Korey Wynne v. City of Los Angeles et al

Filing 28

PROTECTIVE ORDER by Magistrate Judge Alka Sagar re Stipulation for Protective Order 27 . (See document for complete details) (afe)

1
2
3
4
5
6
7

ARNOLDO CASILLAS, ESQ., SBN
158519
DENISSE O. GASTÉLUM, SBN 282771
CASILLAS & ASSOCIATES
3777 Long Beach Boulevard, Third Floor
Long Beach, California 90807
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Elizabeth T. Fitzgerald, Deputy City
Attorney
Office of Los Angeles City Attorney
200 N. Main Street, 6th Floor, City Hall
East
Los Angeles, California 90012
Tel: [phone]
Fax: [phone]
Email: [e-mail]

Attorneys for Plaintiff KOREY WYNNE Attorneys for Defendants CITY OF LOS
ANGELES & LOS ANGELES POLICE
DEPARTMENT

8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10
11

KOREY WYNNE,
Plaintiff,

12

vs.

13
14
15
16

CITY OF LOS ANGELES, LOS
ANGELES POLICE
DEPARTMENT, DOES 1 through
10, inclusive,

17

Defendants.

) CASE NO. 2:17 cv 04301 DMG (ASx)
) [Assigned to the Hon. Dolly M. Gee]
)
) STIPULATED PROTECTIVE ORDER
)
)
)
)
)
)
)

18
19
20

1.

A. PURPOSES AND LIMITATIONS
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 be

23

warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter

24

the following Stipulated Protective Order. The parties acknowledge that this Order

25

does not confer blanket protections on all disclosures or responses to discovery and

26

that the protection it affords from public disclosure and use extends only to the

27

limited information or items that are entitled to confidential treatment under the

28
1
STIPULATED PROTECTIVE ORDER

1

applicable legal principles. The parties further acknowledge, as set forth in Section

2

12.3, below, that this Stipulated Protective Order does not entitle them to file

3

confidential information under seal; Civil Local Rule 79-5 sets forth the procedures

4

that must be followed and the standards that will be applied when a party seeks

5

permission from the court to file material under seal

6

B. GOOD CAUSE STATEMENT

7

Good cause exists for entry of this order.

As Plaintiff is seeking and

8

Defendants may produce, among other things, third party private and confidential

9

information; portions of the personnel files of the police and detention officers

10

involved in the subject incident, which contains confidential information, and

11

information the City regards as official information; performance evaluations, work

12

schedules/logs and rosters, and training records for the involved police/detention

13

officers; administrative investigation files - including but not limited to Detective and

14

Crime Scene Investigator(s) materials, Internal Affairs materials – which contain

15

incident reports, witness statements, and other sensitive materials which the City

16

believes need special protection from public disclosure; detention records pertaining

17

to Plaintiff including but not limited to visitor and communication logs and medical

18

and mental health records; the City’s protocol and procedure concerning detention

19

facilities, and any official information documents produced to Plaintiffs during the

20

course of discovery in this litigation and any subsequent reproduction thereof, as well

21

as private information of the Los Angeles Police Department employees.

22

Additionally, these documents include sensitive law enforcement information.

23

Limiting disclosure of these documents to the context of this litigation as provided

24

herein will, accordingly, further important law-enforcement objectives and interests,

25

including safety of personnel and the public.

26

The documents identified in this Protective Order, which Defendants believe in

27

good faith constitute or embody confidential information which the City maintains as

28
2
STIPULATED PROTECTIVE ORDER

1

strictly confidential and are otherwise generally unavailable to the public, or which

2

may be privileged or otherwise protected from disclosure under state or federal

3

statutes, court rules, case decisions, or common law, are therefore entitled to

4

heightened protection from disclosure.

5

The City contends that absent a protective order delineating the responsibilities

6

of nondisclosure on the part of the parties hereto, there is a specific risk of

7

unnecessary and undue disclosure by one or more of the many attorneys, secretaries,

8

law clerks, paralegals and expert witnesses involved in this case, as well as the

9

corollary risk of embarrassment, harassment and professional and legal harm on the

10

part of the LAPD officers referenced in the materials and information.

11

The City also contends that the unfettered disclosure of the materials and

12

information, absent a protective order, would allow the media to share this

13

information with potential jurors in the area, impacting the rights of the City herein to

14

receive a fair trial.

15

Accordingly, to expedite the flow of information, to facilitate the prompt

16

resolution of disputes over confidentiality of discovery materials, to adequately

17

protect information the parties are entitled to keep confidential, to ensure that the

18

parties are permitted reasonable necessary uses of such material in preparation for

19

and in the conduct of trial, to address their handling at the end of the litigation, and

20

serve the ends of justice, a protective order for such information is justified in this

21

matter. It is the intent of the parties that information will not be designated as

22

confidential for tactical reasons and that nothing be so designated without a good

23

faith belief that it has been maintained in a confidential, non-public manner, and there

24

is good cause why it should not be part of the public record of this case.

25

///

26

///

27

///

28
3
STIPULATED PROTECTIVE ORDER

1

2.

DEFINITIONS

2

2.1

Action: This pending federal law suit.

3

2.2

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

4

of information or items under this Order.

5

2.3

“CONFIDENTIAL” Information or Items: information (regardless of

6

how it is generated, stored or maintained) or tangible things that qualify for

7

protection under Federal Rule of Civil Procedure 26(c), and as specified above in the

8

Good Cause Statement. This also includes (1) any information copied or extracted

9

from the Confidential information; (2) all copies, excerpts, summaries or

10

compilations of Confidential information; and (3) any testimony, conversations, or

11

presentations that might reveal Confidential information.

12
13

2.4

Counsel: Counsel of record for the parties to this civil litigation and their

support staff.

14

2.5

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

15

items that it produces in disclosures or in responses to discovery as

16

“CONFIDENTIAL.”

17

2.6

Disclosure or Discovery Material: all items or information, regardless of

18

the medium or manner in which it is generated, stored, or maintained (including,

19

among other things, testimony, transcripts, and tangible things), that are produced or

20

generated in disclosures or responses to discovery in this matter.

21

2.7

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

22

pertinent to the litigation who has been retained by a Party or its counsel to serve as

23

an expert witness or as a consultant in this Action.

24

2.8

House Counsel: attorneys who are employees of a party to this Action.

25

House Counsel does not include Outside Counsel of Record or any other outside

26

counsel.

27

///

28
4
STIPULATED PROTECTIVE ORDER

1
2

2.9

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

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

3

2.10 Outside Counsel of Record: attorneys who are not employees of a party

4

to this Action but are retained to represent or advise a party to this Action and have

5

appeared in this Action on behalf of that party or are affiliated with a law firm which

6

has appeared on behalf of that party, and includes support staff.

7

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

8

board, departments, divisions, employees, consultants, retained experts, and Outside

9

Counsel of Record (and their support staffs).

10
11

2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.

12

2.13 Professional Vendors: persons or entities that provide litigation support

13

services (e.g., photocopying, videotaping, translating, preparing exhibits or

14

demonstrations, and organizing, storing, or retrieving data in any form or medium)

15

and their employees and subcontractors.

16
17

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

18
19

2.15 Receiving Party: A Party that receives Disclosure or Discovery Material
from a Producing Party.

20
21

3.

SCOPE

22

The protections conferred by this Stipulation and Order cover not only

23

Protected Material (as defined above), but also (1) any information copied or

24

extracted from Protected Material; (2) all copies, excerpts, summaries, or

25

compilations of Protected Material; and (3) any testimony, conversations, or

26

presentations by Parties or their Counsel that might reveal Protected Material.

27
28
5
STIPULATED PROTECTIVE ORDER

1
2

Any use of Protected Material at trial shall be governed by the orders of the
trial judge. This Order does not govern the use of Protected Material at trial.

3
4

4.

5

DURATION
Even after final disposition of this litigation, the confidentiality obligations

6

imposed by this Order shall remain in effect until a Designating Party agrees

7

otherwise in writing or a court order otherwise directs. Final disposition shall be

8

deemed to be the later of (1) dismissal of all claims and defenses in this Action, with

9

or without prejudice; and (2) final judgment herein after the completion and

10

exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

11

including the time limits for filing any motions or applications for extension of time

12

pursuant to applicable law.

13
14

5.

DESIGNATING PROTECTED MATERIAL

15

5.1

16

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

Exercise of Restraint and Care in Designating Material for Protection.

17

under this Order must take care to limit any such designation to specific material that

18

qualifies under the appropriate standards. The Designating Party must designate for

19

protection only those parts of material, documents, items, or oral or written

20

communications that qualify so that other portions of the material, documents, items,

21

or communications for which protection is not warranted are not swept unjustifiably

22

within the ambit of this Order.

23

Mass, indiscriminate, or routinized designations are prohibited. Designations

24

that are shown to be clearly unjustified or that have been made for an improper

25

purpose (e.g., to unnecessarily encumber the case development process or to impose

26

unnecessary expenses and burdens on other parties) may expose the Designating

27

Party to sanctions.

28
6
STIPULATED PROTECTIVE ORDER

1

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

2

designated for protection do not qualify for protection, that Designating Party must

3

promptly notify all other Parties that it is withdrawing the inapplicable designation.

4

///

5

5.2

6

Except as otherwise provided in this Order (see, e.g., second paragraph of

Manner and Timing of Designations.

7

section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery

8

Material that qualifies for protection under this Order must be clearly so designated

9

before the material is disclosed or produced.

10

Designation in conformity with this Order requires:

11

(a)

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

12

documents, but excluding transcripts of depositions or other pretrial or trial

13

proceedings), that the Producing Party affix at a minimum, the legend

14

“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

15

contains protected material. If only a portion or portions of the material on a page

16

qualifies for protection, the Producing Party also must clearly identify the protected

17

portion(s) (e.g., by making appropriate markings in the margins).

18

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

19

need not designate them for protection until after the inspecting Party has indicated

20

which documents it would like copied and produced. During the inspection and

21

before the designation, all of the material made available for inspection shall be

22

deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

23

it wants copied and produced, the Producing Party must determine which documents,

24

or portions thereof, qualify for protection under this Order. Then, before producing

25

the specified documents, the Producing Party must affix the “CONFIDENTIAL

26

legend” to each page that contains Protected Material. If only a portion or portions of

27

the material on a page qualifies for protection, the Producing Party also must clearly

28
7
STIPULATED PROTECTIVE ORDER

1

identify the protected portion(s) (e.g., by making appropriate markings in the

2

margins).

3

(b)

for testimony given in depositions that the Designating Party identify the

4

Disclosure or Discovery Material on the record, before the close of the deposition all

5

protected testimony.

6

(c)

for information produced in some form other than documentary and for

7

any other tangible items, that, at a minimum, the Producing Party affix in a prominent

8

place on the exterior of the container or containers in which the information is stored

9

the legend “CONFIDENTIAL.” If only a portion or portions of the information

10

warrants protection, the Producing Party, to the extent practicable, shall identify the

11

protected portion(s).

12

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

13

failure to designate qualified information or items does not, standing alone, waive the

14

Designating Party’s right to secure protection under this Order for such material.

15

Upon timely correction of a designation, the Receiving Party must make reasonable

16

efforts to assure that the material is treated in accordance with the provisions of this

17

Order.

18
19
20

6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

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

21

designation of confidentiality at any time that is consistent with the Court’s

22

Scheduling Order.

23
24
25

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.
6.3

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

26

the Designating Party. Frivolous challenges, and those made for an improper purpose

27

(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

28
8
STIPULATED PROTECTIVE ORDER

1

expose the Challenging Party to sanctions. Unless the Designating Party has waived

2

or withdrawn the confidentiality designation, all parties shall continue to afford the

3

material in question the level of protection to which it is entitled under the Producing

4

Party’s designation until the Court rules on the challenge.

5
6
7

7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

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

8

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

9

Action only for prosecuting, defending, or attempting to settle this Action. Such

10

Protected Material may be disclosed only to the categories of persons and under the

11

conditions described in this Order. When the Action has been terminated, a

12

Receiving Party must comply with the provisions of section 13 below (FINAL

13

DISPOSITION).

14

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

15

location and in a secure manner that ensures that access is limited to the persons

16

authorized under this Order.

17

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

18

otherwise ordered by the court or permitted in writing by the Designating Party, a

19

Receiving Party may disclose any information or item designated

20

“CONFIDENTIAL” only to:

21

(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

22

employees of said Outside Counsel of Record to whom it is reasonably necessary to

23

disclose the information for this Action;

24

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

25

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

26

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

27
28
9
STIPULATED PROTECTIVE ORDER

1

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 Professional Vendors

6

to whom disclosure is reasonably necessary for this Action and who have signed the

7

“Acknowledgment and Agreement to Be Bound” (Exhibit A);

8
9

(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;

10

(h) during their depositions, witnesses, and attorneys for witnesses, in the

11

Action to whom disclosure is reasonably necessary provided: (1) the deposing party

12

requests that the witness sign the “Acknowledgment and Agreement to Be Bound”

13

form attached as Exhibit A hereto; and (2) they will not be permitted to keep any

14

confidential information unless they sign the “Acknowledgment and Agreement to

15

Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered

16

by the court. Pages of transcribed deposition testimony or exhibits to depositions that

17

reveal Protected Material may be separately bound by the court reporter and may not

18

be disclosed to anyone except as permitted under this Stipulated Protective Order;

19

and

20
21

(i) any mediator or settlement officer, and their supporting personnel, mutually
agreed upon by any of the parties engaged in settlement discussions.

22
23

8.

24

OTHER LITIGATION

25

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

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:

28
10
STIPULATED PROTECTIVE ORDER

1
2

(a)

promptly notify in writing the Designating Party. Such notification shall

include a copy of the subpoena or court order;

3

(b)

promptly notify in writing the party who caused the subpoena or order to

4

issues in the other litigation that some or all of the material covered by the subpoena

5

or order is subject to this Protective Order. Such notification shall include a copy of

6

this Stipulated Protective Order; and

7
8

(c)

cooperate with respect to all reasonable procedures south to be pursued

by the Designating Party whose Protected Material may be affected.

9

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

10

the subpoena or court order shall not produce any information designated in this

11

action as “CONFIDENTIAL” before a determination by the court from which the

12

subpoena or order issued, unless the Party has obtained the Designating Party’s

13

permission. The Designating Party shall bear the burden and expense of seeking

14

protection in that court of its confidential material and nothing in these provisions

15

should be construed as authorizing or encouraging a Receiving Party in this Action to

16

disobey a lawful directive from another court.

17
18

9.

19

PRODUCED IN THIS LITIGATION

20

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

(a)

The terms of this Order are applicable to information produced by a

21

Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

22

produced by Non-Parties in connection with this litigation is protected by the

23

remedies and relief provided by this Order. Nothing in these provisions should be

24

construed as prohibiting a Non-Party from seeking additional protections.

25

(b)

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

26

produce a Non-Party’s confidential information in its possession, and the Party is

27

subject to an agreement with the Non-Party not to produce the Non-Party’s

28
11
STIPULATED PROTECTIVE ORDER

1

confidential information, then the Party shall:

2

(1)

promptly notify in writing the Requesting Party and the Non-Party

3

that some or all of the information requested is subject to a confidentiality agreement

4

with a Non-Party;

5

(2)

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

6

Protective Order in this Action, the relevant discovery request(s), and a reasonably

7

specific description of the information requested; and

8

(3)

9

Non-Party, if requested.

10

(c)

make the information requested available for inspection by the

If the Non-Party fails to seek a protective order from this court within 14

11

days of receiving the notice and accompanying information, the Receiving Party may

12

produce the Non-Party’s confidential information responsive to the discovery

13

request. If the Non-Party timely seeks a protective order, the Receiving Party shall

14

not produce any information in its possession or control that is subject to the

15

confidentiality agreement with the Non-Party before a determination by the court.

16

Absent a court order to the contrary, the Non-Party shall bear the burden and expense

17

of seeking protection in this court of its Protected Material.

18
19
20

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL.
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

21

Protected Material to any person or in any circumstance not authorized under this

22

Stipulated Protective Order, the Receiving Party must immediately (a) notify in

23

writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

24

to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

25

persons to whom unauthorized disclosures were made of all the terms of this Order,

26

and (d) request such person or persons to execute the “Acknowledgment and

27

Agreement to Be Bound” that is attached hereto as Exhibit A.

28
12
STIPULATED PROTECTIVE ORDER

1

11.

2

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL.

3

When a Producing Party gives notice to Receiving Parties that certain inadvertently

4

produced material is subject to a claim of privilege or other protection, the

5

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

6

Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

7

may be established in an e-discovery order that provides for production without prior

8

privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

9

parties reach an agreement on the effect of disclosure of a communication or

10

information covered by the attorney-client privilege or work product protection, the

11

parties may incorporate their agreement in the stipulated protective order submitted

12

to the court.

13
14
15
16
17

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

18

Protective Order no Party waives any right it otherwise would have to object to

19

disclosing or producing any information or item on any ground not addressed in this

20

Stipulated Protective Order. Similarly, no Party waives any right to object on any

21

ground to use in evidence of any of the material covered by this Protective Order.

22

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

23

Protected Material must comply with Civil Local Rule 79-5. Protected Material may

24

only be filed under seal pursuant to a court order authorizing the sealing of the

25

specific Protected Material at issue. If a Party's request to file Protected Material

26

under seal is denied by the court, then the Receiving Party may file the information in

27

the public record unless otherwise instructed by the court.

28
13
STIPULATED PROTECTIVE ORDER

1

13.

2

FINAL DISPOSITION.
After the final disposition of this Action (as defined in paragraph 4), within 60

3

days of a written request by the Designating Party, or another period of time agreed

4

upon by the parties, each Receiving Party must return all Protected Material to the

5

Producing Party or destroy such material. As used in this subdivision, “all Protected

6

Material” includes all copies, abstracts, compilations, summaries, and any other

7

format reproducing or capturing any of the Protected Material. Whether the Protected

8

Material is returned or destroyed, the Receiving Party must submit a written

9

certification to the Producing Party (and, if not the same person or entity, to the

10

Designating Party) by the 60 day or agreed upon deadline that (1) identifies (by

11

category, where appropriate) all the Protected Material that was returned or destroyed

12

and (2)affirms that the Receiving Party has not retained any copies, abstracts,

13

compilations, summaries or any other format reproducing or capturing any of the

14

Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

15

archival copy of all pleadings, motion papers, trial, deposition, and hearing

16

transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

17

reports, attorney work product, and consultant and expert work product, even if such

18

materials contain Protected Material. Any such archival copies that contain or

19

constitute Protected Material remain subject to this Protective Order as set forth in

20

Section 4 (DURATION).

21
22

14.

23

measures including, without limitation, contempt proceedings and/or monetary

24

sanctions.

25

///

26

///

27

///

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

28
14
STIPULATED PROTECTIVE ORDER

1
2

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: February 7, 2018

CASILLAS & ASSOCIATES

3

/s/ Arnoldo Casillas
Arnoldo Casillas
Denisse O. Gastelum
Attorneys for PLAINTIFFS

4
5
6
7

DATED: February 7, 2018

LOS ANGELES CITY ATTORNEY’S OFFICE

8

/s/ Elizabeth T. Fitzgerald
Elizabeth T. Fitzgerald, Deputy City Attorney
Attorneys for Defendants CITY OF LOS ANGELES
& LOS ANGELES POLICE DEPARTMENT

9
10
11
12
13
14
15
16

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
Dated: _______________

____________________________________
Honorable Alka Sagar
United States Magistrate Judge
United States District Court

17
18
19
20
21
22
23
24
25
26
27
28
15
STIPULATED PROTECTIVE ORDER

1

APPENDIX “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, Central District entered on

7

the _____ day of ______________, 2018, in the case of Estate of Korey Wynne, et al.

8

v. City of Los Angeles, et al, United States District Court, Central District of

9

California Case No. 2:17-cv-04301-DMG(ASx). I agree to comply with and to be

10

bound by all the terms of this Stipulated Protective Order and I understand and

11

acknowledge that failure to so comply could expose me to sanctions and punishment

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.

19

I hereby appoint __________________________ [print or type full name] of

20

_______________________________________ [print or type full address and

21

telephone number] as my California agent for service of process in connection with

22

this action or any proceedings related to enforcement of this Stipulated Protective

23

Order.

24

Dated: ______________________

25

City and State where sworn and signed: ___________________________

26

Printed Name: ____________________

27

Signature: _______________________

28
16
STIPULATED PROTECTIVE ORDER