John CL Doe v. Corporation of the President of The Church of Jesus Christ of Latter-day Saints et al

Filing 27

PROTECTIVE ORDER by Magistrate Judge Kenly Kiya Kato re Stipulation for Protective Order #26 . (see document for details) (hr)

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Karl N. Haws (SBN 121638) 2 MUNDELL, ODLUM & HAWS LLP 3 650 East Hospitality Lane, Suite 470 4 San Bernardino, CA 92408 Telephone: (909) 890-9500 1 5 Lisa Dearden Trépanier (SBN 156302) 7 TRÉPANIER TAJIMA LLP 8 4605 Lankershim Blvd., Suite 540 North Hollywood, California 91602 9 Telephone: (323) 487-1101 6 10 Attorneys for Defendants Corporation of the President of the Church of 12 Jesus Christ of Latter-day Saints and The Church of Jesus Christ of Latter-day Saints 11 13 14 15 16 17 18 19 20 21 22 23 24 25 26 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA JOHN CL DOE, a minor, by and through his Guardian ad Litem, JOHN IL DOE, Plaintiff, vs. CORPORATION OF THE PRESIDENT OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, a Utah corporation sole; THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, a Utah corporation sole; and DOES 1 to 50, Inclusive, Defendants. Case No. 5:23-cv-02005-JFW (KKx) [DISCOVERY MATTER] [PROPOSED] STIPULATED PROTECTIVE ORDER Discovery Cut-off: Jul. 15, 2024 Pretrial Conf. Date: Sept. 20, 2024 Trial Date: Oct. 8, 2024 27 28 TRÉPANIER TAJIMA LLP 1 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, proprietary, 3 or private information for which special protection from public disclosure and from use 4 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 5 parties hereby stipulate to and petition the Court to enter the following Stipulated 6 Protective Order. The parties acknowledge that this Order does not confer blanket 7 protections on all disclosures or responses to discovery and that the protection it affords 8 from public disclosure and use extends only to the limited information or items that are 9 entitled to confidential treatment under the applicable legal principles. The parties further 10 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 11 does not entitle them to file confidential information under seal; Civil Local Rule 79-5 12 sets forth the procedures that must be followed and the standards that will be applied 13 when a party seeks permission from the court to file material under seal. 14 B. GOOD CAUSE STATEMENT 15 This Action concerns Plaintiff’s claims for damages arising out of alleged sexual 16 abuse for which Defendants (Church corporations) are allegedly liable. This Action is thus 17 likely to involve confidential medical, religious, and third party information for which 18 special protection from public disclosure and from use for any purpose other than 19 prosecution of this action is warranted. Such confidential materials and information 20 consist of, among other things, confidential medical records, religious organization 21 membership records, information implicating privacy rights of third parties (including 22 alleged abuse victims and non-party family members of alleged abuse victims), 23 information identifying minors, including Plaintiff, privileged communications with 24 clergy, and other information otherwise generally unavailable to the public or which may 25 be privileged or otherwise protected from disclosure under state or federal statutes, court 26 rules, case decisions, or common law. Accordingly, to expedite the flow of information, to 27 facilitate the prompt resolution of disputes over confidentiality of discovery materials, to 28 adequately protect information the parties are entitled and/or obligated to keep TRÉPANIER TAJIMA LLP 2 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 confidential, to ensure that the Parties are permitted reasonable necessary uses of such 2 material in preparation for and in the conduct of trial, to address their handling at the end 3 of the litigation, and serve the ends of justice, a protective order for such information is 4 justified in this matter. It is the intent of the Parties that information will not be designated 5 as confidential for tactical reasons and that nothing be so designated without a good faith 6 belief that it has been maintained in a confidential, non-public manner, and there is good 7 cause why it should not be part of the public record of this case. 8 2. DEFINITIONS 9 2.1 Action: The above-entitled proceeding, John CL Doe v. Corporation of the 10 President of The Church of Jesus Christ of Latter-day Saints, et al., Case No. 5:23-cv- 11 2005-JFW (KKx). 12 13 14 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 it is 15 generated, stored or maintained) or tangible things that qualify for protection under 16 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 17 Statement. 18 19 20 21 22 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 23 medium or manner in which it is generated, stored, or maintained (including, among other 24 things, testimony, transcripts, and tangible things), that are produced or generated in 25 disclosures or responses to discovery in this matter. 26 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent 27 to the litigation who has been retained by a Party or its counsel to serve as an expert 28 witness or as a consultant in this Action. TRÉPANIER TAJIMA LLP 3 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 2.8 House Counsel: attorneys who are employees of a party to this Action. House 2 Counsel does not include Outside Counsel of Record or any other outside counsel, except 3 that House Counsel does include attorneys (and their support staff) from the law firm of 4 Kirton McConkie in Salt Lake City, Utah. 5 6 7 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 8 Action but are retained to represent or advise a party to this Action and have appeared in 9 this Action on behalf of that party or are affiliated with a law firm which has appeared on 10 11 behalf of that party, and includes support staff. 2.11 Party: any party to this Action, including all of its officers, directors, 12 employees, consultants, retained experts, and Outside Counsel of Record (and their 13 support staffs). 14 15 16 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 support 17 services (e.g., photocopying, videotaping, translating, preparing exhibits or 18 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 19 their employees and subcontractors. 20 21 22 2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a 23 Producing Party. 24 3. SCOPE 25 The protections conferred by this Stipulation and Order cover not only Protected 26 Material (as defined above), but also (1) any information copied or extracted from 27 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 28 Material; and (3) any testimony, conversations, or presentations by Parties or their TRÉPANIER TAJIMA LLP 4 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 2 3 Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the trial judge. This Order does not govern the use of Protected Material at trial. 4 4. DURATION 5 Even after final disposition of this litigation, the confidentiality obligations imposed 6 by this Order shall remain in effect until a Designating Party agrees otherwise in writing 7 or a court order otherwise directs. Final disposition shall be deemed to be the later of (1) 8 dismissal of all claims and defenses in this Action, with or without prejudice; and (2) final 9 judgment herein after the completion and exhaustion of all appeals, rehearings, remands, 10 trials, or reviews of this Action, including the time limits for filing any motions or 11 applications for extension of time pursuant to applicable law. 12 5. DESIGNATING PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 14 Party or Non-Party that designates information or items for protection under this Order 15 must take care to limit any such designation to specific material that qualifies under the 16 appropriate standards. The Designating Party must designate for protection only those 17 parts of material, documents, items, or oral or written communications that qualify so that 18 other portions of the material, documents, items, or communications for which protection 19 is not warranted are not swept unjustifiably within the ambit of this Order. 20 Mass, indiscriminate, or routinized designations are prohibited. Designations that 21 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 22 to unnecessarily encumber the case development process or to impose unnecessary 23 expenses and burdens on other parties) may expose the Designating Party to sanctions. 24 If it comes to a Designating Party’s attention that information or items that it 25 designated for protection do not qualify for protection, that Designating Party must 26 promptly notify all other Parties that it is withdrawing the inapplicable designation. 27 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 28 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, TRÉPANIER TAJIMA LLP 5 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 Disclosure or Discovery Material that qualifies for protection under this Order must be 2 clearly so designated before the material is disclosed or produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic documents, but 5 excluding transcripts of depositions or other pretrial or trial proceedings), that the 6 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 7 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 8 portion or portions of the material on a page qualifies for protection, the Producing Party 9 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 10 11 in the margins). A Party or Non-Party that makes original documents available for inspection need 12 not designate them for protection until after the inspecting Party has indicated which 13 documents it would like copied and produced. During the inspection and before the 14 designation, all of the material made available for inspection shall be deemed 15 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 16 copied and produced, the Producing Party must determine which documents, or portions 17 thereof, qualify for protection under this Order. Then, before producing the specified 18 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 19 that 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 (b) for testimony given in depositions that the Designating Party identify the 23 Disclosure or Discovery Material on the record, before the close of the deposition all 24 protected testimony. 25 (c) for information produced in some form other than documentary and for any 26 other tangible items, that the Producing Party affix in a prominent place on the exterior of 27 the container or containers in which the information is stored the legend 28 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, TRÉPANIER TAJIMA LLP 6 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 the Producing Party, to the extent practicable, shall identify the protected portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 3 designate qualified information or items does not, standing alone, waive the Designating 4 Party’s right to secure protection under this Order for such material. Upon timely 5 correction of a designation, the Receiving Party must make reasonable efforts to assure 6 that the material is treated in accordance with the provisions of this Order. 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 9 10 11 confidentiality at any time that is consistent with the Court’s Scheduling Order. 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 12 6.3 The burden of persuasion in any such challenge proceeding shall be on the 13 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to 14 harass or impose unnecessary expenses and burdens on other parties) may expose the 15 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the 16 confidentiality designation, all parties shall continue to afford the material in question the 17 level of protection to which it is entitled under the Producing Party’s designation until the 18 Court rules on the challenge. 19 7. ACCESS TO AND USE OF PROTECTED MATERIAL 20 7.1 Basic Principles. A Receiving Party may use Protected Material that is 21 disclosed or produced by another Party or by a Non-Party in connection with this Action 22 only for prosecuting, defending, or attempting to settle this Action. Such Protected 23 Material may be disclosed only to the categories of persons and under the conditions 24 described in this Order. When the Action has been terminated, a Receiving Party must 25 comply with the provisions of section 13 below (FINAL DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a location 27 and in a secure manner that ensures that access is limited to the persons authorized under 28 this Order. TRÉPANIER TAJIMA LLP 7 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 2 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 3 may disclose any information or item designated “CONFIDENTIAL” only to: 4 (a) the parties in this Action, including a party’s Guardian ad Litem; 5 (b) the Receiving Party’s Outside Counsel of Record in this Action, as well as 6 employees of said Outside Counsel of Record to whom it is reasonably necessary to 7 disclose the information for this Action; 8 9 10 (c) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; (d) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 11 reasonably necessary for this Action and who have signed the “Acknowledgment and 12 Agreement to Be Bound” (Exhibit A); 13 (e) the court and its personnel; 14 (f) court reporters and their staff; 15 (g) professional jury or trial consultants, mock jurors, and Professional Vendors to 16 whom disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 19 20 (h) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; (i) during their depositions, witnesses, and attorneys for witnesses, in the Action to 21 whom disclosure is reasonably necessary provided: (1) the deposing party requests that 22 the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be permitted 23 to keep any confidential information unless they sign the “Acknowledgment and 24 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party 25 or ordered by the court. Pages of transcribed deposition testimony or exhibits to 26 depositions that reveal Protected Material may be separately bound by the court reporter 27 and may not be disclosed to anyone except as permitted under this Stipulated Protective 28 Order; and TRÉPANIER TAJIMA LLP 8 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 2 3 4 5 (j) any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION If a Party is served with a subpoena or a court order issued in other litigation that 6 compels disclosure of any information or items designated in this Action as 7 “CONFIDENTIAL,” that Party must: 8 9 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or order to issue 11 in the other litigation that some or all of the material covered by the subpoena or order is 12 subject to this Protective Order. Such notification shall include a copy of this Stipulated 13 Protective Order; and 14 15 16 (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 the 17 subpoena or court order shall not produce any information designated in this action as 18 “CONFIDENTIAL” before a determination by the court from which the subpoena or 19 order issued, unless the Party has obtained the Designating Party’s permission. The 20 Designating Party shall bear the burden and expense of seeking protection in that court of 21 its confidential material and nothing in these provisions should be construed as 22 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 23 from another court. 24 25 26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION (a) The terms of this Order are applicable to information produced by a Non-Party 27 in this Action and designated as “CONFIDENTIAL.” Such information produced by Non- 28 Parties in connection with this litigation is protected by the remedies and relief provided TRÉPANIER TAJIMA LLP 9 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party 2 from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to produce a 4 Non-Party’s confidential information in its possession, and the Party is subject to an 5 agreement with the Non-Party not to produce the Non-Party’s confidential information, 6 then the Party shall: 7 8 (1) promptly notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; 9 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 10 in this Action, the relevant discovery request(s), and a reasonably specific description of 11 the information requested; and 12 13 14 (3) make the information requested available for inspection by the Non-Party, if requested. (c) If the Non-Party fails to seek a protective order from this court within 14 days of 15 receiving the notice and accompanying information, the Receiving Party may produce the 16 Non-Party’s confidential information responsive to the discovery request. If the Non-Party 17 timely seeks a protective order, the Receiving Party shall not produce any information in 18 its possession or control that is subject to the confidentiality agreement with the Non- 19 Party before a determination by the court. Absent a court order to the contrary, the Non- 20 Party shall bear the burden and expense of seeking protection in this court of its Protected 21 Material. 22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 Protected Material to any person or in any circumstance not authorized under this 25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 26 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 27 unauthorized copies of the Protected Material, (c) inform the person or persons to whom 28 unauthorized disclosures were made of all the terms of this Order, and (d) request such TRÉPANIER TAJIMA LLP 10 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is 2 attached hereto as Exhibit A. 3 4 5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL When a Producing Party gives notice to Receiving Parties that certain inadvertently 6 produced material is subject to a claim of privilege or other protection, the obligations of 7 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 8 This provision is not intended to modify whatever procedure may be established in an e- 9 discovery order that provides for production without prior privilege review. Pursuant to 10 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 11 effect of disclosure of a communication or information covered by the attorney-client 12 privilege or work product protection, the parties may incorporate their agreement in the 13 stipulated protective order submitted to the court. 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person 16 17 to seek its modification by the Court in the future. 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 18 Order no Party waives any right it otherwise would have to object to disclosing or 19 producing any information or item on any ground not addressed in this Stipulated 20 Protective Order. Similarly, no Party waives any right to object on any ground to use in 21 evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 23 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 24 under seal pursuant to a court order authorizing the sealing of the specific Protected 25 Material at issue. If a Party's request to file Protected Material under seal is denied by the 26 court, then the Receiving Party may file the information in the public record unless 27 otherwise instructed by the court. 28 TRÉPANIER TAJIMA LLP 11 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 days 3 of a written request by the Designating Party, each Receiving Party must return all 4 Protected Material to the Producing Party or destroy such material. As used in this 5 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected Material. 7 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 8 a written certification to the Producing Party (and, if not the same person or entity, to the 9 Designating Party) by the 60 day deadline that (1) identifies (by category, where 10 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 11 the Receiving Party has not retained any copies, abstracts, compilations, summaries or any 12 other format reproducing or capturing any of the Protected Material. Notwithstanding this 13 provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, 14 trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition 15 and trial exhibits, expert reports, attorney work product, and consultant and expert work 16 product, even if such materials contain Protected Material. Any such archival copies that 17 contain or constitute Protected Material remain subject to this Protective Order as set forth 18 in Section 4 (DURATION). 19 20 21 22 23 24 25 26 27 28 TRÉPANIER TAJIMA LLP 12 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 2 14. Any violation of this Order may be punished by any and all appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. 3 4 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. Dated: November 9, 2023 ___/s/ Lisa Dearden Trépanier___________ TRÉPANIER TAJIMA LLP Lisa Dearden Trépanier Attorneys for Defendants Dated: November 9, 2023 ___/s/ Eric G. Rudin___________________ BAER TREGER LLP Tracy M. Baer Andrew L. Treger Eric G. Rudin Wesley J. Krieger Attorneys for Plaintiff John CL Doe 7 8 9 10 11 12 13 14 15 16 17 18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. November 13, 2023 DATED:________________________ 19 _____________________________________ The Honorable Kenly Kiya Kato 21 United States Magistrate Judge 20 22 23 24 25 26 27 28 TRÉPANIER TAJIMA LLP 13 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 2 Certification Pursuant to Local Rule 5-4.3.4(a)(2)(i) Pursuant to Local Rule 5-4.3.4(a)(2)(i), signatory hereby does attest that all 3 signatories listed, and on whose behalf the filing is submitted, concur in the filing’s 4 content and have authorized the filing. 5 6 Dated: November 9, 2023 TRÉPANIER TAJIMA LLP 7 8 9 10 /s/ Lisa Dearden Trépanier Lisa Dearden Trépanier Attorneys for Defendants 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TRÉPANIER TAJIMA LLP 14 [PROPOSED] STIPULATED PROTECTIVE ORDER 1 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 TRÉPANIER TAJIMA LLP EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 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 John CL Doe v. Corporation of the President of The Church of Jesus Christ of Latterday Saints, et al., Case No. 5:23-cv-2005-JFW (KKx). 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: _______________________________ Signature: __________________________________ 15 [PROPOSED] STIPULATED PROTECTIVE ORDER

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