Maria Soto v. Clougherty Packing LLC et al

Filing 20

STIPULATED PROTECTIVE ORDER by Magistrate Judge Jean P. Rosenbluth re Stipulation for Protective Order 19 . (See document for details). (et)

1
2
3
4
5
6
7
8

BOWMAN AND BROOKE LLP
Paul A. Alarcon (SBN: 275036)
[e-mail]
Eleni A. Swank (SBN: 318462)
[e-mail]
Damion M. Young (SBN: 322053)
[e-mail]
970 West 190th Street, Suite 700
Torrance, California 90502
NOTE: CHANGES MADE BY THE COURT
Tel No:
[phone]
Fax No:
[phone]
Attorneys for Defendants
Hoegger Food Technology, Inc., sued and served as Doe 3; and
Provisur Technologies, Inc. sued and served as Doe 2

9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

11
12
13

Plaintiff,

14
15
16
17
18

CASE NO.: 2:23-cv-04665 JFW (JPRx)

MARIA SOTO,

(Removed from Los Angeles County
Superior Court - Case No.
22STCV19273)

vs.
CLOUGHERTY PACKING, LLC AND
DOING BUSINESS AS FARMER JOHN;
DOE MEAT PRESSER MACHINE
MANUFACTURER; DOE MEAT
PRESSER MACHINE MAINTENANCE
COMPANY AND DOES 1-100
INCLUSIVE,

19

DISCOVERY MATTER TO:
Magistrate Judge Jean P. Rosenbluth
STIPULATED PROTECTIVE
ORDER

Defendants.

Action Filed:

20

June 13, 2022

21
22
23
24

1.

INTRODUCTION
1.1

PURPOSES AND LIMITATIONS

25

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

26

proprietary, or private information for which special protection from public

27

disclosure and from use for any purpose other than prosecuting this litigation may be

28

warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
STIPULATED PROTECTIVE ORDER
28778108v1

1

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

the following Stipulated Protective Order. The parties acknowledge that this Order

2

does not confer blanket protections on all disclosures or responses to discovery

3

and that the protection it affords from public disclosure and use extends only to the

4

limited information or items that are entitled to confidential treatment under the

5

applicable legal principles. The parties further acknowledge, as set forth in Section 12.3,

6

below, that this Stipulated Protective Order does not entitle them to file confidential

7

information under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed

8

and the standards that will be applied when a party seeks permission from the court to file

9

material under seal.

10

1.2

11

This action is likely to involve trade secrets and confidential design and

12

manufacturing documents and other valuable research, development, commercial,

13

financial, technical and/or proprietary information for which special protection from public

14

disclosure and from use for any purpose other than prosecution of this action may be

15

warranted. Such confidential and proprietary materials and information may consist of,

16

among other things, confidential business or financial information, information regarding

17

product designs and manufacturing, or other confidential research, development, or

18

commercial information (including information implicating privacy rights of third parties),

19

information otherwise generally unavailable to the public, or which may be privileged or

20

otherwise protected from disclosure under state or federal statutes, court rules, case

21

decisions, or common law. Accordingly, to expedite the flow of information, to facilitate

22

the prompt resolution of disputes over confidentiality of discovery materials, to adequately

23

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

24

are permitted reasonable necessary uses of such material in preparation for and in the

25

conduct of trial, to address their handling at the end of the litigation, and serve the ends of

26

justice, a protective order for such information is justified in this matter. It is the intent of

27

the parties that information will not be designated as confidential for tactical reasons and

28

that nothing be so designated without a good faith belief that it has been maintained in a

GOOD CAUSE STATEMENT

STIPULATED PROTECTIVE ORDER
28778108v1

2

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

confidential, non-public manner, and there is good cause why it should not be part of the

2

public record of this case.

3

2.

4
5
6
7
8

DEFINITIONS
2.1

Action: The pending federal lawsuit captioned above and entitled Maria Soto

vs. Clougherty Packing, LLC, et al., Case No. 2:23-cv-04665.
2.2

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

information or items under this Order.
2.3

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

9

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

10

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

11

Statement.

12
13
14
15
16

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 of the

17

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

18

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

19

disclosures or responses to discovery in this matter.

20

2.7

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

21

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

22

expert witness or as a consultant in this Action.

23

2.8

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

24

affiliate thereof. House Counsel does not include Outside Counsel of Record or any

25

other outside counsel.

26
27
28

2.9

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

legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: attorneys who are not employees of a party to this
STIPULATED PROTECTIVE ORDER
28778108v1

3

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

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

2

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

3

behalf of that party, and includes support staff.

4

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

5

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

6

staffs).

7
8

2.12 Producing Party: a Party or Non-Party that produces Disclosure of
Discovery Material in this Action.

9

2.13 Professional Vendors: persons or entities that provide litigation support

10

services

11

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

12

their employees and subcontractors.

13
14

(e.g.,

photocopying,

videotaping,

translating,

preparing

exhibits

or

2.14 Protected Material: any Disclosure or Discovery Material that is designated
as “CONFIDENTIAL.”

15

2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from

16

a Producing Party.

17

3.

SCOPE

18

The protections conferred by this Stipulation and Order cover not only

19

Protected Material (as defined above), but also (1) any information copied or

20

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

21

Protected Material; and (3) any testimony, conversations, or presentations by Parties

22

or their Counsel that might reveal Protected Material. Any use of Protected Material at

23

trial shall be governed by the orders of the trial judge. This Order does not govern the use

24

of Protected Material at trial.

25

4.

DURATION

26

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

27

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

28

writing or a court order otherwise directs. Final disposition shall be deemed to be the
STIPULATED PROTECTIVE ORDER
28778108v1

4

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

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

2

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

3

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

4

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

5

5.

6

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

7

Each Party or Non-Party that designates information or items for protection

8

under this Order must take care to limit any such designation to specific material that

9

qualifies under the appropriate standards. The Designating Party must designate for

10

protection only those parts of material, documents, items, or oral or written

11

communications that qualify so that other portions of the material, documents, items, or

12

communications for which protection is not warranted are not swept unjustifiably within

13

the ambit of this Order. Mass, indiscriminate, or routinized designations are prohibited.

14

Designations that are shown to be clearly unjustified or that have been made for an

15

improper purpose (e.g., to unnecessarily encumber the case development process or to

16

impose unnecessary expenses and burdens on other parties) may expose the Designating

17

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

18

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

19

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

20

5.2

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

21

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

22

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

23

must be clearly so designated before the material is disclosed or produced.

24

Designation in conformity with this Order requires:

25

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

26

excluding transcripts of depositions or other pretrial or trial proceedings), that the

27

Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

28

“CONFIDENTIAL legend”), to each page that contains protected material. If only a
STIPULATED PROTECTIVE ORDER
28778108v1

5

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

portion or portions of the material on a page qualifies for protection, the Producing Party

2

also must clearly identify the protected portion(s) (e.g., by making appropriate markings in

3

the margins). A Party or Non-Party that makes original documents available for inspection

4

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

5

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

6

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

7

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

8

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

9

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

10

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

11

that contains Protected Material. If only a portion or portions of the material on a page

12

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

13

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

14

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

15

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

16

all protected testimony.

17

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

18

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

19

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

20

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

21

protection, the Producing Party, to the extent practicable, shall identify the protected

22

portion(s).

23

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

24

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

25

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

26

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

27

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

28

6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

STIPULATED PROTECTIVE ORDER
28778108v1

6

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

6.1

Timing of Challenges.

Any Party or Non-Party may challenge a

2

designation of confidentiality at any time that is consistent with the Court’s Scheduling

3

Order.
6.2

4
5

Meet and Confer. The Challenging Party shall initiate the dispute resolution

process under Local Rule 37.1 et seq.
6.3

6

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

7

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

8

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

9

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

10

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

11

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

12

Court rules on the challenge.

13

7.

14

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

A Receiving Party may use Protected Material that is disclosed or produced

15

by another Party or by a Non-Party in connection with this Action only for prosecuting,

16

defending, or attempting to settle this Action. Such Protected Material may be disclosed

17

only to the categories of persons and under the conditions described in this Order. When

18

the Action has been terminated, a Receiving Party must comply with the provisions of

19

section 13 below (FINAL DISPOSITION).

20

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

21

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

22

this Order.

23

7.2

Unless otherwise ordered by the court or permitted in writing by the

24

Designating Party, a Receiving Party may disclose any information or item designated

25

“CONFIDENTIAL” only to:

26

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

27

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

28

disclose the information for this Action;
STIPULATED PROTECTIVE ORDER
28778108v1

7

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1
2

(b) the officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably necessary for this Action;

3

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

4

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

5

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

6

(d) the court and its personnel;

7

(e) court reporters and their staff;

8

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

9

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

10

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

11
12

(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;

13

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

14

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

15

requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not

16

be

17

“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed

18

by the Designating Party or ordered by the court. Pages of transcribed deposition

19

testimony or exhibits to depositions that reveal Protected Material may be separately

20

bound by the court reporter and may not be disclosed to anyone except as permitted under

21

this Stipulated Protective Order; and

permitted

to

keep

any

confidential

information

unless

they

sign

the

22

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

23

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

24

by the Court.

25

8.

26

IN OTHER LITIGATION

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

27

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

28

compels disclosure of any information or items designated in this Action as
STIPULATED PROTECTIVE ORDER
28778108v1

8

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

“CONFIDENTIAL,” that Party must:

2
3

(a) promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order unless prohibited by law;

4

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

5

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

6

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

7

Stipulated Protective Order; and

8

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

9

the Designating Party whose Protected Material may be affected. If the Designating Party

10

timely seeks a protective order, the Party served with the subpoena or court order shall

11

not produce any information designated in this action as “CONFIDENTIAL” before a

12

determination by the court from which the subpoena or order issued, unless the Party

13

has obtained the Designating Party’s permission. The Designating Party shall bear the

14

burden and expense of seeking protection in that court of its confidential material and

15

nothing in these provisions should be construed as authorizing or encouraging a Receiving

16

Party in this Action to disobey a lawful directive from another court.

17

9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

18

PRODUCED IN THIS LITIGATION

19

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

20

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

21

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

22

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

23

Non-Party from seeking additional protections.

24

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

25

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

26

agreement

27

information, then the Party shall:

28

with the

Non-Party not to

produce

the Non-Party’s confidential

(1) promptly notify in writing the Requesting Party and the Non-Party
STIPULATED PROTECTIVE ORDER
28778108v1

9

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

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

2

agreement with a Non-Party;

3

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

4

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

5

specific description of the information requested; and

6
7

(3) make the information requested available for inspection by the NonParty, if requested.

8

(c) If the Non-Party fails to seek a protective order from this court within 14 days

9

of receiving the notice and accompanying information, the Receiving Party may produce

10

the Non-Party’s confidential information responsive to the discovery request. If the Non-

11

Party timely seeks a protective order, the Receiving Party shall not produce any

12

information in its possession or control that is subject to the confidentiality agreement

13

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

14

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

15

court of its Protected Material.

16

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

17

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

18

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

19

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

20

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

21

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

22

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

23

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

24

is attached hereto as Exhibit A.

25

11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

26

PROTECTED MATERIAL

27

When a Producing Party gives notice to Receiving Parties that certain

28

inadvertently produced material is subject to a claim of privilege or other protection, the
STIPULATED PROTECTIVE ORDER
28778108v1

10

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure

2

26(b)(5)(B). This provision is not intended to modify whatever procedure may be

3

established in an e-discovery order that provides for production without prior privilege

4

review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach

5

an agreement on the effect of disclosure of a communication or information covered by

6

the attorney-client privilege or work product protection, the parties may incorporate their

7

agreement in the stipulated protective order submitted to the court provided the Court so

8

allows.

9

12.

10
11

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

to seek its modification by the Court in the future.

12

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

13

Protective Order no Party waives any right it otherwise would have to object to

14

disclosing or producing any information or item on any ground not addressed in this

15

Stipulated Protective Order. Similarly, no Party waives any right to object on any ground

16

to use in evidence of any of the material covered by this Protective Order.

17

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

18

Protected Material must comply with Civil Local Rule 79-5. Protected Material may only

19

be filed under seal pursuant to a court order authorizing the sealing of the specific

20

Protected Material at issue. If a Party's request to file Protected Material under seal is

21

denied by the court, then the Receiving Party may file the information in the public record

22

unless otherwise instructed by the court.

23

13.

FINAL DISPOSITION

24

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

25

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

26

Protected Material to the Producing Party or destroy such material. As used in this

27

subdivision, “all Protected Material” includes all copies, abstracts, compilations,

28

summaries, and any other format reproducing or capturing any of the Protected
STIPULATED PROTECTIVE ORDER
28778108v1

11

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

Material. Whether the Protected Material is returned or destroyed, the Receiving Party

2

must submit a written certification to the Producing Party (and, if not the same person or

3

entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category,

4

where appropriate) all the Protected Material that was returned or destroyed and

5

(2)affirms that the Receiving Party has not retained any copies, abstracts, compilations,

6

summaries or any other format reproducing or capturing any of the Protected Material.

7

Notwithstanding this provision, Counsel are entitled to retain an archival copy of all

8

pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

9

correspondence, deposition and trial exhibits, expert reports, attorney work product, and

10

consultant and expert work product, even if such materials contain Protected Material.

11

Any such archival copies that contain or constitute Protected Material remain subject

12

to this Protective Order as set forth in Section 4 (DURATION).

13

///

14

///

15

///

16

///

17

///

18

///

19

///

20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

///
STIPULATED PROTECTIVE ORDER
28778108v1

12

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

///

2

///

3

14.

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

4

measures including, without limitation, contempt proceedings and/or monetary

5

sanctions.

6
7

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
BOWMAN AND BROOKE LLP

DATED: November 13, 2023

8
BY: /s/ Paul A. Alarcon
PAUL A. ALARCON
ELENI A. SWANK
DAMION M. YOUNG
Attorneys for Defendants
Hoegger Food Technology, Inc., and
Provisur Technologies, Inc.

9
10
11
12
13
14

DATED: November 13, 2023

AZIZI LAW FIRM

15
BY: /s/ David Azizi
DAVID AZIZI
Attorneys for Plaintiff
MARIA SOTO

16
17
18
19
20

DATED: November 13, 2023

BY: /s/ Meegan Moloney
MEEGAN MOLONEY
Attorneys for Defendants, CLOUGHERTY
PACKING, LLC; SMITHFIELD FOODS,
INC (named as Doe 4); AND SMITHFIELD
PACKAGED MEATS CORP. (named as
Doe 5)

21
22
23
24
25
26
27
28

LEWIS BRISBOIS BISGAARD & SMITH LLP

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: November 13, 2023

STIPULATED PROTECTIVE ORDER
28778108v1

13

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1
2
3

HONORABLE JEAN P. ROSENBLUTH
UNITED STATES MAGISTRATE JUDGE

4

EXHIBIT A

5

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

I,

__________________________

[print or

type full

name],

of

_________________________ [print or type full address], declare under penalty of
perjury that I have read in its entirety and understand the Stipulated Protective Order
that was issued by the United States District Court for the Central District of California
on [date] in the case of Maria Soto vs. Clougherty Packing, LLC, et al., Case No. 2:23cv-04665.
I agree to comply with and to be bound by all the terms of this Stipulated
Protective Order and I understand and acknowledge that failure to so comply could
expose me to sanctions and punishment in the nature of contempt. I solemnly promise that
I will not disclose in any manner any information or item that is subject to this Stipulated
Protective Order to any person or entity except in strict compliance with the provisions of
this Order. I further agree to submit to the jurisdiction of the United States District Court
for the Central District of California for the purpose of enforcing the terms of this
Stipulated Protective Order, even if such enforcement proceedings occur after
termination of this action.
I hereby appoint

[print or type full name] of
[print or type full address and telephone

number] as my California agent for service of process in connection with this action or
any proceedings related to enforcement of this Stipulated Protective Order.
Date:
City and State where sworn and signed:
Printed name:
STIPULATED PROTECTIVE ORDER
28778108v1

14

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665

1

Signature:

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATED PROTECTIVE ORDER
28778108v1

15

Maria Soto v Clougherty Packing, LLC, et al.
Case No. 2:23-cv-04665