Adriana Joseph v. JPMorgan Chase Bank, N.A.

Filing 15

STIPULATED PROTECTIVE ORDER (see changes made by Court) by Magistrate Judge Suzanne H. Segal re Stipulation for Protective Order 14 . (see order for details) (hr)

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STROOCK & STROOCK & LAVAN LLP
ARJUN P. RAO State Bar No. 265347)
3 ADAM P. SNYD R (State Bar No. 312160)
2029 Century Park East
4 Los Angeles, CA 90067-3086
Telephone: [phone]
5 Facsimile: 310-556-5959
Email:
[e-mail]
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Attorneys for Defendant
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JPMORGAN CHASE BANK,N.A.
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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ADRIANA JOSEPH,
Plaintiff,

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Case No. 5:18-cv-00820-DSF~
[Assigned to Hon. Dale Fischer]

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PMORGAN CHASE BANK,N.A.,

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Defendant.

STIPULATED PROTECTIVE ORDER
Discovery Document: Referred to
Magistrate Judge Suzanne H. Segal]

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STIPULATED PROTECTIVE ORDER
LA 52193486

Cas 5:18-cv-00820-DSF-SS Document 14 Filed 09/12/18 P~~e 2 of 18 Pa.c~e ID #:61

In anticipation of discovery that may reach confidential and proprietary

1

2 business information, plaintiff Adriana Joseph and defendant JPMorgan Chase Bank,
3 N.A. hereby stipulate as follows:
4

1.

PURPOSES AND LIMITATIONS
Disclosure and discovery activity in this action are likely to involve production

5

6 of confidential, proprietary, or private information for which special protection from
7 public disclosure and from use for any purpose other than prosecuting this litigation
8

may be warranted. Accordingly, the parties hereby stipulate to and petition the court

9 to enter the following Stipulated Protective Order. The parties acknowledge that this
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Order does not confer blanket protections on all disclosures or responses to discovery

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

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

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17 permission from the court to file material under seal.
18 2.

GOOD CAUSE STATEMENT

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This action is likely to involve confidential financial information as well as

20 commercial, financial, technical and/or proprietary information for which special
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protection from public disclosure and from use for any purpose other than

22 prosecution of this action is warranted. Such confidential and proprietary materials
23

and information consist of, among other things, plaintiff's personal identifying

24 information and financial records, including account application and transaction
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records, confidential business or financial information, information regarding

2 confidential business practices, or other confidential research, development, or
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27 commercial information, information otherwise generally unavailable to the public,
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or which may be privileged or otherwise protected from disclosure under state or
- iSTIPULATED PROTECTIVE ORDER
LA 52193486

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Gas 5:18-cv-00820-DSF-SS Document 14 piled o9I121~.s Page 3 of 18 Page ~D #x:62

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federal statutes, court rules, case decisions, or common law. Accordingly, to

2 expedite the flow of information, to facilitate the prompt resolution of disputes over
3

confidentiality of discovery materials, to adequately protect information the parties

4 are entitled to keep confidential, to ensure that the parties are permitted reasonable
5

necessary uses of such material in preparation for and in the conduct of trial, to

6 address their handling at the end of the litigation, and serve the ends ofjustice, a
7 protective order for such information is justified in this matter. It is the intent ofthe
8

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

9 that nothing be so designated without a good faith belief that it has been maintained
10 in a confidential, non-public manner, and there is good cause why it should not be

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part ofthe public record ofthis case.

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DEFINITIONS
3.1

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

of information or items under this Order.

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3.2

"CONFIDENTIAL"Information or Items: information (regardless of

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

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protection under Federal Rule of Civil Procedure 26(c).
3.3

Counsel without qualifier): Outside Counsel of Record and In-House

19 Counsel (as well as their support staff.
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3.4

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

items that it produces in disclosures or in responses to discovery as

22 "CONFIDENTIAL."
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3.5

Disclosure or Discovery Material: all items or information, regardless

24 ofthe medium or manner in which it is generated, stored, or maintained (including,
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among other things, testimony, transcripts, and tangible things), that are produced or

2 generated in disclosures or responses to discovery in this matter.
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-2STIPULATED PROTECTIVE ORDER
LA 52193486

Cas 5:18-cv-00820-DSF-SS Document 14 Filed 09/1.2/18 Pane 4 of 18 Page ID ~,~~:63

3.6

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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
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an expert witness or as a consultant in this action.
3.7

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In-House Counsel: attorneys who are employees of a party to this

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action. In-House Counsel does not include Outside Counsel of Record or any other

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outside counsel.

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3.8

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other legal entity not named as a Party to this action.
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Non-Party: any natural person, partnership, corporation, association, or

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

to this action but are retained to represent or advise a party to this action and have
appeared in this action on behalf ofthat party or are affiliated with a law firm which

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has appeared on behalf ofthat party.

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

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3.10 Party: any party to this action, including all of its officers, directors,

support staffs).
3.11 Producing PartX: a Party or Non-Party that produces Disclosure or

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Discovery Material in this action.
3.12 Professional Vendors: persons or entities that provide litigation support

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services (e.g., photocopying, videotaping, translating, preparing exhibits or

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

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and their employees and subcontractors.
3.13 Protected Material: any Disclosure or Discovery Material that is

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designated as "CONFIDENTIAL".
3.14 Receiving Party: a Party that receives Disclosure or Discovery Material

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from a Producing Party.

2 4.
6

SCOPE

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The protections conferred by this Stipulation and Order cover not only

28 Protected Material(as defined above), but also (1)any information copied or
- 3STIPULATED PROTECTIVE ORDER
LA 52193486

Cas 5:18-cv-00820-DSF-SS Document 14 Filed 09/12/18 Page 5 of 18 Page fD #.:64

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

2 compilations ofProtected Material; and (3)any testimony, conversations, or
3

presentations by Parties or their Counsel that might reveal Protected Material.

4 However,the protections conferred by this Stipulation and Order do not cover the
5

following information: (a) any information that is in the public domain at the time of

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disclosure to a Receiving Party or becomes part of the public domain after its

7 disclosure to a Receiving Party as a result of publication not involving a violation of
8 this Order, including becoming part of the public record through trial or otherwise;
9 and (b)any information known to the Receiving Party prior to the disclosure or
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obtained by the Receiving Party after the disclosure from a source who obtained the

11 information lawfully and under no obligation of confidentiality to the Designating
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5.

DURATION

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Even after final disposition of this litigation, the confidentiality obligations
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otherwise in writing or a court order otherwise directs. Final disposition shall be

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deemed to be the later of(1)dismissal of all claims and defenses in this action, with

19 or without prejudice; and (2)final judgment herein after the completion and
2 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
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including the time limits for filing any motions or applications for extension of time

22 pursuant to applicable law.
23 6.

DESIGNATING PROTECTED MATERIAL

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6.1

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Exercise of Restraint and Care in Desi~natin~ Material for Protection.

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

2 this Order must take care to limit any such designation to specific material that
6
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qualifies under the appropriate standards. The Designating Party must designate for

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protection only those parts of material, documents, items, or oral or written
- 4STIPULATED PROTECTIVE ORDER
LA 52193486

Cas 5:18-cv-00820-DSF-SS Document 14 Filed 09/12/18 Parye 6 of 18 Page ID #:65

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communications that qualify — so that other portions of the material, documents,

2 items, or communications for which protection is not warranted are not swept
3

unjustifiably within the ambit ofthis Order. Mass, indiscriminate, or routinized

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designations are prohibited. Designations that are shown to be clearly unjustified or

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that have been made for an improper purpose (e.g., to unnecessarily encumber or

6 retard the case development process or to impose unnecessary expenses and burdens
7 on other parties) expose the Designating Party to sanctions.
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If it comes to a Designating Party's attention that information or items that it

9 designated for protection do not qualify for protection, that Designating Party must
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promptly notify all other Parties that it is withdrawing the mistaken designation.
6.2

Manner and Timin~of Desibnations. Except as otherwise provided in

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under this Order must be clearly so designated before the material is disclosed or

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produced.
Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic

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documents, but excluding transcripts of depositions or other pretrial or trial

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proceedings), that the Producing Party affix the legend "CONFIDENTIAL" to each

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

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a page qualifies for protection, the Producing Party also must clearly identify the

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protected portions)(e.g., by making appropriate markings in the margins). Ifthe

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information is produced in a native format or some other format where affixing the

2 legend "CONFIDENTIAL" to each page is not feasible, the Producing Party may
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affix the legend "CONFIDENTIAL" to the title ofthe document.
A Party or Non-Party that makes original documents or materials available for

27 inspection need not designate them for protection until after the inspecting Party has
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indicated which material it would like copied and produced. During the inspection
- 5PROTECTIVE ORDER
STIPULATED
LA 52193486

CasE

1

18-cv-00820-DSF-SS Document 14 Filed 09!12/18 Pine 7 of 18 Page ID ##:66

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

2 deemed "CONFIDENTIAL." After the inspecting Party has identified the
3

documents it wants copied and produced, the Producing Party must determine which

4 documents, or portions thereof, qualify for protection under this Order. Then, before
5

producing the specified documents, the Producing Party must affix the

CONFIDENTIAL" legend to each page that contains Protected Material. If only a
6 "
7 portion or portions ofthe material on a page qualifies for protection, the Producing
8 Party also must clearly identify the protected portions)(e.g., by making appropriate
9 markings in the margins).
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( for testimony given in deposition or in other pretrial or trial
b)
proceedings, that the Designating Party identify on the record, before the close ofthe
deposition, hearing, or other proceeding, all protected testimony.
( for information produced in some form other than documentary and
c)

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the exterior ofthe container or containers in which the information or item is stored
the legend "CONFIDENTIAL." If only a portion or portions ofthe information or

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item warrant protection, the Producing Party, to the extent practicable, shall identify

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the protected portion(s).
6.3

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Inadvertent Failures to Desi~Lnate. If timely corrected, an inadvertent

ailure to designate qualified information or items does not, standing alone, waive the
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Designating Party's right to secure protection under this Order for such material.

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

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efforts to assure that the material is treated in accordance with the provisions ofthis

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Order.

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6

CHALLENGING CONFIDENTIALITY DESIGNATIONS
7.1

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

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designation of confidentiality at any time. Unless a prompt challenge to a

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Designating Party's confidentiality designation is necessary to avoid foreseeable,
- 6STIPULATED PROTECTIVE ORDER
LA 52193486

Cas 5:18-cv-00820-DSF-SS Document 14 Filed 09/12/18 P~rye 8 of 18 Pale ID #:67

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substantial unfairness, unnecessary economic burdens, or a significant disruption or

2 delay of the litigation, a Party does not waive its right to challenge a confidentiality
3

designation by electing not to mount a challenge promptly after the original
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4 designation is disclosed.
5

Meet and Confer. The Challenging Pa y shall initiate the dispute

7.2

6 resol ion pr

by providing written notice of ach designation it is challenging

7 and describing the ba 's for each challenge. To void ambiguity.as to whether a
8

challenge has been made, the written notice

st recite that the challenge to

9 confidentiality is being ma e in accordance ith this specific paragraph of the
10 Protective Order. The parti s shall attemp to resolve each challenge in good faith

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directly (in voice to voice dialogue; other

and must begin the process y conferri

W o 12 forms of communication ar not Buff Tent) within 14 days ofthe date of service of

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notice. In conferring, the C alle ing Party must explain the basis for its belief that

14 the confidentiality designati n as not proper and must give the Designating Party
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an opportunity to review the esignated material, to reconsider the circumstances,

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and, if no change in design ti

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designation. A Challen

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process only if it has e gaged in thi

is offered, to explain the basis for the chosen

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7.3

eet and confer process first or establishes that

is unwilling to participa e in the meet and confer process in a

19 the Designating Pa
2 timely manner.
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may proceed to the next stage ofthe challenge

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Judicial Intervention'. Ifthe Pa

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resolve a challenge without

22 court intervention, the Designating Party shall f and serve a motion to retain
23

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confidentiality under Civil Local Rule 7

2 79-5, if applicable) within 21 days
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of the parties agreeing that the

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whichever is earlier. Each

pliance with Civil Local Rule

the initial n tice of challenge or within 14 days

eet and confer p ocess will not resolve their dispute,

ch motion must be a companied by a competent

27 declaration affirming th the movant has complied ith the meet and confer
28 requirements imposed in the preceding paragraph. Fai
- ~STIPULATED PROTECTIVE ORDER
LA 52193486

e by the Designating Party

>:18-cv-00820-DSF-SS Document 14 Filed U9/12/18 Page 9 of 18 Page ID #:68

1

to make such a

'ncluding the required declaration within 21 days (or 14 days,

2 if applicable) shall automatically wa' e the confide
3 challenged designation. In addition, th C
4 challenging a confidentiality
5

so, including a challenge to

6 thereof. Any motio
7 competent dec
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at any time if there is good cause for doing
e designati~ n of a deposition transcript or any portions

rought pursuant to

is provision must be accompanied by a

ation affirming that the ~no

t has co

with the meet and

irements imposed by the preceding paragraph.

10 Designating Party. Frivolous challenges, and those made for an improper purpose

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enging Party may file a motion

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

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ity designation for each

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e.g., to harass or impose unnecessary expenses and burdens on other parties) may

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13 the confidentiality designation by failing to file a motion to retain confidentiality as
14 described above, all parties shall continue to afford the material in question the level

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ACCESS TO AND USE OF PROTECTED MATERIAL

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8.1

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

19 disclosed or produced by another Party or by a Non-Party in connection with this
2 case only for prosecuting, defending, or attempting to settle this litigation. Such
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Protected Material may be disclosed only to the categories of persons and under the

22 conditions described in this Order. When the litigation has been terminated, a
23

Receiving Party must comply with the provisions of section 14 below(FINAL

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DISPOSITION).

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

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

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authorized under this Order.

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-gSTIPULATED PROTECTIVE ORDER
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Case I~;18-cv-00820-D5F-SS Da~ument 14 Filed 09/12/18 Page 10 of 18 Page ID.#:69

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8.2

Disclosure of"CONFIDENTIAL"Information or Items. Unless

2 i otherwise ordered by the court or permitted in writing by the Designating Party, a
3 Receiving Party may disclose any information or item designated
4 "
CONFIDENTIAL" only to:
( the Receiving Party and Receiving Party's Outside Counsel of
a)

5

6 Record in this action, as well as employees of said Outside Counsel of Record to
7 whom it is reasonably necessary to disclose the information for this litigation;
( the officers, directors, and employees (including In-House Counsel)
b)

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9 ofthe Receiving Party to whom disclosure is reasonably necessary for this litigation;
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Acknowledgment and Agreement to Be Bound"(E~ibit A);
( the court and its personnel;
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( court reporters and their staff, professional jury or trial consultants,
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mock jurors, and Professional Vendors to whom disclosure is reasonably necessary

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

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

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16 for this litigation and who have signed the "Acknowledgment and Agreement to Be
17 Bound"(Exhibit A);
( during their depositions, witnesses in the action to whom disclosure
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19 is reasonably necessary and who have signed the "Acknowledgment and Agreement
2 to Be Bound"(Exhibit. A), unless otherwise agreed by the Designating Party or
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ordered by the court. Pages oftranscribed deposition testimony or exhibits to

22 depositions that reveal Protected Material must be separately bound by the court
23 reporter and may not be disclosed to anyone except as permitted under this Stipulated
2 Protective Order.
4
( the author or recipient of a document containing the information or
g)

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26 a custodian or other person who otherwise possessed or knew the information.
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-9STIPULATED PROTECTIVE ORDER
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Case :18-cv-00820-D5F-SS Document 14 Filed 09/12/18 Pang 11 of 18 Page ID #:70

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9.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

2

OTHER LITIGATION

3

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

4 that compels disclosure of any information or items designated in this action as
5 "CONFIDENTIAL," that Party must:
(a) promptly notify in writing the Designating Party. Such notification

6

7 shall include a copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or

8

9 order to issue in the other litigation that some or all ofthe material covered by the
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subpoena or order is subject to this Protective Order. Such notification shall include a ~'
copy of this Stipulated Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be
pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with

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17 subpoena or order issued, unless the Party has obtained the Designating Party's
18

permission. The Designating Party shall bear the burden and expense of seeking

19 protection in that court of its confidential material —and nothing in these provisions
2 should be construed as authorizing or encouraging a Receiving Party in this action to
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disobey a lawful directive from another court.

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10.

23

ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a) The terms ofthis Order are applicable to information produced by a

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Non-Party in this action and designated as "CONFIDENTIAL." Such information

2
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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 allon-Party from seeking additional protections.
- ioSTIPULATED PROTECTIVE ORDER
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(b) In the event that a Party is required, by a valid discovery request, to

2 (, produce allon-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:
( promptly notify in writing the Requesting Party and the Non1)

5

6 Party that some or all of the information requested is subject to a confidentiality
7 agreement with allon-Party;
( promptly provide the Non-Party with a copy of the Stipulated
2)

8

9 Protective Order in this litigation, the relevant discovery request(s), and a reasonably
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10 specific description ofthe information requested; and

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( make the information requested available for inspection by
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( Ifthe Non-Party fails to object or seek a protective order from this
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14 court within 14 days of receiving the notice and accompanying information, the

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Receiving Party may produce the Non-Party's confidential information responsive to

16 the discovery request. Ifthe Non-Party timely seeks a protective order, the
17 Receiving Party shall not produce any information in its possession or control that is
18

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

19 by the court. Absent a court order to the contrary, the Non-Party shall bear the
2
0 burden and expense of seeking protection in this court of its Protected Material.
21
22

1 1.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

23 Protected Material to any person or in any circumstance not authorized under this
2
4

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

25

writing the Designating Party ofthe unauthorized disclosures,(b)use its best efforts

2 to retrieve all unauthorized copies of the Protected Material,(c)inform the person or
6
27 persons to whom unauthorized disclosures were made of all the terms ofthis Order,
28
STIPULATED PROTECTIVE ORDER
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Case :18-cv-00820-DSF-SS Document 1.4 Filed 09f12/18 Pine 13 of 18 Page iD~#:72

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and (d)request such person or persons to execute the "Acknowledgment and

2 Agreement to Be Bound" that is attached hereto as Exhibit A.
3

12.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

4

PROTECTED MATERIAL

5

When a Producing Party gives notice to Receiving Parties that certain

6

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

7 the obligations ofthe Receiving Parties are those set forth in Federal Rule of Civil
8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
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may be established in an e-discovery order that provides for production without prior
privilege review.
13.

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

person to seek its modification by the court in the future.
13.2 Right to Assert Other Objections. By stipulating to the entry ofthis

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

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

17

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

18

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

19

13.3 Filing Protected Material. Without written permission from the

2
0 Designating Party or a court order secured after appropriate notice to all interested
21

persons, a Party may not file in the public record in this action any Protected

22

Material. A Party that seeks to file under seal any Protected Material must comply

23

with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant

24

to a court order authorizing the sealing of the specific Protected Material at issue.

25

Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request

2
6

establishing that the Protected Material at issue is privileged, protectable as a trade

27 secret, or otherwise entitled to protection under the law. If a Receiving Party's
28

request to file Protected Material under seal pursuant to Civil Local Rule 79-5 is
- 12STIPULATED PROTECTIVE ORDER
LA 52193486

'I

Case ~~:18-cv-00820-DSF-S~ Document 14 Filed 09/12
/18 Pry? 14 of 18 Page ID ,#:73

1

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

2 record pursuant to Civil Local Rule 79-5 unless otherwise instructed by the court.

~I 14.

FINAL DISPOSITION

4

Within 60 days after the final disposition of this action, as defined in

5

paragraph 5, each Receiving Party must return all Protected Material to the

6 Producing Party or destroy such material. As used in this subdivision,"all Protected
7 Material" includes all copies, abstracts, compilations, summaries, and any other
8 format reproducing or capturing any ofthe Protected Material. At the request ofthe
9 Producing Party, the Receiving Party must submit a written certification to the
a

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

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13 copies, abstracts, compilations, summaries or any other format reproducing or
14 capturing any of the Protected Material. Notwithstanding this provision, Counsel are

~ ~~ 15 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
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17 exhibits, expert reports, attorney work product, and consultant and expert work
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product, even if such materials contain Protected Material. Any such archival copies

19 that contain or constitute Protected Material remain subject to this Protective Order
20 as set forth in Section 5(DURATION).
21
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-13STIPULATED PROTECTIVE ORDER
LA 52193486

Case x$;18-cv-00820-DSF-SS Document 14 Filed 09/12/18 Para 15 of 18 Page id #:74

1 I

IT IS SO STIPULATED.

3 ~I

STROOCK & STROOCK & LAVAN LLP
ARJUN P. RAO
ADAM P. SNYDER

4

By:

2 ~' Dated: September 12, 2018

/s/Ar'un P. Rao
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Attorneys for Defendant
JPMorgan Chase Bank, N.A.

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7
8 Dated: September 12, 2018
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KIMMEL & SILVERMAN,P.C.
AMYL.BENNECOFF GINSBERG

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By:

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/s/Amy L. Bennecoff Ginsberg
enneco mains erg
my

Attornexs for Plaintiff
Adriana Joseph

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RDERED.

IT IS SO

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Dated:

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States M strate Judge
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- 14STIPULATED PROTECTIVE ORDER
~ LA 52193486

Case I! .:18-cv-OQ82~-DSF-SS Document 14 Filed 09/12/18 Pa~+Q 16 of 18 Page ID #:75

EXHIBIT A

1

AGREEMENT TO BE BOUND

2
3

[print or type full name], of

I,

4
5

[
print or type full address], declare under
penalty of perjury that I have read in its entirety and understand the Protective Order

6 that was issued by the United States District Court for the Central District of
7 California on

[date] in the case of Adriana Joseph v.

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Chase Bank, N.A., Case No. 5:18-cv-00820-DSF-SS. I agree to comply with and to
be bound by all the terms ofthis Protective Order, and I understand and acknowledge

10 that failure to so comply could expose me to sanctions and punishment for contempt.

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o 1 1 I solemnly promise that I will not disclose in any manner any information or item
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I further agree to submit to the jurisdiction ofthe United States District Court

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f the Central District of California for the purpose of enforcing this Order, even if
or

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16 such enforcement proceedings occur after termination ofthis action.
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[print or type full name] of

I hereby appoint

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[
print or type full address and

19 telephone number] as my California agent for service of process in connection with
2
0 this action or any proceedings related to enforcement ofthis Order.
21
2
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23

Date:
City and State where sworn and signed:
Printed name:
printe name

24
25

Signature:
signature

26
27
28
AGREEMENT TO BE BOUND
LA 52193486

Case ~~:18-cu-00820-DSF-SS Document 14 filed 09/12/18 Pang 17 of 18 Page ID #:76

ECF CERTIFICATION

1
2
3

Pursuant to L.R. 5-4.3.4(a)(2), I hereby certify that the content of this
document is acceptable to Amy L. Bennecoff Ginsberg, counsel for Plaintiff, and that

4 I have obtained authorization to affix Ms. Bennecoff Ginsberg's electronic signature
5

to this document.

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/s/ Ar'un P. Rao
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ECF CERTIFICATION
LA 52193486

Case x$:18-cv-00820-DSF-SS Dacument 14 Fiied 09/12/18 Para 18 of 18 Page •ID ,x:77

CERTIFICATE OF SERVICE

1
2

I hereby certify that on September 12, 2018, a copy ofthe foregoing

3 STIPULATED PROTECTIVE ORDER was filed electronically and served by
4

mail on anyone unable to accept electronic filing. Notice of this filing will be sent by

5

e-mail to all parties by operation ofthe court's electronic filing system or by mail to

6 anyone unable to accept electronic filing as indicated on the Notice of Electronic
7 Filing. Parties may access this filing through the court's CM/ECF System.
8
/s/ Ar'un P. Rao
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CERTIFICATE OF SERVICE
LA 52193486