Evox Productions, LLC v. California Rent-A-Car, Inc., et al

Filing 21

STIPULATED PROTECTIVE ORDER 20 by Magistrate Judge Rozella A. Oliver. *See Order for details.* (es)

1 BROWNE GEORGE ROSS LLP

Keith J. Wesley (State Bar No. 229276)
[e-mail]
Jonathan L. Gottfried (State Bar No. 282301)
3
[e-mail]
2121 Avenue of the Stars, Suite 2400
4 Los Angeles, California 90067
Telephone: [phone]
5 Facsimile: [phone]
2

6 Attorneys for EVOX Productions, LLC
7 DEL TONDO & THOMAS

Douglas J. Del Tondo (State Bar No. 100563)
[e-mail]
2201 Dupont Drive, Suite 820
9 Irvine, California 92612
Telephone: [phone]
10 Facsimile: [phone]
8

11 Attorneys for California Rent-A-Car, Inc. and Steve Vahidi
12
13

UNITED STATES DISTRICT COURT

14

CENTRAL DISTRICT OF CALIFORNIA

15
16 EVOX Productions, LLC,

Case No. 2:15-cv-08046-MWF-RAO

Plaintiff,

17

STIPULATED PROTECTIVE

vs.

18

ORDER

19 California Rent-A-Car, Inc., and ,

STEVE VAHIDI, an individual,

20

Defendant.
21
22

1.

23

A.

PURPOSES AND LIMITATIONS

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

24 proprietary, or private information for which special protection from public
25 disclosure and from use for any purpose other than prosecuting this litigation may
26 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
27 enter the following Stipulated Protective Order. The parties acknowledge that this
28 Order does not confer blanket protections on all disclosures or responses to
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1 discovery and that the protection it affords from public disclosure and use extends
2 only to the limited information or items that are entitled to confidential treatment
3 under the applicable legal principles. The parties further acknowledge, as set forth
4 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
5 file confidential information under seal; Civil Local Rule 79-5 sets forth the
6 procedures that must be followed and the standards that will be applied when a party
7 seeks permission from the court to file material under seal.
8

B.

9

GOOD CAUSE STATEMENT

This action is likely to involve trade secrets and other valuable commercial

10 and/or proprietary information for which special protection from public disclosure
11 and from use for any purpose other than prosecution of this action is warranted.
12 Such confidential and proprietary materials and information consist of, among other
13 things, confidential business or financial information, information regarding
14 confidential business practices, or other confidential commercial information,
15 information otherwise generally unavailable to the public, or which may be
16 privileged or otherwise protected from disclosure under state or federal statutes,
17 court rules, case decisions, or common law. Accordingly, to expedite the flow of
18 information, to facilitate the prompt resolution of disputes over confidentiality of
19 discovery materials, to adequately protect information the parties are entitled to keep
20 confidential, to ensure that the parties are permitted reasonable necessary uses of
21 such material in preparation for and in the conduct of trial, to address their handling
22 at the end of the litigation, and serve the ends of justice, a protective order for such
23 information is justified in this matter. It is the intent of the parties that information
24 will not be designated as confidential for tactical reasons and that nothing be so
25 designated without a good faith belief that it has been maintained in a confidential,
26 non-public manner, and there is good cause why it should not be part of the public
27 record of this case.
28
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1

C.

2

ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
SEAL

3

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

4 Stipulated Protective Order does not entitle them to file confidential information
5 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
6 and the standards that will be applied when a party seeks permission from the court
7 to file material under seal.
8

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

9 proceedings and records in civil cases. In connection with non-dispositive motions,
10 good cause must be shown to support a filing under seal. See Kamakana v. City and
11 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
12 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
13 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
14 require good cause showing), and a specific showing of good cause or compelling
15 reasons with proper evidentiary support and legal justification, must be made with
16 respect to Protected Material that a party seeks to file under seal. The parties’ mere
17 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
18 without the submission of competent evidence by declaration, establishing that the
19 material sought to be filed under seal qualifies as confidential, privileged, or
20 otherwise protectable—constitute good cause.
21

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

22 compelling reasons, not only good cause, for the sealing must be shown, and the
23 relief sought shall be narrowly tailored to serve the specific interest to be protected.
24 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
25 each item or type of information, document, or thing sought to be filed or introduced
26 under seal in connection with a dispositive motion or trial, the party seeking
27 protection must articulate compelling reasons, supported by specific facts and legal
28
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1 justification, for the requested sealing order. Again, competent evidence supporting
2 the application to file documents under seal must be provided by declaration
3

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

4 its entirety will not be filed under seal if the confidential portions can be redacted.
5 If documents can be redacted, then a redacted version for public viewing, omitting
6 only the confidential, privileged, or otherwise protectable portions of the document,
7 shall be filed. Any application that seeks to file documents under seal in their
8 entirety should include an explanation of why redaction is not feasible.
9 2.
10

DEFINITIONS
2.1

Action: EVOX Productions, LLC v. California Rent-A-

11 Car, Inc. and Steve Vahidi., 2:15-cv-08046
12

2.2

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

13 designation of information or items under this Order.
14

2.3

“CONFIDENTIAL” Information or Items: information (regardless of

15 how it is generated, stored or maintained) or tangible things that qualify for
16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
17 the Good Cause Statement.
18

2.4

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

19 their support staff).
20

2.5

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

21 items that it produces in disclosures or in responses to discovery as
22 “CONFIDENTIAL.”
23

2.6

Disclosure or Discovery Material: all items or information, regardless

24 of the medium or manner in which it is generated, stored, or maintained (including,
25 among other things, testimony, transcripts, and tangible things), that are produced or
26 generated in disclosures or responses to discovery in this matter.
27
28
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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 party

10 to this Action but are retained to represent or advise a party to this Action and have
11 appeared in this Action on behalf of that party or are affiliated with a law firm which
12 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 support

19 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 Material

25 from a Producing Party.
26 3.

SCOPE

27

The protections conferred by this Stipulation and Order cover not only

28 Protected Material (as defined above), but also (1) any information copied or
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1 extracted from Protected Material; (2) all copies, excerpts, summaries, or
2 compilations of Protected Material; and (3) any testimony, conversations, or
3 presentations by Parties or their Counsel that might reveal Protected Material.
4

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

5 trial judge. This Order does not govern the use of Protected Material at trial.
6 4.

DURATION

7

Once a case proceeds to trial, all of the information that was designated as

8 confidential or maintained pursuant to this protective order becomes public and will
9 be presumptively available to all members of the public, including the press, unless
10 compelling reasons supported by specific factual findings to proceed otherwise are
11 made to the trial judge in advance of the trial. See Kamakana v. City and County of
12 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
13 showing for sealing documents produced in discovery from “compelling reasons”
14 standard when merits-related documents are part of court record). Accordingly, the
15 terms of this protective order do not extend beyond the commencement of the trial.
16 5.

DESIGNATING PROTECTED MATERIAL

17

5.1

Exercise of Restraint and Care in Designating Material for Protection.

18 Each Party or Non-Party that designates information or items for protection under
19 this Order must take care to limit any such designation to specific material that
20 qualifies under the appropriate standards. The Designating Party must designate for
21 protection only those parts of material, documents, items, or oral or written
22 communications that qualify so that other portions of the material, documents,
23 items, or communications for which protection is not warranted are not swept
24 unjustifiably within the ambit of this Order.
25

Mass, indiscriminate, or routinized designations are prohibited. Designations

26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber the case development process or to impose
28
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1 unnecessary expenses and burdens on other parties) may expose the Designating
2 Party to sanctions.
3

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

4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6

5.2

Manner and Timing of Designations. Except as otherwise provided in

7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
9 under this Order must be clearly so designated before the material is disclosed or
10 produced.
11

Designation in conformity with this Order requires:

12

(a)

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

13 documents, but excluding transcripts of depositions or other pretrial or trial
14 proceedings), that the Producing Party affix at a minimum, the legend
15 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
16 contains protected material. If only a portion or portions of the material on a page
17 qualifies for protection, the Producing Party also must clearly identify the protected
18 portion(s) (e.g., by making appropriate markings in the margins).
19

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

20 need not designate them for protection until after the inspecting Party has indicated
21 which documents it would like copied and produced. During the inspection and
22 before the designation, all of the material made available for inspection shall be
23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
24 documents it wants copied and produced, the Producing Party must determine which
25 documents, or portions thereof, qualify for protection under this Order. Then,
26 before producing the specified documents, the Producing Party must affix the
27 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
28 portion or portions of the material on a page qualifies for protection, the Producing
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1 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
2 markings in the margins).
3

(b)

for testimony given in depositions that the Designating Party

4 identify the Disclosure or Discovery Material on the record, before the close of the
5 deposition all protected testimony, or within five calendar days of receipt of the
6 transcript.
7

(c)

for information produced in some form other than documentary

8 and for any other tangible items, that the Producing Party affix in a prominent place
9 on the exterior of the container or containers in which the information is stored the
10 legend “CONFIDENTIAL.” If only a portion or portions of the information
11 warrants protection, the Producing Party, to the extent practicable, shall identify the
12 protected portion(s).
13

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

14 failure to designate qualified information or items does not, standing alone, waive
15 the Designating Party’s right to secure protection under this Order for such material.
16 Upon timely correction of a designation, the Receiving Party must make reasonable
17 efforts to assure that the material is treated in accordance with the provisions of this
18 Order.
19 6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

20

6.1

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

21 designation of confidentiality at any time that is consistent with the Court’s
22 Scheduling Order.
23

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

24 resolution process under Local Rule 37.1 et seq.
25

6.3

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

26 the Designating Party. Frivolous challenges, and those made for an improper
27 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
28 parties) may expose the Challenging Party to sanctions. Unless the Designating
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1 Party has waived or withdrawn the confidentiality designation, all parties shall
2 continue to afford the material in question the level of protection to which it is
3 entitled under the Producing Party’s designation until the Court rules on the
4 challenge.
5 7.

ACCESS TO AND USE OF PROTECTED MATERIAL

6

7.1

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

7 disclosed or produced by another Party or by a Non-Party in connection with this
8 Action only for prosecuting, defending, or attempting to settle this Action. Such
9 Protected Material may be disclosed only to the categories of persons and under the
10 conditions described in this Order. When the Action has been terminated, a
11 Receiving Party must comply with the provisions of section 13 below (FINAL
12 DISPOSITION).
13

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

14 location and in a secure manner that ensures that access is limited to the persons
15 authorized under this Order.
16

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

17 otherwise ordered by the court or permitted in writing by the Designating Party, a
18 Receiving Party may disclose any information or item designated
19 “CONFIDENTIAL” only to:
20

(a)

the Receiving Party’s Outside Counsel of Record in this Action,

21 as well as employees of said Outside Counsel of Record to whom it is reasonably
22 necessary to disclose the information for this Action;
23

(b)

the officers, directors, and employees (including House Counsel)

24 of the Receiving Party to whom disclosure is reasonably necessary for this Action;
25

(c)

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

26 whom disclosure is reasonably necessary for this Action and who have signed the
27 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
28

(d)
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1

(e)

court reporters and their staff;

2

(f)

professional jury or trial consultants, mock jurors, and

3 Professional Vendors to whom disclosure is reasonably necessary for this Action
4 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
5 A);
6

(g)

the author or recipient of a document containing the information

7 or a custodian or other person who otherwise possessed or knew the information;
8

(h)

during their depositions, witnesses ,and attorneys for witnesses,

9 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing
10 party requests that the witness sign the form attached as Exhibit 1 hereto; and
11 (2) they will not be permitted to keep any confidential information unless they sign
12 the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
13 agreed by the Designating Party or ordered by the court. Pages of transcribed
14 deposition testimony or exhibits to depositions that reveal Protected Material may
15 be separately bound by the court reporter and may not be disclosed to anyone except
16 as permitted under this Stipulated Protective Order; and
17

(i)

any mediator or settlement officer, and their supporting

18 personnel, mutually agreed upon by any of the parties engaged in settlement
19 discussions.
20 8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

21 IN OTHER LITIGATION
22

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

23 that compels disclosure of any information or items designated in this Action as
24 “CONFIDENTIAL,” that Party must:
25

(a)

promptly notify in writing the Designating Party. Such

26 notification shall include a copy of the subpoena or court order;
27

(b)

promptly notify in writing the party who caused the subpoena or

28 order to issue in the other litigation that some or all of the material covered by the
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1 subpoena or order is subject to this Protective Order. Such notification shall include
2 a copy of this Stipulated Protective Order; and
3

(c)

cooperate with respect to all reasonable procedures sought to be

4 pursued by the Designating Party whose Protected Material may be affected.
5

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

6 the subpoena or court order shall not produce any information designated in this
7 action as “CONFIDENTIAL” before a determination by the court from which the
8 subpoena or order issued, unless the Party has obtained the Designating Party’s
9 permission. The Designating Party shall bear the burden and expense of seeking
10 protection in that court of its confidential material and nothing in these provisions
11 should be construed as authorizing or encouraging a Receiving Party in this Action
12 to disobey a lawful directive from another court.
13 9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

14 PRODUCED IN THIS LITIGATION
15

(a)

The terms of this Order are applicable to information produced

16 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
17 information produced by Non-Parties in connection with this litigation is protected
18 by the remedies and relief provided by this Order. Nothing in these provisions
19 should be construed as prohibiting a Non-Party from seeking additional protections.
20

(b)

In the event that a Party is required, by a valid discovery request,

21 to produce a Non-Party’s confidential information in its possession, and the Party is
22 subject to an agreement with the Non-Party not to produce the Non-Party’s
23 confidential information, then the Party shall:
24

(1)

promptly notify in writing the Requesting Party and the Non-

25 Party that some or all of the information requested is subject to a confidentiality
26 agreement with a Non-Party;
27
28
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1

(2)

promptly provide the Non-Party with a copy of the Stipulated

2 Protective Order in this Action, the relevant discovery request(s), and a reasonably
3 specific description of the information requested; and
4

(3)

make the information requested available for inspection by the

5 Non-Party, if requested.
6

(c)

If the Non-Party fails to seek a protective order from this court

7 within 14 days of receiving the notice and accompanying information, the Receiving
8 Party may produce the Non-Party’s confidential information responsive to the
9 discovery request. If the Non-Party timely seeks a protective order, the Receiving
10 Party shall not produce any information in its possession or control that is subject to
11 the confidentiality agreement with the Non-Party before a determination by the
12 court. Absent a court order to the contrary, the Non-Party shall bear the burden and
13 expense of seeking protection in this court of its Protected Material.
14 10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

15

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

16 Protected Material to any person or in any circumstance not authorized under this
17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
18 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
19 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
20 persons to whom unauthorized disclosures were made of all the terms of this Order,
21 and (d) request such person or persons to execute the “Acknowledgment and
22 Agreement to Be Bound” that is attached hereto as Exhibit A.
23 11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

24 PROTECTED MATERIAL
25

When a Producing Party gives notice to Receiving Parties that certain

26 inadvertently produced material is subject to a claim of privilege or other protection,
27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
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1 procedure may be established in an e-discovery order that provides for production
2 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
3 (e), insofar as the parties reach an agreement on the effect of disclosure of a
4 communication or information covered by the attorney-client privilege or work
5 product protection, the parties may incorporate their agreement in the stipulated
6 protective order submitted to the court.
7 12.

MISCELLANEOUS

8

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

9 person to seek its modification by the Court in the future.
10

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

11 Protective Order no Party waives any right it otherwise would have to object to
12 disclosing or producing any information or item on any ground not addressed in this
13 Stipulated Protective Order. Similarly, no Party waives any right to object on any
14 ground to use in evidence of any of the material covered by this Protective Order.
15

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

16 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
17 only be filed under seal pursuant to a court order authorizing the sealing of the
18 specific Protected Material at issue. If a Party's request to file Protected Material
19 under seal is denied by the court, then the Receiving Party may file the information
20 in the public record unless otherwise instructed by the court.
21

12.4 Privilege Log. The parties are not required to include on any privilege

22 log documents or things otherwise protected by the attorney-client privilege, work
23 product immunity, or other privilege or protection (“Privileged Materials”) dated on
24 or after October 14, 2015 (the “cut-off date”). In addition, Privileged Materials
25 created by or on behalf of litigation counsel or exchanged with litigation counsel,
26 regardless of their date, do not need to be included on any privilege log.
27

12.5 Communications Between Expert and People Employed by Expert.

28 The parties agree that communications between any Expert and people employed by
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1 that Expert in connection with this Action will be treated as privileged and will not
2 be produced.
3

13.

4

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

FINAL DISPOSITION

5 days of a written request by the Designating Party, each Receiving Party must return
6 all Protected Material to the Producing Party or destroy such material. As used in
7 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
8 summaries, and any other format reproducing or capturing any of the Protected
9 Material. Whether the Protected Material is returned or destroyed, the Receiving
10 Party must submit a written certification to the Producing Party (and, if not the same
11 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
12 (by category, where appropriate) all the Protected Material that was returned or
13 destroyed and (2) affirms that the Receiving Party has not retained any copies,
14 abstracts, compilations, summaries or any other format reproducing or capturing any
15 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
16 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
17 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
18 reports, attorney work product, and consultant and expert work product, even if such
19 materials contain Protected Material. Any such archival copies that contain or
20 constitute Protected Material remain subject to this Protective Order as set forth in
21 Section 4 (DURATION).
22
23 //
24 //
25 //
26 //
27
28
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1 14.

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

2 measures including, without limitation, contempt proceedings and/or monetary
3 sanctions.
4
5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
7 DATED: January , 2016
8

BROWNE GEORGE ROSS LLP
Keith J. Wesley
Jonathan L. Gottfried

9
10

By

11

Jonathan L. Gottfried
Attorneys for EVOX Productions, LLC

12
13 DATED: January

, 2016

14

DEL TONDO & THOMAS
Douglas J. Del Tondo

15

By

16

Douglas J. Del Tondo
Attorneys for California Rent-A-Car, Inc.
and Steve Vahidi

17
18
19

20 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21 DATED: January 19, 2016
22
23 ______________________________
24 United States District/Magistrate Judge
25
26
27
28
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1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I,

[print or type full name], of

4

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

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 [date] in the case of EVOX Productions, LLC v. California Rent-A-Car, Inc. and
8 Steve Vahidi, 2:15-cv-08046. I agree to comply with and to be bound by all the
9 terms of this Stipulated Protective Order and I understand and acknowledge that
10 failure to so comply could expose me to sanctions and punishment in the nature of
11 contempt. I solemnly promise that I will not disclose in any manner any information
12 or item that is subject to this Stipulated Protective Order to any person or entity
13 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 the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint
18 or type full name] of

[print

[print or type

19 full address and telephone number] as my California agent for service of process in
20 connection with this action or any proceedings related to enforcement of this
21 Stipulated Protective Order.
22 Date:
23 City and State where sworn and signed:
24 Printed name:
25 Signature:
26
27
28
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