even stipulated protective orders require good cause 19 showing
How later courts described this case
- even stipulated protective orders require good cause 19 showing
Written by the judges who cited it.
The opinion
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 1 of 16 Page ID #:231
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8
UNITED STATES DISTRICT COURT
9
CENTRAL DISTRICT OF CALIFORNIA
10
HEBA AHMED, ) Case No.: 8:22-cv-00366-CJC-JDE
11 )
)
12 Plaintiff, )
)
13
)
v. ) STIPULATED PROTECTIVE
)
14 ) ORDER
TRANS UNION RENTAL SCREENING )
15
SOLUTIONS, INC. and RENTSPREE, )
)
16 INC., )
17 )
Defendants. )
18 )
19 AHMED AHMED, ) Case No. 8:22-cv-00367-CJC-JDE
)
20 )
Plaintiff, )
)
21
)
v. )
22
)
)
23 TRANS UNION RENTAL SCREENING )
24 SOLUTIONS, INC., et al., ) )
)
25 Defendants. )
)
26
27 Pursuant to the parties’ Stipulation and for good cause shown, the Court
28 finds and orders as follows.
1
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 2 of 16 Page ID #:232
1 1. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public
4 disclosure and from use for any purpose other than pursuing this litigation may
5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court
6 to enter the following Stipulated Protective Order. The parties acknowledge that
7
this Order does not confer blanket protections on all disclosures or responses to
8
discovery and that the protection it affords from public disclosure and use
9
extends only to the limited information or items that are entitled to confidential
10
treatment under the applicable legal principles.
11
2. GOOD CAUSE STATEMENT
12
This action is likely to involve trade secrets, customer and pricing lists and
13
other valuable research, development, commercial, financial, technical and/or
14
proprietary information for which special protection from public disclosure and
15
from use for any purpose other than prosecution of this action is warranted. Such
16
confidential and proprietary materials and information consist of, among other
17
things, confidential business or financial information, information regarding
18
confidential business practices, or other confidential research, development, or
19
commercial information (including information implicating privacy rights of
20
21 third parties), information otherwise generally unavailable to the public, or
22 which may be privileged or otherwise protected from disclosure under state or
23 federal statutes, court rules, case decisions, or common law. Accordingly, to
24 expedite the flow of information, to facilitate the prompt resolution of disputes
25 over confidentiality of discovery materials, to adequately protect information
26 the parties are entitled to keep confidential, to ensure that the parties are
27 permitted reasonable necessary uses of such material in preparation for and in
28 the conduct of trial, to address their handling at the end of the litigation, and
2
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 3 of 16 Page ID #:233
1 serve the ends of justice, a protective order for such information is justified in
2 this matter. It is the intent of the parties that information will not be designated
3 as confidential for tactical reasons and that nothing be so designated without a
4 good faith belief that it has been maintained in a confidential, non-public
5 manner, and there is good cause why it should not be part of the public record
6 of this case.
7
3. UNDER SEAL FILING PROCEDURE
8
The parties further acknowledge, as set forth in Section 14.3, below, that
9
this Stipulated Protective Order does not entitle them to file confidential
10
information under seal; Local Civil Rule 79-5 sets forth the procedures that must
11
be followed and the standards that will be applied when a party seeks permission
12
from the court to file material under seal. There is a strong presumption that the
13
public has a right of access to judicial proceedings and records in civil cases. In
14
connection with non-dispositive motions, good cause must be shown to support
15
a filing under seal. See Kamakana v. City and County of Honolulu, 447 F.3d
16
1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-
17
11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577
18
(E.D. Wis. 1999) (even stipulated protective orders require good cause
19
showing), and a specific showing of good cause or compelling reasons with
20
21 proper evidentiary support and legal justification, must be made with respect to
22 Protected Material that a party seeks to file under seal. The parties’ mere
23 designation of Disclosure or Discovery Material as CONFIDENTIAL does
24 not— without the submission of competent evidence by declaration, establishing
25 that the material sought to be filed under seal qualifies as confidential,
26 privileged, or otherwise protectable—constitute good cause.
27 Further, if a party requests sealing related to a dispositive motion or trial,
28 then compelling reasons, not only good cause, for the sealing must be shown,
3
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 4 of 16 Page ID #:234
1 and the relief sought shall be narrowly tailored to serve the specific interest to be
2 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.
3 2010). For each item or type of information, document, or thing sought to be
4 filed or introduced under seal, the party seeking protection must articulate
5 compelling reasons, supported by specific facts and legal justification, for the
6 requested sealing order. Again, competent evidence supporting the application
7
to file documents under seal must be provided by declaration.
8
Any document that is not confidential, privileged, or otherwise
9
protectable in its entirety will not be filed under seal if the confidential portions
10
can be redacted. If documents can be redacted, then a redacted version for public
11
viewing, omitting only the confidential, privileged, or otherwise protectable
12
portions of the document, shall be filed. Any application that seeks to file
13
documents under seal in their entirety should include an explanation of why
14
redaction is not feasible.
15
4. DEFINITIONS
16
4.1 Action: Heba Ahmed v. Trans Union Rental Screening Solutions, Inc., et
17
al.; Case No. 8:22-cv-00366-CJC-JDE consolidated with Ahmed Ahmed v. Trans
18
19
Union Rental Screening Solutions, Inc., et al.; Case No. 8:22-cv-00367-CJC-JDE
20 4.2 Challenging Party: a Party or Non-Party that challenges the
21 designation of information or items under this Order.
22 4.3 “CONFIDENTIAL” Information or Items: information (regardless
23 of how it is generated, stored or maintained) or tangible things that qualify for
24 protection under Federal Rule of Civil Procedure 26(c), and as specified above
25 in the Good Cause Statement.
26 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
27 their support staff).
28
4
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 5 of 16 Page ID #:235
1 4.5 Designating Party: a Party or Non-Party that designates
2 information or items that it produces in disclosures or in responses to discovery
3 as “CONFIDENTIAL.”
4 4.6 Disclosure or Discovery Material: all items or information,
5 regardless of the medium or manner in which it is generated, stored, or
6 maintained (including, among other things, testimony, transcripts, and tangible
7
things), that are produced or generated in disclosures or responses to discovery.
8
4.7 Expert: a person with specialized knowledge or experience in a
9
matter pertinent to the litigation who has been retained by a Party or its counsel
10
to serve as an expert witness or as a consultant in this Action.
11
4.8 House Counsel: attorneys who are employees of a party to this
12
Action. House Counsel does not include Outside Counsel of Record or any
13
other outside counsel.
14
4.9 Non-Party: any natural person, partnership, corporation,
15
association or other legal entity not named as a Party to this action.
16
4.10 Outside Counsel of Record: attorneys who are not employees of a
17
party to this Action but are retained to represent a party to this Action and have
18
appeared in this Action on behalf of that party or are affiliated with a law firm
19
that has appeared on behalf of that party, and includes support staff.
20
21 4.11 Party: any party to this Action, including all of its officers, directors,
22 employees, consultants, retained experts, and Outside Counsel of Record (and
23 their support staffs).
24 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
25 Discovery Material in this Action.
26 4.13 Professional Vendors: persons or entities that provide litigation
27 support services (e.g., photocopying, videotaping, translating, preparing exhibits
28
5
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 6 of 16 Page ID #:236
1 or demonstrations, and organizing, storing, or retrieving data in any form or
2 medium) and their employees and subcontractors.
3 4.14 Protected Material: any Disclosure or Discovery Material that is
4 designated as “CONFIDENTIAL.”
5 4.15 Receiving Party: a Party that receives Disclosure or Discovery
6 Material from a Producing Party.
7
5. SCOPE
8
The protections conferred by this Stipulation and Order cover not only
9
Protected Material (as defined above), but also (1) any information copied or
10
extracted from Protected Material; (2) all copies, excerpts, summaries, or
11
compilations of Protected Material; and (3) any testimony, conversations, or
12
presentations by Parties or their Counsel that might reveal Protected Material.
13
Any use of Protected Material at trial shall be governed by the orders of
14
the trial judge and other applicable authorities. This Order does not govern the
15
use of Protected Material at trial.
16
6. DURATION
17
Once a case proceeds to trial, information that was designated as
18
CONFIDENTIAL or maintained pursuant to this protective order used or
19
introduced as an exhibit at trial becomes public and will be presumptively
20
21 available to all members of the public, including the press, unless compelling
22 reasons supported by specific factual findings to proceed otherwise are made to
23 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
24 (distinguishing “good cause” showing for sealing documents produced in
25 discovery from “compelling reasons” standard when merits-related documents
26 are part of court record). Accordingly, the terms of this protective order do not
27 extend beyond the commencement of the trial.
28
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Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 7 of 16 Page ID #:237
1 7. DESIGNATING PROTECTED MATERIAL
2 7.1 Exercise of Restraint and Care in Designating Material for
Protection.
3
Each Party or Non-Party that designates information or items for
4
protection under this Order must take care to limit any such designation to
5
specific material that qualifies under the appropriate standards. The Designating
6
Party must designate for protection only those parts of material, documents,
7
items or oral or written communications that qualify so that other portions of
8
the material, documents, items or communications for which protection is not
9
warranted are not swept unjustifiably within the ambit of this Order.
10
Mass, indiscriminate or routinized designations are prohibited.
11
Designations that are shown to be clearly unjustified or that have been made for
12
13 an improper purpose (e.g., to unnecessarily encumber the case development
14 process or to impose unnecessary expenses and burdens on other parties) may
15 expose the Designating Party to sanctions.
16 If it comes to a Designating Party’s attention that information or items
17 that it designated for protection do not qualify for protection, that Designating
18 Party must promptly notify all other Parties that it is withdrawing the
19 inapplicable designation.
20 7.2 Manner and Timing of Designations. Except as otherwise provided
21 in this Order, or as otherwise stipulated or ordered, Disclosure of Discovery
22 Material that qualifies for protection under this Order must be clearly so
23
designated before the material is disclosed or produced.
24
Designation in conformity with this Order requires:
25
(a) for information in documentary form (e.g., paper or electronic
26
documents, but excluding transcripts of depositions or other pretrial or trial
27
proceedings), that the Producing Party affix at a minimum, the legend
28
7
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 8 of 16 Page ID #:238
1 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page
2 that contains protected material. If only a portion of the material on a page
3 qualifies for protection, the Producing Party also must clearly identify the
4 protected portion(s) (e.g., by making appropriate markings in the margins).
5 A Party or Non-Party that makes original documents available for
6 inspection need not designate them for protection until after the inspecting Party
7
has indicated which documents it would like copied and produced. During the
8
inspection and before the designation, all of the material made available for
9
inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
10
identified the documents it wants copied and produced, the Producing Party
11
must determine which documents, or portions thereof, qualify for protection
12
under this Order. Then, before producing the specified documents, the
13
Producing Party must affix the “CONFIDENTIAL legend” to each page that
14
contains Protected Material. If only a portion of the material on a page qualifies
15
for protection, the Producing Party also must clearly identify the protected
16
portion(s) (e.g., by making appropriate markings in the margins).
17
(b) for testimony given in depositions that the Designating Party
18
identifies the Disclosure or Discovery Material on the record, before the close of
19
the deposition all protected testimony.
20
21 (c) for information produced in some form other than documentary
22 and for any other tangible items, that the Producing Party affix in a prominent
23 place on the exterior of the container or containers in which the information is
24 stored the legend “CONFIDENTIAL.” If only a portion or portions of the
25 information warrants protection, the Producing Party, to the extent practicable,
26 shall identify the protected portion(s).
27 7.3 Inadvertent Failures to Designate. If timely corrected, an
28 inadvertent failure to designate qualified information or items does not, standing
8
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 9 of 16 Page ID #:239
1 alone, waive the Designating Party’s right to secure protection under this Order
2 for such material. Upon timely correction of a designation, the Receiving Party
3 must make reasonable efforts to assure that the material is treated in accordance
4 with the provisions of this Order.
5 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
6 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
7
designation of confidentiality at any time that is consistent with the Court’s
8
Scheduling Order.
9
8.2 Meet and Confer. The Challenging Party shall initiate the dispute
10
resolution process under Local Rule 37-1 et seq.
11
8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
12
joint stipulation pursuant to Local Rule 37-2.
13
8.4 The burden of persuasion in any such challenge proceeding shall be
14
on the Designating Party. Frivolous challenges, and those made for an
15
improper purpose (e.g., to harass or impose unnecessary expenses and burdens
16
on other parties) may expose the Challenging Party to sanctions. Unless the
17
Designating Party has waived or withdrawn the confidentiality designation, all
18
parties shall continue to afford the material in question the level of protection
19
to which it is entitled under the Producing Party’s designation until the Court
20
21 rules on the challenge.
22 9. ACCESS TO AND USE OF PROTECTED MATERIAL
23 9.1 Basic Principles. A Receiving Party may use Protected Material that
24 is disclosed or produced by another Party or by a Non-Party in connection
25 with this Action only for prosecuting, defending or attempting to settle this
26 Action. Such Protected Material may be disclosed only to the categories of
27 persons and under the conditions described in this Order. When the Action has
28
9
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 10 of 16 Page ID #:240
1 been terminated, a Receiving Party must comply with the provisions of section
2 15 below (FINAL DISPOSITION).
3 Protected Material must be stored and maintained by a Receiving Party
4 at a location and in a secure manner that ensures that access is limited to the
5 persons authorized under this Order.
6 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
7
otherwise ordered by the court or permitted in writing by the Designating
8
Party, a Receiving Party may disclose any information or item designated
9
“CONFIDENTIAL” only to:
10
(a) the Receiving Party’s Outside Counsel of Record in this
11
Action, as well as employees of said Outside Counsel of Record to whom it is
12
reasonably necessary to disclose the information for this Action;
13
(b) the officers, directors, and employees (including House
14
Counsel) of the Receiving Party to whom disclosure is reasonably necessary
15
for this Action;
16
(c) Experts (as defined in this Order) of the Receiving Party to
17
whom disclosure is reasonably necessary for this Action and who have signed
18
the “Acknowledgment and Agreement to Comply” (Exhibit A);
19
(d) the court and its personnel;
20
21 (e) court reporters and their staff;
22 (f) professional jury or trial consultants, mock jurors, and
23 Professional Vendors to whom disclosure is reasonably necessary for this
24 Action and who have signed the “Acknowledgment and Agreement to
25 Comply” (Exhibit A);
26 (g) the author or recipient of a document containing the
27 information or a custodian or other person who otherwise possessed or knew
28 the information;
10
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 11 of 16 Page ID #:241
1 (h) during their depositions, witnesses, and attorneys for witnesses,
2 in the Action to whom disclosure is reasonably necessary provided: (1) the
3 deposing party requests that the witness sign the form attached as Exhibit A
4 hereto; and (2) they will not be permitted to keep any confidential information
5 unless they sign the “Acknowledgment and Agreement to Comply” (Exhibit
6 A), unless otherwise agreed by the Designating Party or ordered by the court.
7
Pages of transcribed deposition testimony or exhibits to depositions that reveal
8
Protected Material may be separately bound by the court reporter and may not
9
be disclosed to anyone except as permitted under this Stipulated Protective
10
Order; and
11
(i) any mediators or settlement officers and their supporting
12
personnel, mutually agreed upon by any of the parties engaged in settlement
13
discussions.
14
10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
15
PRODUCED IN OTHER LITIGATION
16 If a Party is served with a subpoena or a court order issued in other
17 litigation that compels disclosure of any information or items designated in this
18 Action as “CONFIDENTIAL,” that Party must:
19 (a) promptly notify in writing the Designating Party. Such
20 notification shall include a copy of the subpoena or court order;
21
(b) promptly notify in writing the party who caused the subpoena or
22
order to issue in the other litigation that some or all of the material covered by
23
the subpoena or order is subject to this Protective Order. Such notification shall
24
include a copy of this Stipulated Protective Order; and
25
(c) cooperate with respect to all reasonable procedures sought to be
26
27 pursued by the Designating Party whose Protected Material may be affected. If
28 the Designating Party timely seeks a protective order, the Party served with the
11
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 12 of 16 Page ID #:242
1 subpoena or court order shall not produce any information designated in this
2 action as “CONFIDENTIAL” before a determination by the court from which
3 the subpoena or order issued, unless the Party has obtained the Designating
4 Party’s permission. The Designating Party shall bear the burden and expense of
5 seeking protection in that court of its confidential material and nothing in these
6 provisions should be construed as authorizing or encouraging a Receiving Party
7
in this Action to disobey a lawful directive from another court.
8
11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
9 BE PRODUCED IN THIS LITIGATION
10 (a) The terms of this Order are applicable to information produced
11 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
12 information produced by Non-Parties in connection with this litigation is
13 protected by the remedies and relief provided by this Order. Nothing in these
14 provisions should be construed as prohibiting a Non-Party from seeking
15 additional protections.
16 (b) In the event that a Party is required, by a valid discovery request,
17
to produce a Non-Party’s confidential information in its possession, and the
18
Party is subject to an agreement with the Non-Party not to produce the Non-
19
Party’s confidential information, then the Party shall:
20
(1) promptly notify in writing the Requesting Party and the Non-
21
Party that some or all of the information requested is subject to a confidentiality
22
agreement with a Non-Party;
23
(2) promptly provide the Non-Party with a copy of the Stipulated
24
Protective Order in this Action, the relevant discovery request(s), and a
25
reasonably specific description of the information requested; and
26
(3) make the information requested available for inspection by the
27
Non-Party, if requested.
28
12
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 13 of 16 Page ID #:243
1 (c) If the Non-Party fails to seek a protective order from this court
2 within 14 days of receiving the notice and accompanying information, the
3 Receiving Party may produce the Non-Party’s confidential information
4 responsive to the discovery request. If the Non-Party timely seeks a protective
5 order, the Receiving Party shall not produce any information in its possession
6 or control that is subject to the confidentiality agreement with the Non-Party
7
before a determination by the court. Absent a court order to the contrary, the
8
Non-Party shall bear the burden and expense of seeking protection in this court
9
of its Protected Material.
10
12. UNAUTHORIZED DISCLOSURE OF PROTECTED
11 MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has
12
13 disclosed Protected Material to any person or in any circumstance not
14 authorized under this Stipulated Protective Order, the Receiving Party must
15 immediately (a) notify in writing the Designating Party of the unauthorized
16 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
17 Protected Material, (c) inform the person or persons to whom unauthorized
18 disclosures were made of all the terms of this Order, and (d) request such person
19 or persons to execute the “Acknowledgment and Agreement to Comply”
20 attached hereto as Exhibit A.
21 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
22 OTHERWISE PROTECTED MATERIAL
23 When a Producing Party gives notice to Receiving Parties that certain
24 inadvertently produced material is subject to a claim of privilege or other
25 protection, the obligations of the Receiving Parties are those set forth in Federal
26 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
27 whatever procedure may be established in an e-discovery order that provides for
28 production without prior privilege review. Pursuant to Federal Rule of Evidence
13
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 14 of 16 Page ID #:244
1 502(d) and (e), insofar as the parties reach an agreement on the effect of
2 disclosure of a communication or information covered by the attorney-client
3 privilege or work product protection, the parties may incorporate their
4 agreement in the stipulated protective order submitted to the court.
5 14. MISCELLANEOUS
6 14.1 Right to Further Relief. Nothing in this Order abridges the right of
7
any person to seek its modification by the Court in the future.
8
14.2 Right to Assert Other Objections. By stipulating to the entry of this
9
Protective Order, no Party waives any right it otherwise would have to object to
10
disclosing or producing any information or item on any ground not addressed
11
in this Stipulated Protective Order. Similarly, no Party waives any right to object
12
on any ground to use in evidence of any of the material covered by this
13
Protective Order.
14
14.3 Filing Protected Material. A Party that seeks to file under seal any
15
Protected Material must comply with Local Civil Rule 79-5. Protected Material
16
may only be filed under seal pursuant to a court order authorizing the sealing of
17
the specific Protected Material. If a Party’s request to file Protected Material
18
under seal is denied by the court, then the Receiving Party may file the
19
information in the public record unless otherwise instructed by the court.
20
21 15. FINAL DISPOSITION
22 After the final disposition of this Action, as defined in paragraph 6, within
23 60 days of a written request by the Designating Party, each Receiving Party must
24 return all Protected Material to the Producing Party or destroy such material.
25 As used in this subdivision, “all Protected Material” includes all copies,
26 abstracts, compilations, summaries, and any other format reproducing or
27 capturing any of the Protected Material. Whether the Protected Material is
28 returned or destroyed, the Receiving Party must submit a written certification to
14
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page15o0f16 Page ID #:245
I ||the Producing Party (and, if not the same person or entity, to the Designating
2 || Party) by the 60-day deadline that (1) identifies (by category, where appropriate)
3 | all the Protected Material that was returned or destroyed and (2) affirms that the
4 || Receiving Party has not retained any copies, abstracts, compilations, summaries
> any other format reproducing or capturing any of the Protected Material.
6 Notwithstanding this provision, Counsel are entitled to retain an archival copy
” |i of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
8 memoranda, correspondence, deposition and trial exhibits, expert reports,
° attorney work product, and consultant and expert work product, even if such
0 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 6 (DURATION).
4 16. VIOLATION
5 Any violation of this Order may be punished by appropriate measures
16 including, without limitation, contempt proceedings and/or monetary
17 || Sanctions.
18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
19
30 DATED: January 03, 2023 Hf te
21 tbr. 7
39 esr ND. EARLY :
nited States Magistrate Judge
23
24
25
26
27
28
15
Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 16 of 16 Page ID #:246
1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO COMPLY
2
I, _____________________________ [print or type full name], of
3
_________________ [print or type full address], declare under penalty of perjury
4
that I have read in its entirety and understand the Stipulated Protective Order that
5
was issued by the United States District Court for the Central District of California
6
7
on December 30, 2022, in the case of Heba Ahmed v. Trans Union Rental Screening
8 Solutions, Inc., et al.; Case No. 8:22-cv-00366-CJC-JDE consolidated with Ahmed
9 Ahmed v. Trans Union Rental Screening Solutions, Inc., et al.; Case No. 8:22-cv-
10 00367-CJC-JDE. I agree to comply with all the terms of this Stipulated Protective
11 Order and I understand and acknowledge that failure to so comply could expose me
12 to sanctions and punishment in the nature of contempt. I solemnly promise that I will
13 not disclose in any manner any information or item that is subject to this Stipulated
14 Protective Order to any person or entity except in strict compliance with the
15 provisions of this Order. I further agree to submit to the jurisdiction of the United
16 States District Court for the Central District of California for enforcing the terms of
17 this Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint __________________________ [print
19 or type full name] of _______________________________________ [print or type
20 full address and telephone number] as my California agent for service of process in
21
connection with this action or any proceedings related to enforcement of this
22
Stipulated Protective Order.
23
Date: ______________________________________
24
City and State where sworn and signed: _________________________________
25
Printed name: _______________________________
26
27
Signature: __________________________________
28
16