Neyda Flores v. Costco Wholesale Corporation et al

Filing 16

PROTECTIVE ORDER [CHANGES MADE BY COURT] by Magistrate Judge Jacqueline Chooljian re Stipulation for Protective Order 15 . (see document for details) (hr)

1
2
3
4
5
6

STEPHEN M. HARBER, STATE BAR #119830
AMY ARSENEAUX EVENSTAD, STATE BAR #305828
McCUNE & HARBER, LLP
515 South Figueroa Street, Suite 1100
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
[e-mail] and [e-mail]
Attorneys for Defendant, COSTCO WHOLESALE CORPORATION

7
8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

11

NEYDA FLORES,

12

Case No: 2:20-cv-09264-FMO-JC

Plaintiff,

13
14

STIPULATED PROTECTIVE ORDER

vs.
COSTCO WHOLESALE
CORPORATION; DOES 1 through 10,

15

[CHANGES MADE BY COURT TO
PARAGRAPHS 7.2(h) & 8]

Defendants.

16
17
18

1. A. PURPOSES AND LIMITATIONS

19

Discovery in this action is likely to involve production of confidential, proprietary,

20

or private information for which special protection from public disclosure and from use

21

for any purpose other than prosecuting this litigation may be warranted. Accordingly, the

22

parties hereby stipulate to and petition the Court to enter the following Stipulated

23

Protective Order. The parties acknowledge that this Order does not confer blanket

24

protections on all disclosures or responses to discovery and that the protection it affords

25

from public disclosure and use extends only to the limited information or items that are

26

entitled to confidential treatment under the applicable legal principles. The parties further

27

acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does

28

not entitle them to file confidential information under seal; Local Rule 79-5 sets forth the
-1-

30900097

Stipulated Protective Order

1

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

2

permission from the court to file material under seal.

3

B.

5

Defendant COSTCO WHOLESALE CORPORATION (“Costco”) maintains that

6

its procedures, operations and training materials are confidential, proprietary, commercial

7

information pertaining to the internal operations of Costco. Costco maintains that

8

dissemination of any information learned throughout the pendency of this action could

9

have the same negative effect on the company as dissemination of the above-referenced

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

4

GOOD CAUSE STATEMENT

materials. To allow the dissemination of confidential and/or proprietary information

11

would compromise Costco’s market position and business interests by exposing its

12

confidential business information to competitors and individuals outside the Costco

13

corporation. Dissemination of these materials to outside parties exposes the Company’s

14

methodologies and could subject Costco to unwarranted criticism from competitors or

15

other third parties. Such unwarranted criticism could have potentially damaging effects on

16

the company’s public image and affect its relationship with consumers. Further, allowing

17

distribution of Costco’s policies, procedures and training materials could provide potential

18

plaintiffs and attorneys with unfair and unwarranted insight into the company’s internal

19

practices which, in turn, could hinder the company in subsequent litigation.

20

As such, this action is likely to involve commercial, confidential, and/or proprietary

21

information for which special protection from public disclosure and from use for any

22

purpose other than prosecution of this action is warranted.

23

In light of the nature of the claims and allegations in this case and the parties’

24

representations that discovery in this case will involve the production of confidential

25

records, and in order to expedite the flow of information, to facilitate the prompt

26

resolution of disputes over confidentiality of discovery materials, to adequately protect

27

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

28

permitted reasonable necessary uses of such material in connection with this action, to
-230900097

Stipulated Protective Order

1

address their handling of such material at the end of the litigation, and to serve the ends

2

of justice, a protective order for such information is justified in this matter. The parties

3

shall not designate any information/documents as confidential without a good faith belief

4

that such information/documents have been maintained in a confidential, non-public

5

manner, and that there is good cause or a compelling reason why it should not be part of

6

the public record of this case.

7
8

2.

2.1

9
10

Action: The instant action: Neyda Flores v. Costco Wholesale

Corporation; Case No. 2:20-cv-09264-FMO-JC.

MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

2.2

11
12

DEFINITIONS

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

designation of information or items under this Order.
2.3

13

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

14

is generated, stored or maintained) or tangible things that qualify for protection under

15

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

16

Statement.
2.4

17
18

support staff).
2.5

19
20

Counsel: Outside Counsel of Record and House Counsel (as well as their
Designating Party: a Party or Non-Party that designates information or items

that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
2.6

21

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

22

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

23

things, testimony, transcripts, and tangible things), that are produced or generated in

24

disclosures or responses to discovery in this matter.
2.7

25

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

26

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

27

expert witness or as a consultant in this Action.

28
-330900097

Stipulated Protective Order

2.8

1
2

Counsel does not include Outside Counsel of Record or any other outside counsel.
2.9

3
4

House Counsel: attorneys who are employees of a party to this Action. House
Non-Party: any natural person, partnership, corporation, association, or other

legal entity not named as a Party to this action.

5

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

6

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

7

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

8

on behalf of that party, and includes support staff.
2.11 Party: any party to this Action, including all of its officers, directors,

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

9

employees, consultants, retained experts, and Outside Counsel of Record (and their

11

support staffs).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery

12
13

Material in this Action.
2.13 Professional Vendors: persons or entities that provide litigation support

14
15

services

16

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

17

their employees and subcontractors.

videotaping,

translating,

preparing

exhibits

or

as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from

20
21

photocopying,

2.14 Protected Material: any Disclosure or Discovery Material that is designated

18
19

(e.g.,

a Producing Party.

22
23

3.

SCOPE
The protections conferred by this Order cover not only Protected Material (as

24
25

defined above), but also (1) any information copied or extracted from Protected

26

Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and

27

(3) any deposition testimony, conversations, or presentations by Parties or their Counsel

28

that might reveal Protected Material, other than during a court hearing or at trial.
-430900097

Stipulated Protective Order

Any use of Protected Material during a court hearing or at trial shall be governed

1
2

by the orders of the presiding judge. This Order does not govern the use of Protected

3

Material during a court hearing or at trial.

4
5

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

7

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

8

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

9

later of (1) dismissal of all claims and defenses in this Action, with or without prejudice;

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

6

and (2) final judgment herein after the completion and exhaustion of all appeals,

11

rehearings, remands, trials, or reviews of this Action, including the time limits for filing

12

any motions or applications for extension of time pursuant to applicable law.

13
14

5. DESIGNATING PROTECTED MATERIAL
5.1

15

Exercise of Restraint and Care in Designating Material for Protection. Each

16

Party or Non-Party that designates information or items for protection under this Order

17

must take care to limit any such designation to specific material that qualifies under the

18

appropriate standards. The Designating Party must designate for protection only those

19

parts of material, documents, items, or oral or written communications that qualify so that

20

other portions of the material, documents, items, or communications for which protection

21

is not warranted are not swept unjustifiably within the ambit of this Order.

22

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

23

are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

24

to unnecessarily encumber the case development process or to impose unnecessary

25

expenses and burdens on other parties) may expose the Designating Party to sanctions.

26

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

27

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

28

promptly notify all other Parties that it is withdrawing the inapplicable designation.
-530900097

Stipulated Protective Order

5.2

1

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

2

Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise stipulated or

3

ordered, Disclosure or Discovery Material that qualifies for protection under this Order

4

must be clearly so designated before the material is disclosed or produced.
Designation in conformity with this Order requires:

6

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

7

excluding transcripts of depositions), that the Producing Party affix at a minimum, the

8

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

9

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

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

5

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

11

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

12

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

13

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

14

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

15

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

16

“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

17

copied and produced, the Producing Party must determine which documents, or portions

18

thereof, qualify for protection under this Order. Then, before producing the specified

19

documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page

20

that 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).
(b) for testimony given in depositions that the Designating Party identifies on the

23
24

record, before the close of the deposition as protected testimony.

25

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

26

other tangible items, that the Producing Party affix in a prominent place on the exterior

27

of the container or containers in which the information is stored the legend

28

///
-630900097

Stipulated Protective Order

1

“CONFIDENTIAL.” If only a portion or portions of the information warrants protection,

2

the Producing Party, to the extent practicable, shall identify the protected portion(s).5.3
5.3

3

Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

4

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

5

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

6

correction of a designation, the Receiving Party must make reasonable efforts to assure

7

that the material is treated in accordance with the provisions of this Order.

8
9

6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

10

6.1

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

MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

11

of confidentiality at any time that is consistent with the Court’s Scheduling Order.
6.2

12
13

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.
6.3

14

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

15

Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

16

to harass or impose unnecessary expenses and burdens on other parties) may expose the

17

Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

18

the confidentiality designation, all parties shall continue to afford the material in

19

question the level of protection to which it is entitled under the Producing Party’s

20

designation until the Court rules on the challenge.

21
22

7.

ACCESS TO AND USE OF PROTECTED MATERIAL

23

7.1

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

24

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

25

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

26

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

27

described in this Order. When the Action has been terminated, a Receiving Party must

28

comply with the provisions of Section 13 below.
-730900097

Stipulated Protective Order

1

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

2

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

3

this Order.
7.2

4

Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

5

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

6

may disclose any information or item designated “CONFIDENTIAL” only to:

7

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

8

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

9

disclose the information for this Action;
(b) the officers, directors, and employees (including House Counsel) of the

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

11

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

12

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

13

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

14

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

15

(d) the court and its personnel;

16

(e) court reporters and their staff;

17

(f)

professional jury or trial consultants, mock jurors, and Professional

18

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

19

the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(g) the author or recipient of a document containing the information or a

20
21

custodian or other person who otherwise possessed or knew the information;

22

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

23

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

24

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

25

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

26

information unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit

27

A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of

28

transcribed deposition testimony or exhibits to depositions that reveal Protected Material
-830900097

Stipulated Protective Order

1

may be separately bound by the court reporter and may not be disclosed to anyone except

2

as permitted under this Stipulated Protective Order; and
(i)

3
4

any mediator or settlement officer, and their supporting personnel,

mutually agreed upon by any of the parties engaged in settlement discussions.

5

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

6

PRODUCED IN OTHER LITIGATION

7
8

If a Party is served with a subpoena or a court order issued in other litigation that

9

compels disclosure of any information or items designated in this Action as

10

“CONFIDENTIAL,” that Party must:

MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

(a)

11
12

promptly notify in writing the Designating Party. Such notification shall

include a copy of the subpoena or court order;
(b)

13

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

14

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

15

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

16

Stipulated Protective Order; and
(c)

17
18

cooperate with respect to all reasonable procedures sought to be pursued

by the Designating Party whose Protected Material may be 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” before a determination by the court from which the subpoena or order

22

issued, unless the Party has obtained the Designating Party’s permission or unless

23

otherwise required by the law or court order. The Designating Party shall bear the burden

24

and 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 in

26

this Action to disobey a lawful directive from another court.

27

///

28

///
-930900097

Stipulated Protective Order

9.

1

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION

2

(a)

3

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

4

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

5

by Non-Parties in connection with this litigation is protected by the remedies and relief

6

provided by this Order. Nothing in these provisions should be construed as prohibiting a

7

Non-Party from seeking additional protections.
(b)

8

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

a Non-Party’s confidential information in its possession, and the Party is subject to an

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

9

agreement with the Non-Party not to produce the Non-Party’s confidential information,

11

then the Party shall:

12

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

13

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

14

Non-Party;

15

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

16

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

17

description of the information requested; and
(3) make the information requested available for inspection by the Non-

18
19

Party, if requested.
(c)

20

If a Non-Party represented by counsel fails to commence the process called

21

for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving the notice and

22

accompanying information or fails contemporaneously to notify the Receiving Party that

23

it has done so, the Receiving Party may produce the Non-Party’s confidential information

24

responsive to the discovery request. If an unrepresented Non-Party fails to seek a

25

protective order from this court within 14 days of receiving the notice and accompanying

26

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

27

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

28

Receiving Party shall not produce any information in its possession or control that is
-1030900097

Stipulated Protective Order

1

subject to the confidentiality agreement with the Non-Party before a determination by the

2

court unless otherwise required by the law or court order. Absent a court order to the

3

contrary, the Non-Party shall bear the burden and expense of seeking protection in this

4

court of its Protected Material.

5

10.

7

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

8

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

9

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

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

6

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all

11

unauthorized copies of the Protected Material, (c) inform the person or persons to whom

12

unauthorized disclosures were made of all the terms of this Order, and (d) request such

13

person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is

14

attached hereto as Exhibit A.

15

11.

16

INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL

17
18

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

19

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

20

the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).

21

This provision is not intended to modify whatever procedure may be established in an e-

22

discovery order that provides for production without prior privilege review. Pursuant to

23

Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the

24

effect of disclosure of a communication or information covered by the attorney-client

25

privilege or work product protection, the parties may incorporate their agreement into this

26

Protective Order.

27

///

28

///
-1130900097

Stipulated Protective Order

1

12.

2

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

3

MISCELLANEOUS

to seek its modification by the Court in the future.

4

12.2 Right to Assert Other Objections. No Party waives any right it otherwise

5

would have to object to disclosing or producing any information or item on any ground

6

not addressed in this Protective Order. Similarly, no Party waives any right to object on

7

any 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 Protected

9

Material must comply with Civil Local Rule 79-5 and with any pertinent orders of the

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

8

assigned District Judge and Magistrate Judge. If a Party's request to file Protected Material

11

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

12

public record unless otherwise instructed by the court.

13
14

13.

FINAL DISPOSITION

15

After the final disposition of this Action, as defined in Section 4, within 60 days of

16

a written request by the Designating Party, each Receiving Party must return all Protected

17

Material to the Producing Party or destroy such material. As used in this subdivision, “all

18

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

19

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

20

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

21

to the Producing Party (and, if not the same person or entity, to the Designating Party) by

22

the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected

23

Material that was returned or destroyed and (2) affirms that the Receiving Party has not

24

retained any copies, abstracts, compilations, summaries or any other format reproducing

25

or capturing any of the Protected Material. Notwithstanding this provision, Counsel are

26

entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and

27

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

28

reports, attorney work product, and consultant and expert work product, even if such
-1230900097

Stipulated Protective Order

1

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

2

Protected Material remain subject to this Protective Order as set forth in Section 4.

3
4

14.

5

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

6

BREACH

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

7
8
9
10

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

June 2, 2021

MANNING LAW OFFICE

MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

By: /s/Babak Hashemi
JOSEPH R. MANNING, ESQ.
BABAK HASHEMI, ESQ.
Attorneys for Plaintiff, NEYDA FLORES

11
12
13
14
15

DATED:

June 7, 2021

McCUNE & HARBER, LLP

16

By: /s/ Amy A. Evenstad
STEPHEN M. HARBER, ESQ.
AMY A. EVENSTAD, ESQ.
Attorneys for Defendant, COSTCO
WHOLESALE CORPORATION

17
18
19
20

IT IS SO ORDERED AS MODIFIED.

21
22

DATED: June 7, 2021

23
24

____________/s/______________________

25

Honorable Jacqueline Chooljian
United States Magistrate Judge

26
27
28

-1330900097

Stipulated Protective Order

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I,__________________________, [print or type full name], of

4
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 June 7,

8

2021 in the case of Neyda Flores v. Costco Wholesale Corporation; Case No. 2:20-cv-

9

09264-FMO-JC.
I agree to comply with and to be bound by all the terms of this Stipulated

10
MCCUNE & HARBER, LLP
515 SOUTH FIGUEROA ST.
LOS ANGELES, CA 90071
[phone]
Fax [phone]

11

Protective Order and I understand and acknowledge that failure to so comply could

12

expose me to sanctions and punishment in the nature of contempt. I solemnly promise

13

that I will not disclose in any manner any information or item that is subject to this

14

Stipulated Protective Order to any person or entity except in strict compliance with the

15

provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court for

16
17

the Central District of California for the purpose of enforcing the terms of this Stipulated

18

Protective Order, even if such enforcement proceedings occur after termination of this

19

action. I hereby appoint ________________________________ [print or type full name]

20

of ________________________________ [print or type full address and telephone

21

number] as my California agent for service of process in connection with this action or

22

any proceedings related to enforcement of this Stipulated Protective Order.

23
24

Date: __________________________________

25

City and State where sworn and signed: ____________________________________

26

Printed name: _______________________________________

27

Signature:

_________________________________________

28
-1430900097

Stipulated Protective Order