Beverly Hills Unified School District v. Federal Transit Administration et al

Filing 199

STIPULATED PROTECTIVE ORDER by Judge George H. Wu: re Stipulation for Protective Order 193 . (sbou)

1 MARY C. WICKHAM, SBN 145664
2
3
4
5
6
7

County Counsel
CHARLES M. SAFER, SBN 82771
Assistant County Counsel
RONALD W. STAMM, SBN 91919
Principal Deputy County Counsel
[e-mail]
LOS ANGELES COUNTY COUNSEL
One Gateway Plaza | Los Angeles, CA 90012
Tel.: [phone] | Fax: [phone]

8 TIFFANY K. WRIGHT, SBN 210060

[e-mail]

9 LAURA M. HARRIS, SBN 246064

[e-mail]
CHRISTOPHER L. STILES, SBN 280816
11 [e-mail]
REMY MOOSE MANLEY, LLP
12 555 Capitol Mall, Suite 800 | Sacramento, CA 95814
13 Tel.: [phone] | Fax: [phone]
10

14 Attorneys for Defendants
15

LOS ANGELES COUNTY METROPOLITAN
TRANSPORTATION AUTHORITY and PHILLIP A. WASHINGTON

16

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

17
18
19

BEVERLY HILLS UNIFIED SCHOOL
DISTRICT,

20
21
22
23
24
25

Plaintiff,
v.
FEDERAL TRANSIT
ADMINISTRATION, et al.,
Defendants.

26
27
28
STIPULATED PROTECTIVE ORDER
2:18-cv-00716 GW(SSx)

Case No. 2:18-cv-00716 GW(SSx)
Related to Case Nos.
2:12-cv-09861 GW(SSx)
2:16-cv-08390 GW(SSx)
STIPULATED PROTECTIVE ORDER
Judge George H. Wu
Action filed: January 26, 2018

Local Defendants Los Angeles County Metropolitan Transportation Authority and

1

2 Phillip A. Washington (“Metro”), Plaintiff Beverly Hills Unified School District
3 (“BHUSD” or “Plaintiff”), and Federal Defendants Federal Transit Administration, K.
4 Jane Williams and Raymond Tellis (“FTA,” and collectively with Metro, “Defendants”),
5 collectively referred to as “the Parties,” by and through their respective counsel, hereby
6 agree and stipulate as follows:
7 1.

PURPOSES AND LIMITATIONS

8

The Court has authorized Plaintiff to serve a negotiated set of Requests for

9 Production of Documents (the “Requests”) on Defendants. Defendants’ production of
10 documents in response to the Requests is likely to involve production of confidential,
11 proprietary, or private information for which special protection from public disclosure
12 and from use for any purpose other than prosecuting this litigation, may be warranted.
13 Accordingly, the Parties hereby stipulate to and petition the Court to enter the following
14 Stipulated Protective Order. The Parties acknowledge that this Order does not confer
15 blanket protections on all disclosures or responses to discovery and that the protection it
16 affords from public disclosure and use extends only to the limited information or items
17 that are entitled to confidential treatment under applicable legal principles. The Parties
18 further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective
19 Order does not entitle them to file confidential information under seal; Civil Local Rule
20 79-5 sets forth the procedures that must be followed and the standards that will be
21 applied when a party seeks permission from the court to file material under seal.]
22 2.

GOOD CAUSE STATEMENT

23

Certain documents produced in this case, including documents produced in

24 response to the Requests, are likely to include information protected as confidential trade
25 secrets, development, commercial, financial, technical and/or other proprietary
26 information for which special protection from public disclosure and from use for any
27 purpose other than litigation of this action is warranted.
28
STIPULATED PROTECTIVE ORDER
2:18-cv-00716 GW(SSx)

2

Confidential and proprietary materials and information consist of, among other

1

2 things, confidential business or financial information, information regarding confidential
3 business practices, or other confidential research, development, or commercial
4 information (including information implicating privacy rights of third parties),
5 information 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 facilitate
8 the prompt resolution of disputes over confidentiality of discovery materials, to
9 adequately protect information the Parties are entitled to keep confidential, to ensure that
10 the Parties are permitted reasonable necessary uses of such material in preparation for
11 and in the conduct of trial or other merits hearing in this Action, to address their
12 handling at the end of the litigation, and serve the ends of justice, a protective order for
13 such information is justified in this matter. It is the intent of the Parties that information
14 will not be designated as confidential for tactical reasons and that nothing be so
15 designated without a good faith belief that it has been maintained in a confidential, non16 public manner, and there is good cause why it should not be part of the public record of
17 this case.
18 3.

DEFINITIONS

19

3.1

Action: this pending lawsuit entitled Beverly Hills Unified School District v.

20 Federal Transit Administration et al., Case No. 2:18-cv-00716 GW(SSx), before the
21 honorable Judge George H. Wu and any subsequent appeal of this Action.

3.2

22

“Confidential Information or Items”: information (regardless of how it is

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

3.3

26

Counsel: Counsel for the Parties, as well as their support staff or contracted

27 staff.
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2:18-cv-00716 GW(SSx)

3

3.4

1

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

2 items that it produces in response to discovery as “CONFIDENTIAL/SUBJECT TO
3 PROTECTIVE ORDER.”

3.5

4

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

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

3.6

8

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

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

3.7

10

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

11 employees, consultants, retained experts, and counsel (and their support staffs).

3.8

12

Producing Party: a Party or Non-Party that produces discovery material in

13 this Action.

3.9

14

Professional Vendors: persons or entities that provide litigation support

15 services (e.g., photocopying, videotaping, translating, preparing exhibits or
16 demonstrations, and organizing, storing, or retrieving data in any form or medium
17 including hosting a document management database or eDiscovery software system) and
18 their employees and subcontractors.

3.10 Protected Material: any discovery material that is designated as

19

20 “CONFIDENTIAL/SUBJECT TO PROTECTIVE ORDER.”

3.11 Receiving Party: a Party that receives discovery material from a Producing

21
22 Party.
23 4.

SCOPE

24

The protections conferred by this Stipulation and Order cover not only Protected

25 Material (as defined above), but also (1) any information copied or extracted from
26 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
27 Material; and (3) any testimony, conversations, or presentations by Parties or their
28 Counsel that might reveal Protected Material.
STIPULATED PROTECTIVE ORDER
2:18-cv-00716 GW(SSx)

4

Any use of Protected Material at any trial before the judge shall be governed by

1

2 the orders of the judge. This Order does not govern the use of Protected Material at any
3 trial.
4 5.

DURATION

5

Once this Action proceeds to a trial, all of the information designated as

6 confidential and maintained pursuant to the protective order becomes public and will be
7 presumptively available to all members of the public, including the press, unless
8 compelling reasons supported by specific factual findings to proceed otherwise are made
9 to the trial judge in advance of the trial. See Kamakana v. City and County of Honololu,
10 447 F.3d 1172, 1180 -81 (9th Cir. 2006) (distinguishing “good cause” showing for
11 sealing documents produced in discovery from “compelling reasons” standard when
12 merits related documents are part of the court records). Accordingly, the terms of this
13 protective order do not extend beyond the commencement of a trial in this Action.
14 6.

DESIGNATING PROTECTED MATERIAL

15

6.1

Exercise of Restraint and Care in Designating Material for Protection.

16 Each Party or Non-Party that designates information or items for protection under this
17 Order must take care to limit any such designation to specific material that qualifies
18 under the appropriate standards. The Designating Party must designate for protection
19 only those parts of material, documents, items, or oral or written communications that
20 qualify so that other portions of the material, documents, items, or communications for
21 which protection is not warranted are not swept unjustifiably within the ambit of this
22 Order.
23

Mass, indiscriminate, or routinized designations are prohibited. Designations that

24 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
25 to unnecessarily encumber the case development process or to impose unnecessary
26 expense and burdens on the other parties) may expose the Designating Party to
27 sanctions. If it comes to a Designating Party’s attention that information or items that it
28
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1 designated for protection do not qualify for protection, that Designating Party must
2 promptly notify all other Parties that it is withdrawing the inapplicable designation.
3

6.2

Manner and Timing of Designations. Except as otherwise provided in this

4 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
5 or ordered, Disclosure or Discovery Material that qualifies for protection under this
6 Order must be clearly so designated before the material is disclosed or produced.
7

Designation in conformity with this Order requires:

8

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

9

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

10

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

11

“CONFIDENTIAL/SUBJECT TO PROTECTIVE ORDER” to each page

12

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

13

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

14

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

15

markings in the margins).

16

(b) for testimony given in depositions that the Designating Party identify

17

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

18

deposition all protected material.

19

(c) for information produced in some form other than documentary and

20

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

21

place on the exterior of the container or containers in which the

22

information is stored the legend “CONFIDENTIAL/SUBJECT TO

23

PROTECTIVE ORDER.” If only a portion or portions of the information

24

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

25

identify the protected portion(s).

26

6.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

27 failure to designate qualified information or items does not, standing alone, waive the
28 Designating Party’s right to secure protection under this Order for such material. Upon
STIPULATED PROTECTIVE ORDER
2:18-cv-00716 GW(SSx)

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1 timely correction of a designation, the Receiving Party must make reasonable efforts to
2 assure that the material is treated in accordance with the provisions of this Order.
3 7.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

4

7.1

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 Scheduling
6 Order.

7.2

7

Meet and Confer. The Challenging Party shall initiate the dispute

8 resolution process under Local Rule 37.1 et seq., provided that this paragraph does not
9 preclude challenging the designation of Confidential Information or Items on an ex
10 parte basis if justified by the situation.

7.3

11

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

12 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
13 to harass or impose unnecessary expenses and burdens on other parties) may expose the
14 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
15 the protected material designation, all parties shall continue to afford the material in
16 question the level of protection to which it is entitled under the Producing Party’s
17 designation until the Court rules on the challenge.
18 8.

ACCESS TO AND USE OF PROTECTED MATERIAL

19

8.1

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

20 disclosed or produced by another Party or by a Non-Party in connection with this Action
21 only for prosecuting, defending, or attempting to settle this Action. Such Protected
22 Material may be disclosed only to the categories of persons and under the conditions
23 described in this Order. When the Action has been terminated, a Receiving Party must
24 comply with the provisions of section 13 below (FINAL DISPOSITION).
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

8.2

Disclosure of “Confidential Information or Items”. Unless otherwise

STIPULATED PROTECTIVE ORDER
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1 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
2 may disclose any information or item designated “CONFIDENTIAL/SUBJECT TO
3 PROTECTIVE ORDER” only to:
4

(a) the Receiving Party’s Counsel, including but not limited to employees

5

of said Counsel to whom it is reasonably necessary to disclose the

6

information for this Action;

7

(b) the officers, directors, employees (including Counsel), consultants of

8

the Receiving Party to whom disclosure is reasonably necessary for this

9

Action;

10

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

11

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

12

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

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(d) the court and its personnel;

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(e) court reporters and their staff;

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(f) professional jury or trial consultants, mock jurors, and Professional

16

Vendors to whom disclosure is reasonably necessary for this Action and

17

who have signed the “Acknowledgment and Agreement to Be Bound”

18

(Exhibit A);

19

(g) the author or recipient of a document containing the information or a

20

custodian or other person who otherwise possessed or knew the

21

information;

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

23

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

24

deposing party requests that the witness sign the form attached as Exhibit

25

A hereto; and (2) they will not be permitted to keep any confidential

26

information. Pages of transcribed deposition testimony or exhibits to

27

depositions that reveal Protected Material may be separately bound by the

28

court reporter and may not be disclosed to anyone except as permitted
STIPULATED PROTECTIVE ORDER
2:18-cv-00716 GW(SSx)

8

1

under this Stipulated Protective Order; and

2

(i) any mediator or settlement officer, and their supporting personnel,

3

mutually agreed upon by any of the parties engaged in settlement

4

discussions.

5 9.

PROTECTED MATERIAL SUBPOENAED OR OTHERWISE SUBJECT

6

TO PRODUCTION OUTSIDE THIS LITIGATION

7

Should any non-Party seek disclosure of Protected Material by way of a

8 subpoena, a bona fide discovery request, or request pursuant to the federal or state
9 Freedom of Information Acts (“Discovery Requests”) that Party must:
10

(a) promptly notify in writing the Designating Party. Such notification

11

shall include a copy of the Discovery Request;

12

(b) promptly notify in writing the party who made the Discovery Request

13

that some or all of the material covered by the subpoena or order is subject

14

to this Protective Order. Such notification shall include a copy of this

15

Stipulated Protective Order; and

16

(c) cooperate with respect to all reasonable procedures sought to be

17

pursued by the Designating Party whose Protected Material may be

18

affected.

19

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

20 subpoena or court order shall not produce any information designated in this action as
21 “CONFIDENTIAL/SUBJECT TO PROTECTIVE ORDER” before a determination by
22 the court from which the subpoena or order issued, unless the Party has obtained the
23 Designating Party’s permission. The Designating Party shall bear the burden and
24 expense of seeking protection in that court of its confidential material and nothing in
25 these provisions should be construed as authorizing or encouraging a Receiving Party
26 in this Action to disobey a lawful directive from another court. In the circumstances of
27 a FOIA request, nothing in this Order shall prevent any Party from producing Protected
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1 Information unless it is prohibited by the applicable law.
2 10.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

3

PRODUCED IN THIS LITIGATION

4

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

5

Non-Party in this Action, if any, and designated as

6

“CONFIDENTIAL/SUBJECT TO PROTECTIVE ORDER.” Such

7

information produced by Non-Parties in connection with this litigation is

8

protected by the remedies and relief provided by this Order. Nothing in

9

these provisions should be construed as prohibiting a Non-Party from

10

seeking additional protections.

11

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

12

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

13

Party is subject to an agreement with the Non-Party not to produce the

14

Non-Party’s confidential information, then the Party shall:

15

(1) promptly notify in writing the Requesting Party and the Non-

16

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

17

confidentiality agreement with a Non-Party;

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(2) promptly provide the Non-Party with a copy of the Stipulated

19

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

20

and a reasonably specific description of the information

21

requested; and

22
23

(3) make the information requested available for inspection by the
Non-Party, if requested.

24

(c) If the Non-Party fails to seek a protective order from this court within

25

14 days of receiving the notice and accompanying information, the

26

Receiving Party may produce the Non-Party’s confidential information

27

responsive to the discovery request. If the Non-Party timely seeks a

28

protective order, the Receiving Party shall not produce any information in
STIPULATED PROTECTIVE ORDER
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1

its possession or control that is subject to the confidentiality agreement

2

with the Non-Party before a determination by the court. Absent a court

3

order to the contrary, the Non-Party shall bear the burden and expense of

4

seeking protection in this court of its Protected Material.

5 11.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

6

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

7 Protected Material to any person or in any circumstance not authorized under this
8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
9 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
10 all unauthorized copies of the Protected Material, (c) inform the person or persons to
11 whom unauthorized disclosures were made of all the terms of this Order, and (d)
12 request such person or persons to execute the “Acknowledgment and Agreement to Be
13 Bound” that is attached hereto as Exhibit A.
14 12.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

15

PROTECTED MATERIAL

16

When a Producing Party gives notice to Receiving Parties that certain

17 inadvertently produced material is subject to a claim of privilege or other protection,
18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
20 may be established in an e-discovery order that provides for production without prior
21 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
22 Parties reach an agreement on the effect of disclosure of a communication or
23 information covered by the attorney-client privilege or work product protection, the
24 Parties may incorporate their agreement in the stipulated protective order submitted to
25 the court.
26 13.

MISCELLANEOUS

27

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

28
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1 person to seek its modification by the Court in the future.

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

2

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

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

7

8 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
9 only be filed under seal pursuant to a court order authorizing the sealing of the specific
10 Protected Material at issue. If a Party's request to file Protected Material under seal is
11 denied by the court, then the Receiving Party may file the information in the public
12 record unless otherwise instructed by the court.
13 14.

FINAL DISPOSITION

14

After the final disposition of this Action, as defined in paragraph 3.1, within 60

15 days of a written request by the Designating Party, each Receiving Party must return all
16 Protected Material to the Producing Party or destroy such material. As used in this
17 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
18 summaries, and any other format reproducing or capturing any of the Protected
19 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
20 must submit a written certification to the Producing Party (and, if not the same person
21 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
22 category, where appropriate) all the Protected Material that was returned or destroyed
23 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
24 compilations, summaries or any other format reproducing or capturing any of the
25 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
26 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
27 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
28 work product, and consultant and expert work product, even if such materials contain
STIPULATED PROTECTIVE ORDER
2:18-cv-00716 GW(SSx)

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1 Protected Material. Any such archival copies that contain or constitute Protected
2 Material remain subject to this Protective Order as set forth in Section 4 (DURATION).
3 15.

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

4 including, without limitation, contempt proceedings and/or monetary sanctions.
5 16.

All signatories listed, and on whose behalf the filing is submitted, concur in this

6 stipulation’s content and have authorized the filing.
7
8 IT IS HEREBY STIPULATED AND AGREED.
9
10 Dated: November 22, 2019
11
12

LOS ANGELES COUNTY COUNSEL
MARY C. WICKHAM, County Counsel
CHARLES M. SAFER, Assistant County Counsel
RONALD W. STAMM, Principal Deputy

13

REMY MOOSE MANLEY, LLP

14
15

/s/ Tiffany K. Wright
TIFFANY K. WRIGHT

16
17

Attorneys for Defendants
LOS ANGELES COUNTY METROPOLITAN
TRANSPORTATION AUTHORITY and
PHILLIP A. WASHINGTON

18
19
20
21 Dated: November 22, 2019
22

STROOCK & STROOCK & LAVAN LLP
/s/ Jennifer S. Recine
JENNIFER S. RECINE

23
24

Attorneys for Plaintiff
BEVERLY HILLS UNIFIED SCHOOL
DISTRICT

25
26
27 / / /
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1 Dated: November 22, 2019
2
3
4

JEAN E. WILLIAMS
Deputy Assistant Attorney General
United States Department of Justice
Environment & Natural Resources Division
/s/ Joshua P. Wilson
JOSHUA P. WILSON
Senior Attorney
Natural Resources Section

5
6
7

OF COUNSEL, NANCY-ELLEN ZUSMAN
Assistant Chief Counsel for Litigation
and Regional Operations
Federal Transit Administration

8
9
10
11
12

MARTIA FOX, Regional Counsel
Federal Transit Administration, Region IX

13

Attorneys for Federal Defendants

14
15
16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
17
18 DATED: November 26, 2019
19
20
21

Honorable George H. Wu

22 United States District Judge
23
24
25
26
27
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1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3
4 I, ______________________________________________ [print or type full name], of
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 was
7 issued by the United States District Court for the Central District of California on
8 _____[date]______ in the case of _________________ [insert formal name of the case
9 and the number and initials assigned to it by the court]. I agree to comply with and to
10 be 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 in
12 the nature of contempt. I solemnly promise that I will not disclose in any manner any
13 information or item that is subject to this Stipulated Protective Order to any person or
14 entity except in strict compliance with the provisions of this Order. I further agree to
15 submit to the jurisdiction of the United States District Court for the Central District of
16 California for the purpose of enforcing the terms of this Stipulated Protective Order,
17 even if such enforcement proceedings occur after termination of this action. I hereby
18 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 this
21 action or any proceedings related to enforcement of this Stipulated Protective Order.
22
23
24

Date: _______________________________________
City and State where sworn and signed: _____________________________________

25 Printed name: _____________________________________________________
26 Signature: ________________________________________________
27
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