Golnaz Kamali v. Walgreen Co.

Filing 14

STIPULATED PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg re Stipulation for Protective Order 13 . ***** SEE ORDER FOR DETAILS. ***** (mp)

1 BRYAN CAVE LLP
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3
4
5
6

Leslie H. Helmer (SBN 150296)
Nicole N. King (SBN 290204)
120 Broadway, Suite 300
Santa Monica, CA 90401
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
[e-mail]

7

Attorneys for Defendant

8 WALGREEN CO., a Corporation
9

Santa Monica, CA 90301

Bryan Cave LLP

UNITED STATES DISTRICT COURT

11
120 Broadway, Suite 300

10

CENTRAL DISTRICT OF CALIFORNIA

12
13 GOLNAZ KAMALI,
14

Case No. 2:16-cv-08662-PA-AGR
Plaintiff,

15

(Los Angeles County Superior Court
Case No. BC633041)

vs.

16

WALGREEN CO., a Corporation and
17 DOES 1-10, INCLUSIVE,
18

STIPULATED PROTECTIVE
ORDER

Defendants.

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STIPULATED PROTECTIVE ORDER
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A.

1

PURPOSES AND LIMITATIONS

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

2

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. The parties further acknowledge, as set forth in

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11 Section 12.3, below, that this Stipulated Protective Order does not entitle them to
12 file confidential information under seal; Civil Local Rule 79-5 sets forth the
13 procedures that must be followed and the standards that will be applied when a party
14 seeks permission from the court to file material under seal.

B.

15

GOOD CAUSE STATEMENT

This action may involve the production of confidential information, including

16

17 complaints customers have made regarding their experience at Walgreens’
18 pharmacies (“Walgreens”) for which special protection from public disclosure and
19 from use for any purpose other than litigation of this action is warranted because the
20 information implicates privacy rights of third parties.1 In addition, this action may
21 involve the production of employee personnel information for which special
22 protection from public disclosure and from use for any purpose other than litigation of
23 this action is warranted because the information implicates privacy rights of third
24
1

Note: This Protective Order does not contemplate the production of customer
information, including customer names and contact information. Therefore, such
26 issues are not included in this Protective Order and the parties have agreed to further
27 meet and confer regarding such issues, possibly with the help of a Magistrate Judge,
in the future.
25

28

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PROOF OF SERVICE
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1 parties. Further, this action may involve production of private medical information
2 concerning Plaintiff, including information related to emotional distress. The action
3 may also involve other confidential and/or proprietary business information, including
4 the production of internal policies of Walgreens and Walgreens’ store procedures that
5 are otherwise generally unavailable to the public, or which may be privileged or
6 otherwise protected from disclosure under state or federal statutes, court rules, case
7 decisions, or common law. Accordingly, to expedite the flow of information, to
8 facilitate the prompt resolution of disputes over confidentiality of discovery materials,
9 to adequately protect information the parties are entitled to keep confidential, to
10 ensure that the parties are permitted reasonable necessary uses of such material in

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11 preparation for and in the conduct of trial, to address their handling at the end of the
12 litigation, and serve the ends of justice, a protective order for such information is
13 justified in this matter. It is the intent of the parties that information will not be
14 designated as confidential for tactical reasons and that nothing be so designated
15 without a good faith belief that it has been maintained in a confidential, non-public
16 manner, and there is good cause why it should not be part of the public record of this
17 case.
18 1.

DEFINITIONS

19

1.1

Action: This pending federal law suit.

20

1.2

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

21 of information or items under this Order.
22

1.3

“CONFIDENTIAL” Information or Items: information (regardless of

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

1.4

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

27 their support staff).
28

1.5

Designating Party: a Party or Non-Party that designates information or
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1 items that it produces in disclosures or in responses to discovery as
2 “CONFIDENTIAL.”
3

1.6

Disclosure or Discovery Material: all items or information, regardless

4 of the medium or manner in which it is generated, stored, or maintained (including,
5 among other things, testimony, transcripts, and tangible things), that are produced or
6 generated in disclosures or responses to discovery in this matter.
7

1.7

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

8 pertinent to the litigation who has been retained by a Party or its counsel to serve as
9 an expert witness or as a consultant in this Action.
10

1.8

In-House Counsel: Attorneys who are employees of a Party to this

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11 Action. In-House Counsel does not include Outside Counsel of Record or any other
12 outside counsel.
13

1.9

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

14 other legal entity not named as a Party to this action.
15

1.10 Outside Counsel of Record: Attorneys who are not employees of a

16 Party to this Action but are retained to represent or advise a Party to this Action and
17 have appeared in this Action on behalf of that Party or are affiliated with a law firm
18 which has appeared on behalf of that Party, and includes support staff.
19

1.11 Party: any Party to this Action, including all of its officers, directors,

20 employees, consultants, retained experts, and Outside Counsel of Record (and their
21 support staffs).
22

1.12 Producing Party: a Party or Non-Party that produces Disclosure or

23 Discovery Material in this Action.
24

1.13 Professional Vendors: persons or entities that provide litigation support

25 services (e.g., photocopying, videotaping, translating, preparing exhibits or
26 demonstrations, and organizing, storing, or retrieving data in any form or medium)
27 and their employees and subcontractors.
28

1.14 Protected Material: any Disclosure or Discovery Material that is
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1 designated as “CONFIDENTIAL.”

1.15 Receiving Party: a Party that receives Disclosure or Discovery Material

2

3 from a Producing Party.
4 2.

SCOPE

5

The protections conferred by this Stipulation and Order cover not only

6 Protected Material (as defined above), but also (1) any information copied or
7 extracted from Protected Material; (2) all copies, excerpts, summaries, or
8 compilations of Protected Material; and (3) any testimony, conversations, or
9 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

10

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11 trial judge. This Order does not govern the use of Protected Material at trial.
12 3.

DURATION

13

Even after final disposition of this litigation, the confidentiality obligations

14 imposed by this Order shall remain in effect until a Designating Party agrees
15 otherwise in writing or a court order otherwise directs. Final disposition shall be
16 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
17 or without prejudice; and (2) final judgment herein after the completion and
18 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
19 including the time limits for filing any motions or applications for extension of time
20 pursuant to applicable law.
21 4.

DESIGNATING PROTECTED MATERIAL

22

4.1

23

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

Exercise of Restraint and Care in Designating Material for Protection.

24 under this Order must take care to limit any such designation to specific material
25 that qualifies under the appropriate standards. The Designating Party must designate
26 for protection only those parts of material, documents, items, or oral or written
27 communications that qualify so that other portions of the material, documents,
28 items, or communications for which protection is not warranted are not swept

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1 unjustifiably within the ambit of this Order.
2

Mass, indiscriminate, or routinized designations are prohibited. Designations

3 that are shown to be clearly unjustified or that have been made for an improper
4 purpose (e.g., to unnecessarily encumber the case development process or to impose
5 unnecessary expenses and burdens on other parties) may expose the Designating
6 Party to sanctions.
7

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

8 designated for protection do not qualify for protection, that Designating Party must
9 promptly notify all other Parties that it is withdrawing the inapplicable designation.
10

4.2

Manner and Timing of Designations. Except as otherwise provided in

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11 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
12 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
13 under this Order must be clearly so designated before the material is disclosed or
14 produced.
15

Designation in conformity with this Order requires:
(a)

16

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

17 documents, but excluding transcripts of depositions or other pretrial or trial
18 proceedings), that the Producing Party affix at a minimum, the legend
19 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
20 contains protected material. If only a portion or portions of the material on a page
21 qualifies for protection, the Producing Party also must clearly identify the protected
22 portion(s) (e.g., by making appropriate markings in the margins).
23

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

24 need not designate them for protection until after the inspecting Party has indicated
25 which documents it would like copied and produced. During the inspection and
26 before the designation, all of the material made available for inspection shall be
27 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
28 documents it wants copied and produced, the Producing Party must determine which

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1 documents, or portions thereof, qualify for protection under this Order. Then, before
2 producing the specified documents, the Producing Party must affix the
3 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
4 portion or portions of the material on a page qualifies for protection, the Producing
5 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
6 markings in the margins).

(b)

7

for testimony given in depositions that the Designating Party

8 identify the Disclosure or Discovery Material on the record, before the close of the
9 deposition all protected testimony.

(c)

10

for information produced in some form other than documentary

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

4.3

16

Inadvertent Failures to Designate. If timely corrected, an inadvertent

17 failure to designate qualified information or items does not, standing alone, waive
18 the Designating Party’s right to secure protection under this Order for such material.
19 Upon timely correction of a designation, the Receiving Party must make reasonable
20 efforts to assure that the material is treated in accordance with the provisions of this
21 Order.
22 5.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

23

5.1

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

24 designation of confidentiality at any time that is consistent with the Court’s
25 Scheduling Order.
26

5.2

Meet and Confer. The Challenging Party shall initiate the

27 dispute resolution process under Local Rule 37.1 et seq.
28

5.3

The burden of persuasion in any such challenge proceeding shall be on
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1 the Designating Party. Frivolous challenges, and those made for an improper
2 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
3 parties) may expose the Challenging Party to sanctions. Unless the Designating
4 Party has waived or withdrawn the confidentiality designation, all parties shall
5 continue to afford the material in question the level of protection to which it is
6 entitled under the Producing Party’s designation until the Court rules on the
7 challenge.
8 6.

ACCESS TO AND USE OF PROTECTED MATERIAL

9

6.1

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

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

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11 Action only for prosecuting, defending, or attempting to settle this Action. Such
12 Protected Material may be disclosed only to the categories of persons and under the
13 conditions described in this Order. When the Action has been terminated, a
14 Receiving Party must comply with the provisions of section 13 below (FINAL
15 DISPOSITION).
16

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

17 location and in a secure manner that ensures that access is limited to the persons
18 authorized under this Order.
19

6.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

(a)

23

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

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

(b)

26

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

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

(c)

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Experts (as defined in this Order) of the Receiving Party to
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1 whom disclosure is reasonably necessary for this Action and who have signed the
2 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
3

(d)

the court and its personnel;

4

(e)

court reporters and their staff;

5

(f)

professional jury or trial consultants, mock jurors, and

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

(g)

9

the author or recipient of a document containing the information

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

(h)

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11

during their depositions, witnesses, and attorneys for witnesses,

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

(i)

20

any mediator or settlement officer, and their supporting

21 personnel, mutually agreed upon by any of the parties engaged in settlement
22 discussions.
23 7.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

24

IN OTHER LITIGATION

25

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

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

(a)

28

promptly notify in writing the Designating Party. Such
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1 notification shall include a copy of the subpoena or court order;

(b)

2

promptly notify in writing the party who caused the subpoena or

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

(c)

6

cooperate with respect to all reasonable procedures sought to be

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

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

8

9 the subpoena or court order shall not produce any information designated in this
10 action as “CONFIDENTIAL” before a determination by the court from which the

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11 subpoena or order issued, unless the Party has obtained the Designating Party’s
12 permission. The Designating Party shall bear the burden and expense of seeking
13 protection in that court of its confidential material and nothing in these provisions
14 should be construed as authorizing or encouraging a Receiving Party in this Action
15 to disobey a lawful directive from another court.
16 8.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

17

PRODUCED IN THIS LITIGATION
(a)

18

The terms of this Order are applicable to information produced

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

(b)

23

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

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

(1)

27

promptly notify in writing the Requesting Party and the

28 Non-Party that some or all of the information requested is subject to a

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1 confidentiality agreement with a Non-Party;

(2)

2

promptly provide the Non-Party with a copy of the

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

(3)

5

make the information requested available for inspection by

6 the Non-Party, if requested.

(c)

7

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

8 within 14 days of receiving the notice and accompanying information, the Receiving
9 Party may produce the Non-Party’s confidential information responsive to the
10 discovery request. If the Non-Party timely seeks a protective order, the Receiving

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11 Party shall not produce any information in its possession or control that is subject to
12 the confidentiality agreement with the Non-Party before a determination by the
13 court. Absent a court order to the contrary, the Non-Party shall bear the burden and
14 expense of seeking protection in this court of its Protected Material.
15 9.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

16

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

17 Protected Material to any person or in any circumstance not authorized under this
18 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
19 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
20 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
21 persons to whom unauthorized disclosures were made of all the terms of this Order,
22 and (d) request such person or persons to execute the “Acknowledgment and
23 Agreement to Be Bound” that is attached hereto as Exhibit A.
24 10.

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 protection,
28 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

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1 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
2 may be established in an e-discovery order that provides for production without
3 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
4 as the parties reach an agreement on the effect of disclosure of a communication or
5 information covered by the attorney-client privilege or work product protection, the
6 parties may incorporate their agreement in the stipulated protective order submitted
7 to the court.
8 11.

MISCELLANEOUS

9

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

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

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

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11

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

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

16

17 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
18 only be filed under seal pursuant to a court order authorizing the sealing of the
19 specific Protected Material at issue. If a Party’s request to file Protected Material
20 under seal is denied by the court, then the Receiving Party may file the information
21 in the public record unless otherwise instructed by the court.
22 12.

FINAL DISPOSITION

23

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

24 days of a written request by the Designating Party, each Receiving Party must return
25 all Protected Material to the Producing Party or destroy such material. As used in
26 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
27 summaries, and any other format reproducing or capturing any of the Protected
28 Material. Whether the Protected Material is returned or destroyed, the Receiving

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1 Party must submit a written certification to the Producing Party (and, if not the same
2 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
3 (by category, where appropriate) all the Protected Material that was returned or
4 destroyed and (2) affirms that the Receiving Party has not retained any copies,
5 abstracts, compilations, summaries or any other format reproducing or capturing any
6 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
7 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
8 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
9 reports, attorney work product, and consultant and expert work product, even if such
10 materials contain Protected Material. Any such archival copies that contain or

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11 constitute Protected Material remain subject to this Protective Order as set forth in
12 Section 3 (DURATION).
13 ///
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1 13.

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

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

5
6 DATED: February 15, 2017
7

/s/ Tyler F. Clark
Tyler F. Clark, Esq.
9 Yi-Hsuan Rachel Lin, Esq.
Attorneys for Plaintiff GOLNAZ KAMALI
10 [e-mail]
[e-mail]
8

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11

12 DATED: February 15, 2017
13

/s/ Nicole N. King
Leslie H. Helmer
15 Nicole N. King
Attorneys for Defendant WALGREEN CO.
16 [e-mail]
[e-mail]
14

17
18

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

19
20

DATED: February 23, 2017

21
22

__________________________________

23 Alicia G. Rosenberg
24

United States 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 ________________ [print

4 or type full address], declare under penalty of perjury that I have read in its entirety
5 and understand the Stipulated Protective Order that was issued by the United States
6 District Court for the Central District of California on [date] in the case of Golnaz
7 Kamali vs. Walgreen Co., et al., Case No. 2:16-cv-08662-BRO-AGRx. I agree to
8 comply with and to be bound by all the terms of this Stipulated Protective Order and
9 I understand and acknowledge that failure to so comply could expose me to sanctions
10 and punishment in the nature of contempt. I solemnly promise that I will not disclose

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11 in any manner any information or item that is subject to this Stipulated Protective
12 Order to any person or entity except in strict compliance with the provisions of this
13 Order. I further agree to submit to the jurisdiction of the United States District
14 Court for the Central District of California for the purpose of enforcing the
15 terms of this Stipulated Protective Order, even if such enforcement proceedings
16 occur after termination of this action. I hereby appoint _______________ [print
17 or type full name] of ____________________ [print or type full address and
18 telephone number] as my California agent for service of process in connection with
19 this action or any proceedings related to enforcement of this Stipulated Protective
20 Order.
21 Date:________________________________
22 City and State where sworn and signed:___________________________
23 Printed Name:_________________________
24 Signature:___________________________
25
26
27
28

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