have read in its entirety and understand the Stipulated
6
7 Protective Order that was issue by the United States District Court for the
8 Central District of California on [DATE] in the case of
9 [insert formal name of the case and the number and initials
10
assigned to it by the Court]. I agree to comply with and to be bound by all
11
the terms of this Stipulated Protective Order and I understand and
12
acknowledge that failure to so comply could expose me to sanctions and
13
14 punishment in the nature of contempt. I solemnly promise that I will not
15 disclose in any manner any information or item that is subject to this
16 Stipulated Protective Order to any person or entity except in strict
17
compliance with the provisions of this Order.
18
I further agree to submit to the jurisdiction of the United States
19
District Court for the Central District of California for the purpose of
20
21 enforcing the terms of this Stipulated Protective Order, even if such
22 enforcement proceedings occur after termination of this action. I hereby
23 appoint [print or type full name] of
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23
STIPULATED PROTECTIVE ORDER
Case 2:21-cv-02272-CBM-PLA Document 34 Filed 05/31/22 Page 24 of 24 Page ID #:237
1 [print or type full address and telephone number] as my
2 California agent for service of process in connection with this action or any
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proceedings related to enforcement of this Stipulated Protective Order.
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Date:
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City and State where sworn and signed:
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7 Printed Name:
8 Signature:
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STIPULATED PROTECTIVE ORDER