David Whitaker v. U.S. Renal Care, Inc.

Filing 28

STIPULATED PROTECTIVE ORDER by Judge Manuel L. Real, re Stipulation 27 . See document for details. (gk)

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1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9 10 11 12 DAVID WHITAKER, individually and on behalf of all others similarly situated, Plaintiff, 13 16 2:17-cv-02661-R (GJSx) STIPULATED PROTECTIVE ORDER v. 14 15 Case No. U.S. RENAL CARE, INC., and DOES 1 through 20, inclusive Defendants. 17 18 19 20 1. A. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary or private information for which special protection from public disclosure 23 and from use for any purpose other than prosecuting this litigation may be warranted. 24 Accordingly, the parties hereby stipulate to and petition the Court to enter the 25 following Stipulated Protective Order. The parties acknowledge that this Order does 26 not confer blanket protections on all disclosures or responses to discovery and that 27 the protection it affords from public disclosure and use extends only to the limited 28 1 STIPULATED PROTECTIVE ORDER 1 information or items that are entitled to confidential treatment under the applicable 2 legal principles. 3 B. GOOD CAUSE STATEMENT 4 This action is likely to involve third-party contact information and pay records, 5 trade secrets, customer and pricing lists and other valuable research, development, 6 commercial, financial, technical and/or proprietary information for which special 7 protection from public disclosure and from use for any purpose other than 8 prosecution of this action is warranted. Such confidential and proprietary materials 9 and information consist of, among other things, confidential business or financial 10 information, information regarding confidential business practices, or other 11 confidential 12 information implicating privacy rights of third parties), information otherwise 13 generally unavailable to the public, or which may be privileged or otherwise 14 protected from disclosure under state or federal statutes, court rules, case decisions, 15 or common law. Accordingly, to expedite the flow of information, to facilitate the 16 prompt resolution of disputes over confidentiality of discovery materials, to 17 adequately protect information the parties are entitled to keep confidential, to ensure 18 that the parties are permitted reasonable necessary uses of such material in 19 preparation for and in the conduct of trial, to address their handling at the end of the 20 litigation, and serve the ends of justice, a protective order for such information is 21 justified in this matter. It is the intent of the parties that information will not be 22 designated as confidential for tactical reasons and that nothing be so designated 23 without a good faith belief that it has been maintained in a confidential, non-public 24 manner, and there is good cause why it should not be part of the public record of this 25 case. 26 /// 27 /// research, development, or commercial information 28 2 STIPULATED PROTECTIVE ORDER (including 1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 2 The parties further acknowledge, as set forth in Section 12.3, below, that this 3 Stipulated Protective Order does not entitle them to file confidential information 4 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 5 the standards that will be applied when a party seeks permission from the court to file 6 material under seal. 7 There is a strong presumption that the public has a right of access to judicial 8 proceedings and records in civil cases. In connection with non-dispositive motions, 9 good cause must be shown to support a filing under seal. See Kamakana v. City and 10 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 11 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 12 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 13 good cause showing), and a specific showing of good cause or compelling reasons 14 with proper evidentiary support and legal justification, must be made with respect to 15 Protected Material that a party seeks to file under seal. The parties’ mere designation 16 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 17 submission of competent evidence by declaration, establishing that the material 18 sought to be filed under seal qualifies as confidential, privileged, or otherwise 19 protectable—constitute good cause. 20 Further, if a party requests sealing related to a dispositive motion or trial, then 21 compelling reasons, not only good cause, for the sealing must be shown, and the 22 relief sought shall be narrowly tailored to serve the specific interest to be protected. 23 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For 24 each item or type of information, document, or thing sought to be filed or introduced 25 under seal in connection with a dispositive motion or trial, the party seeking 26 protection must articulate compelling reasons, supported by specific facts and legal 27 justification, for the requested sealing order. Again, competent evidence supporting 28 the application to file documents under seal must be provided by declaration. 3 STIPULATED PROTECTIVE ORDER 1 Any document that is not confidential, privileged, or otherwise protectable in 2 its entirety will not be filed under seal if the confidential portions can be redacted. If 3 documents can be redacted, then a redacted version for public viewing, omitting only 4 the confidential, privileged, or otherwise protectable portions of the document, shall 5 be filed. Any application that seeks to file documents under seal in their entirety 6 should include an explanation of why redaction is not feasible. 7 Notwithstanding any other provisions herein, the parties recognize that the 8 contact information and employment records for some putative class members may 9 be produced at some point during the pendency of this litigation. None of the contact 10 information or employment records of putative class members shall be used for any 11 purpose outside of this litigation, and will not be disseminated to any third party 12 under any circumstances, except where agreed to in writing by counsel for both 13 parties – e.g., to a third-party administrator for the dissemination of a privacy opt-out 14 notice to putative class members pursuant to Belaire-West Landscape, Inc. v. 15 Superior Court, 149 Cal.App.4th 554, 556–57 (2007) – or in accordance with the 16 procedures set forth in this Order for the disclosure of documents and information 17 designated as “CONFIDENTIAL” to authorized persons. 18 19 20 21 22 23 24 2. DEFINITIONS 2.1 Action: shall mean the above entitled case: David Whitaker v. U.S. Renal Care, Inc., Case No.: 2:17-cv-02661-R (GJSx) 2.2 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 25 how it is generated, stored or maintained) or tangible things that qualify for 26 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 27 Good Cause Statement. 28 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 4 STIPULATED PROTECTIVE ORDER 1 2 their support staff). 2.5 Designating Party: a Party or Non-Party that designates information or 3 items that it produces in disclosures or in responses to discovery as 4 “CONFIDENTIAL.” 5 2.6 Disclosure or Discovery Material: all items or information, regardless of 6 the medium or manner in which it is generated, stored, or maintained (including, 7 among other things, testimony, transcripts, and tangible things), that are produced or 8 generated in disclosures or responses to discovery in this matter. 9 2.7 Expert: a person with specialized knowledge or experience in a matter 10 pertinent to the litigation who has been retained by a Party or its counsel to serve as 11 an expert witness or as a consultant in this Action. 12 2.8 House Counsel: attorneys who are employees of a party to this Action. 13 House Counsel does not include Outside Counsel of Record or any other outside 14 counsel. 15 16 2.9 Non-Party: any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. 17 2.10 Outside Counsel of Record: attorneys who are not employees of a party 18 to this Action but are retained to represent or advise a party to this Action and have 19 appeared in this Action on behalf of that party or are affiliated with a law firm that 20 has appeared on behalf of that party, and includes support staff. 21 2.11 Party: any party to this Action, including all of its officers, directors, 22 employees, consultants, retained experts, and Outside Counsel of Record (and their 23 support staffs). 24 25 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 26 2.13 Professional Vendors: persons or entities that provide litigation support 27 services (e.g., photocopying, videotaping, translating, preparing exhibits or 28 demonstrations, and organizing, storing, or retrieving data in any form or medium) 5 STIPULATED PROTECTIVE ORDER 1 and their employees and subcontractors. 2 2.14 Protected Material: 3 any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 4 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 5 6 from a Producing Party. 7 8 3. SCOPE 9 The protections conferred by this Stipulation and Order cover not only 10 Protected Material (as defined above), but also (1) any information copied or 11 extracted from Protected Material; (2) all copies, excerpts, summaries, or 12 compilations of Protected Material; and (3) any testimony, conversations, or 13 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 14 15 trial judge. This Order does not govern the use of Protected Material at trial. 16 4. DURATION 17 Once a case proceeds to trial, information that was designated as 18 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 19 as an exhibit at trial becomes public and will be presumptively available to all 20 members of the public, including the press, unless compelling reasons supported by 21 specific factual findings to proceed otherwise are made to the trial judge in advance 22 of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” 23 showing for sealing documents produced in discovery from “compelling reasons” 24 standard when merits-related documents are part of court record). Accordingly, the 25 terms of this protective order do not extend beyond the commencement of the trial. 26 /// 27 /// 28 /// 6 STIPULATED PROTECTIVE ORDER 1 2 5. DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for protection under 4 this Order must take care to limit any such designation to specific material that 5 qualifies under the appropriate standards. The Designating Party must designate for 6 protection only those parts of material, documents, items or oral or written 7 communications that qualify so that other portions of the material, documents, items 8 or communications for which protection is not warranted are not swept unjustifiably 9 within the ambit of this Order. 10 Mass, indiscriminate or routinized designations are prohibited. Designations 11 that are shown to be clearly unjustified or that have been made for an improper 12 purpose (e.g., to unnecessarily encumber the case development process or to impose 13 unnecessary expenses and burdens on other parties) may expose the Designating 14 Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the inapplicable designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in 19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 21 under this Order must be clearly so designated before the material is disclosed or 22 produced. 23 24 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 25 documents, but excluding transcripts of depositions or other pretrial or trial 26 proceedings), that the Producing Party affix at a minimum, the legend 27 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 28 contains protected material. If only a portion of the material on a page qualifies for 7 STIPULATED PROTECTIVE ORDER 1 protection, the Producing Party also must clearly identify the protected portion(s) 2 (e.g., by making appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for 4 inspection need not designate them for protection until after the inspecting Party has 5 indicated which documents it would like copied and produced. During the inspection 6 and before the designation, all of the material made available for inspection shall be 7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 8 it wants copied and produced, the Producing Party must determine which documents, 9 or portions thereof, qualify for protection under this Order. Then, before producing 10 the specified documents, the Producing Party must affix the “CONFIDENTIAL 11 legend” to each page that contains Protected Material. If only a portion of the 12 material on a page qualifies for protection, the Producing Party also must clearly 13 identify the protected portion(s) (e.g., by making appropriate markings in the 14 margins). (b) 15 for testimony given in depositions that the Designating Party 16 identifies the Disclosure or Discovery Material on the record, before the close of the 17 deposition all protected testimony. (c) 18 for information produced in some form other than documentary 19 and for any other tangible items, that the Producing Party affix in a prominent place 20 on the exterior of the container or containers in which the information is stored the 21 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 22 protection, the Producing Party, to the extent practicable, shall identify the protected 23 portion(s). 24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 25 failure to designate qualified information or items does not, standing alone, waive the 26 Designating Party’s right to secure protection under this Order for such material. 27 Upon timely correction of a designation, the Receiving Party must make reasonable 28 efforts to assure that the material is treated in accordance with the provisions of this 8 STIPULATED PROTECTIVE ORDER 1 Order. 2 3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 4 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time that is consistent with the Court’s 6 Scheduling Order. 6.2 7 8 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 6.3 9 The burden of persuasion in any such challenge proceeding shall be on 10 the Designating Party. Frivolous challenges, and those made for an improper purpose 11 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 12 expose the Challenging Party to sanctions. Unless the Designating Party has waived 13 or withdrawn the confidentiality designation, all parties shall continue to afford the 14 material in question the level of protection to which it is entitled under the Producing 15 Party’s designation until the Court rules on the challenge. 16 17 18 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 19 disclosed or produced by another Party or by a Non-Party in connection with this 20 Action only for prosecuting, defending or attempting to settle this Action. Such 21 Protected Material may be disclosed only to the categories of persons and under the 22 conditions described in this Order. 23 Receiving Party must comply with the provisions of section 13 below (FINAL 24 DISPOSITION). When the Action has been terminated, a 25 Protected Material must be stored and maintained by a Receiving Party at a 26 location and in a secure manner that ensures that access is limited to the persons 27 authorized under this Order. 28 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 9 STIPULATED PROTECTIVE ORDER Unless 1 otherwise ordered by the court or permitted in writing by the Designating Party, a 2 Receiving 3 “CONFIDENTIAL” only to: 4 (a) Party may disclose any information or item designated the Receiving Party’s Outside Counsel of Record in this Action, 5 as well as employees of said Outside Counsel of Record to whom it is reasonably 6 necessary to disclose the information for this Action; 7 8 9 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; (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 15 Professional Vendors to whom disclosure is reasonably necessary for this Action and 16 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 18 19 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; (h) during their depositions, witnesses, and attorneys for witnesses, in 20 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 21 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they 22 will not be permitted to keep any confidential information unless they sign the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 24 agreed by the Designating Party or ordered by the court. 25 deposition testimony or exhibits to depositions that reveal Protected Material may be 26 separately bound by the court reporter and may not be disclosed to anyone except as 27 permitted under this Stipulated Protective Order; and 28 (i) Pages of transcribed any mediator or settlement officer, and their supporting personnel, 10 STIPULATED PROTECTIVE ORDER 1 mutually agreed upon by any of the parties engaged in settlement discussions. 2 3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 4 OTHER LITIGATION 5 If a Party is served with a subpoena or a court order issued in other litigation 6 that compels disclosure of any information or items designated in this Action as 7 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification 8 9 shall include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or 11 order to issue in the other litigation that some or all of the material covered by the 12 subpoena or order is subject to this Protective Order. Such notification shall include 13 a copy of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be 14 15 pursued by the Designating Party whose Protected Material may be affected. 16 If the Designating Party timely seeks a protective order, the Party served with 17 the subpoena or court order shall not produce any information designated in this 18 action as “CONFIDENTIAL” before a determination by the court from which the 19 subpoena or order issued, unless the Party has obtained the Designating Party’s 20 permission. The Designating Party shall bear the burden and expense of seeking 21 protection in that court of its confidential material and nothing in these provisions 22 should be construed as authorizing or encouraging a Receiving Party in this Action to 23 disobey a lawful directive from another court. 24 25 9. A NON-PARTY’S PROTECTED 26 (a) SOUGHT TO BE PRODUCED IN THIS LITIGATION 27 MATERIAL 28 The terms of this Order are applicable to information produced by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 11 STIPULATED PROTECTIVE ORDER 1 produced by Non-Parties in connection with this litigation is protected by the 2 remedies and relief provided by this Order. Nothing in these provisions should be 3 construed as prohibiting a Non-Party from seeking additional protections. (b) 4 In the event that a Party is required, by a valid discovery request, to 5 produce a Non-Party’s confidential information in its possession, and the Party is 6 subject to an agreement with the Non-Party not to produce the Non-Party’s 7 confidential information, then the Party shall: (1) 8 9 10 promptly notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; (2) 11 promptly provide the Non-Party with a copy of the Stipulated 12 Protective Order in this Action, the relevant discovery request(s), and a reasonably 13 specific description of the information requested; and (3) 14 15 make the information requested available for inspection by the Non-Party, if requested. (c) 16 If the Non-Party fails to seek a protective order from this court within 14 17 days of receiving the notice and accompanying information, the Receiving Party may 18 produce the Non-Party’s confidential information responsive to the discovery request. 19 If the Non-Party timely seeks a protective order, the Receiving Party shall not 20 produce any information in its possession or control that is subject to the 21 confidentiality agreement with the Non-Party before a determination by the court. 22 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 23 of seeking protection in this court of its Protected Material. 24 25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 27 Protected Material to any person or in any circumstance not authorized under this 28 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 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 8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 9 10 When a Producing Party gives notice to Receiving Parties that certain 11 inadvertently produced material is subject to a claim of privilege or other protection, 12 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 13 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 14 may be established in an e-discovery order that provides for production without prior 15 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 16 parties reach an agreement on the effect of disclosure of a communication or 17 information covered by the attorney-client privilege or work product protection, the 18 parties may incorporate their agreement in the stipulated protective order submitted 19 to the court. 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. 24 12.2 Right to Assert Other Objections. By stipulating to the entry of this 25 Protective Order, no Party waives any right it otherwise would have to object to 26 disclosing or producing any information or item on any ground not addressed in this 27 Stipulated Protective Order. Similarly, no Party waives any right to object on any 28 ground to use in evidence of any of the material covered by this Protective Order. 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 may 3 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 in 6 the public record unless otherwise instructed by the court. 7 8 13. FINAL DISPOSITION 9 After the final disposition of this Action, as defined in paragraph 4, within 60 10 days of a written request by the Designating Party, each Receiving Party must return 11 all Protected Material to the Producing Party or destroy such material. As used in 12 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 13 summaries, and any other format reproducing or capturing any of the Protected 14 Material. Whether the Protected Material is returned or destroyed, the Receiving 15 Party must submit a written certification to the Producing Party (and, if not the same 16 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 17 (by category, where appropriate) all the Protected Material that was returned or 18 destroyed and (2) affirms that the Receiving Party has not retained any copies, 19 abstracts, compilations, summaries or any other format reproducing or capturing any 20 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 21 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 22 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 23 reports, attorney work product, and consultant and expert work product, even if such 24 materials contain Protected Material. 25 constitute Protected Material remain subject to this Protective Order as set forth in 26 Section 4 (DURATION). 27 /// 28 /// Any such archival copies that contain or 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 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 Dated: June 22, 2017 AEGIS LAW FIRM 7 By: /s/Ali S. Carlsen Kashif Haque Ali S. Carlsen Attorneys for Plaintiff 8 9 10 11 Dated: June 22, 2017 EPSTEIN BECKER & GREEN, P.C. 12 By: /s/Kevin D. Sullivan James A. Goodman Kevin D. Sullivan Attorneys for Defendant 13 14 15 16 I, the filer of this document, attest that all other signatories listed, and on 17 whose behalf the filing is submitted, concur in the filing’s content and have 18 authorized the filing. AEGIS LAW FIRM, P.C. 19 20 /s/ Ali S. Carlsen Ali S. Carlsen 21 22 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 25 DATED: June 27, 2017 26 27 28 __________________________________ HON. MANUEL L. REAL United States District Judge 15 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on __________ in the case of David Whitaker v. U.S. Renal Care, Inc., Case No.: 9 2:17-cv-02661-R (GJSx). I agree to comply with and to be bound by all the terms 10 of this Stipulated Protective Order and I understand and acknowledge that failure to 11 so comply could expose me to sanctions and punishment in the nature of contempt. 12 I solemnly promise that I will not disclose in any manner any information or item 13 that is subject to this Stipulated Protective Order to any person or entity except in 14 strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Central District of California for enforcing the terms of this Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 16 STIPULATED PROTECTIVE ORDER full name], of

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