Opinion

Jorge Alejandro Acosta-Quiroz v. Los Angeles County

Court: District Court, C.D. California
Filed: Aug 17, 2022
Cited by: 0 cases
Authority: More cited than 16.4%

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

How later courts described this case

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

Written by the judges who cited it.

The opinion

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 1 of 14 Page ID #:140

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

JORGE ALEJANDRO ACOSTA- CASE NO. 2:21-CV-09033-MWF-RAO

Action Filed: November 17, 2021

QUIROZ,

Plaintiff,

v. [PROPOSED] PROTECTIVE

ORDER

LOS ANGELES COUNTY, a public

entity; and K. Thompson (#648688),

and DOES 1 through 10, inclusive,

individually and their official capacity

as Los Angeles County Sheriff’s

deputies,

Defendants.

1. A. PURPOSES AND LIMITATIONS

Discovery in this action is likely to involve production of confidential,

proprietary, or private information for which special protection from public

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

be warranted. Accordingly, defendant County of Los Angeles petitions the Court to

enter the following Protective Order. The parties acknowledge that this Order does

not confer blanket protections on all disclosures or responses to discovery and that

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

information or items that are entitled to confidential treatment under the applicable

legal principles. The parties further acknowledge, as set forth in Section 13.3,

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

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below, that this Protective Order does not entitle them to file confidential

information under seal; Civil Local Rule 79-5 sets forth the procedures that must

be followed and the standards that will be applied when a party seeks permission

from the court to file material under seal. Discovery in this action is likely to

involve production of confidential, proprietary, or private information for which

special protection from public disclosure and from use for any purpose other than

prosecuting this litigation may be warranted.

B. GOOD CAUSE STATEMENT

Good cause exists for entry of this order as Plaintiff is seeking and

Defendant may produce, among other things, internal, security sensitive, third

party and law enforcement private and confidential information, administrative and

institutional documents, which contain sensitive information that the County of

Los Angeles believes need special protection from public disclosure.

The documents identified in this Protective Order, which Defendant believes

in good faith constitute or embody confidential information which the County of

Los Angeles maintains as strictly confidential and are 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, are therefore entitled to heightened protection from disclosure. 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

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 3 of 14 Page ID #:142

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.

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), including Plaintiff Pro Per.

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.

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

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

counsel.

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

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

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

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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 which 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,

board, departments, divisions, employees, consultants, retained experts, and

Outside Counsel of Record (and their support staff).

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 Proposed Protective Order 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 or their Counsel that might reveal Protected Material.

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

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

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

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4. DURATION

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

confidential or maintained pursuant to this Protective Order becomes public and

presumptively will be 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 v. City

and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (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 purpose (e.g., to unnecessarily encumber the case development process

or to impose unnecessary expenses and burdens on other parties) may expose the

Designating Party to sanctions.

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

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 6 of 14 Page ID #:145

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. The legend must not obstruct a Party’s ability to view

the contents of that document. If only a portion or portions 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 legend” to each page that contains Protected Material. If

only a portion or portions 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).

(b) for testimony given in depositions that the Designating Party identify

the Disclosure or Discovery Material on the record, before the close of the

deposition all protected testimony.

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 7 of 14 Page ID #:146

for any other tangible items, that, at a minimum, 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.

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

resolution process under Local Rule 37.1 et seq.

6.3 Burden of Persuasion. 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.

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 8 of 14 Page ID #:147

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 reaches a final disposition,

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 Stipulated Protective 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:

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

as employees of said Outside Counsel of Record to whom it is reasonably

necessary to disclose the information for this Action;

(b) the officers, directors, and employees (including House Counsel) 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;

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 9 of 14 Page ID #:148

(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 “Acknowledgment and Agreement to Be

Bound” form attached as Exhibit A hereto; and (2) the witness 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.

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

If a Party is served with a subpoena or a court order issued in other litigation

that compels disclosure of any information or items designated in this Action as

“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 issues in the other litigation that some or all of the material covered by the

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 10 of 14 Page ID #:149

subpoena or order is subject to this Protective Order. Such notification shall

include a copy of this Stipulated Protective Order; and

pursued 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

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

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

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

produce a Non-Party’s confidential information in its possession, and the Party is

subject to an 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

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 11 of 14 Page ID #:150

(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.

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

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

efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the

person or persons to whom unauthorized disclosures were made of all the terms of

this Order, and (d) request such person or persons to execute the

“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

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

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 12 of 14 Page ID #:151

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 Civil Local Rule 79-5. Protected Material

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

specific Protected Material at issue. If a Party's request to file Protected Material

under seal is denied by the court, then the Receiving Party may file the information

in the public 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,

Case □□□□□□□□□□□□□□□□□□□□□□ Document 31 Filed 08/17/22 Page130f14 Page ID #:152

1 ||}compilations, summaries, and any other format reproducing or capturing any of the

2 || Protected Material. Whether the Protected Material is returned or destroyed, the

3 || Receiving Party must submit a written certification to the Producing Party (and, if

4 || not the same person or entity, to the Designating Party) by the 60 day deadline that

5 ||(1) identifies (by category, where appropriate) all the Protected Material that was

6 |/returned or destroyed and (2) affirms that the Receiving Party has not retained any

7 |lcopies, abstracts, compilations, summaries or any other format reproducing or

8 || capturing any of the Protected Material. Notwithstanding this provision, Counsel

9 llare entitled to retain an archival copy of all pleadings, motion papers, trial,

10 || deposition, and hearing transcripts, legal memoranda, correspondence, deposition

8 11 || and trial exhibits, expert reports, attorney work product, and consultant and expert

g 8 12 || work product, even if such materials contain Protected Material. Any such archival

5 558 13 ||copies that contain or constitute Protected Material remain subject to this

□□ bs 14 || Protective Order as set forth in Section 4 (DURATION).

gk 15/14. VIOLATION

a3 16 Any violation of this Order may be punished by any and all appropriate

3 2" od 17 || measures including, without limitation, contempt proceedings and/or monetary

3 18 || sanctions.

21 |/FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

3 DATED: August 17, 2022

24 Rapetis, A, OC

25 |[HON. ROZELLA A.OLIVER its

6 United States Magistrate Judge

[PROPOSED] PROTECTIVE ORDER

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[PROPOSED] PROTECTIVE ORDER

OCERG & WOLNI ,EKNHEAD ,NOSNILLOC

008 ETIUS ,.DVLB ENROHTWAH 51512

30509 AINROFILAC ,ECNARROT

7577-212 )424( XAF | 7777-212 )424( .LET

Case 2:21-cv-09033-MWF-RAO Document 31 Filed 08/17/22 Page 14 of 14 Page ID #:153

EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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

_________________ [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 ___________ in the case of Gary Salzman et al. v. County of Los Angeles, et

al., Case No. 21-CV-04604-PA-SK. 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 Order.

Date: ______________________________________

City and State where sworn and signed: _________________________________

Printed name: _______________________________

Signature: _______________________________

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