distinguishing “good cause” showing for sealing 22 documents produced in discovery from “compelling reasons” standard when merits- 23 related documents are part of court record
How later courts described this case
- distinguishing “good cause” showing for sealing 22 documents produced in discovery from “compelling reasons” standard when merits- 23 related documents are part of court record
- even stipulated protective orders 14 require good cause showing
Written by the judges who cited it.
The opinion
Case 2:22-cv-00407-FLA-AFM Document 41 Filed 07/06/22 Page 1 of 17 Page ID #:208
1 Elliot G. Johnson (State Bar No. 317303)
johnsoneg@ballardspahr.com
Elanor A. Mulhern (State Bar No. 279103)
2
mulherne@ballardspahr.com
BALLARD SPAHR LLP
3 2029 Century Park East, Suite 1400
Los Angeles, CA 90067-2915
4 Telephone: 424.204.4400
Facsimile: 424.204.4350
5
Attorneys for Defendant
Capital One, N.A. d/b/a Capital One Auto
6 Finance
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 JASMIN NUNEZ; AND, Case No. 2:22-cv-00407-FLA-AFM
ISABEL ALVAREZ,
11 STIPULATED PROTECTIVE
Plaintiffs, ORDER1
12
v. Date Action Filed: January 20, 2022
13 CAPITAL ONE BANK (USA) N.A.;
EQUIFAX INFORMATION
14 SERVICES, LLC; AND
TRANS UNION LLC,
15
Defendants.
16
17
I. PURPOSES AND LIMITATIONS
18
Discovery in this action is likely to involve production of confidential,
19
proprietary, or private information for which special protection from public disclosure
20
and from use for any purpose other than prosecuting this litigation may be warranted.
21
22
23
1 This Stipulated Protective Order is based substantially on the model protective
24 order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures.
1
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1 Accordingly, the parties hereby stipulate to and petition the Court to enter the following
2 Stipulated Protective Order. The parties acknowledge that this Order does not confer
3 blanket protections on all disclosures or responses to discovery and that the protection
4 it affords from public disclosure and use extends only to the limited information or
5 items that are entitled to confidential treatment under the applicable legal principles.
6 II. GOOD CAUSE STATEMENT
7 This action is likely to involve trade secrets, commercial, financial, technical
8 and/or proprietary information for which special protection from public disclosure and
9 from use for any purpose other than prosecution of this action is warranted. Such
10 confidential and proprietary materials and information consist of, among other things,
11 information regarding confidential business practices, or other confidential proprietary
12 commercial information (including information implicating privacy rights of third
13 parties), information otherwise generally unavailable to the public, or which may be
14 privileged or otherwise protected from disclosure under state or federal statutes, court
15 rules, case decisions, or common law. Accordingly, to expedite the flow of information,
16 to facilitate the prompt resolution of disputes over confidentiality of discovery
17 materials, to adequately protect information the parties are entitled to keep
18 confidential, to ensure that the parties are permitted reasonable necessary uses of such
19 material in preparation for and in the conduct of trial, to address their handling at the
20 end of the litigation, and serve the ends of justice, a protective order for such
21 information is justified in this matter. It is the intent of the parties that information
22 will not be designated as confidential for tactical reasons and that nothing be so
23 designated without a good faith belief that it has been maintained in a confidential,
24
2
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1 non-public manner, and there is good cause why it should not be part of the public
2 record of this case.
3 III. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER SEAL
4 The parties further acknowledge, as set forth in Section XIV C., below, that this
5 Stipulated Protective Order does not entitle them to file confidential information under
6 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
7 standards that will be applied when a party seeks permission from the court to file
8 material under seal. There is a strong presumption that the public has a right of access
9 to judicial proceedings and records in civil cases. In connection with non-dispositive
10 motions, good cause must be shown to support a filing under seal. See Kamakana v.
11 City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen.
12 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony
13 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
14 require good cause showing), and a specific showing of good cause or compelling
15 reasons with proper evidentiary support and legal justification, must be made with
16 respect to Protected Material that a party seeks to file under seal. The parties’ mere
17 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— without
18 the submission of competent evidence by declaration, establishing that the material
19 sought to be filed under seal qualifies as confidential, privileged, or otherwise
20 protectable—constitute good cause. Further, if a party requests sealing related to a
21 dispositive motion or trial, then compelling reasons, not only good cause, for the
22 sealing must be shown, and the relief sought shall be narrowly tailored to serve the
23 specific interest to be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665,
24 677-79 (9th Cir. 2010). For each item or type of information, document, or thing sought
3
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1 to be filed or introduced under seal in connection with a dispositive motion or trial, the
2 party seeking protection must articulate compelling reasons, supported by specific facts
3 and legal justification, for the requested sealing order. Again, competent evidence
4 supporting the application to file documents under seal must be provided by
5 declaration.
6 Any document that is not confidential, privileged, or otherwise protectable in its
7 entirety will not be filed under seal if the confidential portions can be redacted. If
8 documents can be redacted, then a redacted version for public viewing, omitting only
9 the confidential, privileged, or otherwise protectable portions of the document, shall be
10 filed. Any application that seeks to file documents under seal in their entirety should
11 include an explanation of why redaction is not feasible.
12 IV. DEFINITIONS
13 A. Action: This pending federal law suit.
14 B. Challenging Party: A Party or Non-Party that challenges the designation
15 of information or items under this Order.
16 C. “CONFIDENTIAL” Information or Items: Information (regardless of how
17 it is generated, stored or maintained) or tangible things that qualify for
18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
19 the Good Cause Statement.
20 D. Counsel: Outside Counsel of Record and House Counsel (as well as their
21 support staff).
22 E. Designating Party: A Party or Non-Party that designates information or
23 items that it produces in disclosures or in responses to discovery as
24 “CONFIDENTIAL.”
4
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1 F. Disclosure or Discovery Material: All items or information, regardless of
2 the medium or manner in which it is generated, stored, or maintained
3 (including, among other things, testimony, transcripts, and tangible things), that
4 are produced or generated in disclosures or responses to discovery in this
5 matter.
6 G. Expert: A person with specialized knowledge or experience in a matter
7 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 H. House Counsel: Attorneys who are employees of a party to this Action.
10 House Counsel does not include Outside Counsel of Record or any other outside
11 counsel.
12 I. Non-Party: Any natural person, partnership, corporation, association, or
13 other legal entity not named as a Party to this action.
14 J. Outside Counsel of Record: Attorneys who are not employees of a party
15 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
17 firm which has appeared on behalf of that party, and includes support staff.
18 K. 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 L. Producing Party: A Party or Non-Party that produces Disclosure or
22 Discovery Material in this Action.
23 M. Professional Vendors: Persons or entities that provide litigation support
24 services (e.g., photocopying, videotaping, translating, preparing exhibits or
5
Case 2:22-cv-00407-FLA-AFM Document 41 Filed 07/06/22 Page 6 of 17 Page ID #:213
1 demonstrations, and organizing, storing, or retrieving data in any form or
2 medium) and their employees and subcontractors.
3 N. Protected Material: Any Disclosure or Discovery Material that is
4 designated as “CONFIDENTIAL.”
5 O. Receiving Party: A Party that receives Disclosure or Discovery Material
6 from a Producing Party.
7 V. SCOPE
8 The protections conferred by this Stipulation and Order cover not only Protected
9 Material (as defined above), but also (1) any information copied or extracted from
10 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
11 Material; and (3) any testimony, conversations, or presentations by Parties or their
12 Counsel that might reveal Protected Material.
13 Any use of Protected Material at trial shall be governed by the orders of the
14 trial judge. This Order does not govern the use of Protected Material at trial.
15 VI. DURATION
16 Once a case proceeds to trial, information that was designated as
17 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as
18 an exhibit at trial becomes public and will be presumptively available to all members of
19 the public, including the press, unless compelling reasons supported by specific factual
20 findings to proceed otherwise are made to the trial judge in advance of the trial. See
21 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
22 documents produced in discovery from “compelling reasons” standard when merits-
23 related documents are part of court record). Accordingly, the terms of this protective
24
6
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1 order do not extend beyond the commencement of the trial.
2 VII. DESIGNATING PROTECTED MATERIAL
3 A. Exercise of Restraint and Care in Designating Material for Protection.
4 Each Party or Non-Party that designates information or items for protection
5 under this Order must take care to limit any such designation to specific material that
6 qualifies under the appropriate standards. The Designating Party must designate for
7 protection only those parts of material, documents, items, or oral or written
8 communications that qualify so that other portions of the material, documents, items,
9 or communications for which protection is not warranted are not swept unjustifiably
10 within the ambit of this Order.
11 Mass, indiscriminate, or routinized designations are prohibited. Designations
12 that are shown to be clearly unjustified or that have been made for an improper
13 purpose (e.g., to unnecessarily encumber the case development process or to impose
14 unnecessary expenses and burdens on other parties) may expose the Designating Party
15 to sanctions.
16 If it comes to a Designating Party’s attention that information or items that it
17 designated for protection do not qualify for protection, that Designating Party must
18 promptly notify all other Parties that it is withdrawing the inapplicable designation.
19 B. Manner and Timing of Designations
20 Except as otherwise provided in this Order (see, e.g., Section B(2)(b) below), or
21 as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for
22 protection under this Order must be clearly so designated before the material is
23 disclosed or produced.
24 Designation in conformity with this Order requires:
7
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1 (a) For information in documentary form (e.g., paper or electronic
2 documents, but excluding transcripts of depositions or other pretrial or trial
3 proceedings), that the Producing Party affix at a minimum, the legend
4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that contains
5 protected material. If only a portion or portions of the material on a page qualifies for
6 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
7 by making appropriate markings in the margins).
8 A Party or Non-Party that makes original documents available for inspection
9 need not designate them for protection until after the inspecting Party has indicated
10 which documents it would like copied and produced. During the inspection and before
11 the designation, all of the material made available for inspection shall be deemed
12 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
13 copied and produced, the Producing Party must determine which documents, or
14 portions thereof, qualify for protection under this Order. Then, before producing the
15 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to
16 each page that contains Protected Material. If only a portion or portions of the material
17 on a page qualifies for protection, the Producing Party also must clearly identify the
18 protected portion(s) (e.g., by making appropriate markings in the margins).
19 (b) For testimony given in depositions, that the Designating Party identify
20 the Disclosure or Discovery Material on the record, before the close of the deposition all
21 protected testimony.
22 (c) For information produced in form other than document and for any other
23 tangible items, that the Producing Party affix in a prominent place on the exterior of the
24 container or containers in which the information is stored the legend
8
Case 2:22-cv-00407-FLA-AFM Document 41 Filed 07/06/22 Page 9 of 17 Page ID #:216
1 “CONFIDENTIAL.” If only a portion or portions of the information warrants
2 protection, the Producing Party, to the extent practicable, shall identify the protected
3 portion(s).
4 C. Inadvertent Failure to Designate
5 If timely corrected, an inadvertent failure to designate qualified information or
6 items does not, standing alone, waive the Designating Party’s right to secure protection
7 under this Order for such material. Upon timely correction of a designation, the
8 Receiving Party must make reasonable efforts to assure that the material is treated in
9 accordance with the provisions of this Order.
10 VIII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
11 A. Timing of Challenges
12 Any party or Non-Party may challenge a designation of confidentiality at any
13 time that is consistent with the Court’s Scheduling Order.
14 B. Meet and Confer
15 The Challenging Party shall initiate the dispute resolution process under Local
16 Rule 37.1 et seq.
17 C. Joint Stipulation
18 Any challenge submitted to the Court shall be via a joint stipulation pursuant to
19 Local Rule 37-2.
20 The burden of persuasion in any such challenge proceeding shall be on the
21 Designating Party. Frivolous challenges, and those made for an improper purpose
22 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
23 expose the Challenging Party to sanctions. Unless the Designating Party has waived or
24 withdrawn the confidentiality designation, all parties shall continue to afford the
9
Case 2:22-cv-00407-FLA-AFM Document 41 Filed 07/06/22 Page 10 of 17 Page ID #:217
1 material in question the level of protection to which it is entitled under the Producing
2 Party’s designation until the Court rules on the challenge.
3 //
4 IX. ACCESS TO AND USE OF PROTECTED MATERIAL
5 A. Basic Principles
6 A Receiving Party may use Protected Material that is disclosed or produced by
7 another Party or by a Non-Party in connection with this Action only for prosecuting,
8 defending, or attempting to settle this Action. Such Protected Material may be
9 disclosed only to the categories of persons and under the conditions described in this
10 Order. When the Action has been terminated, a Receiving Party must comply with the
11 provisions of Section XV below.
12 Protected Material must be stored and maintained by a Receiving Party at a
13 location and in a secure manner that ensures that access is limited to the persons
14 authorized under this Order.
15 B. Disclosure of “CONFIDENTIAL” Information or Items
16 Unless otherwise ordered by the Court or permitted in writing by the
17 Designating Party, a Receiving Party may disclose any information or item designated
18 “CONFIDENTIAL” only to:
19 (a) The Receiving Party’s Outside Counsel of Record in this Action, as well as
20 employees of said Outside Counsel of Record to whom it is reasonably necessary to
21 disclose the information for this Action;
22 (b) The officers, directors, and employees (including House Counsel) of the
23 Receiving Party to whom disclosure is reasonably necessary for this Action;
24
10
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1 (c) Experts (as defined in this Order) of the Receiving Party to whom
2 disclosure is reasonably necessary for this Action and who have signed the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (d) The Court and its personnel;
5 (e) Court reporters and their staff;
6 (f) Professional jury or trial consultants, mock jurors, and Professional
7 Vendors to whom disclosure is reasonably necessary or this Action and who have
8 signed the “Acknowledgment and Agreement to be Bound” attached as Exhibit A
9 hereto;
10 (g) The author or recipient of a document containing the information or a
11 custodian or other person who otherwise possessed or knew the information;
12 (h) During their depositions, witnesses, and attorneys for witnesses, in the
13 Action to whom disclosure is reasonably necessary provided: (i) the deposing party
14 requests that the witness sign the “Acknowledgment and Agreement to Be Bound;” and
15 (ii) they will not be permitted to keep any confidential information unless they sign the
16 “Acknowledgment and Agreement to Be Bound,” unless otherwise agreed by the
17 Designating Party or ordered by the Court. Pages of transcribed deposition testimony
18 or exhibits to depositions that reveal Protected Material may be separately bound by
19 the court reporter and may not be disclosed to anyone except as permitted under this
20 Stipulated Protective Order; and
21 (i) Any mediator or settlement officer, and their supporting personnel,
22 mutually agreed upon by any of the parties engaged in settlement discussions.
23 X. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
24 IN OTHER LITIGATION
11
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1 If a Party is served with a subpoena or a court order issued in other litigation
2 that compels disclosure of any information or items designated in this Action as
3 “CONFIDENTIAL,” that Party must:
4 (a) Promptly notify in writing the Designating Party. Such notification shall
5 include a copy of the subpoena or court order;
6 (b) Promptly notify in writing the party who caused the subpoena or order to
7 issue in the other litigation that some or all of the material covered by the subpoena or
8 order is subject to this Protective Order. Such notification shall include a copy of this
9 Stipulated Protective Order; and
10 (c) Cooperate with respect to all reasonable procedures sought to be pursued
11 by the Designating Party whose Protected Material may be affected.
12 If the Designating Party timely seeks a protective order, the Party served with
13 the subpoena or court order shall not produce any information designated in this action
14 as “CONFIDENTIAL” before a determination by the Court from which the subpoena or
15 order issued, unless the Party has obtained the Designating Party’s permission. The
16 Designating Party shall bear the burden and expense of seeking protection in that court
17 of its confidential material and nothing in these provisions should be construed as
18 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
19 from another court.
20 XI. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
21 PRODUCED IN THIS LITIGATION
22 (a) The terms of this Order are applicable to information produced by a Non-
23 Party in this Action and designated as “CONFIDENTIAL.” Such information produced
24 by Non-Parties in connection with this litigation is protected by the remedies and relief
12
Case 2:22-cv-00407-FLA-AFM Document 41 Filed 07/06/22 Page 13 of 17 Page ID #:220
1 provided by this Order. Nothing in these provisions should be construed as prohibiting
2 a Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to
4 produce a Non-Party’s confidential information in its possession, and the Party is
5 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 Non-Party
8 that some or all of the information requested is subject to a confidentiality agreement
9 with a Non-Party;
10 (2) Promptly provide the Non-Party with a copy of the Stipulated
11 Protective Order in this Action, the relevant discovery request(s), and a reasonably
12 specific description of the information requested; and
13 (3) Make the information requested available for inspection by the
14 Non-Party, if requested.
15 (c) If the Non-Party fails to seek a protective order from this court within 14
16 days of receiving the notice and accompanying information, the Receiving Party may
17 produce the Non-Party’s confidential information responsive to the discovery request.
18 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
19 any information in its possession or control that is subject to the confidentiality
20 agreement with the Non-Party before a determination by the court. Absent a court
21 order to the contrary, the Non-Party shall bear the burden and expense of seeking
22 protection in this court of its Protected Material.
23 XII. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
24
13
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1 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
2 Protected Material to any person or in any circumstance not authorized under this
3 Stipulated Protective Order, the Receiving Party must immediately (1) notify in writing
4 the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve
5 all unauthorized copies of the Protected Material, (3) inform the person or persons to
6 whom unauthorized disclosures were made of all the terms of this Order, and (4)
7 request such person or persons to execute the “Acknowledgment and Agreement to be
8 Bound” that is attached hereto as Exhibit A.
9 XIII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
10 PROTECTED MATERIAL
11 When a Producing Party gives notice to Receiving Parties that certain
12 inadvertently produced material is subject to a claim of privilege or other protection,
13 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
14 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
15 may be established in an e-discovery order that provides for production without prior
16 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
17 parties reach an agreement on the effect of disclosure of a communication or
18 information covered by the attorney-client privilege or work product protection, the
19 parties may incorporate their agreement in the Stipulated Protective Order submitted
20 to the Court.
21 XIV. MISCELLANEOUS
22 A. Right to Further Relief
23 1. Nothing in this Order abridges the right of any person to seek its
24 modification by the Court in the future.
14
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1 B. Right to Assert Other Objections
2 1. By stipulating to the entry of this Protective Order, no Party waives
3 any right it otherwise would have to object to disclosing or producing any
4 information or item on any ground not addressed in this Stipulated
5 Protective Order. Similarly, no Party waives any right to object on any
6 ground to use in evidence of any of the material covered by this Protective
7 Order.
8 C. Filing Protected Material
9 1. A Party that seeks to file under seal any Protected Material must
10 comply with Civil Local Rule 79-5. Protected Material may only be filed
11 under seal pursuant to a court order authorizing the sealing of the specific
12 Protected Material at issue. If a Party's request to file Protected Material
13 under seal is denied by the Court, then the Receiving Party may file the
14 information in the public record unless otherwise instructed by the Court.
15 XV. FINAL DISPOSITION
16 After the final disposition of this Action, as defined in Section VI, within sixty
17 (60) days of a written request by the Designating Party, each Receiving Party must
18 return all Protected Material to the Producing Party or destroy such material. As used
19 in this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
20 summaries, and any other format reproducing or capturing any of the Protected
21 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
22 must submit a written certification to the Producing Party (and, if not the same person
23 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
24 category, where appropriate) all the Protected Material that was returned or destroyed
15
Cuse 2:22-cv-00407-FLA-AFM Document 41 Filed 07/06/22 Page 16o0f17 Page ID #:223
1 || and (2) affirms that the Receiving Party has not retained any copies, abstracts,
2 || compilations, summaries or any other format reproducing or capturing any of the
3 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
4 || archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
5 || legal memoranda, correspondence, deposition and trial exhibits, expert reports,
6 || attorney work product, and consultant and expert work product, even if such materials
7 contain Protected Material. Any such archival copies that contain or constitute
8 || Protected Material remain subject to this Protective Order as set forth in Section VI.
9 ||XV. 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 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
15
Dated: July 5, 2022 /s/ Matthew L. Locker
16 (as authorized on June 30, 2022)
Attorneys for Plaintiffs
17
Dated: July 5, 2022 /s/ Elanor A. Mulhern
18 Attorneys for Defendant Capital One
19
20 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21 .
Dated: 7/6/2022 ————
22
HONORABLE ALEXANDER F, MacKINNON
23 United States Magistrate Judge
24
16
Case 2:22-cv-00407-FLA-AFM Document 41 Filed 07/06/22 Page 17 of 17 Page ID #:224
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 perjury that I
5 have read in its entirety and understand the Stipulated Protective Order that was issue
6 by the United States District Court for the Central District of California on [DATE] in
7 the case of Nunez v. Capital One et al., Case No. 2:22-cv-00407-FLA-AFM. I agree to
8 comply with and to be bound by all the terms of this Stipulated Protective Order and I
9 understand and acknowledge that failure to so comply could expose me to sanctions
10 and punishment in the nature of contempt. I solemnly promise that I will not disclose
11 in any manner any information or item that is subject to this Stipulated Protective
12 Order to any person or entity except in strict compliance with the provisions of this
13 Order.
14 I further agree to submit to the jurisdiction of the United States District Court
15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint [print or
18 type full name] of [print or type full address and
19 telephone number] as my California agent for service of process in connection with this
20 action or any proceedings related to enforcement of this Stipulated Protective Order.
21 Date:
22 City and State where sworn and signed:
23 Printed Name:
24 Signature:
17