Opinion

Jayson D. Palmer v. Primerica Life Insurance Company

Court: District Court, C.D. California
Filed: Jun 10, 2022
Cited by: 0 cases
Authority: More cited than 16.3%

distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record

How later courts described this case

distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record
even stipulated protective orders require good 12 cause showing

Written by the judges who cited it.

The opinion

Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 1 of 17 Page ID #:538

1 Ophir Johna (SBN CA 228193)

ojohna@maynardcooper.com

2 Vivian I. Orlando (SBN CA 213833)

vorlando@maynardcooper.com

3 MAYNARD COOPER & GALE

10100 Santa Monica Boulevard, Suite 550

4 Los Angeles, CA 90067

Telephone: (310) 596-4500

Attorneys for Defendant

6 Primerica Life Insurance Company

8 UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

JAYSON D. PALMER, JUDITH Case No. 2:21-cv-00914-AB

PALMER, AND JENNIFER (AFMx)

WITHERSPOON,

13 Plaintiff,

STIPULATED PROTECTIVE

14 vs. ORDER REGARDING NON-

DISCLOSURE OF

15 PRIMERICA LIFE INSURANCE CONFIDENTIAL

16 COMPANY, I NFORMATION1

17 Defendant. Complaint Filed: February 1, 2021

19 1. A. PURPOSES AND LIMITATIONS

20 Discovery and disclosures in this action are likely to involve production of

21 confidential, proprietary and/or private information for which special protection from

22 public disclosure and from use for any purpose other than prosecuting this litigation

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

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

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

1 This Stipulated Protective Order is based substantially on the model protective

order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures.

Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 2 of 17 Page ID #:539

1 and that the protection it affords from public disclosure and use extends only to the

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

3 applicable legal principles.

5 B. GOOD CAUSE STATEMENT

This action is likely to involve trade secrets and/or other confidential and

proprietary materials, such as records reflecting operational policies and procedures,

underwriting guidelines, claims manuals and procedures, other company manuals,

private information pertaining to individuals, etc., for which special protection from

public disclosure and from use for any purpose other than prosecution of this action

is warranted. Such confidential and proprietary materials and information consist of,

among other things, confidential business or financial information, information

regarding confidential business practices and procedures, or other confidential

research, development, or commercial information (including information

implicating privacy rights of third parties), information otherwise generally

unavailable to the public, or which may be privileged or otherwise protected from

disclosure under state or federal statutes, court rules, case decisions, or common law.

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

of disputes over confidentiality of discovery materials, to adequately protect

information the parties are entitled to keep confidential, to ensure that the parties are

permitted reasonable necessary uses of such material in preparation for and in the

conduct of trial, to address their handling at the end of the litigation, and serve the

ends of justice, a protective order for such information is justified in this matter. It is

the intent of the parties that information will not be designated as confidential for

tactical reasons and that nothing be so designated without a good faith belief that it

has been maintained in a confidential, non-public manner, and there is good cause

why it should not be part of the public record of this case.

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1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

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

3 Stipulated Protective Order does not entitle them to file confidential information

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

5 the standards that will be applied when a party seeks permission from the court to file

material under seal.

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

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

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

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

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

187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

cause showing), and a specific showing of good cause or compelling reasons with

proper evidentiary support and legal justification, must be made with respect to

Protected Material that a party seeks to file under seal. The parties’ mere designation

of Disclosure or Discovery Material as CONFIDENTIAL does not— without the

submission of competent evidence by declaration, establishing that the material

sought to be filed under seal qualifies as confidential, privileged, or otherwise

protectable—constitute good cause.

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

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

sought shall be narrowly tailored to serve the specific interest to be protected. See

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

or type of information, document, or thing sought to be filed or introduced under seal

in connection with a dispositive motion or trial, the party seeking protection must

articulate compelling reasons, supported by specific facts and legal justification, for

the requested sealing order. Again, competent evidence supporting the application to

27 file documents under seal must be provided by declaration.

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

2 its entirety will not be filed under seal if the confidential portions can be redacted. If

3 documents can be redacted, then a redacted version for public viewing, omitting only

4 the confidential, privileged, or otherwise protectable portions of the document, shall

5 be filed. Any application that seeks to file documents under seal in their entirety

should include an explanation of why redaction is not feasible.

2. DEFINITIONS

2.1 Action: this pending federal lawsuit.

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

of information or items under this Order.

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

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

under Federal Rule of Civil Procedure 26(c), and as specified above in the Good

Cause Statement.

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

support staff).

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

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

“CONFIDENTIAL.”

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

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

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

generated in disclosures or responses to discovery in this matter.

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

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

an expert witness or as a consultant in this Action.

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1 2.8 House Counsel: attorneys who are employees of a party to this Action.

2 House Counsel does not include Outside Counsel of Record or any other outside

3 counsel.

4 2.9 Non-Party: any natural person, partnership, corporation, association or

5 other legal entity not named as a Party to this action.

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

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

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

has appeared on behalf of that party, and includes support staff.

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

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

support staffs).

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

Discovery Material in this Action.

2.13 Professional Vendors: persons or entities that provide litigation support

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

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

and their employees and subcontractors.

2.14 Protected Material: any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL.”

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

from a Producing Party.

3. SCOPE

The protections conferred by this Stipulation and Order cover not only

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

from Protected Material; (2) all copies, excerpts, summaries, or compilations of

Protected Material; and (3) any testimony, conversations, or presentations by Parties

Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 6 of 17 Page ID #:543

1 or their Counsel that might reveal Protected Material. Nothing in this order shall

2 prevent the parties from negotiating additional protections for specific categories of

3 documents or information.

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

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

4. DURATION

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

CONFIDENTIAL or maintained pursuant to this protective order used or introduced

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

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

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

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

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

standard when merits-related documents are part of court record). Accordingly, the

terms of this protective order do not extend beyond the commencement of the trial.

5. DESIGNATING PROTECTED MATERIAL

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

Each Party or Non-Party that designates information or items for protection under this

Order must take care to limit any such designation to specific material that qualifies

under the appropriate standards. The Designating Party must designate for protection

only those parts of material, documents, items or oral or written communications that

qualify so that other portions of the material, documents, items, or communications

for which protection is not warranted are not swept unjustifiably within the ambit of

this Order.

Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

2 unnecessary expenses and burdens on other parties) may expose the Designating Party

3 to sanctions.

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

5 designated for protection do not qualify for protection, that Designating Party must

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

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

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

stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

under this Order must be clearly so designated before the material is disclosed or

produced.

Designation in conformity with this Order requires:

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

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

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

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

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

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

in the margins).

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

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

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

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

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

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

or portions thereof, qualify for protection under this Order. Then, before producing

the specified documents, the Producing Party must affix the “CONFIDENTIAL

27 legend” to each page that contains Protected Material. If only a portion or portions

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1 of the material on a page qualifies for protection, the Producing Party also must clearly

2 identify the protected portion(s) (e.g., by making appropriate markings in the

3 margins).

4 (b) for testimony given in depositions, that the Designating Party either (i)

5 identify the Disclosure or Discovery Material on the record or (ii) provisionally

designate the entire transcript as Confidential and provide narrowed designations

within thirty (30) days after delivery of the deposition transcript by the court reporter.

This deadline may be extended by mutual agreement of the parties. During the

pendency of the thirty-day period, the entire transcript shall be treated as confidential

absent agreement by the parties.

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

of the container or containers in which the information is stored the legend

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

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

portion(s).

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

failure to designate qualified information or items does not, standing alone, waive the

Designating Party’s right to secure protection under this Order for such material.

Upon timely correction of a designation, the Receiving Party must make reasonable

efforts to assure that the material is treated in accordance with the provisions of this

Order.

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

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

designation of confidentiality at any time that is consistent with the Court’s

Scheduling Order.

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1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

2 resolution process under Local Rule 37-1 et seq.

3 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

4 joint stipulation pursuant to Local Rule 37-2.

5 6.4 The burden of persuasion in any such challenge proceeding shall be on

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

(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

expose the Challenging Party to sanctions. Unless the Designating Party has waived

or withdrawn the confidentiality designation, all parties shall continue to afford the

material in question the level of protection to which it is entitled under the Producing

Party’s designation until the Court rules on the challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

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

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

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

Protected Material may be disclosed only to the categories of persons and under the

conditions described in this Order. When the Action has been terminated, a Receiving

Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

Protected Material must be stored and maintained by a Receiving Party at a

location and in a secure manner that ensures that access is limited to the persons

authorized under this Order.

7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

otherwise ordered by the court or permitted in writing by the Designating Party, a

Receiving Party may disclose any information or item designated

“CONFIDENTIAL” only to:

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

2 employees of said Outside Counsel of Record to whom it is reasonably necessary to

3 disclose the information for this Action;

4 (b) the officers, directors, and employees (including House Counsel), if any,

5 of the Receiving Party to whom disclosure is reasonably necessary for this Action;

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

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

(d) the court and its personnel;

(e) court reporters and their staff;

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

to whom disclosure is reasonably necessary for this Action and who have signed the

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

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

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

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

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

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

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

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

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

deposition testimony or exhibits to depositions that reveal Protected Material may be

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

permitted under this Stipulated Protective Order; and

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

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

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1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

2 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:

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

include a copy of the subpoena or court order;

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

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

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

this Stipulated Protective Order; and

by the Designating Party whose Protected Material may be affected.

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

the subpoena or court order shall not produce any information designated in this action

as “CONFIDENTIAL” before a determination by the court from which the subpoena

or order issued, unless the Party has obtained the Designating Party’s permission. The

Designating Party shall bear the burden and expense of seeking protection in that court

of its confidential material and nothing in these provisions should be construed as

authorizing or encouraging a Receiving Party in this Action to disobey a lawful

directive from another court.

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

PRODUCED IN THIS LITIGATION

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

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

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

Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 12 of 17 Page ID #:549

1 remedies and relief provided by this Order. Nothing in these provisions should be

2 construed as prohibiting a Non-Party from seeking additional protections.

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

4 a Non-Party’s confidential information in its possession, and the Party is subject to an

5 agreement with the Non-Party not to produce the Non-Party’s confidential

information, then the Party shall:

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

some or all of the information requested is subject to a confidentiality agreement with

a Non-Party;

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

Order in this Action, the relevant discovery request(s), and a reasonably specific

description of the information requested; and

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

if requested.

days of receiving the notice and accompanying information, the Receiving Party may

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

If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

any information in its possession or control that is subject to the confidentiality

agreement with the Non-Party before a determination by the court. Absent a court

order to the contrary, the Non-Party shall bear the burden and expense of seeking

protection in this court of its Protected Material.

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 13 of 17 Page ID #:550

1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

2 persons to whom unauthorized disclosures were made of all the terms of this Order,

3 and (d) request such person or persons to execute the “Acknowledgment and

4 Agreement to Be Bound” that is attached hereto as Exhibit A.

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

inadvertently produced material is subject to a claim of privilege or other protection,

the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

may be established in an e-discovery order that provides for production without prior

privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

parties reach an agreement on the effect of disclosure of a communication or

information covered by the attorney-client privilege or work product protection, the

parties may incorporate their agreement in the stipulated protective order submitted

to the court.

12. MISCELLANEOUS

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

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

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

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

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

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

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

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

Protected Material must comply with Local Civil Rule 79-5. Protected Material may

Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 14 of 17 Page ID #:551

1 only be filed under seal pursuant to a court order authorizing the sealing of the specific

2 Protected Material at issue. If a Party’s request to file Protected Material under seal

3 is denied by the court, then the Receiving Party may file the information in the public

4 record unless otherwise instructed by the court.

13. FINAL DISPOSITION

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

days of a written request by the Designating Party, each Receiving Party must return

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

subdivision, “all Protected Material” includes all copies, abstracts, compilations,

summaries, and any other format reproducing or capturing any of the Protected

Material. Whether the Protected Material is returned or destroyed, the Receiving

Party must submit a written certification to the Producing Party (and, if not the same

person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

(by category, where appropriate) all the Protected Material that was returned or

destroyed and (2) affirms that the Receiving Party has not retained any copies,

abstracts, compilations, summaries or any other format reproducing or capturing any

of the Protected Material. Notwithstanding this provision, Counsel are entitled to

retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

reports, attorney work product, and consultant and expert work product, even if such

materials contain Protected Material. Any such archival copies that contain or

constitute Protected Material remain subject to this Protective Order as set forth in

Section 4 (DURATION).

14. VIOLATION

Any violation of this Order may be punished by appropriate measures

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

Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 15 of 17 Page ID #:552

2 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

DATED: June 9, 2022 KLEVATT & ASSOCIATES, LLC

5 By: /s/ David S. Klevatt

DAVID S. KLEVATT

6 TIMOTHY M. HOWE

Attorneys for Plaintiffs Jayson D.

7 Palmer, Judith Palmer, and Jennifer

Witherspoon, individually and on

8 behalf of all others similarly situated

DATED: June 9, 2022 MAYNARD, COOPER & GALE LLP

By: /s/ Ophir Johna

Ophir Johna

Vivian I. Orlando

Attorneys for Defendant Primerica Life

Insurance Company

16 Filer’s Attestation: Pursuant to Local Rule 5-4.3.4(a)(2)(i) regarding

17 signatures, I hereby attest that concurrence in the filing of this document and its

18 content has been obtained by all signatories listed.

20 DATED: June 9, 2022 MAYNARD, COOPER & GALE LLP

By: /s/ Ophir Johna

22 Ophir Johna

Vivian I. Orlando

23 Attorneys for Defendant Primerica Life

Insurance Company

Case 2}21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 16o0f17 Page ID #:553

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

3 || DATED: 6/10/2022

| Qty Mock

‘ ——

7 || HON, ALEXANDER F. MacKINNON

g || United States Magistrate Judge

□ 16

Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 17 of 17 Page ID #:554

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4 I, _____________________________ [print or type full name], of

5 ___________________________________________________________________

[print or type full address], declare under penalty of perjury that I have read in its

entirety and understand the Stipulated Protective Order that was issued by the United

States District Court for the Central District of California on ____________ [date] in

the case of Jayson D. Palmer, et al. v. Primerica Life Insurance Company, Case No.

2:21-cv-00914-AB (AFMx). I agree to comply with and to be bound by all the terms

of this Stipulated Protective Order and I understand and acknowledge that failure to

so comply could expose me to sanctions and punishment in the nature of contempt. I

solemnly promise that I will not disclose in any manner any information or item that

is subject to this Stipulated Protective Order to any person or entity except in strict

compliance with the provisions of this Order.

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

for the Central District of California for the purpose of enforcing the terms of this

Stipulated Protective Order, even if such enforcement proceedings occur after

termination of this action. I hereby appoint __________________________ [print or

type full name] of ________________________________________ [print or type

full address and telephone number] as my California agent for service of process in

connection with this action or any proceedings related to enforcement of this

Stipulated Protective Order.

Date: ______________________________________

City and State where sworn and signed: ___________________________________

Printed name: _______________________________

27 Signature: __________________________________

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