Nagravsion S.A.R.L. v. Triller, Inc.

Filing 29

PROTECTIVE ORDER by Magistrate Judge Steve Kim re Stipulation for Protective Order 28 . (see document for details) (hr)

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1 2 3 4 5 6 7 Attorneys for Plaintiff Nagravision S.A.R.L. 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 HAZEL MAE B. PANGAN (SBN: 272657) hpangan@grsm.com PATRICK J. MULKERN (SBN: 307272) pmulkern@grsm.com GORDON REES SCULLY MANSUKHANI 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 Telephone: 213-576-5000 Facsimile: 213-680-4470 NAGRAVISION S.A.R.L., a Swiss corporation, STIPULATED PROTECTIVE ORDER 12 Plaintiff, 13 16 District Judge Hon. George H. Wu vs. 14 15 Case No. 2:23-cv-06802-GW-(SKx) TRILLER, INC., a Delaware corporation, 17 Magistrate Judge Hon. Steve Kim Defendant. 18 19 1. INTRODUCTION 20 A. Purposes and Limitations 21 Discovery in this action is likely to involve production of confidential, 22 proprietary, or private information for which special protection from public 23 disclosure and from use for any purpose other than prosecuting this litigation may 24 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 25 enter the following Stipulated Protective Order. The parties acknowledge that this 26 Order does not confer blanket protections on all disclosures or responses to 27 discovery and that the protection it affords from public disclosure and use extends 28 only to the limited information or items that are entitled to confidential treatment STIPULATED PROTECTIVE ORDER -1- CASE NO. 2:23-cv-06802-GW-SKx Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 1 under the applicable legal principles. The parties further acknowledge, as set forth 2 in Section 12.3 (Filing Protected Material), below, that this Stipulated Protective 3 Order does not entitle them to file confidential information under seal; Civil Local 4 Rule 79-5 sets forth the procedures that must be followed and the standards that will 5 be applied when a party seeks permission from the court to file material under seal. 6 B. Good Cause Statement 7 The present litigation is a breach of contract action between two businesses 8 in which Plaintiff Nagravision S.A.R.L. (“Nagravision”) alleges that Defendant 9 Triller, Inc. (“Triller”) has breached a patent license agreement. Discovery 10 encompasses communications and documentation that reflect Nagravision’s 11 internal operations, including materials that embody or otherwise reflect 12 Nagravision’s proprietary and confidential business information (including 13 licensing strategy), the public disclosure of which would cause it competitive harm. 14 Accordingly, Nagravision and Triller (together, the “Parties”) are in accord that the 15 present Stipulated Protective Order is warranted. 16 2. 17 18 19 20 21 DEFINITIONS 2.1 Action: The above-captioned case—specifically, Nagravision S.A.R.L. v. Triller, Inc., Case No. 23-cv-6802 (C.D. Cal.). 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 22 how it is generated, stored, or maintained) or tangible things that qualify for 23 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 24 the Good Cause Statement. 25 26 27 28 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 STIPULATED PROTECTIVE ORDER -2- CASE NO. 2:23-cv-06802-GW-SKx 1 2 2.6 Disclosure or Discovery Material: all items or information, regardless 3 of the medium or manner in which it is generated, stored, or maintained (including, 4 among other things, testimony, transcripts, and tangible things), that are produced 5 or generated in disclosures or responses to discovery in this matter. 6 2.7 Expert: a person with specialized knowledge or experience in a matter 7 pertinent to the litigation who has been retained by a Party or its counsel to serve as 8 an expert witness or as a consultant in this Action. 9 Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 “CONFIDENTIAL.” 2.8 House Counsel: attorneys who are employees of a party to this Action. 10 House Counsel does not include Outside Counsel of Record or any other outside 11 counsel. 12 13 2.9 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 14 2.10 Outside Counsel of Record: attorneys who are not employees of a 15 party to this Action but are retained to represent or advise a party to this Action and 16 have appeared in this Action on behalf of that party or are affiliated with a law firm 17 which has appeared on behalf of that party, including support staff. 18 2.11 Party: any party to this Action, including all of its officers, directors, 19 employees, consultants, retained experts, and Outside Counsel of Record (and their 20 support staffs). 21 22 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 2.13 Professional Vendors: persons or entities that provide litigation 24 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 25 demonstrations, and organizing, storing, or retrieving data in any form or medium) 26 and their employees and subcontractors. 27 28 2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” STIPULATED PROTECTIVE ORDER -3- CASE NO. 2:23-cv-06802-GW-SKx 1 2.15 Receiving Party: 2 Material from a Producing Party. 3 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or 6 extracted from Protected Material; (2) all copies, excerpts, summaries, or 7 compilations of Protected Material; and (3) any testimony, conversations, or 8 presentations by Parties or their Counsel that might reveal Protected Material. 9 Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 a Party that receives Disclosure or Discovery Any use of Protected Material at trial shall be governed by the orders of the 10 trial judge. This Order does not govern the use of Protected Material at trial. 11 4. DURATION 12 Even after final disposition of this litigation, the confidentiality obligations 13 imposed by this Order shall remain in effect until a Designating Party agrees 14 otherwise in writing or a court order otherwise directs. Final disposition shall be 15 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 16 with or without prejudice; and (2) final judgment herein after the completion and 17 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 18 including the time limits for filing any motions or applications for extension of time 19 pursuant to applicable law. 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 22 Each Party or Non-Party that designates information or items for protection 23 under this Order must take care to limit any such designation to specific material 24 that qualifies under the appropriate standards. 25 designate for protection only those parts of material, documents, items, or oral or 26 written communications that qualify so that other portions of the material, 27 documents, items, or communications for which protection is not warranted are not 28 swept unjustifiably within the ambit of this Order. Exercise of Restraint and Care in Designating Material for Protection. STIPULATED PROTECTIVE ORDER -4- The Designating Party must CASE NO. 2:23-cv-06802-GW-SKx 1 Mass, indiscriminate, or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to impose 4 unnecessary expenses and burdens on other parties) may expose the Designating 5 Party to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 promptly notify all other Parties that it is withdrawing the inapplicable designation. Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 9 5.2 Manner and Timing of Designations. Except as otherwise provided in 10 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise 11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 12 under this Order must be clearly so designated before the material is disclosed or 13 produced. 14 Designation in conformity with this Order requires: 15 (a) for information in documentary form (e.g., paper or electronic 16 documents, but excluding transcripts of depositions or other pretrial or trial 17 proceedings), that the Producing Party affix at a minimum, the legend 18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 19 contains protected material. If only a portion or portions of the material on a page 20 qualifies for protection, the Producing Party also must clearly identify the protected 21 portion(s) (e.g., by making appropriate markings in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and 25 before the designation, all of the material made available for inspection shall be 26 deemed “CONFIDENTIAL.” 27 documents it wants copied and produced, the Producing Party must determine 28 which documents, or portions thereof, qualify for protection under this Order. After the inspecting Party has identified the STIPULATED PROTECTIVE ORDER -5- CASE NO. 2:23-cv-06802-GW-SKx 1 Then, before producing the specified documents, the Producing Party must affix the 2 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 3 portion or portions of the material on a page qualifies for protection, the Producing 4 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 5 markings in the margins). 6 (b) 7 the Disclosure or Discovery Material on the record, before the close of the 8 deposition all protected testimony. 9 Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 for testimony given in depositions that the Designating Party identify (c) for information produced in some form other than documentary and 10 for any other tangible items, that the Producing Party affix in a prominent place on 11 the exterior of the container or containers in which the information is stored the 12 legend “CONFIDENTIAL.” If only a portion or portions of the information 13 warrants protection, the Producing Party, to the extent practicable, shall identify the 14 protected portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not, standing alone, waive 17 the Designating Party’s right to secure protection under this Order for such material. 18 Upon timely correction of a designation, the Receiving Party must make reasonable 19 efforts to assure that the material is treated in accordance with the provisions of this 20 Order. 21 6. 22 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 23 designation of confidentiality at any time that is consistent with the Court’s 24 Scheduling Order. 25 26 27 28 6.2 Meet and Confer. The Challenging Party Shall initiate the dispute resolution process under Civil Local Rule 37-1 et seq. 6.3 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous challenges, and those made for an improper STIPULATED PROTECTIVE ORDER -6- CASE NO. 2:23-cv-06802-GW-SKx 1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 parties), may expose the Challenging Party to sanctions. Unless the Designating 3 Party has waived or withdrawn the confidentiality designation, all parties shall 4 continue to afford the material in question the level of protection to which it 5 is entitled under the Producing Party’s designation until the Court rules on the 6 challenge. 7 7. Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 8 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that 9 is disclosed or produced by another Party or by a Non-Party in connection with 10 this Action only for prosecuting, defending, or attempting to settle this Action. 11 Such Protected Material may be disclosed only to the categories of persons and 12 under the conditions described in this Order. 13 terminated, a Receiving Party must comply with the provisions of Section 13 below 14 (FINAL DISPOSITION). When the Action has been 15 Protected Material must be stored and maintained by a Receiving Party at 16 a location and in a secure manner that ensures that access is limited to the 17 persons authorized under this Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 19 otherwise ordered by the Court or permitted in writing by the Designating Party, a 20 Receiving 21 “CONFIDENTIAL” only to: 22 (a) Party may disclose any information or item designated the Receiving Party’s Outside Counsel of Record in this Action, as 23 well as employees of said Outside Counsel of Record to whom it is reasonably 24 necessary to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of 26 the Receiving Party to whom disclosure is reasonably necessary for this Action; 27 /// 28 /// STIPULATED PROTECTIVE ORDER -7- CASE NO. 2:23-cv-06802-GW-SKx 1 (c) 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) the Court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and Professional 7 Vendors to whom disclosure is reasonably necessary for this Action and who have 8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 10 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 11 Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 Experts (as defined in this Order) of the Receiving Party to whom (h) during their depositions, witnesses, and attorneys for witnesses, in the 12 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 13 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 14 will not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 16 agreed by the Designating Party or ordered by the Court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may 18 be separately bound by the court reporter and may not be disclosed to anyone except 19 as permitted under this Stipulated Protective Order; and 20 (i) any mediator or settlement officer, and their supporting personnel, 21 mutually agreed upon by any of the parties engaged in settlement discussions. 22 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 23 PRODUCED IN OTHER LITIGATION 24 If a Party is served with a subpoena or a court order issued in other litigation 25 that compels disclosure of any information or items designated in this Action as 26 “CONFIDENTIAL,” that Party must: 27 28 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; STIPULATED PROTECTIVE ORDER -8- CASE NO. 2:23-cv-06802-GW-SKx 1 (b) 2 to issue in the other litigation that some or all of the material covered by the 3 subpoena or order is subject to this Protective Order. Such notification shall include 4 a copy of this Stipulated Protective Order; and 5 6 Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 promptly notify in writing the party who caused the subpoena or order (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with 8 the subpoena or court order shall not produce any information designated in this 9 action as “CONFIDENTIAL” before a determination by the court from which the 10 subpoena or order issued, unless the Party has obtained the Designating Party’s 11 permission. The Designating Party shall bear the burden and expense of seeking 12 protection in that court of its confidential material, and nothing in these provisions 13 should be construed as authorizing or encouraging a Receiving Party in this Action 14 to disobey a lawful directive from another court. 15 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 16 PRODUCED IN THIS LITIGATION 17 (a) The terms of this Order are applicable to information produced by a 18 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 19 produced by Non-Parties in connection with this litigation is protected by the 20 remedies and relief provided by this Order. Nothing in these provisions should be 21 construed as prohibiting a Non-Party from seeking additional protections. 22 (b) In the event that a Party is required, by a valid discovery request, to 23 produce a Non-Party’s confidential information in its possession, and the Party is 24 subject to an agreement with the Non-Party not to produce the Non-Party’s 25 confidential information, then the Party shall: 26 (1) promptly notify in writing the Requesting Party and the Non- 27 Party that some or all of the information requested is subject to a 28 confidentiality agreement with a Non-Party; STIPULATED PROTECTIVE ORDER -9- CASE NO. 2:23-cv-06802-GW-SKx 1 (2) 2 Protective Order in this Action, the relevant discovery request(s), and a 3 reasonably specific description of the information requested; and 4 Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 promptly provide the Non-Party with a copy of the Stipulated (3) make the information requested available for inspection by the 5 Non-Party, if requested. 6 (c) If the Non-Party fails to seek a protective order from this Court within 7 14 days of receiving the notice and accompanying information, the Receiving Party 8 may produce the Non-Party’s confidential information responsive to the discovery 9 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 10 not produce any information in its possession or control that is subject to the 11 confidentiality agreement with the Non-Party before a determination by the Court. 12 Absent a court order to the contrary, the Non-Party shall bear the burden and 13 expense of seeking protection in this Court of its Protected Material. 14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 Protected Material to any person or in any circumstance not authorized under this 17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 18 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 19 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 20 or persons to whom unauthorized disclosures were made of all the terms of this 21 Order, and (d) request such person or persons to execute the “Acknowledgment and 22 Agreement to Be Bound” that is attached hereto as Exhibit A. 23 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 24 OTHERWISE PROTECTED MATERIAL 25 When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other protection, 27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever STIPULATED PROTECTIVE ORDER -10- CASE NO. 2:23-cv-06802-GW-SKx 1 procedure may be established in an e-discovery order that provides for production 2 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 3 (e), insofar as the parties reach an agreement on the effect of disclosure of a 4 communication or information covered by the attorney-client privilege or work 5 product protection, the parties may incorporate their agreement in the stipulated 6 protective order submitted to the Court. 7 12. 8 Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 9 MISCELLANEOUS 12.1 Right to Relief. Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 Protective Order, no Party waives any right it otherwise would have to object to 12 disclosing or producing any information or item on any ground not addressed in this 13 Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 ground to use in evidence of any of the material covered by this Protective Order. 15 12.3 Filing Protected Material. A Party that seeks to file under seal any 16 Protected Material must comply with Civil Local Rule 79-5. Protected Material 17 may only be filed under seal pursuant to a court order authorizing the sealing of the 18 specific Protected Material at issue. If a Party’s request to file Protected Material 19 under seal is denied by the court, then the Receiving Party may file the information 20 in the public record unless otherwise instructed by the court. 21 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in Section 4 23 (DURATION), within 60 days of a written request by the Designating Party, each 24 Receiving Party must return all Protected Material to the Producing Party or destroy 25 such material. As used in this subdivision, “all Protected Material” includes all 26 copies, abstracts, compilations, summaries, and any other format reproducing or 27 capturing any of the Protected Material. Whether the Protected Material is returned 28 or destroyed, the Receiving Party must submit a written certification to the STIPULATED PROTECTIVE ORDER -11- CASE NO. 2:23-cv-06802-GW-SKx Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 1 Producing Party (and, if not the same person or entity, to the Designating Party) by 2 the 60 day deadline that (1) identifies (by category, where appropriate) all the 3 Protected Material that was returned or destroyed; and (2) affirms that the Receiving 4 Party has not retained any copies, abstracts, compilations, summaries, or any other 5 format reproducing or capturing any of the Protected Material. Notwithstanding 6 this provision, Counsel are entitled to retain an archival copy of all pleadings, 7 motion papers, trial, deposition, and hearing transcripts, legal memoranda, 8 correspondence, deposition and trial exhibits, expert reports, attorney work product, 9 and consultant and expert work product, even if such materials contain Protected 10 Material. Any such archival copies that contain or constitute Protected Material 11 remain subject to this Protective Order as set forth in Section 4 (DURATION). 12 14. Any violation of this Order may be punished by any and all appropriate 13 measures including, without limitation, contempt proceedings and/or monetary 14 sanctions. 15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 16 17 Dated: May 7, 2024 18 GORDON REES SCULLY MANSUKHANI By: /s/ Patrick J. Mulkern Hazel Mae B. Pangan Patrick J. Mulkern Attorneys for Plaintiff NAGRAVISION, S.A.R.L. 19 20 21 22 23 24 25 26 27 28 Dated: May 7, 2024 NOVIAN & NOVIAN, LLP By: /s/ Amber Miller Farhad Novian (SBN: 118129) Lauren Woodland (SBN: 283052) Amber Miller (SBN: 346793) Attorneys for Defendant TRILLER, INC. STIPULATED PROTECTIVE ORDER -12- CASE NO. 2:23-cv-06802-GW-SKx 1 Attestation of E-Filed Signature 2 I, Patrick J. Mulkern, am the ECF user whose ID and password are being 3 used to file this stipulation. Pursuant to C.D. Cal. L.R. 5-4.3.4, I attest that all other 4 signatories listed, and on whose behalf the present filing is submitted, concur in the 5 filing’s contents and have authorized the filing. 6 7 Date: May 7, 2024 /s/ Patrick J. Mulkern Patrick J. Mulkern 8 9 ORDER 10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 11 12 13 DATED: May 8, 2024 HON. STEVE KIM United States Magistrate Judge 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1312179/80705531v.1 STIPULATED PROTECTIVE ORDER -13- CASE NO. 2:23-cv-06802-GW-SKx 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND Gordon Rees Scully Mansukhani, LLP 633 W. Fifth Street, 52nd Floor Los Angeles, CA 90071 3 4 I, _________________ [full name], of _________________ [full address], 5 declare under penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States District Court for 7 the Central District of California on 8 Nagravision S.A.R.L. v. Triller, Inc., Case No. 2:23-cv-6802-GW-SKx (C.D. Cal.). 9 I agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order, and I understand and acknowledge that failure to so comply could expose 11 me to sanctions and punishment in the nature of contempt. I solemnly promise that 12 I will not disclose in any manner any information or item that is subject to this 13 Stipulated Protective Order to any person or entity except in strict compliance with 14 the provisions of this Order. [date] in the case of 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint _____________________________ 19 [full name] of _______________________________________ [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 STIPULATED PROTECTIVE ORDER -14- CASE NO. 2:23-cv-06802-GW-SKx

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