Charlynn Odahl v. Primeritus Financial Services, Inc. et al

Filing 20

STIPULATED PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg. re Stipulation for Protective Order 16 . (See Order for Further Details) (kl)

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1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 CHARLYNN ODAHL, Plaintiff, 13 14 Case No: 2:17 cv 08570 SJO AGR vs. 15 PRIMERITUS FINANCIAL STIPULATED PROTECTIVE ORDER Honorable S. James Otero Honorable Alicia G. Rosenberg SERVICES, INC., KEY AUTO 16 RECOVERY, and DOES 1 through 20, inclusive, 17 Defendants. 18 19 20 21 22 23 24 25 26 27 28 –1– STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that the 8 protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 11 that this Stipulated Protective Order does not entitle them to file confidential 12 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 13 followed and the standards that will be applied when a party seeks permission from 14 the court to file material under seal. 15 B. GOOD CAUSE STATEMENT 16 Defendants Primeritus Financial Services, Inc. (“Primeritus”) and Key Auto 17 Recovery ("KAR") are herein collectively referred to as "Defendants." This action is 18 likely to involve confidential financial and proprietary information relating to the 19 confidential financial information and business practices and policies of Defendants, 20 and confidential financial information relating to California consumers for which 21 special protection from public disclosure and from use for any purpose other than the 22 litigation of this action is warranted. Such confidential and proprietary materials and 23 information consist of, among other things, confidential financial information, 24 information regarding confidential business practices, or other confidential research, 25 development, or commercial information (including information implicating privacy 26 rights of third parties and putative class members), information otherwise generally 27 unavailable to the public, or which may be privileged or otherwise protected from 28 disclosure under state or federal statutes, court rules, case decisions, or common law. –2– STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 Disclosure of this information would result in the dissemination of private financial 2 information, and confidential/proprietary information developed and used internally 3 by Primeritus only and/or by KAR only , resulting in personal and/or financial harm to 4 Primeritus and/or KAR and/or third parties. Accordingly, to expedite the flow of 5 information, to facilitate the prompt resolution of disputes over confidentiality of 6 discovery materials, to adequately protect information the parties are entitled to keep 7 confidential, to ensure that the parties are permitted reasonable necessary uses of such 8 material in preparation for and in the conduct of trial, to address their handling at the 9 end of the litigation, and serve the ends of justice, a protective order for such REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 information is justified in this matter. It is the intent of the parties that information 11 will not be designated as confidential for tactical reasons and that nothing be so 12 designated without a good faith belief that it has been maintained in a confidential, 13 non-public manner, and there is good cause why it should not be part of the public 14 record of this case. 15 2. DEFINITIONS 16 2.1 Action: the instant lawsuit entitled Charylnn Odahl. v. Primeritus 17 Financial Services, Inc., et al., Case No. 2:17-cv-08570. 18 2.2 Challenging Party: a Party or Non-Party that challenges the designation 19 of information or items under this Order. 20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 21 how it is generated, stored or maintained) or tangible things that qualify for protection 22 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 23 Cause Statement. 24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 25 support staff). 26 2.5 Designating Party: a Party or Non-Party that designates information or 27 items that it produces in disclosures or in responses to discovery as 28 “CONFIDENTIAL.” –3– STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 2.6 Disclosure or Discovery Material: all items or information, regardless of 2 the medium or manner in which it is generated, stored, or maintained (including, 3 among other things, testimony, transcripts, and tangible things), that are produced or 4 generated in disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in a matter 6 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 7 expert witness or as a consultant in this Action. 8 2.8 House Counsel: attorneys who are employees of a party to this Action. 9 House Counsel does not include Outside Counsel of Record or any other outside REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 counsel. 11 2.9 Non-Party: any natural person, partnership, corporation, association, or 12 other legal entity not named as a Party to this action. 13 2.10 Outside Counsel of Record: attorneys who are not employees of a party 14 to this Action but are retained to represent or advise a party to this Action and have 15 appeared in this Action on behalf of that party or are affiliated with a law firm which 16 has appeared on behalf of that party, and includes support staff. 17 2.11 Party: any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, and Outside Counsel of Record (and their 19 support staffs). 20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 21 Discovery Material in this Action. 22 2.13 Professional Vendors: persons or entities that provide litigation support 23 services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) 25 and their employees and subcontractors. 26 2.14 Protected Material: any Disclosure or Discovery Material that is 27 designated as “CONFIDENTIAL.” 28 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material –4– STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 from a Producing Party. 2 3. SCOPE 3 The protections conferred by this Stipulation and Order cover not only 4 Protected Material (as defined above), but also (1) any information copied or extracted 5 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 6 Protected Material; and (3) any testimony, conversations, or presentations by Parties 7 or their Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the trial 8 9 judge. This Order does not govern the use of Protected Material at trial. REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 4. DURATION 11 The terms of this protective order do not govern the use of Protected Material at 12 trial. 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 5. DESIGNATING PROTECTED MATERIAL 22 5.1 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 that 25 qualifies under the appropriate standards. The Designating Party must designate for 26 protection only those parts of material, documents, items, or oral or written 27 communications that qualify so that other portions of the material, documents, items, 28 or communications for which protection is not warranted are not swept unjustifiably –5– STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 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 Party 6 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. REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 5.2 Manner and Timing of Designations. Except as otherwise provided in 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: 16 (a) 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 documents 28 it wants copied and produced, the Producing Party must determine which documents, –6– STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 or portions thereof, qualify for protection under this Order. Then, before producing the 2 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 3 to each page that contains Protected Material. If only a portion or portions of the 4 material on a page qualifies for protection, the Producing Party also must clearly 5 identify the protected portion(s) (e.g., by making appropriate markings in the 6 margins). 7 (b) for testimony given in depositions that the Designating Party identify the 8 Disclosure or Discovery Material on the record, before the close of the deposition all 9 protected testimony. REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 (c) for information produced in some form other than documentary and for 11 any other tangible items, that the Producing Party affix in a prominent place on the 12 exterior of the container or containers in which the information is stored the legend 13 “CONFIDENTIAL.” If only a portion or portions of the information warrants 14 protection, the Producing Party, to the extent practicable, shall identify the protected 15 portion(s). 16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive the 18 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 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 6.1 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 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 27 resolution process under Local Rule 37.1, et seq. 28 –7– STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 6.3 The burden of persuasion in any such challenge proceeding shall be on 2 the Designating Party. Frivolous challenges, and those made for an improper purpose 3 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 4 expose the Challenging Party to sanctions. Unless the Designating Party has waived 5 or withdrawn the confidentiality designation, all parties shall continue to afford the 6 material in question the level of protection to which it is entitled under the Producing 7 Party’s designation until the Court rules on the challenge. 8 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 7.1 Basic Principles. A Receiving Party may use Protected Material that is REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 disclosed or produced by another Party or by a Non-Party in connection with this 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 Receiving 14 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 authorized under this Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 19 otherwise ordered by the court or permitted in writing by the Designating Party, a 20 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 21 only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 23 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 24 disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of the 26 Receiving Party to whom disclosure is reasonably necessary for this Action; 27 (c) Experts (as defined in this Order) of the Receiving Party to whom 28 disclosure is reasonably necessary for this Action and who have signed the –8– STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 2 (d) the court and its personnel; 3 (e) court reporters and their staff; 4 (f) professional jury or trial consultants, mock jurors, and Professional 5 Vendors to whom disclosure is reasonably necessary for this Action and who have 6 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (g) the author or recipient of a document containing the information or a 8 custodian or other person who otherwise possessed or knew the information; 9 (h) during their depositions, witnesses ,and attorneys for witnesses, in the REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 11 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 12 not be permitted to keep any confidential information unless they sign the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 14 agreed by the Designating Party or ordered by the court. Pages of transcribed 15 deposition testimony or exhibits to depositions that reveal Protected Material may be 16 separately bound by the court reporter and may not be disclosed to anyone except as 17 permitted under this Stipulated Protective Order; and 18 (i) any mediator or settlement officer, and their supporting personnel, 19 mutually agreed upon by any of the parties engaged in settlement discussions. 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 21 OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 23 that compels disclosure of any information or items designated in this Action as 24 “CONFIDENTIAL,” that Party must: 25 (a) promptly notify in writing the Designating Party. Such notification shall 26 include a copy of the subpoena or court order; 27 (b) promptly notify in writing the party who caused the subpoena or order to 28 issue in the other litigation that some or all of the material covered by the subpoena or –9– STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 order is subject to this Protective Order. Such notification shall include a copy of this 2 Stipulated Protective Order; and 3 (c) cooperate with respect to all reasonable procedures sought to be pursued 4 by the Designating Party whose Protected Material may be affected. 5 If the Designating Party timely seeks a protective order, the Party served with 6 the subpoena or court order shall not produce any information designated in this 7 action as “CONFIDENTIAL” before a determination by the court from which the 8 subpoena or order issued, unless the Party has obtained the Designating Party’s 9 permission. The Designating Party shall bear the burden and expense of seeking REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 protection in that court of its confidential material and nothing in these provisions 11 should be construed as authorizing or encouraging a Receiving Party in this Action to 12 disobey a lawful directive from another court. 13 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 14 PRODUCED IN THIS LITIGATION 15 (a) The terms of this Order are applicable to information produced by a Non- 16 Party in this Action and designated as “CONFIDENTIAL.” Such information 17 produced by Non-Parties in connection with this litigation is protected by the 18 remedies and relief provided by this Order. Nothing in these provisions should be 19 construed as prohibiting a Non-Party from seeking additional protections. 20 (b) In the event that a Party is required, by a valid discovery request, to 21 produce a Non-Party’s confidential information in its possession, and the Party is 22 subject to an agreement with the Non-Party not to produce the Non-Party’s 23 confidential information, then the Party shall: 24 (1) promptly notify in writing the Requesting Party and the Non-Party that 25 some or all of the information requested is subject to a confidentiality agreement with 26 a Non-Party; 27 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 28 Order in this Action, the relevant discovery request(s), and a reasonably specific – 10 – STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 description of the information requested; and (3) 2 make the information requested available for inspection by the Non- 3 Party, if requested. (c) 4 If the Non-Party fails to seek a protective order from this court within 14 5 days of receiving the notice and accompanying information, the Receiving Party may 6 produce the Non-Party’s confidential information responsive to the discovery request. 7 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 8 any information in its possession or control that is subject to the confidentiality 9 agreement with the Non-Party before a determination by the court. Absent a court REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 order to the contrary, the Non-Party shall bear the burden and expense of seeking 11 protection in this court of its Protected Material. 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 16 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 17 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 18 persons to whom unauthorized disclosures were made of all the terms of this Order, 19 and (d) request such person or persons to execute the “Acknowledgment and 20 Agreement to Be Bound” that is attached hereto as Exhibit A. 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 22 PROTECTED MATERIAL 23 When a Producing Party gives notice to Receiving Parties that certain 24 inadvertently produced material is subject to a claim of privilege or other protection, 25 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 26 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 27 may be established in an e-discovery order that provides for production without prior 28 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the – 11 – STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 parties reach an agreement on the effect of disclosure of a communication or 2 information covered by the attorney-client privilege or work product protection, the 3 parties may incorporate their agreement in the stipulated protective order submitted to 4 the court. 5 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 7 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 8 9 Protective Order no Party waives any right it otherwise would have to object to REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 disclosing or producing any information or item on any ground not addressed in this 11 Stipulated Protective Order. Similarly, no Party waives any right to object on any 12 ground to use in evidence of any of the material covered by this Protective Order. 12.3 Filing Protected Material. A Party that seeks to file under seal any 13 14 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 15 only be filed under seal pursuant to a court order authorizing the sealing of the 16 specific Protected Material at issue. If a Party’s request to file Protected Material 17 under seal is denied by the court, then the Receiving Party may file the information in 18 the public record unless otherwise instructed by the court. 19 13. FINAL DISPOSITION 20 After the final disposition of this Action, as defined in paragraph 4, within 60 21 days of a written request by the Designating Party, each Receiving Party must return 22 all Protected Material to the Producing Party or destroy such material. As used in this 23 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 24 summaries, and any other format reproducing or capturing any of the Protected 25 Material. Whether the Protected Material is returned or destroyed, the Receiving 26 Party must submit a written certification to the Producing Party (and, if not the same 27 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 28 (by category, where appropriate) all the Protected Material that was returned or – 12 – STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 destroyed and (2)affirms that the Receiving Party has not retained any copies, 2 abstracts, compilations, summaries or any other format reproducing or capturing any 3 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 4 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 5 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 6 reports, attorney work product, and consultant and expert work product, even if such 7 materials contain Protected Material. Any such archival copies that contain or 8 constitute Protected Material remain subject to this Protective Order as set forth in 9 Section 4 (DURATION). REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 14. Any violation of this Order may be punished by any and all appropriate 11 measures including, without limitation, contempt proceedings and/or monetary 12 sanctions. 13 14 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 15 16 Dated: December 21, 2017 17 TRUEBLOOD LAW FIRM /s/Alexander Trueblood Alexander Trueblood Attorneys for Plaintiff CHARLYNN ODAHL 18 19 20 Dated: December 21, 2017 21 REED SMITH LLP /s/ Raymond Kim1 Raymond Kim Attorneys for Defendant PRIMERITUS FINANCIAL SERVICES, INC. 22 23 24 25 26 1 Pursuant to Central District Local Rule 5-4.3.4(a)(2)(i) [Eastern District Local Rule 27 131(e)] [Northern District Local Rule 5-1(i)(3)], filing counsel attests that all other signatories listed and on whose behalf this filing is submitted concur in the filing’s 28 content and have authorized the filing. – 13 – STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 1 Dated: December 21, 2017 2 WOOD, SMITH, HENNING & BERMAN LLP /s/ Michael J. Partos Michael J. Partos Attorneys for Defendant KEY AUTO RECOVERY 3 4 5 6 7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 8 9 DATED: REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 11 Honorable Alicia G Rosenberg United States Magistrate Judge 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 – 14 – STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR 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 of perjury that I have read in its 5 entirety and understand the Stipulated Protective Order that was issued by the United 6 States District Court for the Central District of California on [date] in the case of 7 __________ Charlynn Odahl v. Primeritus Financial Services, Inc., et al., Case No. 8 2:17 cv 08570 SJO AGR. I agree to comply with and to be bound by all the terms 9 of this Stipulated Protective Order and I understand and acknowledge that failure to so REED SMITH LLP A limited liability partnership formed in the State of Delaware 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that is 12 subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. I further agree to submit to the 14 jurisdiction of the United States District Court for the Central District of California for 15 the purpose of enforcing the terms of this Stipulated Protective Order, even if such 16 enforcement proceedings occur after termination of this action. I hereby appoint 17 ___________________ [print or type full name] of _____________ [print or type full 18 address and telephone number] as my California agent for service of process in 19 connection with this action or any proceedings related to enforcement of this 20 Stipulated Protective Order. 21 22 23 24 Date: City and State where sworn and signed: Printed name: Signature: 25 26 27 28 – 15 – STIPULATED PROTECTIVE ORDER, CASE NO. 2:17 CV 08570 SJO AGR

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