Sonia Barrientos v. Law office of Jeffery H. Jordan

Filing 36

STIPULATED PROTECTIVE ORDER by Magistrate Judge Gail J. Standish re Stipulation for Protective Order 35 . (ec)

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1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 18 19 20 21 SONIA BARRIENTOS, individually ) CASE NO. 2:15-cv-06282-JAK-GJS and on behalf of all others similarly ) ) STIPULATIVE PROTECTIVE situated, ) ORDER1 ) Plaintiffs, ) DISCOVERY MATTER v. ) ) LAW OFFICE OF JEFFREY H. ) JORDAN, ) ) Defendant ) ) 22 23 1. Discovery in this action is likely to involve production of confidential, 24 25 A. PURPOSES AND LIMITATIONS proprietary or private information for which special protection from public 26 This Stipulated Protective Order is substantially based on the model protective 27 1 28 order provided under Magistrate Judge Gail J. Standish’s Procedures. {00074281;1} 1 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 3 enter the following Stipulated Protective Order. The parties acknowledge that this 4 Order does not confer blanket protections on all disclosures or responses to 5 discovery and that the protection it affords from public disclosure and use extends 6 only to the limited information or items that are entitled to confidential treatment 7 under the applicable legal principles. 8 9 B. GOOD CAUSE STATEMENT 10 11 12 13 14 15 This action is likely to involve trade secrets, confidential and proprietary policy and procedure information and other valuable research, development, commercial, financial, technical and/or proprietary information, and private and sensitive financial information of alleged putative class members (likely debtors) for which special protection from public disclosure and from use for any purpose 16 other than prosecution of this action is warranted. Such confidential and 17 proprietary materials and information consist of, among other things, confidential 18 business or financial information, information regarding confidential business 19 practices, or other confidential research, development, or commercial information 20 (including information implicating privacy rights of third parties), information 21 otherwise generally unavailable to the public, or which may be privileged or 22 otherwise protected from disclosure under state or federal statutes, court rules, case 23 decisions, or common law. Accordingly, to expedite the flow of information, to 24 facilitate the prompt resolution of disputes over confidentiality of discovery 25 materials, to adequately protect information the parties are entitled to keep 26 confidential, to ensure that the parties are permitted reasonable necessary uses of 27 such material in preparation for and in the conduct of trial, to address their 28 {00074281;1} 2 1 handling at the end of the litigation, and serve the ends of justice, a protective order 2 for such information is justified in this matter. It is the intent of the parties that 3 information will not be designated as confidential for tactical reasons and that 4 nothing be so designated without a good faith belief that it has been maintained in 5 a confidential, non-public manner, and there is good cause why it should not be 6 part of the public record of this case. 7 8 9 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 10 11 12 13 14 15 The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to file material under seal. There is a strong presumption that the public has a right of access to judicial 16 17 proceedings and records in civil cases. In connection with non-dispositive 18 motions, good cause must be shown to support a filing under seal. See Kamakana 19 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. 20 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. 21 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 22 protective orders require good cause showing), and a specific showing of good 23 cause or compelling reasons with proper evidentiary support and legal justification, 24 must be made with respect to Protected Material that a party seeks to file under 25 seal. The parties’ mere designation of Disclosure or Discovery Material as 26 CONFIDENTIAL does not—without the submission of competent evidence by 27 28 {00074281;1} 3 1 declaration, establishing that the material sought to be filed under seal qualifies as 2 confidential, privileged, or otherwise protectable—constitute good cause. 3 Further, if a party requests sealing related to a dispositive motion or trial, 4 then compelling reasons, not only good cause, for the sealing must be shown, and 5 the relief sought shall be narrowly tailored to serve the specific interest to be 6 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 7 2010). For each item or type of information, document, or thing sought to be filed 8 9 10 11 12 13 or introduced under seal in connection with a dispositive motion or trial, the party seeking protection must articulate compelling reasons, supported by specific facts and legal justification, for the requested sealing order. Again, competent evidence supporting the application to file documents under seal must be provided by declaration. Any document that is not confidential, privileged, or otherwise protectable 14 15 16 17 18 19 20 in its entirety will not be filed under seal if the confidential portions can be redacted. If documents can be redacted, then a redacted version for public viewing, omitting only the confidential, privileged, or otherwise protectable portions of the document, shall be filed. Any application that seeks to file documents under seal in their entirety should include an explanation of why redaction is not feasible. 21 22 2. 2.1 24 Action: this pending federal lawsuit. 2.2 23 25 DEFINITIONS Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.3 26 “CONFIDENTIAL” Information or Items: information (regardless of 27 how it is generated, stored or maintained) or tangible things that qualify for 28 protection under Federal Rule of Civil Procedure 26(c), and as specified above in {00074281;1} 4 1 the Good Cause Statement. 2.4 2 3 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 4 2.5 Designating Party: a Party or Non-Party that designates information 5 or items that it produces in disclosures or in responses to discovery as 6 “CONFIDENTIAL.” 7 8 9 10 2.6 of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter. 11 2.7 12 13 14 Disclosure or Discovery Material: all items or information, regardless Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this Action. 2.8 15 House Counsel: attorneys who are employees of a party to this 16 Action. House Counsel does not include Outside Counsel of Record or any other 17 outside counsel. 18 2.9 19 Non-Party: any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. 20 2.10 Outside Counsel of Record: attorneys who are not employees of a 21 party to this Action but are retained to represent or advise a party to this Action 22 and have appeared in this Action on behalf of that party or are affiliated with a law 23 firm that has appeared on behalf of that party, and includes support staff. 24 2.11 Party: any party to this Action, including all of its officers, directors, 25 employees, consultants, retained experts, and Outside Counsel of Record (and their 26 support staffs). 27 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 28 {00074281;1} 5 1 Discovery Material in this Action. 2 2.13 Professional Vendors: persons or entities that provide litigation 3 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 4 demonstrations, and organizing, storing, or retrieving data in any form or medium) 5 and their employees and subcontractors. 6 7 2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 8 9 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 10 11 3. 12 13 14 15 16 17 The protections conferred by this Stipulation and Order cover not only Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the 18 19 SCOPE trial judge. This Order does not govern the use of Protected Material at trial. 20 21 4. DURATION Once a case proceeds to trial, information that was designated as 22 23 CONFIDENTIAL or maintained pursuant to this protective order used or 24 introduced as an exhibit at trial becomes public and will be presumptively 25 available to all members of the public, including the press, unless compelling 26 reasons supported by specific factual findings to proceed otherwise are made to the 27 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 28 (distinguishing “good cause” showing for sealing documents produced in {00074281;1} 6 1 discovery from “compelling reasons” standard when merits-related documents are 2 part of court record). Accordingly, the terms of this protective order do not extend 3 beyond the commencement of the trial. 4 5 5. DESIGNATING PROTECTED MATERIAL 5.1 6 Exercise of Restraint and Care in Designating Material for Protection. 7 Each Party or Non-Party that designates information or items for protection under 8 this Order must take care to limit any such designation to specific material that 9 qualifies under the appropriate standards. The Designating Party must designate 10 for protection only those parts of material, documents, items or oral or written 11 communications that qualify so that other portions of the material, documents, 12 13 items or communications for which protection is not warranted are not swept unjustifiably within the ambit of this Order. 14 15 16 17 18 19 Mass, indiscriminate or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber the case development process or to impose unnecessary expenses and burdens on other parties) may expose the Designating Party to sanctions. If it comes to a Designating Party’s attention that information or items that it 20 21 22 designated for protection do not qualify for protection, that Designating Party must promptly notify all other Parties that it is withdrawing the inapplicable designation. 5.2 23 Manner and Timing of Designations. Except as otherwise provided in 24 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. Designation in conformity with this Order requires: 28 {00074281;1} 7 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains protected material. If only a portion of the material on a page qualifies for 6 protection, the Producing Party also must clearly identify the protected portion(s) 7 (e.g., by making appropriate markings in the margins). 8 9 10 11 12 13 14 15 16 17 18 19 A Party or Non-Party that makes original documents available for inspection need not designate them for protection until after the inspecting Party has indicated which documents it would like copied and produced. During the inspection and before the designation, all of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under this Order. Then, before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page that contains Protected Material. If only a portion of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). 20 21 22 (b) for testimony given in depositions that the Designating Party identifies the Disclosure or Discovery Material on the record, before the close of the deposition all protected testimony. 23 (c) for information produced in some form other than documentary and 24 25 26 27 28 for any other tangible items, that the Producing Party affix in a prominent place on the exterior of the container or containers in which the information is stored the legend “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, the Producing Party, to the extent practicable, shall identify {00074281;1} 8 1 the protected portion(s). 5.3 2 Inadvertent Failures to Designate. If timely corrected, an inadvertent 3 failure to designate qualified information or items does not, standing alone, waive 4 the Designating Party’s right to secure protection under this Order for such 5 material. Upon timely correction of a designation, the Receiving Party must make 6 reasonable efforts to assure that the material is treated in accordance with the 7 provisions of this Order. 8 9 6. 10 11 12 6.1 Scheduling Order. 6.2 14 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 6.3 16 17 Timing of Challenges. Any Party or Non-Party may challenge a designation of confidentiality at any time that is consistent with the Court’s 13 15 CHALLENGING CONFIDENTIALITY DESIGNATIONS The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous challenges, and those made for an improper 18 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 19 parties) may expose the Challenging Party to sanctions. Unless the Designating 20 Party has waived or withdrawn the confidentiality designation, all parties shall 21 continue to afford the material in question the level of protection to which it is 22 entitled under the Producing Party’s designation until the Court rules on the 23 challenge. 24 25 7. 26 27 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Non-Party in connection with this 28 {00074281;1} 9 1 Action only for prosecuting, defending or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under 3 the conditions described in this Order. When the Action has been terminated, a 4 Receiving Party must comply with the provisions of section 13 below (FINAL 5 DISPOSITION). 6 7 8 Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Order. 9 10 11 12 13 7.2 otherwise ordered by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or item designated “CONFIDENTIAL” only to: (a) the Receiving Party’s Outside Counsel of Record in this Action, as 14 15 16 Disclosure of “CONFIDENTIAL” Information or Items. Unless well as employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this Action; (b) the officers, directors, and employees (including House Counsel) of 17 18 the Receiving Party to whom disclosure is reasonably necessary for this Action; 19 (c) Experts (as defined in this Order) of the Receiving Party to whom 20 disclosure is reasonably necessary for this Action and who have signed the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 (d) the court and its personnel; 23 (e) court reporters and their staff; 24 (f) professional jury or trial consultants, mock jurors, and Professional 25 Vendors to whom disclosure is reasonably necessary for this Action and who have 26 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (g) the author or recipient of a document containing the information or a 28 {00074281;1} 10 1 custodian or other person who otherwise possessed or knew the information; (h) during their depositions, witnesses, and attorneys for witnesses, in 2 3 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 4 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 5 they will not be permitted to keep any confidential information unless they sign the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 7 agreed by the Designating Party or ordered by the court. Pages of transcribed 8 9 10 deposition testimony or exhibits to depositions that reveal Protected Material may be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this Stipulated Protective Order; and 11 (i) any mediator or settlement officer, and their supporting personnel, 12 13 mutually agreed upon by any of the parties engaged in settlement discussions. 14 15 8. IN OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation 17 18 19 that compels disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification 20 21 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED shall include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or 22 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 27 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 28 {00074281;1} 11 If the Designating Party timely seeks a protective order, the Party served 1 2 with the subpoena or court order shall not produce any information designated in 3 this action as “CONFIDENTIAL” before a determination by the court from which 4 the subpoena or order issued, unless the Party has obtained the Designating Party’s 5 permission. The Designating Party shall bear the burden and expense of seeking 6 protection in that court of its confidential material and nothing in these provisions 7 should be construed as authorizing or encouraging a Receiving Party in this Action 8 to disobey a lawful directive from another court. 9 10 9. 11 PRODUCED IN THIS LITIGATION 12 13 14 15 16 17 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE (a) The terms of this Order are applicable to information produced by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional protections. (b) In the event that a Party is required, by a valid discovery request, to 18 19 produce a Non-Party’s confidential information in its possession, and the Party is 20 subject to an agreement with the Non-Party not to produce the Non-Party’s 21 confidential information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non- 22 23 Party that some or all of the information requested is subject to a confidentiality 24 agreement with a Non-Party; 25 (2) promptly provide the Non-Party with a copy of the Stipulated 26 Protective Order in this Action, the relevant discovery request(s), and a reasonably 27 specific description of the information requested; and 28 {00074281;1} 12 (3) make the information requested available for inspection by the 1 2 Non-Party, if requested. 3 (c) If the Non-Party fails to seek a protective order from this court within 4 14 days of receiving the notice and accompanying information, the Receiving 5 Party may produce the Non-Party’s confidential information responsive to the 6 discovery request. If the Non-Party timely seeks a protective order, the Receiving 7 Party shall not produce any information in its possession or control that is subject 8 9 10 to the confidentiality agreement with the Non-Party before a determination by the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of seeking protection in this court of its Protected Material. 11 12 10. 13 If a Receiving Party learns that, by inadvertence or otherwise, it has 14 15 16 17 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL disclosed Protected Material to any person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use its 18 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 19 the person or persons to whom unauthorized disclosures were made of all the terms 20 of this Order, and (d) request such person or persons to execute the 21 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 22 A. 23 24 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 25 PROTECTED MATERIAL 26 When a Producing Party gives notice to Receiving Parties that certain 27 inadvertently produced material is subject to a claim of privilege or other 28 {00074281;1} 13 1 protection, the obligations of the Receiving Parties are those set forth in Federal 2 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 3 whatever procedure may be established in an e-discovery order that provides for 4 production without prior privilege review. 5 If a Producing Party inadvertently discloses information in connection with 6 the pending litigation to another Party that the Producing Party thereafter claims to 7 be privileged or protected by the attorney-client privilege or attorney work product 8 9 10 11 12 13 protection (“Disclosed Protected Information”), the disclosure of the Disclosed Protected Information shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or work product protection that the Producing Party would otherwise be entitled to assert with respect to the Disclosed Protected Information and its subject matter in this proceeding or in any other federal or state proceeding. A Producing Party may assert, in writing, attorney-client privilege or work 14 15 product protection with respect to Disclosed Protected Information. The Receiving 16 Party must—unless it contests the claim of attorney-client privilege or work 17 product protection—within five business days of receipt of that writing, (i) return 18 or destroy all copies of the Disclosed Protected Information, and (ii) provide a 19 certification of counsel that all of the Disclosed Protected Information has been 20 returned or destroyed. If the Receiving Party contests the claim of attorney-client privilege within 21 22 five business days after assertion of attorney-client privilege or work product 23 protection with respect to Disclosed Protected Information, the Producing Party 24 must produce a privilege log with respect to the Disclosed Protected Information. 25 If the Receiving Party still contests the claim of attorney-client privilege 26 after receipt of the privilege log, the Receiving Party must then—within five 27 business days of receipt of the privilege log— initiate the dispute resolution 28 {00074281;1} 14 1 process under Local Rule 37.1 et seq. to move the Court for an Order compelling 2 disclosure of the information claimed as not privileged (a “Disclosure Motion”). 3 The Receiving Party must seek to file the Disclosure Motion under seal and it must 4 not assert as a ground for compelling disclosure the fact or circumstances of the 5 disclosure. Pending resolution of the Disclosure Motion, the Receiving Party must 6 not use the challenged information in any way or disclose it to any person other 7 than those required by law to be served with a copy of the sealed Disclosure 8 Motion. The parties may stipulate to extend the contemplated time periods set 9 forth in this Paragraph. 10 11 12. 12 13 MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. 14 12.2 Right to Assert Other Objections. By stipulating to the entry of this 15 Protective Order, no Party waives any right it otherwise would have to object to 16 disclosing or producing any information or item on any ground not addressed in 17 18 19 this Stipulated Protective Order. Similarly, no Party waives any right to object on any ground to use in evidence of any of the material covered by this Protective Order. 20 12.3 Filing Protected Material. A Party that seeks to file under seal any 21 22 23 24 Protected Material must comply with Local Civil Rule 79-5. Protected Material may only be filed under seal pursuant to a court order authorizing the sealing of the specific Protected Material at issue. If a Party’s request to file Protected Material 25 under seal is denied by the court, then the Receiving Party may file the information 26 in the public record unless otherwise instructed by the court. 27 28 {00074281;1} 15 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 3 60 days of a written request by the Designating Party, each Receiving Party must 4 return all Protected Material to the Producing Party or destroy such material. As 5 used in this subdivision, “all Protected Material” includes all copies, abstracts, 6 compilations, summaries, and any other format reproducing or capturing any of the 7 Protected Material. Whether the Protected Material is returned or destroyed, the 8 9 10 11 12 13 14 15 Receiving Party must submit a written certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, 16 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 17 and trial exhibits, expert reports, attorney work product, and consultant and expert 18 work product, even if such materials contain Protected Material. Any such 19 archival copies that contain or constitute Protected Material remain subject to this 20 Protective Order as set forth in Section 4 (DURATION). 21 // 22 // 23 // 24 25 26 27 28 {00074281;1} 16 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. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 DATED September 21, 2017 8 9 10 /s/Todd M. Friedman Attorneys for Plaintiff 11 12 DATED: September 21, 2017 13 14 15 /s/ David J. Kaminski Attorneys for Defendant 16 17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 18 19 DATED: September 27, 2017 20 21 22 23 _____________________________________ GAIL J. STANDISH UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28 {00074281;1} 17 1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 4 I, _____________________________ [print or type full name], of _________________ 5 [print or type full address], declare under penalty of perjury that I have read in its entirety 6 and understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the case of Sonia 8 Barrientos v. Law Office of Jeffrey H. Jordan, 2:15-cv-06282-JAK-GJSI agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order and I 10 understand and 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 in any 12 manner any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the 15 Central District of California for enforcing the terms of this Stipulated Protective Order, 16 even if such enforcement proceedings occur after termination of this action. I hereby 17 appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and telephone 19 number] as my California agent for service of process in connection with this action or 20 any proceedings related to enforcement of this Stipulated Protective Order. 21 Date: ______________________________________ 22 City and State where sworn and signed: _________________________________ 23 24 Printed name: _______________________________ 25 26 Signature: __________________________________ 27 28 {00074281;1} 18

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