Broadway Financial Corporation v. Continental Casualty Company et al

Filing 30

PROTECTIVE ORDER by Magistrate Judge Karen L. Stevenson re Stipulation for Protective Order 29 (See order for details) (rh)

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1 2 3 4 5 GARY J. VALERIANO (Bar No. 89644) MARK J. KRONE (Bar No. 219806) ANDERSON, McPHARLIN & CONNERS LLP 707 Wilshire Boulevard Suite 4000 Los Angeles, California 90017-3623 TELEPHONE: (213) 688-0080  FACSIMILE: (213) 622-7594 6 Attorneys for Defendant COLUMBIA CASUALTY COMPANY 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 11 BROADWAY FINANCIAL CORPORATION, 12 Plaintiff, 13 vs. 14 CONTINENTAL CASUALTY 15 COMPANY; COLUMBIA CASUALTY COMPANY; and DOES 1 16 through 10, Case No. 2:16-cv-2983 RGK-KS STIPULATED PROTECTIVE ORDER Trial Date: May 9, 2017 Defendants. 17 18 19 1. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary, or private information for which special protection from public 22 disclosure and from use for any purpose other than prosecuting this litigation may 23 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 24 enter the following Stipulated Protective Order. The parties acknowledge that this 25 Order does not confer blanket protections on all disclosures or responses to 26 discovery and that the protection it affords from public disclosure and use extends 27 only to the limited information or items that are entitled to confidential treatment 28 under the applicable legal principles. The parties further acknowledge, as set forth in 1550129.1 05303-699 STIPULATED PROTECTIVE ORDER 1 Section 12.3, below, that this Stipulated Protective Order does not entitle them to 2 file confidential information under seal; Civil Local Rule 79-5 sets forth the 3 procedures that must be followed and the standards that will be applied when a party 4 seeks permission from the court to file material under seal. 5 B. GOOD CAUSE STATEMENT 6 This action is likely to involve trade secrets, customer and pricing lists and 7 other valuable research, development, commercial, financial, technical and/or 8 proprietary information for which special protection from public disclosure and 9 from use for any purpose other than prosecution of this action is warranted. Such LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 things, information implicating privacy rights of third parties including but not 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 confidential and proprietary materials and information consist of, among other 12 limited to loan applications, loan applicants’ financial records, financial account 13 information, banking information, and loan payment and performance information. 14 Additionally, the parties which are in the business of insurance and banking, will 15 likely disclose information regarding their confidential business practices, trade 16 secret or other proprietary information including but not limited to company 17 manuals, procedures, guides and training materials; attorney fee billing invoices; 18 investigative and audit reports; underwriting information; attorney-client or work 19 product information; reinsurance information; and reserve information. 20 Additionally, this action will likely involve confidential communications between 21 the parties and law enforcement personnel and information otherwise generally 22 unavailable to the public, or which may be privileged or otherwise protected from 23 disclosure under state or federal statutes, court rules, case decisions, or common 24 law. 25 Accordingly, to expedite the flow of information, to facilitate the prompt 26 resolution of disputes over confidentiality of discovery materials, to adequately 27 protect information the parties are entitled to keep confidential, to ensure that the 28 parties are permitted reasonable necessary uses of such material in preparation for 1550129.1 05303-699 2 STIPULATED PROTECTIVE ORDER 1 and in the conduct of trial, to address their handling at the end of the litigation, and 2 serve the ends of justice, a protective order for such information is justified in this 3 matter. It is the intent of the parties that information will not be designated as 4 confidential for tactical reasons and that nothing be so designated without a good 5 faith belief that it has been maintained in a confidential, non-public manner, and 6 there is good cause why it should not be part of the public record of this case. 7 2. DEFINITIONS 8 2.1 Action: this pending federal law suit. 9 2.2 Challenging Party: a Party or Non-Party that challenges the designation LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 12 how it is generated, stored or maintained) or tangible things that qualify for 13 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 14 the Good Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 16 their support staff). 17 2.5 Designating Party: a Party or Non-Party that designates information or 18 items that it produces in disclosures or in responses to discovery as 19 “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless 21 of the medium or manner in which it is generated, stored, or maintained (including, 22 among other things, testimony, transcripts, and tangible things), that are produced or 23 generated in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 pertinent to the litigation who has been retained by a Party or its counsel to serve as 26 an expert witness or as a consultant in this Action. 27 / / / 28 / / / 1550129.1 05303-699 3 STIPULATED PROTECTIVE ORDER 1 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association, or 5 other legal entity not named as a Party to this action. 6 2.10 Outside Counsel of Record: attorneys who are not employees of a party 7 to this Action but are retained to represent or advise a party to this Action and have 8 appeared in this Action on behalf of that party or are affiliated with a law firm which 9 has appeared on behalf of that party, and includes support staff. 2.11 Party: any party to this Action, including all of its officers, directors, LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 12 support staffs). 13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 2.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 and their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is 20 designated as “CONFIDENTIAL.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 22 from a Producing Party. 23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only 25 Protected Material (as defined above), but also (1) any information copied or 26 extracted from Protected Material; (2) all copies, excerpts, summaries, or 27 compilations of Protected Material; and (3) any testimony, conversations, or 28 presentations by Parties or their Counsel that might reveal Protected Material. 1550129.1 05303-699 4 STIPULATED PROTECTIVE ORDER 1 Any use of Protected Material at trial shall be governed by the orders of the 2 trial judge. This Order does not govern the use of Protected Material at trial. 3 4. DURATION 4 Even after final disposition of this litigation, the confidentiality obligations 5 imposed by this Order shall remain in effect until a Designating Party agrees 6 otherwise in writing or a court order otherwise directs. Final disposition shall be 7 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 8 or without prejudice; and (2) final judgment herein after the completion and 9 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 pursuant to applicable law. 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 including the time limits for filing any motions or applications for extension of time 12 5. DESIGNATING PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Non-Party that designates information or items for protection under 15 this Order must take care to limit any such designation to specific material that 16 qualifies under the appropriate standards. The Designating Party must designate for 17 protection only those parts of material, documents, items, or oral or written 18 communications that qualify so that other portions of the material, documents, 19 items, or communications for which protection is not warranted are not swept 20 unjustifiably within the ambit of this Order. 21 Mass, indiscriminate, or routinized designations are prohibited. Designations 22 that are shown to be clearly unjustified or that have been made for an improper 23 purpose (e.g., to unnecessarily encumber the case development process or to impose 24 unnecessary expenses and burdens on other parties) may expose the Designating 25 Party to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 designated for protection do not qualify for protection, that Designating Party must 28 promptly notify all other Parties that it is withdrawing the inapplicable designation. 1550129.1 05303-699 5 STIPULATED PROTECTIVE ORDER 1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the material is disclosed or 5 produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix at a minimum, the legend LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 contains protected material. If only a portion or portions of the material on a page 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 12 qualifies for protection, the Producing Party also must clearly identify the protected 13 portion(s) (e.g., by making appropriate markings in the margins). 14 A Party or Non-Party that makes original documents available for inspection 15 need not designate them for protection until after the inspecting Party has indicated 16 which documents it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for inspection shall be 18 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 19 documents it wants copied and produced, the Producing Party must determine which 20 documents, or portions thereof, qualify for protection under this Order. Then, before 21 producing the specified documents, the Producing Party must affix the 22 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 23 portion or portions of the material on a page qualifies for protection, the Producing 24 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 25 markings in the margins). 26 (b) for testimony given in depositions that the Designating Party identify 27 the Disclosure or Discovery Material on the record, before the close of the 28 deposition all protected testimony. 1550129.1 05303-699 6 STIPULATED PROTECTIVE ORDER 1 (c) for information produced in some form other than documentary and for 2 any other tangible items, that the Producing Party affix in a prominent place on the 3 exterior of the container or containers in which the information is stored the legend 4 “CONFIDENTIAL.” If only a portion or portions of the information warrants 5 protection, the Producing Party, to the extent practicable, shall identify the protected 6 portion(s). 7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 failure to designate qualified information or items does not, standing alone, waive 9 the Designating Party’s right to secure protection under this Order for such material. LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 efforts to assure that the material is treated in accordance with the provisions of this 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 Upon timely correction of a designation, the Receiving Party must make reasonable 12 Order. 13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 15 designation of confidentiality at any time that is consistent with the Court’s 16 Scheduling Order. 17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 18 resolution process under Local Rule 37.1 et seq. 19 6.3 The burden of persuasion in any such challenge proceeding shall be on 20 the Designating Party. Frivolous challenges, and those made for an improper 21 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 22 parties) may expose the Challenging Party to sanctions. Unless the Designating 23 Party has waived or withdrawn the confidentiality designation, all parties shall 24 continue to afford the material in question the level of protection to which it is 25 entitled under the Producing Party’s designation until the Court rules on the 26 challenge. 27 / / / 28 / / / 1550129.1 05303-699 7 STIPULATED PROTECTIVE ORDER 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 Action only for prosecuting, defending, or attempting to settle this Action. Such 5 Protected Material may be disclosed only to the categories of persons and under the 6 conditions described in this Order. When the Action has been terminated, a 7 Receiving Party must comply with the provisions of section 13 below (FINAL 8 DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 authorized under this Order. 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 location and in a secure manner that ensures that access is limited to the persons 12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 otherwise ordered by the court or permitted in writing by the Designating Party, a 14 Receiving Party may disclose any information or item designated 15 “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 17 as employees of said Outside Counsel of Record to whom it is reasonably necessary 18 to disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of the 20 Receiving Party to whom disclosure is reasonably necessary for this Action; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 disclosure is reasonably necessary for this Action and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 Vendors to whom disclosure is reasonably necessary for this Action and who have 28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1550129.1 05303-699 8 STIPULATED PROTECTIVE ORDER 1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses, and attorneys for witnesses, in the 4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 6 not be permitted to keep any confidential information unless they sign the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 8 agreed by the Designating Party or ordered by the court. Pages of transcribed 9 deposition testimony or exhibits to depositions that reveal Protected Material may LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 as permitted under this Stipulated Protective Order; and 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 be separately bound by the court reporter and may not be disclosed to anyone except 12 (i) any mediator or settlement officer, and their supporting personnel, 13 mutually agreed upon by any of the parties engaged in settlement discussions. 14 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation 17 that compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL,” that Party must: 19 (a) promptly notify in writing the Designating Party. Such notification 20 shall include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or order 22 to issue in the other litigation that some or all of the material covered by the 23 subpoena or order is subject to this Protective Order. Such notification shall include 24 a copy of this Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be 26 pursued by the Designating Party whose Protected Material may be affected. 27 If the Designating Party timely seeks a protective order, the Party served with 28 the subpoena or court order shall not produce any information designated in this 1550129.1 05303-699 9 STIPULATED PROTECTIVE ORDER 1 action as “CONFIDENTIAL” before a determination by the court from which the 2 subpoena or order issued, unless the Party has obtained the Designating Party’s 3 permission. The Designating Party shall bear the burden and expense of seeking 4 protection in that court of its confidential material and nothing in these provisions 5 should be construed as authorizing or encouraging a Receiving Party in this Action 6 to disobey a lawful directive from another court. 7 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 8 PRODUCED IN THIS LITIGATION 9 (a) The terms of this Order are applicable to information produced by a LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 produced by Non-Parties in connection with this litigation is protected by the 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 12 remedies and relief provided by this Order. Nothing in these provisions should be 13 construed as prohibiting a Non-Party from seeking additional protections. 14 (b) In the event that a Party is required, by a valid discovery request, to 15 produce a Non-Party’s confidential information in its possession, and the Party is 16 subject to an agreement with the Non-Party not to produce the Non-Party’s 17 confidential information, then the Party shall: (1) 18 promptly notify in writing the Requesting Party and the Non- 19 Party that some or all of the information requested is subject to a confidentiality 20 agreement with a Non-Party; (2) 21 promptly provide the Non-Party with a copy of the Stipulated 22 Protective Order in this Action, the relevant discovery request(s), and a reasonably 23 specific description of the information requested; and (3) 24 make the information requested available for inspection by the 25 Non-Party, if requested. 26 (c) If the Non-Party fails to seek a protective order from this court within 27 14 days of receiving the notice and accompanying information, the Receiving Party 28 may produce the Non-Party’s confidential information responsive to the discovery 1550129.1 05303-699 10 STIPULATED PROTECTIVE ORDER 1 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 2 not produce any information in its possession or control that is subject to the 3 confidentiality agreement with the Non-Party before a determination by the court. 4 Absent a court order to the contrary, the Non-Party shall bear the burden and 5 expense of seeking protection in this court of its Protected Material. 6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 12 persons to whom unauthorized disclosures were made of all the terms of this Order, 13 and (d) request such person or persons to execute the “Acknowledgment and 14 Agreement to Be Bound” that is attached hereto as Exhibit A. 15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 21 may be established in an e-discovery order that provides for production without 22 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 23 as the parties reach an agreement on the effect of disclosure of a communication or 24 information covered by the attorney-client privilege or work product protection, the 25 parties may incorporate their agreement in the stipulated protective order submitted 26 to the court. 27 12. MISCELLANEOUS 28 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 1550129.1 05303-699 11 STIPULATED PROTECTIVE ORDER 1 person to seek its modification by the Court in the future. 2 12.2 Right to Assert Other Objections. By stipulating to the entry of this 3 Protective Order no Party waives any right it otherwise would have to object to 4 disclosing or producing any information or item on any ground not addressed in this 5 Stipulated Protective Order. Similarly, no Party waives any right to object on any 6 ground to use in evidence of any of the material covered by this Protective Order. 7 12.3 Filing Protected Material. A Party that seeks to file under seal any 8 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 9 only be filed under seal pursuant to a court order authorizing the sealing of the LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 under seal is denied by the court, then the Receiving Party may file the information 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 specific Protected Material at issue. If a Party's request to file Protected Material 12 in the public record unless otherwise instructed by the court. 13 13. FINAL DISPOSITION 14 After the final disposition of this Action, as defined in paragraph 4, within 60 15 days of a written request by the Designating Party, each Receiving Party must return 16 all Protected Material to the Producing Party or destroy such material. As used in 17 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 18 summaries, and any other format reproducing or capturing any of the Protected 19 Material. Whether the Protected Material is returned or destroyed, the Receiving 20 Party must submit a written certification to the Producing Party (and, if not the same 21 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 22 (by category, where appropriate) all the Protected Material that was returned or 23 destroyed and (2)affirms that the Receiving Party has not retained any copies, 24 abstracts, compilations, summaries or any other format reproducing or capturing any 25 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 26 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 27 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 28 reports, attorney work product, and consultant and expert work product, even if such 1550129.1 05303-699 12 STIPULATED PROTECTIVE ORDER 1 materials contain Protected Material. Any such archival copies that contain or 2 constitute Protected Material remain subject to this Protective Order as set forth in 3 Section 4 (DURATION). 4 14. Any violation of this Order may be punished by any and all appropriate 5 measures including, without limitation, contempt proceedings and/or monetary 6 sanctions. 7 8 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 9 DATED: January 4, 2017 LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 Karen L. Stevenson United States Magistrate Judge 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1550129.1 05303-699 13 STIPULATED PROTECTIVE ORDER 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 5 of perjury that I have read in its entirety and understand the Stipulated Protective 6 Order that was issued by the United States District Court for the Central District of 7 California on [date] in the case of Broadway Financial Corporation v. Continental 8 Casualty Company et al., United States District Court for the Central District Of 9 California, Case No. 2:16-cv-02983-RGK-KS. I agree to comply with and to be LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 acknowledge that failure to so comply could expose me to sanctions and punishment 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP  10 bound by all the terms of this Stipulated Protective Order and I understand and 12 in the nature of contempt. I solemnly promise that I will not disclose in any manner 13 any information or item that is subject to this Stipulated Protective Order to any 14 person or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ____________________________ [print 19 or type full name] of _______________________________________ [print or type 20 full address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: 24 City and State where sworn and signed: 25 Printed name: 26 27 Signature: 28 1550129.1 05303-699 STIPULATED PROTECTIVE ORDER

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