De Los Santos et al v. Los Angeles County Sheriff's Department et al

Filing 19

STIPULATED PROTECTIVE ORDER by Magistrate Judge John E. McDermott re Stipulation for Protective Order 18 . See Order for details. (es)

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1 Thomas C. Hurrell, State Bar No. 119876
E-Mail: [e-mail]
2 Diane Martinez, State Bar No. 276499
E-Mail: [e-mail]
3 Jordan S. Stern, State Bar No. 311527
E-Mail: [e-mail]
4 HURRELL CANTRALL LLP
300 South Grand Avenue, Suite 1300
5 Los Angeles, California 90071
Telephone: [phone]
6 Facsimile: [phone]
7 Attorneys for Defendants, LOS ANGELES COUNTY SHERIFF’S
DEPARTMENT, LOS ANGELES COUNTY FIRE DEPARTMENT, COUNTY OF
8 LOS ANGELES (erroneously sued and served as The Los Angeles County),
ERASTO GRANADOS and DANIEL VELASCO
9
10

UNITED STATES DISTRICT COURT

11

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

12
13 MIGUEL DE LOS SANTOS, an
individual, CIELO ZAVALA
14 ESQUIVEL, an individual,
v.

16
18
19
20
21
22

DISCOVERY MATTER

Plaintiffs,

15
17

CASE NO. 2:22-cv-04302 SVW(JEMx)

LOS ANGELES COUNTY
SHERIFF’S DEPARTMENT, a Public
Agency, LOS ANGELES COUNTY
FIRE DEPARTMENT, a Public
Agency, THE LOS ANGELES
COUNTY, a Public Entity, ERASTO
GRANADOS, an individual, DANIEL
VELASCO, an individual, and DOES
1-20, inclusive,

23

Hon. John E. McDermott, Courtroom
640
XXXXXXXX
[PROPOSED] STIPULATED
PROTECTIVE ORDER
[Assigned to Hon. Stephen V. Wilson
Courtroom “10A”]

Defendants.

24 I.

PURPOSES AND LIMITATIONS

25

As the parties have represented that discovery in this action is likely to

26 involve production of confidential or private information for which special
27 protection from public disclosure and from use for any purpose other than
28 prosecuting this litigation may be warranted, this Court enters the following

1 Protective Order. This Order does not confer blanket protections on all disclosures
2 or responses to discovery. The protection it affords from public disclosure and use
3 extends only to the limited information or items that are entitled to confidential
4 treatment under the applicable legal principles. Further, as set forth in Section 13.3,
5 below, this Protective Order does not entitle the parties to file confidential
6 information under seal. Rather, when the parties seek permission from the court to
7 file material under seal, the parties must comply with Civil Local Rule 79-5 and
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8 with any pertinent orders of District Judge Stephen V. Wilson. and Magistrate Judge
9 John E. McDermott.
10

If any material disclosed or obtained in the course of the instant litigation is

11 intended to be used for any purpose other than prosecuting this litigation, the party
12 seeking public disclosure or dissemination of such materials must first seek approval
13 from the Court.
14 II.

GOOD CAUSE STATEMENT

15

This action is likely to involve confidential information pertaining to

16 personnel records and other materials subject to privacy protections for which
17 special protection from public disclosure and from use for any purpose other than
18 prosecution of this action is warranted. Limiting disclosure of these documents to
19 the context of this litigation as provided herein will, accordingly, further important
20 law enforcement objections and interests, including the safety of personnel and the
21 public, as well as individual privacy rights of plaintiffs, the individual defendants,
22 and third parties. Such confidential materials and information consist of, among
23 other things, materials entitled to privileges and/or protections under the following:
24 United States Constitution, First Amendment; the California Constitution, Article I,
25 Section 1; California Penal Code §§ 832.5, 832.7 and 832.8; California Evidence
26 Code §§ 1040 and 1043 et. seq; the Privacy Act of 1974, 5 U.S.C. § 552; Health
27 Insurance Portability and Accountability Act of 1996 (HIPPA); the right to privacy;
28 decisional law relating to such provisions; and information otherwise generally
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1 unavailable to the public, or which may be privileged or otherwise protected from
2 disclosure under state or federal statutes, court rules, case decisions, or common
3 law. Defendants also contend that such confidential materials and information
4 consist of materials entitled to the Official Information Privilege.
5

Confidential information with respect to the Defendants may include, but is

6 not limited to: personnel files; internal investigative files and documents; email and
7 written correspondence records; and policies and procedures that are kept from the
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8 public in the ordinary course of business, as well as other information that is not
9 generally available to the public and is subject to the Official Information Privilege
10 and other privileges. Confidential information with financial records; email and
11 written correspondence records; video footage and/or photographs of the incident;
12 and psychological and medical notes, evaluations, reports, and treatment plans.
13

Testimony taken at a deposition may be designated as Confidential by making

14 a statement to that effect on the record at the deposition. Arrangements shall be
15 made with the court reporter transcribing the deposition to separately bind such
16 portions of the transcript containing information designated as Confidential, and to
17 label such portions appropriately. Confidential photographs, video or audio footage
18 obtained through the course of discovery or otherwise may not be used for any
19 purpose other than litigating this lawsuit. The parties agree to refrain from directly
20 or indirectly disclosing or publicly disseminating confidential deposition testimony,
21 and/or photographs, video or audio footage obtained through the course of discovery
22 or otherwise, specifically including, but not limited to, dissemination via billboard
23 advertisements, print and online media organizations, or any other internet posting
24 or social media. If any party intends to use such confidential materials for any
25 purpose other than litigating this lawsuit, the party seeking public disclosure must
26 first seek approval from the Court.
27

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

28 representations that discovery in this case will involve the production of confidential
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1 records, and in order to expedite the flow of information, to facilitate the prompt
2 resolution of disputes over confidentiality of discovery materials, to adequately
3 protect information the parties are entitled to keep confidential, to ensure that the
4 parties are permitted reasonable necessary uses of such material in connection with
5 this action, to address their handling of such material at the end of the litigation, and
6 to serve the ends of justice, a protective order for such information is justified in this
7 matter. The parties shall not designate any information/documents as confidential
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8 without a good faith belief that such information/documents have been maintained
9 in a confidential, non-public manner, and that there is good cause or a compelling
10 reason why it should not be part of the public record of this case.
11 III.

DEFINITIONS

12

3.1.

Action:

The instant action: Miguel De Los Santos, et al. v. Los

13 Angeles County Sheriff’s Dept., et al., Case No. 2:22-cv-04302-SVW (JEMx)
14

3.2.

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

15 designation of information or items under this Order.
16

3.3.

“CONFIDENTIAL” Information or Items: information (regardless of

17 how it is generated, stored or maintained) or tangible things that qualify for
18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
19 the Good Cause Statement.
20

3.4.

Counsel: Outside Counsel of Record and House Counsel (as well as

21 their support staff).
22

3.5.

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

23 items that it produces in disclosures or in responses to discovery as
24 “CONFIDENTIAL.”
25

3.6.

Disclosure or Discovery Material: all items or information, regardless

26 of the medium or manner in which it is generated, stored, or maintained (including,
27 among other things, testimony, transcripts, and tangible things), that are produced or
28 generated in disclosures or responses to discovery in this matter.
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1

3.7.

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

2 pertinent to the litigation who has been retained by a Party or its counsel to serve as
3 an expert witness or as a consultant in this Action.
4

3.8.

House Counsel: attorneys who are employees of a party to this Action.

5 House Counsel does not include Outside Counsel of Record or any other outside
6 counsel.
7

3.9.

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

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

3.10. Outside Counsel of Record: attorneys who are not employees of a

10 party to this Action but are retained to represent or advise a party to this Action and
11 have appeared in this Action on behalf of that party or are affiliated with a law firm
12 which has appeared on behalf of that party, and includes support staff.
13

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

14 employees, consultants, retained experts, and Outside Counsel of Record (and their
15 support staffs).
16

3.12. Producing Party: a Party or Non-Party that produces Disclosure or

17 Discovery Material in this Action.
18

3.13. Professional Vendors:

persons or entities that provide litigation

19 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
20 demonstrations, and organizing, storing, or retrieving data in any form or medium)
21 and their employees and subcontractors.
22

3.14. Protected Material:

any Disclosure or Discovery Material that is

23 designated as “CONFIDENTIAL.”
24

3.15. Receiving Party: a Party that receives Disclosure or Discovery

25 Material from a Producing Party.
26 / / /
27 / / /
28 IV.

SCOPE
-5-

1

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

2 defined above), but also (1) any information copied or extracted from Protected
3 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;
4 and (3) any deposition testimony, conversations, or presentations by Parties or their
5 Counsel that reveal Protected Material, other than during a court hearing or at trial.
6

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

7 governed by the orders of the presiding judge. This Order does not govern the use
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8 of Protected Material during a court hearing or at trial.
9 V.
10

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

11 imposed by this Order shall remain in effect until a Designating Party agrees
12 otherwise in writing or a court order otherwise directs. Final disposition shall be
13 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
14 or without prejudice; and (2) final judgment herein after the completion and
15 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
16 including the time limits for filing any motions or applications for extension of time
17 pursuant to applicable law.
18 VI.

DESIGNATING PROTECTED MATERIAL

19

6.1

Exercise of Restraint and Care in Designating Material for Protection.

20 Each Party or Non-Party that designates information or items for protection under
21 this Order must take care to limit any such designation to specific material that
22 qualifies under the appropriate standards. The Designating Party must designate for
23 protection only those parts of material, documents, items, or oral or written
24 communications that qualify so that other portions of the material, documents,
25 items, or communications for which protection is not warranted are not swept
26 unjustifiably within the ambit of this Order.
27

Mass, indiscriminate, or routinized designations are prohibited. Designations

28 that are shown to be clearly unjustified or that have been made for an improper
-6-

1 purpose (e.g., to unnecessarily encumber the case development process or to impose
2 unnecessary expenses and burdens on other parties) may expose the Designating
3 Party to sanctions.
4

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

5 designated for protection do not qualify for protection, that Designating Party must
6 promptly notify all other Parties that it is withdrawing the inapplicable designation.
7

6.2

Manner and Timing of Designations. Except as otherwise provided in

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8 this Order (see, e.g., second paragraph of Section 6.2(a) below), or as otherwise
9 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
10 under this Order must be clearly so designated before the material is disclosed or
11 produced.
12

Designation in conformity with this Order requires:

13

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

14 but excluding transcripts of depositions), that the Producing Party affix at a
15 minimum, the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”),
16 to each page that contains protected material. If only a portion or portions of the
17 material on a page qualifies for protection, the Producing Party also must clearly
18 identify the protected portion(s) (e.g., by making appropriate markings in the
19 margins).
20

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

21 need not designate them for protection until after the inspecting Party has indicated
22 which documents it would like copied and produced. During the inspection and
23 before the designation, all of the material made available for inspection shall be
24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
25 documents it wants copied and produced, the Producing Party must determine which
26 documents, or portions thereof, qualify for protection under this Order. Then, before
27 producing the specified documents, the Producing Party must affix the
28 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
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1 portion or portions of the material on a page qualifies for protection, the Producing
2 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
3 markings in the margins).
4

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

5 the record, before the close of the deposition as protected testimony. Confidential
6 photographs, video or audio footage taken at a deposition may not be used for any
7 purpose other than litigating this lawsuit. The parties agree to refrain from directly
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8 or indirectly disclosing or publicly disseminating confidential deposition testimony,
9 and/or photographs, video or audio footage obtained through the course of discovery
10 or otherwise, specifically including, but not limited to, print and online media
11 organizations, or any other internet posting or social media. If any party intends to
12 use such materials for any purpose other than litigating this lawsuit, the party
13 seeking public disclosure must first seek approval from the Court.
14

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

15 any other tangible items, that the Producing Party affix in a prominent place on the
16 exterior of the container or containers in which the information is stored the legend
17 “CONFIDENTIAL.” If only a portion or portions of the information warrants
18 protection, the Producing Party, to the extent practicable, shall identify the protected
19 portion(s).
20

(d)

The legend “CONFIDENTIAL” shall be affixed to documents and

21 other tangible items in a manner that does not obscure the information contained
22 thereon.
23

6.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

24 failure to designate qualified information or items does not, standing alone, waive
25 the Designating Party’s right to secure protection under this Order for such material.
26 Upon timely correction of a designation, the Receiving Party must make reasonable
27 efforts to assure that the material is treated in accordance with the provisions of this
28 Order.
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1 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2

7.1

Timing of Challenges.

Any Party or Non-Party may challenge a

3 designation of confidentiality at any time that is consistent with the Court’s
4 Scheduling Order.
5

7.2

Meet and Confer. The Challenging Party shall initiate the dispute

6 resolution process under Local Rule 37-1 et seq.
7

7.3

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

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

8.1

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

17 disclosed or produced by another Party or by a Non-Party in connection with this
18 Action only for prosecuting, defending, or attempting to settle this Action. Such
19 Protected Material may be disclosed only to the categories of persons and under the
20 conditions described in this Order. When the Action has been terminated, a
21 Receiving Party must comply with the provisions of Section 14 below.
22

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

23 location and in a secure manner that ensures that access is limited to the persons
24 authorized under this Order.
25

8.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

Party

may

disclose

any

28 “CONFIDENTIAL” only to:
-9-

information

or

item

designated

1

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

2 as employees of said Outside Counsel of Record to whom it is reasonably necessary
3 to disclose the information for this Action;
4

(b) the officers, directors, and employees (including House Counsel) of the

5 Receiving Party to whom disclosure is reasonably necessary for this Action;
6

(c)

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

7 disclosure is reasonably necessary for this Action and who have signed the
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8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9

(d) the court and its personnel;

10

(e) court reporters and their staff;

11

(f)

professional jury or trial consultants, mock jurors, and Professional

12 Vendors to whom disclosure is reasonably necessary for this Action and who have
13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14

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

15 custodian or other person who otherwise possessed or knew the information;
16

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

17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
18 requests that the witness sign the “Acknowledgment and Agreement to Be Bound”
19 form attached as Exhibit A hereto; and (2) they will not be permitted to keep any
20 confidential information unless they sign the “Acknowledgment and Agreement to
21 Be Bound” attached as Exhibit A, unless otherwise agreed by the Designating Party
22 or ordered by the court. Pages of transcribed deposition testimony or exhibits to
23 depositions that reveal Protected Material may be separately bound by the court
24 reporter and may not be disclosed to anyone except as permitted under this
25 Protective Order; and
26

(i)

any mediator or settlement officer, and their supporting personnel,

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

PROTECTED

MATERIAL

SUBPOENAED
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OR

ORDERED

1

PRODUCED IN OTHER LITIGATION

2

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

3 that compels disclosure of any information or items designated in this Action as
4 “CONFIDENTIAL,” that Party must:
5

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

6 include a copy of the subpoena or court order unless prohibited by law;
7

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

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8 issue in the other litigation that some or all of the material covered by the subpoena
9 or order is subject to this Protective Order. Such notification shall include a copy of
10 this Protective Order; and
11

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

12 by the Designating Party whose Protected Material may be affected.
13

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

14 the subpoena or court order shall not produce any information designated in this
15 action as “CONFIDENTIAL” before a determination by the court from which the
16 subpoena or order issued, unless the Party has obtained the Designating Party’s
17 permission, or unless otherwise required by the law or court order. The Designating
18 Party shall bear the burden and expense of seeking protection in that court of its
19 confidential material and nothing in these provisions should be construed as
20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
21 directive from another court.
22 X.

A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE

23

PRODUCED IN THIS LITIGATION

24

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

25 Party in this Action and designated as “CONFIDENTIAL.”

Such information

26 produced by Non-Parties in connection with this litigation is protected by the
27 remedies and relief provided by this Order. Nothing in these provisions should be
28 construed as prohibiting a Non-Party from seeking additional protections.
-11-

1

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

2 produce a Non-Party’s confidential information in its possession, and the Party is
3 subject to an agreement with the Non-Party not to produce the Non-Party’s
4 confidential information, then the Party shall:
5

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

6 some or all of the information requested is subject to a confidentiality agreement
7 with a Non-Party;
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8

(2) promptly provide the Non-Party with a copy of the Protective Order in

9 this Action, the relevant discovery request(s), and a reasonably specific description
10 of the information requested; and
11

(3) make the information requested available for inspection by the Non-

12 Party, if requested.
13

(c) If a Non-Party represented by counsel fails to commence the process

14 called for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving the
15 notice and accompanying information or fails contemporaneously to notify the
16 Receiving Party that it has done so, the Receiving Party may produce the Non17 Party’s confidential information responsive to the discovery request.

If an

18 unrepresented Non-Party fails to seek a protective order from this court within 14
19 days of receiving the notice and accompanying information, the Receiving Party
20 may produce the Non-Party’s confidential information responsive to the discovery
21 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
22 not produce any information in its possession or control that is subject to the
23 confidentiality agreement with the Non-Party before a determination by the court
24 unless otherwise required by the law or court order. Absent a court order to the
25 contrary, the Non-Party shall bear the burden and expense of seeking protection in
26 this court of its Protected Material.
27 / / /
28 XI.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
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1

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

2 Protected Material to any person or in any circumstance not authorized under this
3 Protective Order, the Receiving Party must immediately (a) notify in writing the
4 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
5 all unauthorized copies of the Protected Material, (c) inform the person or persons to
6 whom unauthorized disclosures were made of all the terms of this Order, and (d)
7 request such person or persons to execute the “Acknowledgment and Agreement to
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8 Be Bound” that is attached hereto as Exhibit A.
9 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
10

PROTECTED MATERIAL

11

When a Producing Party gives notice to Receiving Parties that certain

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

13.1 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

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

24 otherwise would have to object to disclosing or producing any information or item
25 on any ground not addressed in this Protective Order. Similarly, no Party waives
26 any right to object on any ground to use in evidence of any of the material covered
27 by this Protective Order.
28

13.3 Filing Protected Material. A Party that seeks to file under seal any
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1 Protected Material must comply with Civil Local Rule 79-5 and with any pertinent
2 orders of the assigned District Judge and Magistrate Judge. If a Party's request to
3 file Protected Material under seal is denied by the court, then the Receiving Party
4 may file the information in the public record unless otherwise instructed by the
5 court.
6 XIV. FINAL DISPOSITION
7

After the final disposition of this Action, as defined in Section 5, within 60

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8 days of a written request by the Designating Party, each Receiving Party must return
9 all Protected Material to the Producing Party or destroy such material. As used in
10 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
11 summaries, and any other format reproducing or capturing any of the Protected
12 Material. Whether the Protected Material is returned or destroyed, the Receiving
13 Party must submit a written certification to the Producing Party (and, if not the same
14 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
15 (by category, where appropriate) all the Protected Material that was returned or
16 destroyed and (2) affirms that the Receiving Party has not retained any copies,
17 abstracts, compilations, summaries or any other format reproducing or capturing any
18 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
19 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
20 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
21 reports, attorney work product, and consultant and expert work product, even if such
22 materials contain Protected Material. Any such archival copies that contain or
23 constitute Protected Material remain subject to this Protective Order as set forth in
24 Section 5.
25 / / /
26 / / /
27 / / /
28 / / /
-14-

/s/ Jordan S. Stern

8/2/22

8/2/22

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 Protective Order that was issued
7 by the United States District Court for the Central District of California on
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8 _________________________ in the case of Miguel De Los Santos, et al. v. Los
9 Angeles County Sheriff’s Dept., et al., Case No. 2:22-cv-04302-SVW (JEMx). I
10 agree to comply with and to be bound by all the terms of this Protective Order and I
11 understand and acknowledge that failure to so comply could expose me to sanctions
12 and punishment in the nature of contempt. I solemnly promise that I will not
13 disclose in any manner any information or item that is subject to this Protective
14 Order to any person or entity except in strict compliance with the provisions of this
15 Order.
16

I further agree to submit to the jurisdiction of the United States District Court

17 for the Central District of California for the purpose of enforcing the terms of this
18 Protective Order, even if such enforcement proceedings occur after termination of
19 this action. I hereby appoint __________________________ [print or type full
20 name] of _______________________________________ [print or type full address
21 and telephone number] as my California agent for service of process in connection
22 with this action or any proceedings related to enforcement of this Protective Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27
28 Signature: _

_________________________________
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