Jitrade, Inc. v. Design of DK, Inc. et al

Filing 39

PROTECTIVE ORDER by Magistrate Judge John E. McDermott. (See document for further details.) #35 (sbou)

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- - - . ..-- --~ --~-- ~~.. _ ... _,. . ..y...~ 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 Case No.: 2:18-cv-03034 -SVW-JEM JITRADE,INC., a California Corporation; 13 14 [ + D]STIPULATED PROTECTIVE ORDER Plaintiff, 15 vs. 16 17 DESIGN OF DK,INC. d/b/a CUBE 18 PLUS,a California Corporation; YONG WOO KIM,an individual; 19 CICINDELAE,INC. d1b/a ORANGE 2 0 SHINE, a California Corporation; DO 21 GI KIM, an individual; and DOES 1-10, inclusive, 22 23 Defendants. 24 25 2 6 27 28 ~PROPOSED~ ORDER C e 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 2 of 15 Page ID # 170 1 2 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting or defending this 5 litigation may be warranted. Accordingly, the parties hereby stipulate to and 6 petition the Court to enter the following Stipulated Protective Order. The parties 7 acknowledge that this Order does not confer blanket protections on all disclosures 8 or responses to discovery and that the protection it affords from public disclosure 9 and use extends only to the limited information or items that are entitled to 10 confidential treatment under the applicable legal principles. The parties further 11 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective 12 Order does not entitle the parties to file confidential information under seal; Civil 13 Local Rule 79-5 sets forth the procedures that must be followed and the standards 14 that will be applied when a party seeks permission from the court to file material 15 under seal. 16 17 B. GOOD CAUSE STATEMENT 18 This action is likely to involve trade secrets, customer and pricing lists anc 19 other valuable research, development, commercial, financial, technical and/o. 20 proprietary information for which special protection from public disclosure and fror~ 21 use for any purpose other than prosecution of this action is warranted. Such 22 confidential and proprietary materials and information consist of, among other 23 things, confidential business or financial information, terms of agreements enterer 24 into between parties, information regarding purchase and sale prices of fabric o: 25 garments by suppliers, manufacturers, importers, distributors or fashion retailers 2 information regarding business practices, information regarding the creation 6 27 purchase or sale of graphics used on textiles and garments, or other confidentia 28 commercial information (including information implicating privacy rights of thin z ~PROPOSED~ORDER C e 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 3 of 15 Page ID # 171 1 parties), information generally unavailable to the public, or which may be privilege 2 or otherwise protected from disclosure under state or federal rules, court rules, cas 3 decisions, or common law. Accordingly, to expedite the flow of information, t 4 facilitate the prompt resolution of disputes over confidentiality of discove 5 materials, to adequately protect information the parties are entitled to kee 6 confidential, to ensure that the parties are permitted reasonable necessary uses o 7 such material in preparation for and in the conduct of trial, to address their handlin 8 at the end of the litigation, and serve the ends ofjustice, a protective order for suc 9 information is justified in this matter. It is the intent of the parties that informatio 10 will not be designated as confidential for tactical reasons and that nothing be s 11 designated without a good faith belief that it has been maintained in a confidential 12 non-public manner, and there is good cause why it should not be part of the publi 13 record of this case. 14 15 2. DEFINITIONS 16 2.1 Action: This is a pending federal law suit under Case No. 2:18-cv-03034 17 -SVW-JEM 18 2.2 Challenging Party: a Party or Non-Party that challenges the 19 2 0 21 designation of information or items under this Order. 2.3 "CONFIDENTIAL"Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that qualify for 22 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 23 the Good Cause Statement. 24 25 2 6 2.4 Counsel: Outside Counsel of Record and In-House Counsel(as well as their support staff. 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" or "ATTORNEY'S EYES ONLY" 3 ~PROPOSED~ ORDER C~~e 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 4 of 15 Page ID #X172 1 2.6 Disclosure or Discovery Material: all items or information, regardless 2 ofthe medium or manner in which it is generated, stored, or maintained (including 3 among other things, testimony, transcripts, and tangible things), that are produced 4 or generated in disclosures or responses to discovery in this matter. 5 2 Expert: a person with specialized knowledge or experience in a matter .7 6 pertinent to the litigation who has been retained by a Party or its counsel to serve 7 as an expert witness or as a consultant in this Action. 8 2 In- house Counsel: attorneys who are employees of a party to this .8 Action. 10 In -house Counsel does not include Outside Counsel of Record or any other 11 12 13 14 counsel. 2 Non-Party: any natural person, partnership, corporation, association, or .9 other legal entity not named as a Party to this action. 2 Outside Counsel of Record: attorneys who are not employees of a .10 15 party to this Action but are retained to represent or advise a party to this Action 16 and have appeared in this Action on behalf of that party or are affiliated with a law 17 f which has appeared on behalf of that party, and includes support staff. irm 18 2 Party: any party to this Action, including all of its officers, directors, .11 19 employees, consultants, retained experts, and Outside Counsel of Record (and their 2 ~ support staffs). 0 21 2 Producing Party: a Party or Non-Party that produces Disclosure or .12 22 ~ ~ Discovery Material in this Action. 23 2 Professional Vendors: persons or entities that provide litigation .13 24 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 25 demonstrations, and organizing, storing, or retrieving data in any form or medium) 2 6 and their employees and subcontractors. 27 28 2 Protected Material: any Disclosure or Discovery Material that is .14 designated as "CONFIDENTIAL" or "ATTORNEYS EYES ONLY" 4 PROPOSED)ORDER C e 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 5 of 15 Page ID # 173 1 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 2 from a Producing Party. 3 4 3. SCOPE 5 The protections conferred by this Stipulation and Order cover not only 6 Protected Material(as defined above), but also(1)any information copied or 7 extracted from Protected Material;(2)all copies, excerpts, summaries, or 8 compilations of Protected Material; and (3) any testimony, conversations, or 9 presentations by Parties or their Counsel that might reveal Protected Material. 10 11 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. 12 13 4. DURATION 14 Even after final disposition of this litigation, the confidentiality obligations 15 imposed by this Order shall remain in effect until a Designating Party agrees 16 otherwise in writing or a court order otherwise directs. Final disposition shall be 17 deemed to be the later of(1) dismissal of all claims and defenses in this Action, 18 with or without prejudice; and(2)final judgment herein after the completion and 19 e~austion of all appeals, rehearings, remands, trials, or reviews of this Action, 2 including the time limits for filing any motions or applications for extension of 0 21 time pursuant to applicable law. 22 23 5. DESIGNATING PROTECTED MATERIAL 2 4 5.1 Exercise of Restraint and Care in Desi natin~ Material for Protection. 25 Each Party or Non-Party that designates information or items for protection under 2 this Order must take care to limit any such designation to specific material that 6 27 qualifies under the appropriate standards. The Designating Party must designate fo 28 protection only those parts of material, documents, items, oral or written 5 PROPOSED]ORDER C e 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 6 of 15 Page ID a 1174 1 communications that qualify so that other portions ofthe material, documents, 2 items, or communications for which protection is not warranted are not swept 3 4 5 unjustifiably within the ambit of this Order. Mass, indiscriminate, or routinized designations are prohibited. Designation that are shown to be clearly unjustified or that have been made for an improper 6 purpose (e.g., to unnecessarily encumber the case development process or to 7 impose unnecessary expenses and burdens on other parties) may expose the 8 9 Designating Party to sanctions. If it comes to a Designating Party's attention that information or items that i 10 designated for protection do not qualify for protection, that Designating Party mus 11 promptly notify all other Parties that it is withdrawing the inapplicable designatior 12 5.2 Manner and Timing of Desi nations. Except as otherwise provided in 13 this Order(see, e.g., second paragraph of section 5.2(a) below), or as otherwise 14 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 15 under this Order must be clearly so designated before the material is disclosed or 16 produced. 17 18 Designation in conformity with this Order requires: (a)for information in documentary form (e.g., paper or electronic 19 documents, but excluding transcripts of depositions or other pretrial or trial 20 proceedings), that the Producing Party affix at a minimum,"CONFIDENTIAL" o~ 21 "ATTORNEY'S EYES ONLY"(hereinafter "CONFIDENTIAL legend"), to each 22 page that contains protected material. If only a portion or portions of the material 23 on a page qualifies for protection, the Producing Party also must clearly identify 24 the protected portions)(e.g., by making appropriate markings in the margins). 25 A Party or Non-Party that makes original documents available for inspectioY 2 need not designate them for protection until after the inspecting Party has indicates 6 27 which documents it would like copied and produced. During the inspection and 28 before the designation, all of the material made available for inspection shall be 6 ( PROPOSED ORDER C~~e 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 7 of 15 Page ID 1 deemed "CONFIDENTIAL." After the inspecting Pariy has identified the 2 documents it wants copied and produced, the Producing Party must determine 3 which documents, or portions thereof, qualify for protection under this Order. 4 Then, before producing the specified documents, the Producing Party must affix 5 the "CONFIDENTIAL" or "ATTORNEY's EYES ONLY" to each page that 6 contains Protected Material. If only a portion or portions of the material on a page 7 qualifies for protection, the Producing Party also must clearly identify the 8 protected portions)(e.g., by making appropriate markings in the margins). ( for testimony given in depositions that the Designating Party identify b) 9 10 the Disclosure or Discovery Material on the record, before the close ofthe 11 deposition all protected testimony. ( for information produced in some form other than documentary and c) 12 or 13 f any other tangible items, that the Producing Party affix in a prominent place on 14 the exterior ofthe container or containers in which the information is stored the 15 term "CONFIDENTIAL" or "ATTORNEY'S EYES ONLY." If only a portion or 16 portions ofthe information warrants protection, the Producing Party, to the extent 17 practicable, shall identify the protected portion(s). 18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 failure to designate qualified information or items does not, standing alone, waive 2 the Designating Party's right to secure protection under this Order for such 0 21 material. Upon timely correction of a designation, the Receiving Party must make 22 reasonable efforts to assure that the material is treated in accordance with the 23 provisions of this Order. 24 25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6 6.1 Timing of Challen es. Any Party or Non-Party may challenge a 27 designation of confidentiality at any time that is consistent with the Court's 28 Scheduling Order. ~PROPOSED~ORDER 75 C e 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 8 of 15 Page ID #1176 1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process under Local Rule 37.1 et seq. 6.3 The burden of persuasion in any such challenge proceeding shall be on 3 4 the Designating Party. Frivolous challenges, and those made for an improper 5 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 6 parties) may expose the Challenging Party to sanctions. Unless the Designating 7 Party has waived or withdrawn the confidentiality designation, all parties shall 8 continue to afford the material in question the level of protection to which it is 9 entitled under the Producing Party's designation until the Court rules on the 10 challenge. 11 12 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this 15 Action only for prosecuting, defending, or attempting to settle this Action. Such 16 Protected Material may be disclosed only to the categories of persons and under 17 the conditions described in this Order. When the Action has been terminated, a 18 Receiving Party must comply with the provisions of section 13 below(FINAL 19 DISPOSITION). 20 21 Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons 22 authorized under this Order. 23 7.2 Disclosure of"CONFIDENTIAL"Information or Items. Unless 24 otherwise ordered by the court or permitted in writing by the Designating Party, a 25 Receiving Party may disclose any information or item designated 2 "CONFIDENTIAL" only to: 6 27 28 (a)the Receiving Pariy's Outside Counsel of Record in this Action, as well as employees of said Outside Counsel of Record to whom it is reasonably 8 ~PROPOSED~ ORDER C~~e 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 9 of 15 Page ID #~:L77 1 necessary to disclose the information for this Action; ( the officers, directors, and employees (including House Counsel) of b) 2 3 the Receiving Party to whom disclosure is reasonably necessary for this Action; ( Experts(as defined in this Order)of the Receiving Party to whom c) 4 5 disclosure is reasonably necessary for this Action and who have signed the 6 ~ "Acknowledgment and Agreement to Be Bound"(Exhibit A); 7 ( the court and its personnel; d) 8 ( court reporters and their staff; e) 9 ( professional jury or trial consultants, mock jurors, and Professional ~ 10 Vendors to whom disclosure is reasonably necessary for this Action and who have 11 signed the "Acknowledgment and Agreement to Be Bound"(E~ibit A); 12 ( the author or recipient of a document containing the information or a g) 13 ~ custodian or other person who otherwise possessed or knew the information; 14 ( during their depositions, witnesses, and attorneys for witnesses, in the h) 15 Action to whom disclosure is reasonably necessary provided:(1)the deposing 16 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 17 they will not be permitted to keep any confidential information unless they sign the 18 " Acknowledgment and Agreement to Be Bound"(Exhibit A), unless otherwise 19 agreed by the Designating Party or ordered by the court. Pages oftranscribed 2 deposition testimony or e~ibits to depositions that reveal Protected Material may 0 21 be separately bound by the court reporter and may not be disclosed to anyone 22 except as permitted under this Stipulated Protective Order; and 23 ( any mediator or settlement officer, and their supporting personnel, i) 24 mutually agreed upon by any ofthe parties engaged in settlement discussions. 25 For all information designated as "ATTORNEY'S EYES ONLY," the Receiving 2 Party may only disclose this information to the Outside Counsel of Record in this 6 27 Action. 28 /// 9 ~PROPOSED~ ORDER ase 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 10 of 15 Page # :178 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 "CONFIDENTIAL" or "ATTORNEY'S EYES ONLY" that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification 7 shall include a copy ofthe subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order 9 to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall 11 include a copy of this Stipulated Protective Order; and 12 13 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with 15 the subpoena or court order shall not produce any information designated in this 16 action as "CONFIDENTIAL" before a determination by the court from which the 17 subpoena or order issued, unless the Party has obtained the Designating Party's 18 permission. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 2 should be construed as authorizing or encouraging a Receiving Party in this Action 0 21 to disobey a lawful directive from another court. 22 23 9. ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 2 4 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this Action and designated as "CONFIDENTIAL" or "ATTORNEY'S 27 EYES ONLY." Such information produced by Non-Parties in connection with this 28 litigation is protected by the remedies and relief provided by this Order. Nothing in io ~PROPOSED~ ORDER ase 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 11 of 15 Page # :179 1 these provisions should be construed as prohibiting allon-Party from seeking 2 additional protections. (b)In the event that a Party is required, by a valid discovery request, to 3 4 produce allon-Party's confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Pariy's 6 confidential information, then the Party shall: 7 (1)promptly notify in writing the Requesting Party and the Non-Party 8 that some or all of the information requested is subject to a confidentiality 9 agreement with allon-Party; 10 11 (2)promptly provide the Non-Party with a copy of the Stipulated Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and 13 (3)make the information requested available for inspection by the 14 Non-Party, if requested. 15 16 (c)If the Non-Party fails to seek a protective order from this court within 14 days of receiving the notice and accompanying information, the Receiving 17 Party may produce the Non-Party's confidential information responsive to the 18 discovery request. If the Non-Party timely seeks a protective order, the Receiving 19 Party shall not produce any information in its possession or control that is subject 2 to the confidentiality agreement with the Non-Party before a determination by the 0 21 court. Absent a court order to the contrary, the Non-Party shall bear the burden and 22 expense of seeking protection in this court of its Protected Material. 23 2 4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has 2 6 disclosed Protected Material to any person or in any circumstance not authorized 27 under this Stipulated Protective Order, the Receiving Party must immediately (a) 28 notify in writing the Designating Party ofthe unauthorized disclosures,(b)use its >> [PROPOSED~ORDER ase 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 12 of 15 Page # :180 1 best efforts to retrieve all unauthorized copies of the Protected Material,(c)inform 2 the person or persons to whom unauthorized disclosures were made of all the terms 3 of this Order, and (d)request such person or persons to execute the 4 "Acknowledgment and Agreement to Be Bound" that is attached hereto as Exhibit 5 A. 6 7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 8 PROTECTED MATERIAL 9 When a Producing Party gives notice to Receiving Parties that certain 10 inadvertently produced material is subject to a claim of privilege or other 11 protection, the obligations of the Receiving Parties are those set forth in Federal 12 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 13 whatever procedure may be established in an e-discovery order that provides for 14 production without prior privilege review. Pursuant to Federal Rule of Evidence 15 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 16 of a communication or information covered by the attorney-client privilege or 17 work product protection, the parties may incorporate their agreement in the 18 stipulated protective order submitted to the court. 19 20 21 12. MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 22 person to seek its modification by the Court in the future. 23 12.2 Right to Assert Other Objections. By stipulating to the entry of this 24 Protective Order no Party waives any right it otherwise would have to object to 25 disclosing or producing any information or item on any ground not addressed in 2 this Stipulated Protective Order. Similarly, no Party waives any right to object on 6 27 any ground to use in evidence of any of the material covered by this Protective 28 Order. ~z ~PROPOSED~ ORDER ase 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 13 of 15 Page # :181 12.3 Filing Protected Material. A Party that seeks to file under seal any 1 2 Protected Material must comply with Civil Local Rule 79-5. Protected Material 3 may only be filed under seal pursuant to a court order authorizing the sealing ofthe 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 6 in the public record unless otherwise instructed by the court. 7 g q 13. FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 4, within 10 60 days of a written request by the Designating Party, each Receiving Party must 11 return all Protected Material to the Producing Party or destroy such material. As 12 used in this subdivision,"all Protected Material" includes all copies, abstracts, 13 compilations, summaries, and any other format reproducing or capturing any of the 14 Protected Material. Whether the Protected Material is returned or destroyed, the 15 Receiving Party must submit a written certification to the Producing Party if 16 requested by the Producing Pariy in writing (and, if not the same person or entity, 1 ~ to the Designating Party) by the 60 day deadline that(1)identifies(by category, 1g where appropriate) all the Protected Material that was returned or destroyed and 19 (2)affirms that the Receiving Party has not retained any copies, abstracts, 2 compilations, summaries or any other format reproducing or capturing any of the 0 21 Protected Material. Notwithstanding this provision, Counsel are entitled to retain 22 an archival copy of all pleadings, motion papers, trial documents, discovery 23 questions and responses, and hearing transcripts, legal memoranda, 24. correspondence, deposition and trial exhibits, expert reports, attorney work 25 product, and consultant and expert work product, even if such materials contain 26 Protected Material. Any such archival copies that contain or constitute Protected 27 Material remain subject to this Protective Order as set forth in Section 4 28 (DURATION). 13 (PROPOSED)ORDER I~ _~ ..v - V JVJ' f'JV VV - v~~.. 1 14. Any violation of this Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. 4 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 9 DATED: July 31, 2018 10 / C. Yon Jeon s/ 1 1 C. Yong Jeong, Esq. Regina S. Zernay, Esq. 12 Attorneys for Plaintiff JITRADE,INC. 13 14 DATED: August 1, 2018 15 / Leontvne Fan s/ 16 Tommy SF Wang, Esq. Leontyne Fan, Esq. 17 Attorneys for Defendants 18 DESIGN OF DK,INC. d/b/a CUBE PLUS; YONG WOO KIM; CICINDELAE,INC. 19 d/b/a ORANGE SHINE; and DO GI KIM 2 0 21 FOR GOOD CAUSE SHOWN,IT IS SO ORDERED.DATED. 22 23 24 25 2 6 ~ ' ~~~ ~ `~ ~ ~ ,. ble John E. McDermott States District/Magistrate Judge 27 28 14 ~PROPOSED~ ORDER ~ase 2:18-cv-03034-SVW-JEM Document 35-1 Filed 08/01/18 Page 15 of 15 Page # :183 1 ~VTTTDTT 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 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of Jitrade, Inc. v. Design ofDK,Inc. et al 2:18 8 cv-03034-SVW-JEM. I agree to comply with and to be bound by all the terms of 9 this Stipulated Protective Order and I understand and acknowledge that failure to 10 so comply could expose me to sanctions and punishment in the nature of contempt. 11 I solemnly promise that I will not disclose in any manner any information or item 12 that is subject to this Stipulated Protective Order to any person or entity except in 13 strict compliance with the provisions of this Order. 14 '~, I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint 18 or type full name]of [print [print or 19 type full address and telephone number] as my California agent for service of 2 process in connection with this action or any proceedings related to enforcement o 0 21 this Stipulated Protective Order. 22 Date: 23 City and State where sworn and signed: 2 4 25 2 6 Printed name: Signature: 27 28 IS [ PROPOSED]ORDER

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