David Faris v. Petit Pot, Inc.

1 IAN K. BOYD (SBN 191434) LISA OMOTO (State Bar No. 303830)

2 E-Mail: iboyd@sideman.com E-Mail: lomoto@faruqilaw.com

MICHAEL H. HEWITT (SBN 309691) FARUQI & FARUQI, LLP

3 E-Mail: mhewitt@sideman.com 1901 Avenue of the Stars, Suite 1060

4 SIDEMAN & BANCROFT LLP Los Angeles, California 90067

One Embarcadero Center, 22nd Floor Telephone: (424) 256-2884

5

San Francisco, California 94111-3711 Facsimile: (424) 256-2885

6 Telephone: (415) 392-1960

Facsimile: (415) 392-0827 Counsel for Plaintiff David Faris

7

and the Proposed Classes

8 Attorneys for

Defendant Petit Pot, Inc.

9

10

11 UNITED STATES DISTRICT COURT

12 CENTRAL DISTRICT OF CALIFORNIA

13

DAVID FARIS, individually and on

14 behalf of all others similarly situated, Case No. 2:23-cv-01955-JFW-PD

15 DISCOVERY MATTER -

STIPULATED PROTECTIVE

16 Plaintiff, ORDER1

17 v.

18

PETIT POT, INC.,

19

Defendant.

20

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

26

27

1 This Stipulated Protective Order is substantially based on the model protective

1 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter

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

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

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

5 limited information or items that are entitled to confidential treatment under the

6 applicable legal principles.

7 B. GOOD CAUSE STATEMENT

8 This action is likely to involve trade secrets, customer and pricing lists,

9 product formulation, and other valuable research, development, commercial,

10 financial, technical and/or proprietary information for which special protection from

11 public disclosure and from use for any purpose other than prosecution of this action

12 is warranted. Such confidential and proprietary materials and information consist of,

13 among other things, confidential business or financial information, information

14 regarding confidential business practices, or other confidential research,

15 development, or commercial information (including information implicating privacy

16 rights of third parties), information otherwise generally unavailable to the public, or

17 which may be privileged or otherwise protected from disclosure under state or

18 federal statutes, court rules, case decisions, or common law. Accordingly, to expedite

19 the flow of information, to facilitate the prompt resolution of disputes over

20 confidentiality of discovery materials, to adequately protect information the parties

21 are entitled to keep confidential, to ensure that the parties are permitted reasonable

22 necessary uses of such material in preparation for and in the conduct of trial, to

23 address their handling at the end of the litigation, and serve the ends of justice, a

24 protective order for such information is justified in this matter. It is the intent of the

25 parties that information will not be designated as confidential for tactical reasons

26 and that nothing be so designated without a good faith belief that it has been

27 maintained in a confidential, non-public manner, and there is good cause why it

1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

2 The parties further acknowledge, as set forth in Section 12.3, below, that this

3 Stipulated Protective Order does not entitle them to file confidential information

4 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and

5 the standards that will be applied when a party seeks permission from the court to

6 file material under seal.

7 There is a strong presumption that the public has a right of access to judicial

8 proceedings and records in civil cases. In connection with non-dispositive motions,

9 good cause must be shown to support a filing under seal. See Kamakana v. City and

10 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

11 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,

12 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require

13 good cause showing), and a specific showing of good cause or compelling reasons

14 with proper evidentiary support and legal justification, must be made with respect to

15 Protected Material that a party seeks to file under seal. The parties’ mere designation

16 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the

17 submission of competent evidence by declaration, establishing that the material

18 sought to be filed under seal qualifies as confidential, privileged, or otherwise

19 protectable—constitute good cause.

20 Further, if a party requests sealing related to a dispositive motion or trial, then

21 compelling reasons, not only good cause, for the sealing must be shown, and the

22 relief sought shall be narrowly tailored to serve the specific interest to be protected.

23 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each

24 item or type of information, document, or thing sought to be filed or introduced under

25 seal in connection with a dispositive motion or trial, the party seeking protection

26 must articulate compelling reasons, supported by specific facts and legal

27 justification, for the requested sealing order. Again, competent evidence supporting

1 Any document that is not confidential, privileged, or otherwise protectable in

2 its entirety will not be filed under seal if the confidential portions can be redacted. If

3 documents can be redacted, then a redacted version for public viewing, omitting only

4 the confidential, privileged, or otherwise protectable portions of the document, shall

5 be filed. Any application that seeks to file documents under seal in their entirety

6 should include an explanation of why redaction is not feasible.

7

8 2. DEFINITIONS

9 2.1 Action: Faris v. Petit Pot, Inc., Case No. 2:23-cv-01955-JFW-PD

10 2.2 Challenging Party: a Party or Non-Party that challenges

11 the designation of information or items under this Order.

12 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

13 how it is generated, stored or maintained) or tangible things that qualify for

14 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the

15 Good Cause Statement.

16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

17 their support staff).

18 2.5 Designating Party: a Party or Non-Party that designates information or

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

20 “CONFIDENTIAL.”

21 2.6 Disclosure or Discovery Material: all items or information, regardless

22 of the medium or manner in which it is generated, stored, or maintained (including,

23 among other things, testimony, transcripts, and tangible things), that are produced or

24 generated in disclosures or responses to discovery in this matter.

25 2.7 Expert: a person with specialized knowledge or experience in a matter

26 pertinent to the litigation who has been retained by a Party or its counsel to serve as

27 an expert witness or as a consultant in this Action.

1 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

3 counsel.

4 2.9 Non-Party: any natural person, partnership, corporation, association, or

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

6 2.10 Outside Counsel of Record: attorneys who are not employees of a party

7 to this Action but are retained to represent or advise a party to this Action and have

8 appeared in this Action on behalf of that party or are affiliated with a law firm which

9 has appeared on behalf of that party, and includes support staff.

10 2.11 Party: any party to this Action, including all of its officers, directors,

11 employees, consultants, retained experts, and Outside Counsel of Record (and their

12 support staffs).

13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

14 Discovery Material in this Action.

15 2.13 Professional Vendors: persons or entities that provide litigation support

16 services (e.g., photocopying, videotaping, translating, preparing exhibits or

17 demonstrations, and organizing, storing, or retrieving data in any form or medium)

18 and their employees and subcontractors.

19 2.14 Protected Material: any Disclosure or Discovery Material that is

20 designated as “CONFIDENTIAL.”

21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

22 from a Producing Party.

23

24 3. SCOPE

25 The protections conferred by this Stipulation and Order cover not only

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

27 extracted from Protected Material; (2) all copies, excerpts, summaries, or

1 presentations by Parties or their Counsel that might reveal Protected Material.

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

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

4

5 4. DURATION

6 FINAL DISPOSITION of the action is defined as the conclusion of any

7 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal

8 has run. Except as set forth below, the terms of this protective order apply through

9 FINAL DISPOSITION of the action. The parties may stipulate that they will be

10 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,

11 but will have to file a separate action for enforcement of the agreement once all

12 proceedings in this case are complete.

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

14 CONFIDENTIAL or maintained pursuant to this protective order used or introduced

15 as an exhibit at trial becomes public and will be presumptively available to all

16 members of the public, including the press, unless compelling reasons supported by

17 specific factual findings to proceed otherwise are made to the trial judge in advance

18 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

19 showing for sealing documents produced in discovery from “compelling reasons”

20 standard when merits-related documents are part of court record). Accordingly, for

21 such materials, the terms of this protective order do not extend beyond the

22 commencement of the trial.

23

24 5. DESIGNATING PROTECTED MATERIAL

25 5.1 Exercise of Restraint and Care in Designating Material for Protection.

26 Each Party or Non-Party that designates information or items for protection under

27 this Order must take care to limit any such designation to specific material that

1 protection only those parts of material, documents, items, or oral or written

2 communications that qualify so that other portions of the material, documents, items,

3 or communications for which protection is not warranted are not swept unjustifiably

4 within the ambit of this Order.

5 Mass, indiscriminate, or routinized designations are prohibited. Designations

6 that are shown to be clearly unjustified or that have been made for an improper

7 purpose (e.g., to unnecessarily encumber the case development process or to impose

8 unnecessary expenses and burdens on other parties) may expose the Designating

9 Party to sanctions.

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

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

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

13 5.2 Manner and Timing of Designations. Except as otherwise provided in

14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

15 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

16 under this Order must be clearly so designated before the material is disclosed or

17 produced.

18 Designation in conformity with this Order requires:

19 (a) for information in documentary form (e.g., paper or electronic

20 documents, but excluding transcripts of depositions or other pretrial or trial

21 proceedings), that the Producing Party affix at a minimum, the legend

22 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

23 contains protected material. If only a portion or portions of the material on a page

24 qualifies for protection, the Producing Party also must clearly identify the protected

25 portion(s) (e.g., by making appropriate markings in the margins).

26 A Party or Non-Party that makes original documents available for inspection

27 need not designate them for protection until after the inspecting Party has indicated

1 before the designation, all of the material made available for inspection shall be

2 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

3 documents it wants copied and produced, the Producing Party must determine which

4 documents, or portions thereof, qualify for protection under this Order. Then, before

5 producing the specified documents, the Producing Party must affix the

6 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

7 portion or portions of the material on a page qualifies for protection, the Producing

8 Party also must clearly identify the protected portion(s) (e.g., by making appropriate

9 markings in the margins).

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

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

12 all protected testimony.

13 (c) for information produced in some form other than documentary and for

14 any other tangible items, that the Producing Party affix in a prominent place on the

15 exterior of the container or containers in which the information is stored the legend

16 “CONFIDENTIAL.” If only a portion or portions of the information warrants

17 protection, the Producing Party, to the extent practicable, shall identify the protected

18 portion(s).

19 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

20 failure to designate qualified information or items does not, standing alone, waive

21 the Designating Party’s right to secure protection under this Order for such material.

22 Upon timely correction of a designation, the Receiving Party must make reasonable

23 efforts to assure that the material is treated in accordance with the provisions of this

24 Order.

25

26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

27 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

1 Scheduling Order.

2 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

3 resolution process under Local Rule 37.1 et seq.

4 6.3 The burden of persuasion in any such challenge proceeding shall be on

5 the Designating Party. Frivolous challenges, and those made for an improper purpose

6 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may

7 expose the Challenging Party to sanctions. Unless the Designating Party has waived

8 or withdrawn the confidentiality designation, all parties shall continue to afford the

9 material in question the level of protection to which it is entitled under the Producing

10 Party’s designation until the Court rules on the challenge.

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12 7. ACCESS TO AND USE OF PROTECTED MATERIAL

13 7.1 Basic Principles. A Receiving Party may use Protected Material that is

14 disclosed or produced by another Party or by a Non-Party in connection with this

15 Action only for prosecuting, defending, or attempting to settle this Action. Such

16 Protected Material may be disclosed only to the categories of persons and under the

17 conditions described in this Order. When the Action has been terminated, a

18 Receiving Party must comply with the provisions of section 13 below (FINAL

19 DISPOSITION).

20 Protected Material must be stored and maintained by a Receiving Party at a

21 location and in a secure manner that ensures that access is limited to the persons

22 authorized under this Order.

23 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

24 otherwise ordered by the court or permitted in writing by the Designating Party, a

25 Receiving Party may disclose any information or item designated

26 “CONFIDENTIAL” only to:

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

1 to disclose the information for this Action;

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

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

4 (c) Experts (as defined in this Order) of the Receiving Party to whom

5 disclosure is reasonably necessary for this Action and who have signed the

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

7 (d) the court and its personnel;

8 (e) court reporters and their staff;

9 (f) professional jury or trial consultants, mock jurors, and Professional

10 Vendors to whom disclosure is reasonably necessary for this Action and who have

11 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

12 (g) the author or recipient of a document containing the information or a

13 custodian or other person who otherwise possessed or knew the information;

14 (h) during their depositions, witnesses ,and attorneys for witnesses, in the

15 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

16 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

17 not be permitted to keep any confidential information unless they sign the

18 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

19 agreed by the Designating Party or ordered by the court. Pages of transcribed

20 deposition testimony or exhibits to depositions that reveal Protected Material may

21 be separately bound by the court reporter and may not be disclosed to anyone except

22 as permitted under this Stipulated Protective Order; and

23 (i) any mediator or settlement officer, and their supporting personnel,

24 mutually agreed upon by any of the parties engaged in settlement discussions.

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26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

27 IN OTHER LITIGATION

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

2 “CONFIDENTIAL,” that Party must unless prohibited by law from doing so:

3 (a) promptly notify in writing the Designating Party. Such notification shall

4 include a copy of the subpoena or court order;

5 (b) promptly notify in writing the party who caused the subpoena or order

6 to issue in the other litigation that some or all of the material covered by the subpoena

7 or order is subject to this Protective Order. Such notification shall include a copy of

8 this Stipulated Protective Order; and

9 (c) cooperate with respect to all reasonable procedures sought to be pursued

10 by the Designating Party whose Protected Material may be affected.

11 If the Designating Party timely seeks a protective order, the Party served

12 with the subpoena or court order shall not produce any information designated in this

13 action as “CONFIDENTIAL” before a determination by the court from which the

14 subpoena or order issued, unless the Party has obtained the Designating Party’s

15 permission. The Designating Party shall bear the burden and expense of seeking

16 protection in that court of its confidential material and nothing in these provisions

17 should be construed as authorizing or encouraging a Receiving Party in this Action

18 to disobey a lawful directive from another court.

19

20 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT

21 TO BE PRODUCED IN THIS LITIGATION

22 (a) The terms of this Order are applicable to information produced by a

23 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

24 produced by Non-Parties in connection with this litigation is protected by the

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

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

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

1 subject to an agreement with the Non-Party not to produce the Non-Party’s

2 confidential information, then the Party shall:

3 (1) promptly notify in writing the Requesting Party and the Non-Party

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

5 with a Non-Party;

6 (2) promptly provide the Non-Party with a copy of the Stipulated

7 Protective Order in this Action, the relevant discovery request(s), and a reasonably

8 specific description of the information requested; and

9 (3) make the information requested available for inspection by the

10 Non-Party, if requested.

11 (c) If the Non-Party fails to seek a protective order from this court within

12 14 days of receiving the notice and accompanying information, the Receiving Party

13 may produce the Non-Party’s confidential information responsive to the discovery

14 request. If the Non-Party timely seeks a protective order, the Receiving Party shall

15 not produce any information in its possession or control that is subject to the

16 confidentiality agreement with the Non-Party before a determination by the court.

17 Absent a court order to the contrary, the Non-Party shall bear the burden and expense

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

19

20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

21 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

22 Protected Material to any person or in any circumstance not authorized under this

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

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

25 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

26 persons to whom unauthorized disclosures were made of all the terms of this Order,

27 and (d) request such person or persons to execute the “Acknowledgment and

1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

2 PROTECTED MATERIAL

3 When a Producing Party gives notice to Receiving Parties that certain

4 inadvertently produced material is subject to a claim of privilege or other protection,

5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

7 may be established in an e-discovery order that provides for production without prior

8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

9 parties reach an agreement on the effect of disclosure of a communication or

10 information covered by the attorney-client privilege or work product protection, the

11 parties may incorporate their agreement in the stipulated protective order submitted

12 to the court.

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14 12. MISCELLANEOUS

15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

16 person to seek its modification by the Court in the future.

17 12.2 Right to Assert Other Objections. By stipulating to the entry of this

18 Protective Order no Party waives any right it otherwise would have to object to

19 disclosing or producing any information or item on any ground not addressed in this

20 Stipulated Protective Order. Similarly, no Party waives any right to object on any

21 ground to use in evidence of any of the material covered by this Protective Order.

22 12.3 Filing Protected Material. A Party that seeks to file under seal any

23 Protected Material must comply with Civil Local Rule 79-5 and the Standing Order

24 of Judge John F. Walter (ECF No. 9). Protected Material may only be filed under

25 seal pursuant to a court order authorizing the sealing of the specific Protected

26 Material at issue. If a Party's request to file Protected Material under seal is denied

27 by the court, then the Receiving Party may file the information in the public record

1 13. FINAL DISPOSITION

2 After the final disposition of this Action, as defined in paragraph 4, within 60

3 days of a written request by the Designating Party, each Receiving Party must return

4 all Protected Material to the Producing Party or destroy such material. As used in

5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

6 summaries, and any other format reproducing or capturing any of the Protected

7 Material. Whether the Protected Material is returned or destroyed, the Receiving

8 Party must submit a written certification to the Producing Party (and, if not the same

9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

10 (by category, where appropriate) all the Protected Material that was returned or

11 destroyed and (2)affirms that the Receiving Party has not retained any copies,

12 abstracts, compilations, summaries or any other format reproducing or capturing any

13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to

14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

16 reports, attorney work product, and consultant and expert work product, even if such

17 materials contain Protected Material. Any such archival copies that contain or

18 constitute Protected Material remain subject to this Protective Order as set forth in

19 Section 4 (DURATION).

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1 14. Any violation of this Order may be punished by any and all appropriate

2 measures including, without limitation, contempt proceedings and/or monetary

3 sanctions.

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5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

6

7 Dated: June 12, 2023 SIDEMAN & BANCROFT LLP

8 By: /s/ Ian K. Boyd

9 Ian K. Boyd (Bar No. 191434)

Michael H. Hewitt (Bar No. 309691)

10

11 One Embarcadero Center, 22nd Floor

San Francisco, California 94111-3711

12

Telephone: (415) 392-1960

13 Facsimile: (415) 392-0827

Email: iboyd@sideman.com

14

Email: mhewitt@sideman.com

15

16 Attorneys for Defendant Petit Pot, Inc.

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18

Dated: June 12, 2023 FARUQI & FARUQI, LLP

19

20

By: /s/ Lisa T. Omoto

21 Lisa T. Omoto (Bar No. 303830)

22

1901 Avenue of the Stars, Suite 1060

23 Los Angeles, California 90067

Telephone: (424) 256-2884

24

Facsimile: (424) 256-2885

25 lomoto@faruqilaw.com

26

Attorney for Plaintiff David Faris

27

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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3 || DATED: June 12, 2023

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; Pali Lona

6 Patricia Donahue

, United States Magistrate Judge

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, ________________________ [print or type full name], of ______________

4 [print or type full address], declare under penalty of perjury that I have read in its

5 entirety and understand the Stipulated Protective Order that was issued by the

6 United States District Court for the Central District of California on [date] in the

7 case of __________________ [insert formal name of the case and the number

8 and initials assigned to it by the court]. I agree to comply with and to be bound

9 by all the terms of this Stipulated Protective Order and I understand and

10 acknowledge that failure to so comply could expose me to sanctions and

11 punishment in the nature of contempt. I solemnly promise that I will not disclose

12 in any manner any information or item that is subject to this Stipulated Protective

13 Order to any person or entity except in strict compliance with the provisions of this

14 Order.

15 I further agree to submit to the jurisdiction of the United States District Court for

16 the Central District of California for the purpose of enforcing the terms of this

17 Stipulated Protective Order, even if such enforcement proceedings occur after

18 termination of this action. I hereby appoint ________________________ [print or

19 type full name] of _________ [print or type full address and telephone number] as

20 my California agent for service of process in connection with this action or any

21 proceedings related to enforcement of this Stipulated Protective Order.

22 Date: __________________________

23

24 City and State where sworn and signed: _____________________________

25

26 Printed name: ____________________________________

27