Geoffrey Strehl v. Guitar Center, Inc.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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10 GEOFFREY STREHL, individually No. 2:23-cv-02603 JAK (RAOx)

and on behalf of all others similarly

11 situated,

12 Plaintiff, [xPxRxOxxPxOxSxExxDx] STIPULATED

PROTECTIVE ORDER1

13 v.

14 GUITAR CENTER, INC.,

15 Defendant.

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1. A. PURPOSES AND LIMITATIONS

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Discovery in this action is likely to involve production of confidential,

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proprietary or private information for which special protection from public

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

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

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

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Order does not confer blanket protections on all disclosures or responses to

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discovery and that the protection it affords from public disclosure and use extends

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1 only to the limited information or items that are entitled to confidential treatment

2 under the applicable legal principles.

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4 B. GOOD CAUSE STATEMENT

5 This action is likely to involve trade secrets, customer lists and other valuable

6 research, development, commercial, financial, technical and/or proprietary

7 information for which special protection from public disclosure and from use for

8 any purpose other than prosecution of this action is warranted. Such confidential

9 and proprietary materials and information consist of, among other things,

10 confidential business or financial information (such as confidential licensing

11 agreements), information regarding confidential business practices (such as sales,

12 research and development, marketing, or manufacturing information or software

13 code), or other confidential research, development, or commercial information

14 (including information implicating privacy rights of third parties, such as

15 confidential personal medical, financial, or credit information, or information for

16 which a party is under a duty or obligation of confidentiality), information otherwise

17 generally unavailable to the public, or which may be privileged or otherwise

18 protected from disclosure under state or federal statutes, court rules, case decisions,

19 or common law. Accordingly, to expedite the flow of information, to facilitate the

20 prompt resolution of disputes over confidentiality of discovery materials, to

21 adequately protect information the parties are entitled to keep confidential, to ensure

22 that the parties are permitted reasonable necessary uses of such material in

23 preparation for and in the conduct of trial, to address their handling at the end of the

24 litigation, and serve the ends of justice, a protective order for such information is

25 justified in this matter. It is the intent of the parties that information will not be

26 designated as confidential for tactical reasons and that nothing be so designated

27 without a good faith belief that it has been maintained in a confidential, non-public

1 manner, and there is good cause why it should not be part of the public record of this

2 case.

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4 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

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

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

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

8 and the standards that will be applied when a party seeks permission from the court

9 to file material under seal.

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

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

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

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

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

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

16 require good cause showing), and a specific showing of good cause or compelling

17 reasons with proper evidentiary support and legal justification, must be made with

18 respect to Protected Material that a party seeks to file under seal. The parties’ mere

19 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

20 without the submission of competent evidence by declaration, establishing that the

21 material sought to be filed under seal qualifies as confidential, privileged, or

22 otherwise protectable—constitute good cause.

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

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

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

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

27 each item or type of information, document, or thing sought to be filed or introduced

1 protection must articulate compelling reasons, supported by specific facts and legal

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

3 the application to file documents under seal must be provided by declaration.

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

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

6 If documents can be redacted, then a redacted version for public viewing, omitting

7 only the confidential, privileged, or otherwise protectable portions of the document

8 shall be filed. Any application that seeks to file documents under seal in their

9 entirety should include an explanation of why redaction is not feasible.

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11 2. DEFINITIONS

12 2.1 Action: the civil action captioned Geoffrey Strehl v. Guitar Center,

13 Inc., No. 2:23-cv-02603 JAK (RAOx).

14 2.2 Challenging Party: a Party or Non-Party that challenges the

15 designation of information or items under this Order.

16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

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

19 the Good Cause Statement.

20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

21 their support staff).

22 2.5 Designating Party: a Party or Non-Party that designates information or

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

24 “CONFIDENTIAL.”

25 2.6 Disclosure or Discovery Material: all items or information, regardless

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

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

1 2.7 Expert: a person with specialized knowledge or experience in a matter

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

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

4 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

6 counsel.

7 2.9 Non-Party: any natural person, partnership, corporation, association or

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

9 2.10 Outside Counsel of Record: attorneys who are not employees of a

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

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

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

13 2.11 Party: any party to this Action, including all of its officers, directors,

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

15 support staffs).

16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

17 Discovery Material in this Action.

18 2.13 Professional Vendors: persons or entities that provide litigation

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

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

21 and their employees and subcontractors.

22 2.14 Protected Material: any Disclosure or Discovery Material that is

23 designated as “CONFIDENTIAL.”

24 2.15 Receiving Party: a Party that receives Disclosure or Discovery

25 Material from a Producing Party.

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1 3. SCOPE

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

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

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

5 compilations of Protected Material; and (3) any testimony, conversations, or

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

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

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

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10 4. DURATION

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

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

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

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

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

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

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

18 standard when merits-related documents are part of court record). Accordingly, the

19 terms of this protective order do not extend beyond the commencement of the trial.

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21 5. DESIGNATING PROTECTED MATERIAL

22 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

25 qualifies under the appropriate standards. The Designating Party must designate for

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

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

1 within the ambit of this Order.

2 Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

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

6 Party to sanctions.

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

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

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

10 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

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

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

14 produced.

15 Designation in conformity with this Order requires:

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

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

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

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

20 contains protected material. If only a portion of the material on a page qualifies for

21 protection, the Producing Party also must clearly identify the protected portion(s)

22 (e.g., by making appropriate markings in the margins).

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

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

25 which documents it would like copied and produced. During the inspection and

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

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

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

2 before producing the specified documents, the Producing Party must affix the

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

4 portion of the material on a page qualifies for protection, the Producing Party also

5 must clearly identify the protected portion(s) (e.g., by making appropriate markings

6 in the margins).

7 (b) for testimony given in depositions that the Designating Party identifies

8 the Disclosure or Discovery Material on the record, before the close of the

9 deposition all protected testimony.

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

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

12 the exterior of the container or containers in which the information is stored the

13 legend “CONFIDENTIAL.” If only a portion or portions of the information

14 warrants protection, the Producing Party, to the extent practicable, shall identify the

15 protected portion(s).

16 5.3 Inadvertent Failures to Designate. If a Producing Party discovers from

17 any source that it produced a Disclosure or Discovery Material that should have

18 been designated as Protected Material but was not, that party may thereafter

19 designate that Disclosure or Discovery Material as Protected Material.

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21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

23 designation of confidentiality at any time that is consistent with the Court’s

24 Scheduling Order.

25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

26 resolution process under Local Rule 37.1 et seq.

27 6.3 The burden of persuasion in any such challenge proceeding shall be on

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

3 Party has waived or withdrawn the confidentiality designation, all parties shall

4 continue to afford the material in question the level of protection to which it is

5 entitled under the Producing Party’s designation until the Court rules on the

6 challenge.

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8 7. ACCESS TO AND USE OF PROTECTED MATERIAL

9 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

18 authorized under this Order.

19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

21 Receiving Party may disclose any information or item designated

22 “CONFIDENTIAL” only to:

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

24 well as employees of said Outside Counsel of Record to whom it is reasonably

25 necessary to disclose the information for this Action;

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

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

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

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

3 (d) the court and its personnel;

4 (e) court reporters and their staff;

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

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

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

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

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

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

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

12 requests that the witness sign the form attached as Exhibit A hereto; and (2) they

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

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

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

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

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

18 as permitted under this Stipulated Protective Order; and

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

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

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22 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

23 IN OTHER LITIGATION

24 If a Party is served with a subpoena or a court order issued in other litigation

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

26 “CONFIDENTIAL,” that Party must:

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

1 later than five business days prior to the time when production of the Protected

2 Material is requested or required by the subpoena or court order;

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

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

5 subpoena or order is subject to this Protective Order. Such notification shall include

6 a copy of this Stipulated Protective Order; and

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

8 pursued by the Designating Party whose Protected Material may be affected.

9 If the Designating Party timely seeks a protective order, the Party served with

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

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

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

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

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

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

16 to disobey a lawful directive from another court.

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18 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

19 PRODUCED IN THIS LITIGATION

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

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

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

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

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

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

26 produce a Non-Party’s confidential information in its possession, and the Party is

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

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

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

3 agreement with a Non-Party;

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

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

6 specific description of the information requested; and

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

8 Non-Party, if requested.

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

10 14 days of receiving the notice and accompanying information, the Receiving Party

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

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

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

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

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

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

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18 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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

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

26 Agreement to Be Bound” that is attached hereto as Exhibit A.

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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

7 procedure may be established in an e-discovery order that provides for production

8 without prior privilege review.

9 If a Producing Party discovers from any source that it produced a document

10 (a) protected from disclosure by the attorney-client privilege, the attorney work

11 product protection, or any other privilege, protection, or immunity; and/or

12 (b) prohibited from disclosure by operation of law, that party may request the return

13 of that document. The Receiving Party must, within three business days of

14 receiving that request, return the document, including any copy or extract of it, to

15 the Producing Party. In the event of a dispute as to whether the document (a) is

16 protected from disclosure by a privilege, protection, or immunity; and/or (b) is

17 prohibited from disclosure by operation of law, the burden shall be on the producing

18 party to demonstrate that the document (a) is protected from disclosure by a

19 privilege, protection, or immunity; and/or (b) is prohibited from disclosure by

20 operation of law; provided, however, that until that dispute is resolved by the Court

21 the document shall be treated as (a) being protected from disclosure by a privilege,

22 protection, or immunity; and/or (b) being prohibited from disclosure by operation of

23 law. If the document is submitted to the Court for resolution of a dispute, the parties

24 shall jointly file, or otherwise consent to the filing of, a motion under Local Rule 79-

25 5 to file the document under seal, consistent with Section 12.3. In accordance with

26 Rule 502 of the Federal Rules of Evidence, if a Producing Party requests that a

27 document protected from disclosure by a privilege, protection, or immunity

1 privilege, protection, or immunity, the production of that document shall not waive

2 the applicable privilege, protection, or immunity in the Action or in any other

3 federal or state proceeding. After this Stipulation And Order is entered by the

4 Court, this paragraph is Ordered under Rule 502(d) of the Federal Rules of Evidence

5 and has the full force and effect of an Order made under Rule 502(d), including

6 without limitation binding effect on non-parties to this Stipulation And Order or to

7 the Action, notwithstanding anything to the contrary otherwise in this Stipulation

8 And Order.

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10 12. MISCELLANEOUS

11 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

13 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

18 12.3 Filing Protected Material. A Party that seeks to file under seal any

19 Protected Material must comply with Local Civil Rule 79-5. Protected Material

20 may only be filed under seal pursuant to a court order authorizing the sealing of the

21 specific Protected Material at issue. If a Party’s request to file Protected Material

22 under seal is denied by the court, then the Receiving Party may file the information

23 in the public record unless otherwise instructed by the court.

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25 13. FINAL DISPOSITION

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

15 Section 4 (DURATION).

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1 || 14. VIOLATION

2 || Any violation of this Order may be punished by appropriate measures including,

3 || without limitation, contempt proceedings and/or monetary sanctions.

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5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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7 || DATED: February 26, 2024

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9 || /s/L. Timothy Fisher

L. Timothy Fisher

10 |) Max Roberts (pro hac)

Attomeys for Plaintifi

11 || GEOFFREY STREHL

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DATED: February 26, 2024

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/s/ Scott T. Lashway

16 || John W. McGuinness

Scott T. Lashway (pro hac)

17 || Matthew M.K. Stein (pro hac)

Attorneys for Defendant

18 GUITAR CENTER, INC.

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

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22 || DATED: = 2/26/2024

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24 eayeian ,

HON. R@®ZELLA A. OLIVER

25 || United States Magistrate Judge

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1 ATTESTATION PURSUANT TO LOCAL RULE 5-4.3.4

2 I, Scott T. Lashway, am the ECF User whose ID and password are being used

3 to file this [Proposed] Stipulated Protective Order. In compliance with Local

4 Rule 5-4.3.4(a)(2)(i), I hereby attest that each of the other signatories concur in the

5 filing’s content and have authorized the filing.

6 I declare under penalty of perjury under the laws of the United States of

7 America that the foregoing is true and correct. Executed on February 26, 2024, at

8 Wellesley, Massachusetts.

9 By: /s/ Scott T. Lashway

Scott T. Lashway

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

4 I, _____________________________ [print or type full name], of

5 _________________ [print or type full address], declare under penalty of perjury

6 that I have read in its entirety and understand the Stipulated Protective Order that

7 was issued by the United States District Court for the Central District of California

8 on [date] in the case of Geoffrey Strehl v. Guitar Center, Inc., No. 2:23-cv-02603

9 JAK (RAOx). I agree to comply with and to be bound by all the terms of this

10 Stipulated Protective Order and I understand and acknowledge that failure to so

11 comply could expose me to sanctions and punishment in the nature of contempt. I

12 solemnly promise that I will not disclose in any manner any information or item that

13 is subject to this Stipulated Protective Order to any person or entity except in strict

14 compliance with the provisions of this Order.

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

16 Central District of California for enforcing the terms of this Stipulated Protective

17 Order, even if such enforcement proceedings occur after termination of this action.

18 I hereby appoint __________________________ [print or type full name] of

19 _______________________________________ [print or type full address and

20 telephone number] as my California agent for service of process in connection with

21 this action or any proceedings related to enforcement of this Stipulated Protective

22 Order.

23 Date: ______________________________________

24 City and State where sworn and signed: _________________________________

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26 Printed name: _______________________________

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