even stipulated 9 protective orders require good cause showing
How later courts described this case
- even stipulated 9 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 S. YOUNG LIM (SBN126679
DAVID B. BLOOM (SBN 56573)
2 JAMES E. ADLER (SBN 75653)
PARK & LIM
3 3530 Wilshire Boulevard, Suite 1300
Los Angeles, CA 90010
4 Telephone: (213) 386-5595
Facsimile: (213) 384-7110
5 david@parkandlim.com
james@parkandlim.com
6
Attorneys for Plaintiff, Jeereddi Enterprises, LLC
7
8
UNITED STATES DISTRICT COURT
9
FOR THE CENTRAL DISTRICT OF CALIFORNIA
10
11
JEEREDDI ENTERPRISES, LLC, a ) CASE NO. 2:22-CV-1614-SSS-AFM
12 )
California limited liability company, ) STIPULATED PROTECTIVE
13 ) ) ORDER1
14 Plaintiff )
)
15 vs. ) Date: June 6, 2023
) Time: 10:00 a.m.
16 ) Courtroom: 780
VENKATA SUBASH BANDA, aka )
17 SUBASH BANDA, an individual; and ) ) Discovery Cuttoff: June 13, 2023
18 LODESTAR HOLDINGS LLC, a ) ) Pretrial Conference: Oct. 20, 2023
Texas limited liability company,
19 ) Trial Date: Nov. 6, 2023
)
20 Defendants. )
)
21 )
22
1. A. PURPOSES AND LIMITATIONS
23
Discovery in this action is likely to involve production of confidential,
24
proprietary or private information for which special protection from public
25
26
1 This Stipulated Protective Order is based substantially on the model protective
27
order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures.
28
1 disclosure and from use for any purpose other than prosecuting this litigation may
2 be warranted. Accordingly, the parties hereby stipulate to and petition the Court
to enter the following Stipulated Protective Order. The parties acknowledge that
3
this Order does not confer blanket protections on all disclosures or responses to
4
discovery and that the protection it affords from public disclosure and use extends
5
only to the limited information or items that are entitled to confidential treatment
6
under the applicable legal principles.
7
B. GOOD CAUSE STATEMENT
8
This action, including but not limited to discovery relating to enforcement
9
of the Right to Attach Orders and Writs of attachment, and enforcement of any
10
judgment is likely to involve disclosure of private and confidential financial,
11
asset, and business information for which special protection from public
12
disclosure and from use for any purpose other than prosecution of this action or
13
enforcement of the attachments issued in this action or any judgment is
14
warranted. Accordingly, to expedite the flow of information, to facilitate the
15
prompt resolution of disputes over confidentiality of discovery materials, to
16
adequately protect information the parties are entitled to keep confidential, to
17
ensure that the parties are permitted reasonable necessary uses of such material
18
to address their handling at the end of the litigation, and serve the ends of justice,
19
a protective order for such information is justified in this matter. It is the intent of
20
the parties that information will not be designated as confidential for tactical
21
reasons and that nothing be so designated without a good faith belief that it has
22
been maintained in a confidential, non-public manner, and there is good cause
23
why it should not be part of the public record of this case.
24
C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
25
SEAL
26
The parties further acknowledge, as set forth in Section 12.3, below, that
27
this Stipulated Protective Order does not entitle them to file confidential
28
1 information under seal; Local Civil Rule 79-5 sets forth the procedures that must
2 be followed and the standards that will be applied when a party seeks permission
from the court to file material under seal.
3
There is a strong presumption that the public has a right of access to
4
judicial proceedings and records in civil cases. In connection with non-dispositive
5
motions, good cause must be shown to support a filing under seal. See Kamakana
6
v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v.
7
Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v.
8
Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
9
protective orders require good cause showing), and a specific showing of good
10
cause or compelling reasons with proper evidentiary support and legal
11
justification, must be made with respect to Protected Material that a party seeks to
12
file under seal. The parties’ mere designation of Disclosure or Discovery Material
13
as CONFIDENTIAL does not— without the submission of competent evidence
14
by declaration, establishing that the material sought to be filed under seal
15
qualifies as confidential, privileged, or otherwise protectable—constitute good
16
cause.
17
Further, if a party requests sealing related to a dispositive motion or trial,
18
then compelling reasons, not only good cause, for the sealing must be shown, and
19
the relief sought shall be narrowly tailored to serve the specific interest to be
20
protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.
21
2010). For each item or type of information, document, or thing sought to be filed
22
or introduced under seal in connection with a dispositive motion or trial, the party
23
seeking protection must articulate compelling reasons, supported by specific facts
24
and legal justification, for the requested sealing order. Again, competent evidence
25
supporting the application to file documents under seal must be provided by
26
declaration.
27
Any document that is not confidential, privileged, or otherwise protectable
28
1 in its entirety will not be filed under seal if the confidential portions can be
2 redacted. If documents can be redacted, then a redacted version for public
viewing, omitting only the confidential, privileged, or otherwise protectable
3
portions of the document, shall be filed. Any application that seeks to file
4
documents under seal in their entirety should include an explanation of why
5
redaction is not feasible.
6
2. DEFINITIONS
7
2.1 Action: the above entitled, pending federal lawsuit.
8
2.2 Challenging Party: a Party or Non-Party that challenges the
9
designation of information or items under this Order.
10
2.3 “CONFIDENTIAL” Information or Items: information (regardless
11
of how it is generated, stored or maintained) or tangible things that qualify for
12
protection under Federal Rule of Civil Procedure 26(c), and as specified above in
13
the Good Cause Statement.
14
2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
15
their support staff).
16
2.5 Designating Party: a Party or Non-Party that designates information
17
or items that it produces in disclosures or in responses to discovery as
18
“CONFIDENTIAL.”
19
2.6 Disclosure or Discovery Material: all items or information,
20
regardless of the medium or manner in which it is generated, stored, or
21
maintained (including among other things, testimony, transcripts, and tangible
22
things), that are produced or generated in disclosures or responses to discovery in
23
this matter.
24
2.7 Expert: a person with specialized knowledge or experience in a
25
matter pertinent to the litigation who has been retained by a Party or its counsel to
26
serve as an expert witness or as a consultant in this Action.
27
2.8 House Counsel: attorneys who are employees of a party to this
28
1 Action. House Counsel does not include Outside Counsel of Record or any other
2 outside counsel.
2.9 Non-Party: any natural person, partnership, corporation, association
3
or other legal entity not named as a Party to this action.
4
2.10 Outside Counsel of Record: attorneys who are not employees of a
5
party to this Action but are retained to represent or advise a party to this Action
6
and have appeared in this Action on behalf of that party or are affiliated with a
7
law firm that has appeared on behalf of that party, and includes support staff.
8
2.11 Party: any party to this Action, including all of its officers, directors,
9
employees, consultants, retained experts, and Outside Counsel of Record (and
10
their support staffs).
11
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
12
Discovery Material in this Action.
13
2.13 Professional Vendors: persons or entities that provide litigation
14
support services (e.g., photocopying, videotaping, translating, preparing exhibits
15
or demonstrations, and organizing, storing, or retrieving data in any form or
16
medium) and their employees and subcontractors.
17
2.14 Protected Material: any Disclosure or Discovery Material that is
18
designated as “CONFIDENTIAL.”
19
2.15 Receiving Party: a Party that receives Disclosure or Discovery
20
Material from a Producing Party.
21
3. SCOPE
22
The protections conferred by this Stipulation and Order cover not only
23
Protected Material (as defined above), but also (1) any information copied or
24
extracted from Protected Material; (2) all copies, excerpts, summaries, or
25
compilations of Protected Material; and (3) any testimony, conversations, or
26
presentations by Parties or their Counsel that might reveal Protected Material.
27
Any use of Protected Material at trial shall be governed by the orders of the trial
28
1 judge. This Order does not govern the use of Protected Material at trial.
2 4. DURATION
Once a case proceeds to trial, information that was designated as
3
CONFIDENTIAL or maintained pursuant to this protective order used or
4
introduced as an exhibit at trial becomes public and will be presumptively
5
available to all members of the public, including the press, unless compelling
6
reasons supported by specific factual findings to proceed otherwise are made to
7
the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
8
(distinguishing “good cause” showing for sealing documents produced in
9
discovery from “compelling reasons” standard when merits-related documents are
10
part of court record). Accordingly, the terms of this protective order do not extend
11
beyond the commencement of the trial.
12
Notwithstanding the foregoing, with respect to financial, asset, and
13
business documents relating to enforcement of the right to attach orders and writs
14
of attachment entered in this case, or enforcement of any judgment entered in this
15
case, neither this Order, nor the Action shall not be deemed to have terminated, or
16
disposed of, until such time as any judgment entered has been satisfied.
17
5. DESIGNATING PROTECTED MATERIAL
18
5.1 Exercise of Restraint and Care in Designating Material for
19
Protection. Each Party or Non-Party that designates information or items for
20
protection under this Order must take care to limit any such designation to
21
specific material that qualifies under the appropriate standards. The Designating
22
Party must designate for protection only those parts of material, documents, items
23
or oral or written communications that qualify so that other portions of the
24
material, documents, items or communications for which protection is not
25
warranted are not swept unjustifiably within the ambit of this Order.
26
Mass, indiscriminate or routinized designations are prohibited.
27
Designations that are shown to be clearly unjustified or that have been made for
28
1 an improper purpose (e.g., to unnecessarily encumber the case development
2 process or to impose unnecessary expenses and burdens on other parties) may
expose the Designating Party to sanctions. If it comes to a Designating Party’s
3
attention that information or items that it designated for protection do not qualify
4
for protection, that Designating Party must promptly notify all other Parties that it
5
is withdrawing the inapplicable designation.
6
5.2 Manner and Timing of Designations. Except as otherwise provided
7
in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
8
stipulated or ordered, Disclosure or Discovery Material that qualifies for
9
protection under this Order must be clearly so designated before the material is
10
disclosed or produced.
11
Designation in conformity with this Order requires:
12
(a) for information in documentary form (e.g., paper or electronic
13
documents, but excluding transcripts of depositions or other pretrial or trial
14
proceedings), that the Producing Party affix at a minimum, the legend
15
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
16
contains protected material. If only a portion of the material on a page qualifies
17
for protection, the Producing Party also must clearly identify the protected
18
portion(s) (e.g., by making appropriate markings in the margins).
19
A Party or Non-Party that makes original documents available for
20
inspection need not designate them for protection until after the inspecting Party
21
has indicated which documents it would like copied and produced. During the
22
inspection and before the designation, all of the material made available for
23
inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
24
identified the documents it wants copied and produced, the Producing Party must
25
determine which documents, or portions thereof, qualify for protection under this
26
Order. Then, before producing the specified documents, the Producing Party must
27
affix the “CONFIDENTIAL legend” to each page that contains Protected
28
1 Material. If only a portion of the material on a page qualifies for protection, the
2 Producing Party also must clearly identify the protected portion(s) (e.g., by
making appropriate markings in the margins).
3
(b) for testimony given in depositions that the Designating Party
4
identifies the Disclosure or Discovery Material on the record, before the close of
5
the deposition all protected testimony.
6
(c) for information produced in some form other than documentary and
7
for any other tangible items, that the Producing Party affix in a prominent place
8
on the exterior of the container or containers in which the information is stored
9
the legend “CONFIDENTIAL.” If only a portion or portions of the information
10
warrants protection, the Producing Party, to the extent practicable, shall identify
11
the protected portion(s).
12
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
13
failure to designate qualified information or items does not, standing alone, waive
14
the Designating Party’s right to secure protection under this Order for such
15
material. Upon timely correction of a designation, the Receiving Party must make
16
reasonable efforts to assure that the material is treated in accordance with the
17
provisions of this Order.
18
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
20
designation of confidentiality at any time that is consistent with the Court’s
21
Scheduling Order.
22
6.2 Meet and Confer: The Challenging Party shall initiate the dispute
23
resolution process under Local Rule 37-1 et seq.
24
6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
25
joint stipulation pursuant to Local Rule 37-2.
26
6.4 The burden of persuasion in any such challenge proceeding shall be
27
on the Designating Party. Frivolous challenges, and those made for an improper
28
1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
2 parties) may expose the Challenging Party to sanctions. Unless the Designating
Party has waived or withdrawn the confidentiality designation, all parties shall
3
continue to afford the material in question the level of protection to which it is
4
entitled under the Producing Party’s designation until the Court rules on the
5
challenge.
6
7. ACCESS TO AND USE OF PROTECTED MATERIAL
7
7.1 Basic Principles. A Receiving Party may use Protected Material that
8
is disclosed or produced by another Party or by a Non-Party in connection with
9
this Action only for prosecuting, defending, attempting to settle this Action, for
10
the purpose of enforcing the right to attach orders and writs of attachment issued
11
in this Action, or enforcement of any judgment in this action. Such Protected
12
Material may be disclosed only to the categories of persons and under the
13
conditions described in this Order. When the Action has been terminated, a
14
Receiving Party must comply with the provisions of section 13 below (FINAL
15
DISPOSITION).
16
Notwithstanding the foregoing, including with respect to compliance with
17
the provisions of section 13 below (FINAL DISPOSITION), with respect to
18
financial, asset, and business documents relating to enforcement of the right to
19
attach orders and writs of attachment entered in this case, or enforcement of any
20
judgment entered in this case, the Action shall not be deemed to have terminated,
21
or disposed of, until such time as any judgment entered in the Action has been
22
satisfied.
23
Protected Material must be stored and maintained by a Receiving Party at a
24
location and in a secure manner that ensures that access is limited to the persons
25
authorized under this Order.
26
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
27
otherwise ordered by the court or permitted in writing by the Designating Party, a
28
1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as
3
well as employees of said Outside Counsel of Record to whom it is reasonably
4
necessary to disclose the information for this Action;
5
(b) the officers, directors, managers, members, and employees
6
(including House Counsel) of the Receiving Party to whom disclosure is
7
reasonably necessary for this Action;
8
(c) Experts (as defined in this Order) of the Receiving Party to whom
9
disclosure is reasonably necessary for this Action and who have signed the
10
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
11
(d) the court and its personnel;
12
(e) court reporters and their staff;
13
(f) professional jury or trial consultants, mock jurors, and Professional
14
Vendors to whom disclosure is reasonably necessary for this Action and who
15
have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16
(g) the author or recipient of a document containing the information or a
17
custodian or other person who otherwise possessed or knew the information;
18
(h) during their depositions, witnesses, and attorneys for witnesses, in
19
the Action to whom disclosure is reasonably necessary provided: (1) the deposing
20
party requests that the witness sign the form attached as Exhibit 1 hereto; and (2)
21
they will not be permitted to keep any confidential information unless they sign
22
them “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
23
otherwise agreed by the Designating Party or ordered by the court. Pages of
24
transcribed deposition testimony or exhibits to depositions that reveal Protected
25
Material may be separately bound by the court reporter and may not be disclosed
26
to anyone except as permitted under this Stipulated Protective Order;
27
(i) any mediator or settlement officer, and their supporting personnel,
28
1 mutually agreed upon by any of the parties engaged in settlement discussions;
2 (j) any levying officer and any other person lawfully executing process
or other enforcement method with respect to the right to attach orders or writs of
3
attachment issued in the Action, or any judgment issued in the Action, for the
4
purpose of providing the information necessary for execution of process or other
5
enforcement method;
6
(k) Any attorney, lawyer, or other legal professional retained or
7
consulted with respect to enforcement of any judgment in that jurisdiction; and
8
(l) Any investigator for the purpose of locating additional assets of
9
Defendants, for the purpose of enforcing to the right to attach orders or writs of
10
attachment issued in the Action, or any judgment issued in the Action, provided
11
that scope of such investigations shall be limited to assets located within the
12
United States of America, unless and until a judgment has been entered in the
13
Action, and provided that the investigator has signed the “Acknowledgment and
14
Agreement to Be Bound” (Exhibit A).
15
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
16
IN OTHER LITIGATION
17
If a Party is served with a subpoena or a court order issued in other
18
litigation that compels disclosure of any information or items designated in this
19
Action as “CONFIDENTIAL,” that Party must:
20
(a) promptly notify in writing the Designating Party. Such notification
21
shall include a copy of the subpoena or court order;
22
(b) promptly notify in writing the party who caused the subpoena or
23
order to issue in the other litigation that some or all of the material covered by the
24
subpoena or order is subject to this Protective Order. Such notification shall
25
include a copy of this Stipulated Protective Order; and
26
(c) cooperate with respect to all reasonable procedures sought to be
27
pursued by the Designating Party whose Protected Material may be affected. If
28
1 the Designating Party timely seeks a protective order, the Party served with the
2 subpoena or court order shall not produce any information designated in this
action as “CONFIDENTIAL” before a determination by the court from which the
3
subpoena or order issued, unless the Party has obtained the Designating Party’s
4
permission. The Designating Party shall bear the burden and expense of seeking
5
protection in that court of its confidential material and nothing in these provisions
6
should be construed as authorizing or encouraging a Receiving Party in this
7
Action to disobey a lawful directive from another court.
8
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
9
PRODUCED IN THIS LITIGATION
10
(a) The terms of this Order are applicable to information produced by a
11
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, to
17
produce a Non-Party’s confidential information in its possession, and the Party is
18
subject to an agreement with the Non-Party not to produce the Non-Party’s
19
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
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
Receiving Party may produce the Non-Party’s confidential information
3
responsive to the discovery request. If the Non-Party timely seeks a protective
4
order, the Receiving Party shall not produce any information in its possession or
5
control that is subject to the confidentiality agreement with the Non-Party before
6
a determination by the court. Absent a court order to the contrary, the Non-Party
7
shall bear the burden and expense of seeking protection in this court of its
8
Protected Material.
9
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
10
If a Receiving Party learns that, by inadvertence or otherwise, it has
11
disclosed Protected Material to any person or in any circumstance not authorized
12
under this Stipulated Protective Order, the Receiving Party must immediately (a)
13
notify in writing the Designating Party of the unauthorized disclosures, (b) use its
14
best efforts to retrieve all unauthorized copies of the Protected Material, (c)
15
inform the person or persons to whom unauthorized disclosures were made of all
16
the terms of this Order, and (d) request such person or persons to execute the
17
“Acknowledgment and Agreement to Be Bound” that is attached hereto as
18
Exhibit A.
19
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
20
PROTECTED MATERIAL
21
When a Producing Party gives notice to Receiving Parties that certain
22
inadvertently produced material is subject to a claim of privilege or other
23
protection, the obligations of the Receiving Parties are those set forth in Federal
24
Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
25
whatever procedure may be established in an e-discovery order that provides for
26
production without prior privilege review. Pursuant to Federal Rule of Evidence
27
502(d) and (e), insofar as the parties reach an agreement on the effect of
28
1 disclosure of a communication or information covered by the attorney-client
2 privilege or work product protection, the parties may incorporate their agreement
in the stipulated protective order submitted to the court.
3
12. MISCELLANEOUS
4
12.1 Right to Further Relief. Nothing in this Order abridges the right of
5
any person to seek its modification by the Court in the future.
6
12.2 Right to Assert Other Objections. By stipulating to the entry of this
7
Protective Order, no Party waives any right it otherwise would have to object to
8
disclosing or producing any information or item on any ground not addressed in
9
this Stipulated Protective Order. Similarly, no Party waives any right to object on
10
any ground to use in evidence of any of the material covered by this Protective
11
Order.
12
12.3 Filing Protected Material. A Party that seeks to file under seal any
13
Protected Material must comply with Local Civil Rule 79-5. Protected Material
14
may only be filed under seal pursuant to a court order authorizing the sealing of
15
the specific Protected Material at issue. If a Party’s request to file Protected
16
Material under seal is denied by the court, then the Receiving Party may file the
17
information in the public record unless otherwise instructed by the court.
18
13. FINAL DISPOSITION
19
After the final disposition of this Action, as defined in paragraph 4, and
20
7.1, above, within 60 days of a written request by the Designating Party, each
21
Receiving Party must return all Protected Material to the Producing Party or
22
destroy such material. As used in this subdivision, “all Protected Material”
23
includes all copies, abstracts, compilations, summaries, and any other format
24
reproducing or capturing any of the Protected Material. Whether the Protected
25
Material is returned or destroyed, the Receiving Party must submit a written
26
certification to the Producing Party (and, if not the same person or entity, to the
27
Designating Party) by the 60 day deadline that (1) identifies (by category, where
28
1 ||appropriate) all the Protected Material that was returned or destroyed and (2)
2 ||affirms that the Receiving Party has not retained any copies, abstracts,
3 || compilations, summaries or any other format reproducing or capturing any of the
4 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain
5 |}an archival copy of all pleadings, motion papers, trial, deposition, and hearing
6 || transcripts, legal memoranda, correspondence, deposition and trial exhibits,
7 || expert reports, attorney work product, and consultant and expert work product,
g ||even if such materials contain Protected Material. Any such archival copies that
9 || contain or constitute Protected Material remain subject to this Protective Order as
10 || set forth Section 4 (DURATION).
11 VIOLATION
12 || Any violation of this Order may be punished by appropriate measures including,
13 || without limitation, contempt proceedings and/or monetary sanctions.
14 |} DATED: June 7, 2023 PARK & LIM
15 By: _/S/S. Young Lim
16 Piaintiff Jeereddi Enterprises LLC
17
|| DATED: June 7 , 2023 BARANOV & WITTENBERG, LLP
By: /S/ Michael M. Baranov
21 LLC
22
53 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
||DATED: 6/8/2023
25
|) Bey Maxk&-——
27 || HON. ALEXANDER F. MacKINNON
United States Magistrate Judge
□
STIPULATED PROTECTIVE ORDER
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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
6
California on [date] in the case of Jeereddi Enterprises, LLC v. Venkata Subash
7
Banda, Lodestar Holdings LLC, Case No. 22-cv-1614-SSS-AFM. I agree to
8
comply with and to be bound by all the terms of this Stipulated Protective Order
9
and I understand and acknowledge that failure to so comply could expose me to
10
sanctions and punishment in the nature of contempt. I solemnly promise that I
11
will not disclose in any manner any information or item that is subject to this
12
Stipulated Protective Order to any person or entity except in strict compliance
13
with the provisions of this Order. I further agree to submit to the jurisdiction of
14
the United States District Court for the Central District of California for enforcing
15
the terms of this Stipulated Protective Order, even if such enforcement
16
proceedings occur after termination of this action. I hereby appoint
17
__________________________ [print or type full name] of
18
_______________________________________ [print or type full address and
19
telephone number] as my California agent for service of process in connection
20
with this action or any proceedings related to enforcement of this Stipulated
21
Protective Order.
22
Date: ______________________________________
23
City and State where sworn and signed: _________________________________
24
Printed name: _______________________________
25
Signature: __________________________________
26
27
28