distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record
- even stipulated protective orders require 13 good cause showing
Written by the judges who cited it.
The opinion
1 Michael J. Plati, AZ #016705
2 Admitted pro hac vice
CONSUMER ATTORNEYS
3 8245 N 85th Way
4 Scottsdale, AZ 85258
T: (602) 807-1505
5
F: (718) 715-1750
6 E: mplati@consumerattorneys.com
Attorneys for Plaintiff,
7
Marco Rastelli
8
9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA
11
12
MARCO RASTELLI
Case No. 2:23-cv-01807-JLS-PD
13 Plaintiff,
14 v. STIPULATED PROTECTIVE
ORDER1
15
EQUIFAX INFORMATION
SERVICES, LLC; and ALLEGACY
16 FEDERAL CREDIT UNION
17 Defendants.
18
19
20
1. A. PURPOSES AND LIMITATIONS
21
Discovery in this action is likely to involve production of confidential,
22
proprietary, or private information for which special protection from public
23
disclosure and from use for any purpose other than prosecuting this litigation may be
24
warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
25
26
27
1 This Stipulated Protective Order is substantially based on the model protective
1 the following Stipulated Protective Order. The parties acknowledge that this Order
2 does not confer blanket protections on all disclosures or responses to discovery and
3 that the protection it affords from public disclosure and use extends only to the
4 limited information or items that are entitled to confidential treatment under the
5 applicable legal principles.
6 B. GOOD CAUSE STATEMENT
7 This action is likely to involve trade secrets, cost and pricing information and
8 other valuable commercial, financial, technical and/or proprietary information for
9 which special protection from public disclosure and from use for any purpose other
10 than prosecution of this action is warranted. This action will also likely involve
11 consumer protected personal information. Such confidential and proprietary materials
12 and information consist of, among other things, confidential business or financial
13 information, information regarding confidential business practices, or other
14 confidential commercial information (including information implicating privacy
15 rights of third parties), information otherwise generally unavailable to the public, or
16 which may be privileged or otherwise protected from disclosure under state or
17 federal statutes, court rules, case decisions, or common law. Accordingly, to expedite
18 the flow of information, to facilitate the prompt resolution of disputes over
19 confidentiality of discovery materials, to adequately protect information the parties
20 are entitled to keep confidential, to ensure that the parties are permitted reasonable
21 necessary uses of such material in preparation for and in the conduct of trial, to
22 address their handling at the end of the litigation, and serve the ends of justice, a
23 protective order for such information is justified in this matter. It is the intent of the
24 parties that information will not be designated as confidential for tactical reasons
25 and that nothing be so designated without a good faith belief that it has been
26 maintained in a confidential, non-public manner, and there is good cause why it
27 should not be part of the public record of this case.
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: Marco Rastelli v. Equifax Information Services, LLC,
10 et al.; Case No. 2:23-cv-01807-JLS-PD.
11 2.2 Challenging Party: a Party or Non-Party that challenges
12 the designation of information or items under this Order.
13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
14 how it is generated, stored or maintained) or tangible things that qualify for
15 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the
16 Good Cause Statement.
17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
18 their support staff).
19 2.5 Designating Party: a Party or Non-Party that designates information or
20 items that it produces in disclosures or in responses to discovery as
21 “CONFIDENTIAL.”
22 2.6 Disclosure or Discovery Material: all items or information, regardless
23 of the medium or manner in which it is generated, stored, or maintained (including,
24 among other things, testimony, transcripts, and tangible things), that are produced or
25 generated in disclosures or responses to discovery in this matter.
26 2.7 Expert: a person with specialized knowledge or experience in a matter
27 pertinent to the litigation who has been retained by a Party or its counsel to serve as
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
16 support 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 4. DURATION
5 FINAL DISPOSITION of the action is defined as the conclusion of any
6 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal
7 has run. Except as set forth below, the terms of this protective order apply through
8 FINAL DISPOSITION of the action. The parties may stipulate that the they will be
9 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
10 but will have to file a separate action for enforcement of the agreement once all
11 proceedings in this case are complete.
12
Once a case proceeds to trial, information that was designated as
13
CONFIDENTIAL or maintained pursuant to this protective order used or introduced
14
as an exhibit at trial becomes public and will be presumptively available to all
15
members of the public, including the press, unless compelling reasons supported by
16
specific factual findings to proceed otherwise are made to the trial judge in advance
17
of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
18
showing for sealing documents produced in discovery from “compelling reasons”
19
standard when merits-related documents are part of court record). Accordingly, for
20
such materials, the terms of this protective order do not extend beyond the
21
commencement of the trial.
22
23
5. DESIGNATING PROTECTED MATERIAL
24
5.1 Exercise of Restraint and Care in Designating Material for Protection.
25
Each Party or Non-Party that designates information or items for protection under
26
this Order must take care to limit any such designation to specific material that
27
qualifies under the appropriate standards. The Designating Party must designate for
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.
11
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.
25
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:
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 produce a Non-Party’s confidential information in its possession, and the Party is
2 subject to an agreement with the Non-Party not to produce the Non-Party’s
3 confidential information, then the Party shall:
4 (1) promptly notify in writing the Requesting Party and the Non-Party
5 that some or all of the information requested is subject to a confidentiality agreement
6 with a Non-Party;
7 (2) promptly provide the Non-Party with a copy of the Stipulated
8 Protective Order in this Action, the relevant discovery request(s), and a reasonably
9 specific description of the information requested; and
10 (3) make the information requested available for inspection by the
11 Non-Party, if requested.
12 (c) If the Non-Party fails to seek a protective order from this court within
13 14 days of receiving the notice and accompanying information, the Receiving Party
14 may produce the Non-Party’s confidential information responsive to the discovery
15 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
16 not produce any information in its possession or control that is subject to the
17 confidentiality agreement with the Non-Party before a determination by the court.
18 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
19 of seeking protection in this court of its Protected Material.
20
21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
23
Protected Material to any person or in any circumstance not authorized under this
24
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
25
writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
26
to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
27
persons to whom unauthorized disclosures were made of all the terms of this Order,
1 and (d) request such person or persons to execute the “Acknowledgment and
2 Agreement to Be Bound” that is attached hereto as Exhibit A.
3
4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL
6
When a Producing Party gives notice to Receiving Parties that certain
7
inadvertently produced material is subject to a claim of privilege or other protection,
8
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
9
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
10
may be established in an e-discovery order that provides for production without prior
11
privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
12
parties reach an agreement on the effect of disclosure of a communication or
13
information covered by the attorney-client privilege or work product protection, the
14
parties may incorporate their agreement in the stipulated protective order submitted
15
to the court.
16
17
12. MISCELLANEOUS
18
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
19
person to seek its modification by the Court in the future.
20
12.2 Right to Assert Other Objections. By stipulating to the entry of this
21
Protective Order no Party waives any right it otherwise would have to object to
22
disclosing or producing any information or item on any ground not addressed in this
23
Stipulated Protective Order. Similarly, no Party waives any right to object on any
24
ground to use in evidence of any of the material covered by this Protective Order.
25
12.3 Filing Protected Material. A Party that seeks to file under seal any
26
Protected Material must comply with Civil Local Rule 79-5. Protected Material may
27
only be filed under seal pursuant to a court order authorizing the sealing of the
1 specific Protected Material at issue. If a Party's request to file Protected Material
2 under seal is denied by the court, then the Receiving Party may file the information
3 in the public record unless otherwise instructed by the court.
4 13. FINAL DISPOSITION
5 After the final disposition of this Action, as defined in paragraph 4, within 60
6 days of a written request by the Designating Party, each Receiving Party must return
7 all Protected Material to the Producing Party or destroy such material. As used in
8 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
9 summaries, and any other format reproducing or capturing any of the Protected
10 Material. Whether the Protected Material is returned or destroyed, the Receiving
11 Party must submit a written certification to the Producing Party (and, if not the same
12 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
13 (by category, where appropriate) all the Protected Material that was returned or
14 destroyed and (2)affirms that the Receiving Party has not retained any copies,
15 abstracts, compilations, summaries or any other format reproducing or capturing any
16 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
17 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
18 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
19 reports, attorney work product, and consultant and expert work product, even if such
20 materials contain Protected Material. Any such archival copies that contain or
21 constitute Protected Material remain subject to this Protective Order as set forth in
22 Section 4 (DURATION).
23
24 14. Any violation of this Order may be punished by any and all appropriate
25 measures including, without limitation, contempt proceedings and/or monetary
26 sanctions.
27
1
2 //
3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
4
5 DATED: October 23, 2023
6 By: /s/ Michael J. Plati By: /s/ Justin M. Penn
Michael J. Plati, AZ #016705 JUSTIN M. PENN (SBN 302305)
7
Admitted pro hac vice jpenn@hinshawlaw.com
8 CONSUMER ATTORNEYS S A R A E . FRANKS (SBN 345940)
8245 N 85th Way sfranks@hinshawlaw.com
9
Scottsdale, AZ 85258 HINSHAW & CULBERTSON LLP
10 T: (602) 807-1505 350 South Grand Ave., Suite 3600
F: (718) 715-1750 Los Angeles, CA 90071-3476
11
E: mplati@consumerattorneys.com T e l e p h o n e : 2 1 3 - 6 8 0 - 2 8 0 0
12 Facsimile: 213-614-7399
Lauren Tegan Rodkey (SBN: 275830) Attorneys for Defendant
13
PRICE LAW GROUP, APC Allegacy Federal Credit Union
14 6345 Balboa Blvd., Suite 247
Encino, CA 91316
15
T: (818) 600-5526
16 F: (818) 600-5526
E: tegan@pricelawgroup.com
17
18 Attorneys for Plaintiff,
Marco Rastelli
19
20
SIGNATURE CERTIFICATION
21
22 Pursuant to L.R. 5-4.3.4(a)(2), I hereby certify that all other signatories listed,
23
on whose behalf this filing is submitted, concur with the contents of this filing, and
24
have authorized the filing.
25
26 DATED: October 23, 2023 By: /s/ Michael Plati
Attorneys for Plaintiff Marco Rastelli
27
1
2 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
3
4 DATED: October 24, 2023
5
6 PATRICIA DONAHUE
7 _______________________________________
Hon. Patricia Donahue
8
United States Magistrate Judge
9
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1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3 I, ________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on ___________ in the case of Marco Rastelli v. Equifax Information Services,
8 LLC, et al.; Case No. 2:23-cv-01807-JLS-PD . I agree to comply with and to be
9 bound 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