Shahrooz Sabzehroo v. Capital One Bank (USA), N.A.

Filing 32

STIPULATED PROTECTIVE ORDER by Magistrate Judge Gail J. Standish re Stipulation for Protective Order 31 . (efc)

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1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 CASE NO. 2:20-cv-10615-FMO-GJS SHAHROOZ SABZEHROO, individually and on behalf of all others similarly situated, 12 13 [PROPOSED] STIPULATED PROTECTIVE ORDER1 Plaintiff, 14 15 vs. 16 CAPITAL ONE BANK (USA), N.A. and DOES 1 through 10 inclusive, 17 18 Defendants. 19 20 21 22 23 24 25 26 27 28 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Gail J. Standish’s Procedures. 1 1 1 Plaintiff Shahrooz Sabzehroo (“Plaintiff”) and Defendant Capital One Bank 2 (USA), N.A. (“Defendant”) (collectively, the “Parties”), in order to facilitate the 3 exchange of information and documents that may be subject to confidentiality 4 limitations on disclosure due to federal laws, state laws, and privacy rights, and in 5 order to secure the entry of a protective order limiting the review, copying, 6 dissemination and filing of confidential and/or proprietary documents and 7 information to be produced by the Parties and their respective counsel or by any non- 8 party in the course of discovery in this matter to the extent set forth below, through 9 their respective counsel of record, hereby provide the following Stipulated Protective 10 Order as follows: 11 1. A. PURPOSES AND LIMITATIONS 12 Discovery in this action is likely to involve production of confidential, 13 proprietary or private information for which special protection from public disclosure 14 and from use for any purpose other than prosecuting this litigation may be warranted. 15 Accordingly, the parties hereby stipulate to and petition the Court to enter the 16 following Stipulated Protective Order. The parties acknowledge that this Order does 17 not confer blanket protections on all disclosures or responses to discovery and that 18 the protection it affords from public disclosure and use extends only to the limited 19 information or items that are entitled to confidential treatment under the applicable 20 legal principles. 21 B. GOOD CAUSE STATEMENT 22 This action is likely to involve Defendant’s confidential account records, which 23 include Plaintiff’s non-public personally identifiable information, proprietary system 24 notes and other valuable commercial, financial, technical and/or trade secret 25 information for which special protection from public disclosure and from use for any 26 purpose other than prosecution of this action is warranted. Such confidential and 27 proprietary materials and information consist of, among other things, confidential 28 2 1 business or financial information, information regarding confidential business 2 practices or commercial information (including information implicating privacy 3 rights of third parties), information otherwise generally unavailable to the public, or 4 which may be privileged or otherwise protected from disclosure under state or federal 5 statutes, court rules, case decisions, or common law. Accordingly, to expedite the 6 flow of information, to facilitate the prompt resolution of disputes over confidentiality 7 of discovery materials, to adequately protect information the parties are entitled to 8 keep confidential, to ensure that the parties are permitted reasonable necessary uses 9 of such material in preparation for and in the conduct of trial, to address their handling 10 at the end of the litigation, and serve the ends of justice, a protective order for such 11 information is justified in this matter. It is the intent of the parties that information 12 will not be designated as confidential for tactical reasons and that nothing be so 13 designated without a good faith belief that it has been maintained in a confidential, 14 non-public manner, and there is good cause why it should not be part of the public 15 record of this case. 16 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 17 The parties further acknowledge, as set forth in Section 12.3, below, that this 18 Stipulated Protective Order does not entitle them to file confidential information 19 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 20 the standards that will be applied when a party seeks permission from the court to file 21 material under seal. 22 There is a strong presumption that the public has a right of access to judicial 23 proceedings and records in civil cases. In connection with non-dispositive motions, 24 good cause must be shown to support a filing under seal. See Kamakana v. City and 25 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 26 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 27 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 28 3 1 cause showing), and a specific showing of good cause or compelling reasons with 2 proper evidentiary support and legal justification, must be made with respect to 3 Protected Material that a party seeks to file under seal. The parties’ mere designation 4 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 5 submission of competent evidence by declaration, establishing that the material 6 sought to be filed under seal qualifies as confidential, privileged, or otherwise 7 protectable—constitute good cause. 8 Further, if a party requests sealing related to a dispositive motion or trial, then 9 compelling reasons, not only good cause, for the sealing must be shown, and the relief 10 sought shall be narrowly tailored to serve the specific interest to be protected. See 11 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each 12 item or type of information, document, or thing sought to be filed or introduced under 13 seal in connection with a dispositive motion or trial, the party seeking protection must 14 articulate compelling reasons, supported by specific facts and legal justification, for 15 the requested sealing order. Again, competent evidence supporting the application to 16 file documents under seal must be provided by declaration. 17 Any document that is not confidential, privileged, or otherwise protectable in 18 its entirety will not be filed under seal if the confidential portions can be redacted. If 19 documents can be redacted, then a redacted version for public viewing, omitting only 20 the confidential, privileged, or otherwise protectable portions of the document, shall 21 be filed. Any application that seeks to file documents under seal in their entirety 22 should include an explanation of why redaction is not feasible. 23 2. 24 DEFINITIONS 2.1 Action: this pending federal lawsuit in the United States District Court 25 for the Central District of California titled Shahrooz Sabzehroo v. Capital One Bank 26 (USA), N.A., Case No. 2:20-cv-10615-FMO-GJS. 27 2.2 Challenging Party: a Party or Non-Party that challenges the designation 28 4 1 2 of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 3 how it is generated, stored or maintained) or tangible things that qualify for protection 4 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 5 Cause Statement. 6 7 8 9 10 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.5 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 Disclosure or Discovery Material: all items or information, regardless 12 of the medium or manner in which it is generated, stored, or maintained (including, 13 among other things, testimony, transcripts, and tangible things), that are produced or 14 generated in disclosures or responses to discovery in this matter. 15 2.7 Expert: a person with specialized knowledge or experience in a matter 16 pertinent to the litigation who has been retained by a Party or its counsel to serve as 17 an expert witness or as a consultant in this Action. 18 2.8 House Counsel: attorneys who are employees of a party to this Action. 19 House Counsel does not include Outside Counsel of Record or any other outside 20 counsel. 21 22 2.9 Non-Party: any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. 23 2.10 Outside Counsel of Record: attorneys who are not employees of a party 24 to this Action but are retained to represent or advise a party to this Action and have 25 appeared in this Action on behalf of that party or are affiliated with a law firm that 26 has appeared on behalf of that party, and includes support staff. 27 2.11 Party: any party to this Action, including all of its officers, directors, 28 5 1 employees, consultants, retained experts, and Outside Counsel of Record (and their 2 support staffs). 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 3 4 Discovery Material in this Action. 5 2.13 Professional Vendors: persons or entities that provide litigation support 6 services (e.g., photocopying, videotaping, translating, preparing exhibits or 7 demonstrations, and organizing, storing, or retrieving data in any form or medium) 8 and their employees and subcontractors. 9 2.14 Protected Material: 10 designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 11 12 13 from a Producing Party. 3. SCOPE The protections conferred by this Stipulation and Order cover not only 14 15 16 17 18 Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the 19 20 21 22 23 24 25 26 27 28 any Disclosure or Discovery Material that is trial judge. This Order does not govern the use of Protected Material at trial. 4. DURATION FINAL DISPOSITION of the action is defined as the conclusion of any appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal has run. Except as set forth below, the terms of this protective order apply through FINAL DISPOSITION of the action. The parties may stipulate that they will be contractually bound by the terms of this agreement beyond FINAL DISPOSITION, but will have to file a separate action for enforcement of the agreement once all proceedings in this case are complete. 6 1 Once a case proceeds to trial, information that was designated as 2 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 3 as an exhibit at trial becomes public and will be presumptively available to all 4 members of the public, including the press, unless compelling reasons supported by 5 specific factual findings to proceed otherwise are made to the trial judge in advance 6 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 7 showing for sealing documents produced in discovery from “compelling reasons” 8 standard when merits-related documents are part of court record). Accordingly, for 9 such materials, the terms of this protective order do not extend beyond the 10 commencement of the trial. 11 5. 12 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 13 Each Party or Non-Party that designates information or items for protection under this 14 Order must take care to limit any such designation to specific material that qualifies 15 under the appropriate standards. The Designating Party must designate for protection 16 only those parts of material, documents, items or oral or written communications that 17 qualify so that other portions of the material, documents, items or communications 18 for which protection is not warranted are not swept unjustifiably within the ambit of 19 this Order. 20 Mass, indiscriminate or routinized designations are prohibited. Designations 21 that are shown to be clearly unjustified or that have been made for an improper 22 purpose (e.g., to unnecessarily encumber the case development process or to impose 23 unnecessary expenses and burdens on other parties) may expose the Designating Party 24 to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 26 designated for protection do not qualify for protection, that Designating Party must 27 promptly notify all other Parties that it is withdrawing the inapplicable designation. 28 7 1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the material is disclosed or 5 produced. 6 7 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix at a minimum, the legend 10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 11 contains protected material. If only a portion of the material on a page qualifies for 12 protection, the Producing Party also must clearly identify the protected portion(s) 13 (e.g., by making appropriate markings in the margins). 14 A Party or Non-Party that makes original documents available for inspection 15 need not designate them for protection until after the inspecting Party has indicated 16 which documents it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for inspection shall be 18 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 19 it wants copied and produced, the Producing Party must determine which documents, 20 or portions thereof, qualify for protection under this Order. Then, before producing 21 the specified documents, the Producing Party must affix the “CONFIDENTIAL” 22 legend to each page that contains Protected Material. If only a portion of the material 23 on a page qualifies for protection, the Producing Party also must clearly identify the 24 protected portion(s) (e.g., by making appropriate markings in the margins). 25 (b) for testimony given in depositions that the Designating Party identifies 26 the Disclosure or Discovery Material on the record, before the close of the deposition 27 all protected testimony. 28 8 1 (c) for information produced in some form other than documentary and for 2 any other tangible items, that the Producing Party affix in a prominent place on the 3 exterior of the container or containers in which the information is stored the legend 4 “CONFIDENTIAL.” If only a portion or portions of the information warrants 5 protection, the Producing Party, to the extent practicable, shall identify the protected 6 portion(s). 5.3 7 Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 failure to designate qualified information or items does not, standing alone, waive the 9 Designating Party’s right to secure protection under this Order for such material. 10 Upon timely correction of a designation, the Receiving Party must make reasonable 11 efforts to assure that the material is treated in accordance with the provisions of this 12 Order. 13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 14 Timing of Challenges. Any Party or Non-Party may challenge a 15 designation of confidentiality at any time that is consistent with the Court’s 16 Scheduling Order. 6.2 17 18 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 6.3 19 The burden of persuasion in any such challenge proceeding shall be on 20 the Designating Party. Frivolous challenges, and those made for an improper purpose 21 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 22 expose the Challenging Party to sanctions. Unless the Designating Party has waived 23 or withdrawn the confidentiality designation, all parties shall continue to afford the 24 material in question the level of protection to which it is entitled under the Producing 25 Party’s designation until the Court rules on the challenge. 26 7. 27 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 28 9 1 disclosed or produced by another Party or by a Non-Party in connection with this 2 Action only for prosecuting, defending or attempting to settle this Action. Such 3 Protected Material may be disclosed only to the categories of persons and under the 4 conditions described in this Order. When the Action has been terminated, a Receiving 5 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 6 Protected Material must be stored and maintained by a Receiving Party at a 7 location and in a secure manner that ensures that access is limited to the persons 8 authorized under this Order. 9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 10 otherwise ordered by the court or permitted in writing by the Designating Party, a 11 Receiving 12 “CONFIDENTIAL” only to: Party may disclose any information or item designated 13 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 14 as employees of said Outside Counsel of Record to whom it is reasonably necessary 15 to disclose the information for this Action; 16 17 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; 18 (c) Experts (as defined in this Order) of the Receiving Party to whom 19 disclosure is reasonably necessary for this Action and who have signed the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (d) the court and its personnel; 22 (e) court reporters and their staff; 23 (f) professional jury or trial consultants, mock jurors, and Professional 24 Vendors to whom disclosure is reasonably necessary for this Action and who have 25 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 27 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 28 10 1 (h) during their depositions, witnesses, and attorneys for witnesses, in the 2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 3 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 4 not be permitted to keep any confidential information unless they sign the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 6 agreed by the Designating Party or ordered by the court. Pages of transcribed 7 deposition testimony or exhibits to depositions that reveal Protected Material may be 8 separately bound by the court reporter and may not be disclosed to anyone except as 9 permitted under this Stipulated Protective Order; and (i) any mediator or settlement officer, and their supporting personnel, 10 11 mutually agreed upon by any of the parties engaged in settlement discussions. 12 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 13 OTHER LITIGATION 14 If a Party is served with a subpoena or a court order issued in other litigation 15 that compels disclosure of any information or items designated in this Action as 16 “CONFIDENTIAL,” that Party must: 17 18 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 19 (b) promptly notify in writing the party who caused the subpoena or order 20 to issue in the other litigation that some or all of the material covered by the subpoena 21 or order is subject to this Protective Order. Such notification shall include a copy of 22 this Stipulated Protective Order; and 23 24 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 25 If the Designating Party timely seeks a protective order, the Party served with 26 the subpoena or court order shall not produce any information designated in this action 27 as “CONFIDENTIAL” before a determination by the court from which the subpoena 28 11 1 or order issued, unless the Party has obtained the Designating Party’s permission. The 2 Designating Party shall bear the burden and expense of seeking protection in that court 3 of its confidential material and nothing in these provisions should be construed as 4 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 5 directive from another court. 6 9. 7 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 8 (a) The terms of this Order are applicable to information produced by a 9 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 10 produced by Non-Parties in connection with this litigation is protected by the 11 remedies and relief provided by this Order. Nothing in these provisions should be 12 construed as prohibiting a Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party’s confidential information in its possession, and the Party is 15 subject to an agreement with the Non-Party not to produce the Non-Party’s 16 confidential information, then the Party shall: 17 (1) promptly notify in writing the Requesting Party and the Non-Party 18 that some or all of the information requested is subject to a confidentiality agreement 19 with a Non-Party; 20 (2) promptly provide the Non-Party with a copy of the Stipulated 21 Protective Order in this Action, the relevant discovery request(s), and a reasonably 22 specific description of the information requested; and 23 24 (3) make the information requested available for inspection by the NonParty, if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 26 14 days of receiving the notice and accompanying information, the Receiving Party 27 may produce the Non-Party’s confidential information responsive to the discovery 28 12 1 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 2 not produce any information in its possession or control that is subject to the 3 confidentiality agreement with the Non-Party before a determination by the court. 4 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 5 of seeking protection in this court of its Protected Material. 6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 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 10 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 11 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 12 persons to whom unauthorized disclosures were made of all the terms of this Order, 13 and (d) request such person or persons to execute the “Acknowledgment and 14 Agreement to Be Bound” that is attached hereto as Exhibit A. 15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 21 may be established in an e-discovery order that provides for production without prior 22 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 23 parties reach an agreement on the effect of disclosure of a communication or 24 information covered by the attorney-client privilege or work product protection, the 25 parties may incorporate their agreement in the stipulated protective order submitted 26 to the court. 27 28 13 1 12. 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 2 3 MISCELLANEOUS person to seek its modification by the Court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order, no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 ground to use in evidence of any of the material covered by this Protective Order. 9 12.3 Filing Protected Material. A Party that seeks to file under seal any 10 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 11 only be filed under seal pursuant to a court order authorizing the sealing of the specific 12 Protected Material at issue. If a Party’s request to file Protected Material under seal 13 is denied by the court, then the Receiving Party may file the information in the public 14 record unless otherwise instructed by the court. 15 13. FINAL DISPOSITION 16 After the final disposition of this Action, as defined in paragraph 4, within 60 17 days of a written request by the Designating Party, each Receiving Party must return 18 all Protected Material to the Producing Party or destroy such material. As used in this 19 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 20 summaries, and any other format reproducing or capturing any of the Protected 21 Material. Whether the Protected Material is returned or destroyed, the Receiving 22 Party must submit a written certification to the Producing Party (and, if not the same 23 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 24 (by category, where appropriate) all the Protected Material that was returned or 25 destroyed and (2) affirms that the Receiving Party has not retained any copies, 26 abstracts, compilations, summaries or any other format reproducing or capturing any 27 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 28 14 1 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 2 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 3 reports, attorney work product, and consultant and expert work product, even if such 4 materials contain Protected Material. Any such archival copies that contain or 5 constitute Protected Material remain subject to this Protective Order as set forth in 6 Section 4 (DURATION) 7 14. 8 Any violation of this Order may be punished by appropriate measures including, 9 without limitation, contempt proceedings and/or monetary sanctions. 10 /// 11 /// 12 /// 13 /// 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 VIOLATION /// 28 15 1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 4 DATED: July 14, 2021 THE LAW OFFICES OF AMIR J. GOLDSTEIN, ESQ. 5 6 7 8 /s/ Amir J. Goldstein Amir J. Goldstein Attorneys for Plaintiff Shahrooz Sabzehroo 9 10 11 12 DATED: July 14, 2021 MCGUIREWOODS LLP 13 14 15 16 17 18 19 /s/ Deleyla A. Lawrence Bryan A. Fratkin Seth A. Schaeffer Deleyla A. Lawrence Attorneys for Defendant Capital One Bank (USA), N.A. FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 21 DATED: ____July 16, 2021______________ 22 23 24 25 26 27 _____________________________________ HON. GAIL J. STANDISH United States Magistrate Judge 28 16 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 that 6 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 ___________ in the case of Shahrooz Sabzehroo v. Capital One Bank (USA), N.A., 9 Case No. 2:20-cv-10615-FMO-GJS. I agree to comply with and to be bound by all 10 the terms of this Stipulated Protective Order and I understand and acknowledge that 11 failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 or item that is subject to this Stipulated Protective Order to any person or entity except 14 in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. I hereby 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 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28 17

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