Unico American Corporation v. Insurance Systems, Inc.

Filing 50

STIPULATED PROTECTIVE ORDER by Magistrate Judge Gail J. Standish. (ec)

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1 2 3 4 5 6 7 8 9 10 11 12 13 STEPHEN W. KELKENBERG, pro hac vice email: skelkenberg@hodgsonruss.com RYAN J. LUCINSKI, pro hac vice email: rlucinsk@hodgsonruss.com HODGSON RUSS LLP The Guaranty Building 140 Pearl Street, Suite 100 Buffalo, New York 14202-4040 Telephone: (716) 856-4000 Facsimile: (716) 849-0349 PAUL T. MARTIN (SBN 155367) email: pmartin@hgla.com SHEILA WIRKUS PENDERGAST (SBN 251562) email: spendergast@hgla.com HENNELLY & GROSSFELD LLP 4640 Admiralty Way, Suite 850 Marina del Rey, CA 90292 Telephone:(310) 305-2100 Facsimile: (310) 305-2116 Attorneys for Defendant, INSURANCE SYSTEMS, INC. 14 UNITED STATES DISTRICT COURT 15 FOR THE CENTRAL DISTRICT OF CALIFORNIA 16 17 18 UNICO AMERICAN CORPORATION, a California corporation, Plaintiff, 19 20 21 22 23 24 25 26 27 28 Case No.: 2:15-cv-09592 RGK(GJSx) vs. INSURANCE SYSTEMS, INC., a Canada Corporation, DOES 1-50, inclusive, Defendant. STIPULATED PROTECTIVE ORDER 1 2 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action may involve the exchange of customer and pricing lists, and other 13 valuable research, development, commercial, financial, technical and/or proprietary 14 information for which special protection from public disclosure and from use for 15 any purpose other than prosecution or defense of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties), information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, 22 court rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of 26 such material in preparation for and in the conduct of trial, to address their handling 27 at the end of the litigation, and serve the ends of justice, a protective order for such 28 2 STIPULATED PROTECTIVE ORDER 1 information is justified in this matter. It is the intent of the parties that information 2 will not be designated as confidential for tactical reasons and that nothing be so 3 designated without a good-faith belief that it has been maintained in a confidential, 4 non-public manner, and there is good cause why it should not be part of the public 5 record of this case. 6 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 7 The parties further acknowledge, as set forth in Section 12.3, below, that this 8 Stipulated Protective Order does not entitle them to file confidential information 9 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 10 and the standards that will be applied when a party seeks permission from the court 11 to file material under seal. 12 There is a strong presumption that the public has a right of access to judicial 13 proceedings and records in civil cases. In connection with non-dispositive motions, 14 good cause must be shown to support a filing under seal. See Kamakana v. City and 15 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 16 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 17 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 18 require good cause showing), and a specific showing of good cause or compelling 19 reasons with proper evidentiary support and legal justification, must be made with 20 respect to Protected Material that a party seeks to file under seal. The parties’ mere 21 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 22 without the submission of competent evidence by declaration, establishing that the 23 material sought to be filed under seal qualifies as confidential, privileged, or 24 otherwise protectable—constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, then 26 compelling reasons, not only good cause, for the sealing must be shown, and the 27 relief sought shall be narrowly tailored to serve the specific interest to be protected. 28 3 STIPULATED PROTECTIVE ORDER 1 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 2 each item or type of information, document, or thing sought to be filed or introduced 3 under seal in connection with a dispositive motion or trial, the party seeking 4 protection must articulate compelling reasons, supported by specific facts and legal 5 justification, for the requested sealing order. Again, competent evidence supporting 6 the application to file documents under seal must be provided by declaration. Any document that is not confidential, privileged, or otherwise protectable in 7 8 its entirety will not be filed under seal if the confidential portions can be redacted. 9 If documents can be redacted, then a redacted version for public viewing, omitting 10 only the confidential, privileged, or otherwise protectable portions of the document, 11 shall be filed. Any application that seeks to file documents under seal in their 12 entirety should include an explanation of why redaction is not feasible. 13 14 2. DEFINITIONS 15 2.1 Action: this pending federal lawsuit. 16 2.2 Challenging Party: a Party or Non-Party that challenges the 17 18 designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 19 how it is generated, stored or maintained) or tangible things that qualify for 20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 21 the Good Cause Statement. 22 23 24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.5 Designating Party: a Party or Non-Party that designates information or 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 28 2.6 Disclosure or Discovery Material: all items or information, regardless 4 STIPULATED PROTECTIVE ORDER 1 of the medium or manner in which it is generated, stored, or maintained (including, 2 among other things, testimony, transcripts, and tangible things), that are produced or 3 generated in disclosures or responses to discovery in this matter. 4 2.7 Expert: a person with specialized knowledge or experience in a matter 5 pertinent to the litigation who has been retained by a Party or its counsel to serve as 6 an expert witness or as a consultant in this Action. 7 2.8 House Counsel: attorneys who are employees of a party to this Action. 8 House Counsel does not include Outside Counsel of Record or any other outside 9 counsel. 10 11 12 2.9 Non-Party: any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: attorneys who are not employees of a 13 party to this Action but are retained to represent or advise a party to this Action and 14 have appeared in this Action on behalf of that party or are affiliated with a law firm 15 that has appeared on behalf of that party, and includes support staff. 16 2.11 Party: any party to this Action, including all of its officers, directors, 17 employees, consultants, retained experts, and Outside Counsel of Record (and their 18 support staffs). 19 20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 21 2.13 Professional Vendors: persons or entities that provide litigation 22 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 demonstrations, and organizing, storing, or retrieving data in any form or medium) 24 and their employees and subcontractors. 25 26 27 28 2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery 5 STIPULATED PROTECTIVE ORDER 1 Material from a Producing Party. 2 3 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or 6 extracted from Protected Material; (2) all copies, excerpts, summaries, or 7 compilations of Protected Material; and (3) any testimony, conversations, or 8 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 9 10 trial judge. This Order does not govern the use of Protected Material at trial. 11 12 4. DURATION Once a case proceeds to trial, information that was designated as 13 14 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 15 as an exhibit at trial becomes public and will be presumptively available to all 16 members of the public, including the press, unless compelling reasons supported by 17 specific factual findings to proceed otherwise are made to the trial judge in advance 18 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 19 showing for sealing documents produced in discovery from “compelling reasons” 20 standard when merits-related documents are part of court record). Accordingly, the 21 terms of this protective order do not extend beyond the commencement of the trial. 22 23 24 5. DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 25 Each Party or Non-Party that designates information or items for protection under 26 this Order must take care to limit any such designation to specific material that 27 qualifies under the appropriate standards. The Designating Party must designate for 28 6 STIPULATED PROTECTIVE ORDER 1 protection only those parts of material, documents, items or oral or written 2 communications that qualify so that other portions of the material, documents, items 3 or communications for which protection is not warranted are not swept unjustifiably 4 within the ambit of this Order. 5 Mass, indiscriminate or routinized designations are prohibited. Designations 6 that are shown to be clearly unjustified or that have been made for an improper 7 purpose (e.g., to unnecessarily encumber the case development process or to impose 8 unnecessary expenses and burdens on other parties) may expose the Designating 9 Party to sanctions. 10 If it comes to a Designating Party’s attention that information or items that it 11 designated for protection do not qualify for protection, that Designating Party must 12 promptly notify all other Parties that it is withdrawing the inapplicable designation. 13 5.2 Manner and Timing of Designations. Except as otherwise provided in 14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 15 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 16 under this Order must be clearly so designated before the material is disclosed or 17 produced. 18 Designation in conformity with this Order requires: 19 (a) for information in documentary form (e.g., paper or electronic 20 documents, but excluding transcripts of depositions or other pretrial or trial 21 proceedings), that the Producing Party affix at a minimum, the legend 22 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 23 contains protected material. If only a portion of the material on a page qualifies for 24 protection, the Producing Party also must clearly identify the protected portion(s) 25 (e.g., by making appropriate markings in the margins). 26 A Party or Non-Party that makes original documents available for inspection 27 need not designate them for protection until after the inspecting Party has indicated 28 7 STIPULATED PROTECTIVE ORDER 1 which documents it would like copied and produced. During the inspection and 2 before the designation, all of the material made available for inspection shall be 3 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 4 documents it wants copied and produced, the Producing Party must determine which 5 documents, or portions thereof, qualify for protection under this Order. Then, 6 before producing the specified documents, the Producing Party must affix the 7 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 8 portion of the material on a page qualifies for protection, the Producing Party also 9 must clearly identify the protected portion(s) (e.g., by making appropriate markings 10 in the margins). (b) for testimony given in depositions that the Designating Party identifies 11 12 the Disclosure or Discovery Material on the record, before the close of the 13 deposition all protected testimony. (c) for information produced in some form other than documentary and 14 15 for any other tangible items, that the Producing Party affix in a prominent place on 16 the exterior of the container or containers in which the information is stored the 17 legend “CONFIDENTIAL.” If only a portion or portions of the information 18 warrants protection, the Producing Party, to the extent practicable, shall identify the 19 protected portion(s). 20 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 21 failure to designate qualified information or items does not, standing alone, waive 22 the Designating Party’s right to secure protection under this Order for such material. 23 Upon timely correction of a designation, the Receiving Party must make reasonable 24 efforts to assure that the material is treated in accordance with the provisions of this 25 Order. 26 27 28 8 STIPULATED PROTECTIVE ORDER 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 2 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 Scheduling Order. 6.2 5 6 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 6.3 7 The burden of persuasion in any such challenge proceeding shall be on 8 the Designating Party. Frivolous challenges, and those made for an improper 9 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 10 parties) may expose the Challenging Party to sanctions. Unless the Designating 11 Party has waived or withdrawn the confidentiality designation, all parties shall 12 continue to afford the material in question the level of protection to which it is 13 entitled under the Producing Party’s designation until the Court rules on the 14 challenge. 15 16 17 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 18 disclosed or produced by another Party or by a Non-Party in connection with this 19 Action only for prosecuting, defending or attempting to settle this Action. Such 20 Protected Material may be disclosed only to the categories of persons and under the 21 conditions described in this Order. When the Action has been terminated, a 22 Receiving Party must comply with the provisions of section 13 below (FINAL 23 DISPOSITION). 24 Protected Material must be stored and maintained by a Receiving Party at a 25 location and in a secure manner that ensures that access is limited to the persons 26 authorized under this Order. 27 28 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 9 STIPULATED PROTECTIVE ORDER 1 otherwise ordered by the court or permitted in writing by the Designating Party, a 2 Receiving Party may disclose any information or item designated 3 “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 5 well as employees of said Outside Counsel of Record to whom it is reasonably 6 necessary to disclose the information for this Action; 7 (b) the officers, directors, and employees (including House Counsel) of 8 the Receiving Party to whom disclosure is reasonably necessary for this Action; 9 (c) Experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (d) the court and its personnel; 13 (e) court reporters and their staff; 14 (f) professional jury or trial consultants, mock jurors, and Professional 15 Vendors to whom disclosure is reasonably necessary for this Action and who have 16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (g) during their depositions, witnesses, and their attorneys, in the Action 18 to whom disclosure is reasonably necessary provided: (1) the deposing party 19 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 20 will not be permitted to keep any confidential information unless they sign the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 22 agreed by the Designating Party or ordered by the court. Pages of transcribed 23 deposition testimony or exhibits to depositions that reveal Protected Material may 24 be separately bound by the court reporter and may not be disclosed to anyone except 25 as permitted under this Stipulated Protective Order; and 26 27 28 (h) any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 10 STIPULATED PROTECTIVE ORDER 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification 6 7 shall include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order 8 9 to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall include 11 a copy of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be 12 13 pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with 14 15 the subpoena or court order shall not produce any information designated in this 16 action as “CONFIDENTIAL” before a determination by the court from which the 17 subpoena or order issued, unless the Party has obtained the Designating Party’s 18 permission. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this Action 21 to disobey a lawful directive from another court. 22 23 24 25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 27 produced by Non-Parties in connection with this litigation is protected by the 28 11 STIPULATED PROTECTIVE ORDER 1 remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 produce a Non-Party’s confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Party’s 6 confidential information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non-Party 7 8 that some or all of the information requested is subject to a confidentiality 9 agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated 10 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and (3) make the information requested available for inspection by the 13 14 Non-Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 16 14 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party shall bear the burden and 22 expense of seeking protection in this court of its Protected Material. 23 24 25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 12 STIPULATED PROTECTIVE ORDER 1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 3 persons to whom unauthorized disclosures were made of all the terms of this Order, 4 and (d) request such person or persons to execute the “Acknowledgment and 5 Agreement to Be Bound” that is attached hereto as Exhibit A. 6 7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 8 PROTECTED MATERIAL 9 When a Producing Party gives notice to Receiving Parties that certain 10 inadvertently produced material is subject to a claim of privilege or other protection, 11 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 12 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 13 procedure may be established in an e-discovery order that provides for production 14 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 15 (e), insofar as the parties reach an agreement on the effect of disclosure of a 16 communication or information covered by the attorney-client privilege or work 17 product protection, the parties may incorporate their agreement in the stipulated 18 protective order submitted to the court. 19 20 21 22 23 12. 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. 12.2 Right to Assert Other Objections. By stipulating to the entry of this 24 Protective Order, no Party waives any right it otherwise would have to object to 25 disclosing or producing any information or item on any ground not addressed in this 26 Stipulated Protective Order. Similarly, no Party waives any right to object on any 27 ground to use in evidence of any of the material covered by this Protective Order. 28 13 STIPULATED PROTECTIVE ORDER 1 12.3 Filing Protected Material. A Party that seeks to file under seal any 2 Protected Material must comply with Local Civil Rule 79-5. Protected Material 3 may only be filed under seal pursuant to a court order authorizing the sealing of the 4 specific Protected Material at issue. If a Party’s request to file Protected Material 5 under seal is denied by the court, then the Receiving Party may file the information 6 in the public record unless otherwise instructed by the court. 7 8 9 13. FINAL DISPOSITION After the final disposition of this Action, within 60 days of a written request 10 by the Designating Party, each Receiving Party must return all Protected Material to 11 the Producing Party or destroy such material. As used in this subdivision, “all 12 Protected Material” includes all copies, abstracts, compilations, summaries, and any 13 other format reproducing or capturing any of the Protected Material. Whether the 14 Protected Material is returned or destroyed, the Receiving Party must submit a 15 written certification to the Producing Party (and, if not the same person or entity, to 16 the Designating Party) by the 60 day deadline that (1) identifies (by category, where 17 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 18 that the Receiving Party has not retained any copies, abstracts, compilations, 19 summaries or any other format reproducing or capturing any of the Protected 20 Material. Notwithstanding this provision, Counsel are entitled to retain an archival 21 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 22 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 23 work product, and consultant and expert work product, even if such materials 24 contain Protected Material. Any such archival copies that contain or constitute 25 Protected Material remain subject to this Protective Order as set forth in section 4 26 (DURATION). 27 28 14 STIPULATED PROTECTIVE ORDER 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 13, 2016 8 BERMAN BERMAN BERMAN SCHNEIDER AND LOWARY LLP 9 10 11 12 13 s/ Brian T. Gravdal Brian T. Gravdal Mark E. Lowary Attorneys for Plaintiff Unico American Corporation 14 15 DATED: September 13, 2016 16 HODGSON RUSS LLP 17 18 19 20 s/ Ryan J. Lucinski Stephen W. Kelkenberg Ryan J. Lucinski Attorneys for Defendant Insurance Systems, Inc. 21 22 23 DATED: September 13, 2016 HENNELLY & GROSSFELD LLP 24 25 26 27 28 s/ Paul T. Martin Paul T. Martin Attorney for Defendant Insurance Systems, Inc. 15 STIPULATED PROTECTIVE ORDER 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 DATED: September 22, 2016 4 5 6 _____________________________________ GAIL J. STANDISH UNITED STATES MAGISTRATE JUDGE 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 16 STIPULATED PROTECTIVE ORDER 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 6 perjury that I have read in its entirety and understand the Stipulated Protective Order 7 that was issued by the United States District Court for the Central District of 8 California on September ___, 2016, in the case of Unico American Corporation v. 9 Insurance Systems, Inc., et al. (Case No. 2:15-cv-09592-RGK-GJS). I agree to 10 comply with and to be bound by all the terms of this Stipulated Protective Order and 11 I understand and acknowledge that failure to so comply could expose me to 12 sanctions and punishment in the nature of contempt. I solemnly promise that I will 13 not disclose in any manner any information or item that is subject to this Stipulated 14 Protective Order to any person or entity except in strict compliance with the 15 provisions of this Order. I further agree to submit to the jurisdiction of the United 16 States District Court for the Central District of California for enforcing the terms of 17 this Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. 19 I hereby appoint ______________________[print or type full name] of 20 _________________________________[print or type full address and telephone 21 number] as my California agent for service of process in connection with this action 22 or any proceedings related to enforcement of this Stipulated Protective Order. 23 Date: __________________________ 24 City and State where sworn and signed: _________________________________ 25 Printed name: _______________________________ 26 27 28 Signature: __________________________________ 17 STIPULATED PROTECTIVE ORDER

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