Opinion

Anastasia Martinez v. County of Los Angeles

Court: District Court, C.D. California
Filed: Jan 9, 2023
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

PLL LLARTNAC LLERRUH

0083 ETIUS ,TEERTS AOREUGIF .S 527 71009 AINROFILAC ,SELEGNA SOL

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Thomas C. Hurrell, State Bar No. 119876

E-Mail: thurrell@hurrellcantrall.com

Diane Martinez, State Bar No. 276499

E-Mail: dmartinez@hurrellcantrall.com

Tasha T. Salveron, State Bar No. 336596

E-Mail: tsalveron@hurrellcantrall.com

HURRELL CANTRALL LLP

725 S. Figueroa Street, Suite 3800

Los Angeles, California 90017

Telephone: (213) 426-2000

Facsimile: (213) 426-2020

Attorneys for Defendants, COUNTY OF LOS ANGELES and SHERIFF ALEX

VILLANUEVA

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

ANASTASIA MARTINEZ, Case No. 2:22-cv-06589-DSF(AFMx)

Plaintiff,

STIPULATED PROTECTIVE

v. ORDER AND ORDER

COUNTY OF LOS ANGELES, ALEX

VILLANUEVA, CALIFORNIA

COMMERCE CLUB, INC. and DOES Hon. Alexander F. MacKinnon, Crtm. 780

1 through 10,

Defendants.

1. 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, the parties hereby stipulate to and petition the Court to

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

Stipulated Protective Order does not confer blanket protections on all disclosures or

responses to discovery and that the protection it affords from public disclosure and

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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 below, that this Stipulated Protective Order does not entitle

them to file confidential information under seal. 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.

2. GOOD CAUSE STATEMENT

This action involves the County of Los Angeles (“County”); former Los

Angeles County Sheriff’s Department (“LASD”) Sheriff Alex Villanueva

(“Villanueva”); California Commerce Club, Inc. (“Hotel”); and unnamed LASD

deputy(ies). Plaintiff seeks materials and information that the County maintains as

confidential, such as the personnel files of the deputy(ies) involved in this incident;

Internal Affairs materials and information; Investigative Reports; emergency

responder Records of Service; records and logs, including recordings of Sheriff

radio traffic; cellular phone records and logs; witness statements and reports; body

worn recording device recordings; incident reports; and information and other

administrative materials and information currently in possession of the County, and

which the County believes need special protection from public disclosure and from

use for any purpose other than prosecuting this litigation. Plaintiff is also seeking

official information contained in the personnel files of the deputy(ies) involved in

the subject incident, which the County maintains as strictly confidential and which

the County believes need special protection from public disclosure and from use for

any purpose other than prosecuting this litigation.

The County asserts that the confidentiality of the materials and information

sought by Plaintiff is recognized by California and federal law as evidenced, inter

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alia, by California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for

N.D. Cal., 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The

County has not publicly released the materials and information referenced above,

except under protective order or pursuant to a court order, if at all. These materials

and information are of the type that has been used to initiate disciplinary action

against LASD deputies, and has been used as evidence in disciplinary proceedings,

where the LASD deputies’ conduct were considered to be contrary to LASD policy.

The County contends that absent a protective order delineating the

responsibilities of nondisclosure on the part of the parties hereto, there is a specific

risk of unnecessary and undue disclosure by one or more of the many attorneys,

secretaries, law clerks, paralegals and expert witnesses involved in this case, as well

as the corollary risk of embarrassment, harassment and professional and legal harm

on the part of the LASD deputies referenced in the materials and information.

The County also contends that the unfettered disclosure of the materials and

information, absent a protective order, would allow the media to share this

information with potential jurors in the area, impacting the rights of the County

herein to receive a fair trial.

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.

PLL LLARTNAC LLERRUH

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Plaintiff does not agree with and does not stipulate to the County’s

contentions

stated herein, and nothing in this Stipulation or its associated Order shall resolve the

parties’ disagreement, or bind them, concerning the legal statements and claimed

privileges set forth above. However, Plaintiff agrees that there is Good Cause for a

Protective Order so as to preserve the respective interests of the parties while

streamlining the process of resolving any disagreements.

The parties jointly contend that there is typically a particularized need for

protection as to any medical and psychotherapeutic records and LASD personnel

and investigative records, because of the privacy interests at stake therein. Because

of these sensitive interests, a Court Order should address these documents rather

than a private agreement between the parties.

The parties therefore stipulate that there is Good Cause for, and hereby jointly

request that the honorable Court issue a Protective Order regarding confidential

documents consistent with the terms and provisions of this Stipulation. However,

the entry of a Protective Order by the Court pursuant to this Stipulation shall not be

construed as any ruling by the Court on the aforementioned legal statements or

privilege claims in this section, nor shall this section be construed as part of any

such Court Order.

3. DEFINITIONS

3.1 Action: Anastasia Martinez v. County of Los Angeles, Alex Villanueva,

California Commerce Club, Inc. and DOES 1—10, Case No. CV22-

06589 DSF (AFM).

3.2 Challenging Party: A Party or Nonparty that challenges the

designation of information or items under this Stipulated Protective

Order.

3.3 “CONFIDENTIAL” Information or Items: Information (regardless

of how it is generated, stored or maintained) or tangible things that

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qualify for protection under Federal Rules of Civil Procedure 26(c), and

as specified above in the Good Cause Statement. This also includes (1)

any information copied or extracted from the Confidential information;

(2) all copies, excerpts, summaries, abstracts or compilations of

Confidential information; and (3) any testimony, conversations, or

presentations that might reveal Confidential information.

3.4 Counsel: Outside Counsel of Record and In-House Counsel (as well as

their support staff).

3.5 Designating Party: A Party or Nonparty that designates information

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

“CONFIDENTIAL.”

3.6 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.

3.7 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.

3.8 Final Disposition: when this Action has been fully and completely

terminated by way of settlement, dismissal, trial, appeal, and/or remand

to state court.

3.9 In-House Counsel: Attorneys who are employees of a party to this

Action. In-House Counsel does not include Outside Counsel of Record

or any other outside counsel.

3.10 Non-Party: Any natural person, partnership, corporation, association

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

3.11 Outside Counsel of Record: Attorneys who are not employees of a

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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.

3.12 Party: Any party to this Action, including all of its officers, directors,

boards, departments, divisions, employees, consultants, retained

experts, In-House Counsel, and Outside Counsel of Record (and their

support staff).

3.13 Producing Party: A Party or Nonparty that produces Disclosure or

Discovery Material in this Action.

3.14 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.

3.15 Protected Material: Any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL.”

3.16 Receiving Party: A Party that receives Disclosure or Discovery

Material from a Producing Party.

4. SCOPE

The protections conferred by this Stipulated Protective Order cover not only

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

extracted from Protected Material; (2) all copies, excerpts, abstracts, 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 Stipulated Protective Order does not govern the use of Protected

Material at trial.

///

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5. DURATION

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

CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and

that is introduced or admitted 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 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

as to the CONFIDENTIAL information and materials introduced or admitted as an

exhibit at trial.

6. DESIGNATING PROTECTED MATERIAL

6.1 Exercise of Restraint and Care in Designating Material for

Protection

Each Party or Nonparty that designates information or items for protection

under this Stipulated Protective 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 Stipulated Protective 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.

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

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

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

6.2 Manner and Timing of Designations

Except as otherwise provided in this Stipulated Protective Order (see, e.g.,

second paragraph of section 6.2(a) below), or as otherwise stipulated or ordered,

Disclosure or Discovery Material that qualifies for protection under this Stipulated

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

produced.

Designation in conformity with this Stipulated Protective 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” or words of

a similar effect, and that includes the case name and case number (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 Nonparty 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 Stipulated

Protective 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 of the material on a page qualifies for protection, the

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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 identifies the

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

protected testimony.

any 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).

6.3 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 Stipulated Protective 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 Stipulated

Protective Order.

7. CHALLENGING CONFIDENTIALITY DESIGNATIONS

7.1 Timing of Challenges

Any Party or Nonparty may challenge a designation of confidentiality at any

time that is consistent with the Court’s Scheduling Order.

7.2 Meet and Confer

The Challenging Party shall initiate the dispute resolution process under

Local Rule 371.

1 Magistrate Judge Alexander F. MacKinnon’s chamber rules are available at:

https://www.cacd.uscourts.gov/honorable-alexander-f-mackinnon.

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7.3 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.

8. ACCESS TO AND USE OF PROTECTED MATERIAL

8.1 Basic Principles

A Receiving Party may use Protected Material that is disclosed or produced

by another Party or by a Nonparty 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 Stipulated Protective Order. When the Action reaches a final

disposition, a Receiving Party must comply with the provisions of section 14 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.

8.2 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 Counsel of Record in this Action, as well as

employees of said Counsel of Record to whom it is reasonably necessary to disclose

the information for this Action;

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(b) The officers, directors, and employees (including In-House Counsel) of

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

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: (i) the deposing party

requests that the witness sign the “Acknowledgment and Agreement to Be Bound”

(Exhibit A); and (ii) the witness will not be permitted to keep any confidential

information unless they sign the “Acknowledgment and Agreement to Be Bound,”

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 and

who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A).

9. 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

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“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 Stipulated Protective Order. Such notification

shall include a copy of this Stipulated Protective Order; and

by the Designating Party whose Protected Material may be affected.

The Party served with the subpoena or court order shall not produce any

information designated in this action as “CONFIDENTIAL”, unless the Party has

obtained the Designating Party’s permission or an order from the court from which

the subpoena or order issued. 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.

10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

10.1 Application

The terms of this Stipulated Protective Order are applicable to information

produced by a Nonparty in this Action and designated as “CONFIDENTIAL.” Such

information produced by Nonparties in connection with this litigation is protected

by the remedies and relief provided by this Stipulated Protective Order. Nothing in

these provisions should be construed as prohibiting a Nonparty from seeking

additional protections.

10.2 Notification

In the event that a Party is required, by a valid discovery request, to produce a

Nonparty’s confidential information in its possession, and the Party is subject to an

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agreement with the Nonparty not to produce the Nonparty’s confidential

information, then the Party shall:

(a) Promptly notify in writing the Requesting Party and the Nonparty that

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

with a Nonparty;

(b) Promptly provide the Nonparty 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

Nonparty, if requested.

10.3 Conditions of Production

If the Nonparty fails to seek a protective order from this Court within fourteen

(14) days of receiving the notice and accompanying information, the Receiving

Party may produce the Nonparty’s confidential information responsive to the

discovery request. If the Nonparty 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 Nonparty before a determination by the

Court. Absent a court order to the contrary, the Nonparty shall bear the burden and

expense of seeking protection in this court of its Protected Material.

11. 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

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

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

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

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12. 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.

13. MISCELLANEOUS

13.1 Right to Further Relief

Nothing in this Stipulated Protective Order abridges the right of any person to

seek its modification by the Court in the future.

13.2 Right to Assert Other Objections

By stipulating to the entry of this Stipulated 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 Stipulated Protective Order.

13.3 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 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

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Receiving Party may file the information in the public record unless otherwise

instructed by the Court.

14. FINAL DISPOSITION

After the FINAL DISPOSITION of this Action, as defined in paragraph 3.8,

within sixty (60) days of a written request by the Designating Party, each Receiving

Party must return all Protected Material to the Producing Party. 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. 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 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 is

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 Stipulated

Protective Order.

15. VIOLATION

Any violation of this Stipulated Protective Order may be punished by

appropriate measures including, without limitation, contempt proceedings and/or

monetary sanctions.

Case □□□□□□□□□□□□□□□□□□□□□ Document 30 Filed 01/09/23 Page16o0f17 Page ID#:279

1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD:

3 || Dated: December 2022 ORANGE LAW OFFICES

4 /s/ - Olu K. Orange

5 By:

6 OLU K. ORANGE

7 HURRELL CANTRALL LLP

8 By: /s/ Diane Martinez

9 THOMAS C. HURRELL

10 DIANE MARTINEZ

Attorneys for Defendants, COUNTY OF LOS

11 ANGELES and SHERIFF ALEX VILLANUEVA

ge 12

STEARNS KIM STEARNS & RYAN

Z yee 14 By: /s/_ Danielle Duarte

U say Michael J. Ryan

4 □□□ 15 Danielle Duarte

Bie 16 Attorneys for Defendant CALIFORNIA

PD xo COMMERCE CLUB, INC.

19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

21 Dated: 1/9/2023 :

29 (40 y &

24 Alexander F. MacKinnon

25 U.S. Magistrate Judge

PLL LLARTNAC LLERRUH

0083 ETIUS ,TEERTS AOREUGIF .S 527 71009 AINROFILAC ,SELEGNA SOL

0002-624 )312( ENOHPELET

Case 2:22-cv-06589-DSF-AFM Document 30 Filed 01/09/23 Page 17 of 17 Page ID #:280

ATTACHMENT “A”

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ________________[full name], of ___________________________

[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 Anastasia Martinez v. County of Los Angeles, Alex Villanueva,

California Commerce Club, Inc. and DOES 1—10, United States District Court for

the Central District of California, Central Division, Case No. Case No. CV22-06589

DSF (AFM). 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 Stipulated Protective 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_______________________ [full name]

of ______________________________________ [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.

Signature: ____________________________

Printed Name: ____________________________

Date: ____________________________

City and State Where Sworn and Signed: ____________________________

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