Grupo Salinas Inc. v. J R Salinas Wheels and Tires Inc. et al

Filing 47

STIPULATED PROTECTIVE ORDER 46 by Magistrate Judge Karen E. Scott. (es)

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1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 10 12 GRUPO SALINAS INC. DBA SALINAS TIRES & WHEELS, a California corporation, 13 Plaintiff, 11 vs. 14 17 J R SALINAS WHEELS & TIRES INC., a California corporation; JJTS, INC., a California corporation; and SALINAS WHEELS & TIRES, a California company, 18 Case No. 8:16-cv-01923 JVS (KESx) STIPULATED PROTECTIVE ORDER [DISCOVERY DOCUMENT: REFERRED TO MAGISTRATE JUDGE KAREN E. SCOTT] Defendants. 15 16 19 20 21 1. A. PURPOSES AND LIMITATIONS 22 Discovery in this action is likely to involve production of confidential, 23 proprietary, or private information for which special protection from public 24 disclosure and from use for any purpose other than prosecuting this litigation may 25 be warranted. Accordingly, the parties hereby stipulate to and petition the Court 26 to enter the following Stipulated Protective Order. The parties acknowledge that 27 this Order does not confer blanket protections on all disclosures or responses to 28 discovery and that the protection it affords from public disclosure and use extends 1 only to the limited information or items that are entitled to confidential treatment 2 under the applicable legal principles. The parties further acknowledge, as set forth 3 in Section 12.3, below, that this Stipulated Protective Order does not entitle them 4 to file confidential information under seal; Civil Local Rule 79-5 sets forth the 5 procedures that must be followed and the standards that will be applied when a 6 party seeks permission from the court to file material under seal. 7 B. 9 This action is likely to involve customer, vendor, and pricing lists and other 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 8 valuable commercial, financial and/or proprietary information for which special 11 protection from public disclosure and from use for any purpose other than 12 prosecution of this action is warranted. Such confidential and proprietary 13 materials and information consist of, among other things, confidential business or 14 financial information, information regarding confidential business practices, or 15 other confidential personal or commercial information (including information 16 implicating privacy rights of third parties), information otherwise generally 17 unavailable to the public, or which may be privileged or otherwise protected from 18 disclosure under state or federal statutes, court rules, case decisions, or common 19 law. Accordingly, to expedite the flow of information, to facilitate the prompt 20 resolution of disputes over confidentiality of discovery materials, to adequately 21 protect information the parties are entitled to keep confidential, to ensure that the 22 parties are permitted reasonable necessary uses of such material in preparation for 23 and in the conduct of trial, to address their handling at the end of the litigation, 24 and serve the ends of justice, a protective order for such information is justified in 25 this matter. It is the intent of the parties that information will not be designated as 26 confidential for tactical reasons and that nothing be so designated without a good 27 faith belief that it has been maintained in a confidential, non-public manner, and 28 there is good cause why it should not be part of the public record of this case. GOOD CAUSE STATEMENT -2- 1 2 3 4 5 6 2. DEFINITIONS 2.1 Action: Grupo Salinas, Inc. v. JJTS, Inc. et. al Case No. 8:16-cv- 01923 JVS (KESx). 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 7 how it is generated, stored or maintained) or tangible things that qualify for 8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 9 the Good Cause Statement. 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 10 2.4 HIGHLY CONFIDENTIAL - AEO Information or Items: 11 information (regardless of how it is generated, stored or maintained) or tangible 12 things that qualify for protection under Federal Rule of Civil Procedure 26(c), and 13 as specified above in the Good Cause Statement. 14 CONFIDENTIAL – AEO designation is limited to material that is so 15 commercially sensitive that a party would be at a severe economic disadvantage if 16 its competitors were able to review the material. 17 CONFIDENTIAL – AEO material include, but are not limited to customer lists 18 and trade secrets. 19 2.5 20 21 The HIGHLY Examples of HIGHLY Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.6 Designating Party: a Party or Non-Party that designates information 22 or items that it produces in disclosures or in responses to discovery as 23 “CONFIDENTIAL.” 24 2.7 Disclosure or Discovery Material: all items or information, 25 regardless of the medium or manner in which it is generated, stored, or 26 maintained (including, among other things, testimony, transcripts, and tangible 27 things), that are produced or generated in disclosures or responses to discovery in 28 this matter. -3- 1 2.8 Expert: a person with specialized knowledge or experience in a 2 matter pertinent to the litigation who has been retained by a Party or its counsel to 3 serve as an expert witness or as a consultant in this Action. 4 2.9 House Counsel: attorneys who are employees of a party to this 5 Action. House Counsel does not include Outside Counsel of Record or any other 6 outside counsel. 7 8 2.10 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.11 Outside Counsel of Record: attorneys who are not employees of a 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 9 party to this Action but are retained to represent or advise a party to this Action 11 and have appeared in this Action on behalf of that party or are affiliated with a 12 law firm which has appeared on behalf of that party, and includes support staff. 13 2.12 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and 15 their support staffs). 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 16 17 Discovery Material in this Action. 2.14 Professional Vendors: 18 persons or entities that provide litigation 19 support services (e.g., photocopying, videotaping, translating, preparing exhibits 20 or demonstrations, and organizing, storing, or retrieving data in any form or 21 medium) and their employees and subcontractors. 2.15 Protected Material: any Disclosure or Discovery Material that is 22 23 designated as CONFIDENTIAL or HIGHLY CONFIDENTIAL - AEO 2.16 Receiving Party: 24 a Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 // 27 // 28 // -4- 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 8 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. 9 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 10 4. DURATION 11 Even after final disposition of this litigation, the confidentiality obligations 12 imposed by this Order shall remain in effect until a Designating Party agrees 13 otherwise in writing or a court order otherwise directs. Final disposition shall be 14 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 15 with or without prejudice; and (2) final judgment herein after the completion and 16 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 17 including the time limits for filing any motions or applications for extension of 18 time pursuant to applicable law. 19 20 21 5. DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material 22 for Protection. Each Party or Non-Party that designates information or items for 23 protection under this Order must take care to limit any such designation to 24 specific material that qualifies under the appropriate standards. The Designating 25 Party must designate for protection only those parts of material, documents, 26 items, or oral or written communications that qualify so that other portions of the 27 material, documents items, or communications for which protection is not 28 warranted are not swept unjustifiably within the ambit of this Order. -5- 1 Mass, indiscriminate, or routinized designations are prohibited. 2 Designations that are shown to be clearly unjustified or that have been made for 3 an improper purpose (e.g., to unnecessarily encumber the case development 4 process or to impose unnecessary expenses and burdens on other parties) may 5 expose the Designating Party to sanctions. 6 If it comes to a Designating Party’s attention that information or items that 7 it designated for protection do not qualify for protection, that Designating Party 8 must promptly notify all other Parties that it is withdrawing the inapplicable 9 designation. 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 10 5.2 Manner and Timing of Designations. Except as otherwise provided 11 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 12 stipulated or ordered, Disclosure or Discovery Material that qualifies for 13 protection under this Order must be clearly so designated before the material is 14 disclosed or produced. 15 Designation in conformity with this Order requires: 16 (a) for information in documentary form (e.g., paper or electronic 17 documents, but excluding transcripts of depositions or other pretrial or trial 18 proceedings), that the Producing Party affix at a minimum, the legend 19 CONFIDENTIAL to each page that contains protected material. 20 A Party or Non-Party that makes original documents available for 21 inspection need not designate them for protection until after the inspecting Party 22 has indicated which documents it would like copied and produced. During the 23 inspection and before the designation, all of the material made available for 24 inspection shall be deemed HIGHLY CONFIDENTIAL – AEO. After the 25 inspecting Party has identified the documents it wants copied and produced, the 26 Producing Party must determine which documents, or portions thereof, qualify for 27 protection under this Order. Then, before producing the specified documents, the 28 Producing Party must affix CONFIDENTIAL or HIGHLY CONFIDENTIAL – -6- 1 AEO as appropriate to each page that contains Protected Material. 2 (b) for testimony given in depositions that the Designating Party identify 3 the Disclosure or Discovery Material on the record, before 30 days after the close 4 of the deposition all protected testimony. 5 (c) for information produced in some form other than documentary and for any other tangible items, that the Producing Party affix in a prominent place 7 on the exterior of the container or containers in which the information is stored 8 the legend CONFIDENTIAL or HIGHLY CONFIDENTIAL – AEO as 9 appropriate. If only a portion or portions of the information warrants protection, 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 6 the Producing Party, to the extent practicable, shall identify the protected 11 portion(s). 12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 13 failure to designate qualified information or items does not, standing alone, waive 14 the Designating Party’s right to secure protection under this Order for such 15 material. Upon timely correction of a designation, the Receiving Party must make 16 reasonable efforts to assure that the material is treated in accordance with the 17 provisions of this Order. 18 19 20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 21 designation of confidentiality at any time that is consistent with the Court’s 22 Scheduling Order. 23 24 25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37.1 et seq. 6.3 The burden of persuasion in any such challenge proceeding shall be 26 on the Designating Party. Frivolous challenges, and those made for an improper 27 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 28 parties) may expose the Challenging Party to sanctions. Unless the Designating -7- 1 Party has waived or withdrawn the confidentiality designation, all parties shall 2 continue to afford the material in question the level of protection to which it is 3 entitled under the Producing Party’s designation until the Court rules on the 4 challenge. 5 6 7 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Non-Party in connection with 9 this Action only for prosecuting, defending, or attempting to settle this Action. 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 8 Such Protected Material may be disclosed only to the categories of persons and 11 under the conditions described in this Order. When the Action has been 12 terminated, a Receiving Party must comply with the provisions of section 13 13 below (FINAL DISPOSITION). 14 Protected Material must be stored and maintained by a Receiving Party at a 15 location and in a secure manner that ensures that access is limited to the persons 16 authorized under this Order. 17 7.2 Disclosure of CONFIDENTIAL Information or Items. Unless 18 otherwise ordered by the court or permitted in writing by the Designating Party, a 19 Receiving 20 CONFIDENTIAL only to: 21 (a) Party may disclose any information or item designated the Receiving Party’s Outside Counsel of Record in this Action, as 22 well as employees of said Outside Counsel of Record to whom it is reasonably 23 necessary to disclose the information for this Action; 24 25 26 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; (c) Experts (as defined in this Order) of the Receiving Party to whom 27 disclosure is reasonably necessary for this Action and who have signed the 28 “Acknowledgment and Agreement to Be Bound” (Exhibit A); -8- 1 (d) the court and its personnel; 2 (e) court reporters and their staff; 3 (f) professional jury or trial consultants, mock jurors, and Professional 4 Vendors to whom disclosure is reasonably necessary for this Action and who 5 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 7 8 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; (h) during their depositions, witnesses ,and attorneys for witnesses, in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 9 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 11 they will not be permitted to keep any confidential information unless they sign 12 the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 13 otherwise agreed by the Designating Party or ordered by the court. Pages of 14 transcribed deposition testimony or exhibits to depositions that reveal Protected 15 Material may be separately bound by the court reporter and may not be disclosed 16 to anyone except as permitted under this Stipulated Protective Order; and 17 18 19 (i) any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 7.3 Disclosure of HIGHLY-CONFIDENTIAL - AEO Information or 20 Items. Unless otherwise ordered by the court or permitted in writing by the 21 Designating Party, a Receiving Party may disclose any information or item 22 designated HIGHLY CONFIDENTIAL - AEO only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 24 well as employees of said Outside Counsel of Record to whom it is reasonably 25 necessary to disclose the information for this Action; 26 (b) Experts (as defined in this Order) of the Receiving Party to whom 27 disclosure is reasonably necessary for this Action and who have signed the 28 “Acknowledgment and Agreement to Be Bound” (Exhibit A); -9- 1 (c) the court and its personnel; 2 (d) court reporters and their staff; 3 (e) professional jury or trial consultants, mock jurors, and Professional 4 Vendors to whom disclosure is reasonably necessary for this Action and who 5 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 7 (f) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 8 (g) during their depositions, witnesses ,and attorneys for witnesses, in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 9 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 11 they will not be permitted to keep any confidential information unless they sign 12 the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 13 otherwise agreed by the Designating Party or ordered by the court. Pages of 14 transcribed deposition testimony or exhibits to depositions that reveal Protected 15 Material may be separately bound by the court reporter and may not be disclosed 16 to anyone except as permitted under this Stipulated Protective Order; and (h) 17 18 any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 19 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 21 IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other 23 litigation that compels disclosure of any information or items designated in this 24 Action as CONFIDENTIAL, or HIGHLY CONFIDENTIAL - AEO that Party 25 must: 26 27 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 28 -10- 1 (b) promptly notify in writing the party who caused the subpoena or 2 order 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 4 include a copy of this Stipulated Protective Order; and 5 6 (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 8 with the subpoena or court order shall not produce any information designated in 9 this action as CONFIDENTIAL or HIGHLY CONFIDENTIAL - AEO before a 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 7 determination by the court from which the subpoena or order issued, unless the 11 Party has obtained the Designating Party’s permission. The Designating Party 12 shall bear the burden and expense of seeking protection in that court of its 13 confidential material and nothing in these provisions should be construed as 14 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 15 directive from another court. 16 17 9. 18 PRODUCED IN THIS LITIGATION 19 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE (a) The terms of this Order are applicable to information produced by a 20 Non-Party in this Action and designated as CONFIDENTIAL or HIGHLY 21 CONFIDENTIAL - AEO. Such information produced by Non-Parties in 22 connection with this litigation is protected by the remedies and relief provided by 23 this Order. Nothing in these provisions should be construed as prohibiting a Non- 24 Party from seeking additional protections. 25 (b) In the event that a Party is required, by a valid discovery request, to 26 produce a Non-Party’s confidential information in its possession, and the Party is 27 subject to an agreement with the Non-Party not to produce the Non-Party’s 28 confidential information, then the Party shall: -11- 1 (1) promptly notify in writing the Requesting Party and the Non- 2 Party that some or all of the information requested is subject to a confidentiality 3 agreement with a Non-Party; 4 (2) promptly provide the Non-Party with a copy of the Stipulated 5 Protective Order in this Action, the relevant discovery request(s), and a 6 reasonably specific description of the information requested; and 7 8 (3) make the information requested available for inspection by the Non-Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this court 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 10 within 14 days of receiving the notice and accompanying information, the 11 Receiving Party may produce the Non-Party’s confidential information 12 responsive to the discovery request. If the Non-Party timely seeks a protective 13 order, the Receiving Party shall not produce any information in its possession or 14 control that is subject to the confidentiality agreement with the Non-Party before 15 a determination by the court. Absent a court order to the contrary, the Non-Party 16 shall bear the burden and expense of seeking protection in this court of its 17 Protected Material. 18 19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 20 If a Receiving Party learns that, by inadvertence or otherwise, it has 21 disclosed Protected Material to any person or in any circumstance not authorized 22 under this Stipulated Protective Order, the Receiving Party must immediately 23 (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use 24 its best efforts to retrieve all unauthorized copies of the Protected Material, 25 (c) inform the person or persons to whom unauthorized disclosures were made of 26 all the terms of this Order, and (d) request such person or persons to execute the 27 “Acknowledgment and Agreement to Be Bound” that is attached hereto as 28 Exhibit A. -12- 1 11. 2 PROTECTED MATERIAL INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other 5 protection, the obligations of the Receiving Parties are those set forth in 6 Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to 7 modify whatever procedure may be established in an e-discovery order that 8 provides for production without prior privilege review. Pursuant to Federal Rule 9 of Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 3 of disclosure of a communication or information covered by the attorney-client 11 privilege or work product protection, the parties may incorporate their agreement 12 in the stipulated protective order submitted to the court. 13 14 15 16 12. MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in 20 this Stipulated Protective Order. Similarly, no Party waives any right to object on 21 any ground to use in evidence of any of the material covered by this 22 Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any 24 Protected Material must comply with Civil Local Rule 79-5. Protected Material 25 may only be filed under seal pursuant to a court order authorizing the sealing of 26 the specific Protected Material at issue. If a Party's request to file Protected 27 Material under seal is denied by the court, then the Receiving Party may file the 28 information in the public record unless otherwise instructed by the court. -13- 1 13. FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 4, within 3 60 days of a written request by the Designating Party, each Receiving Party must 4 return all Protected Material to the Producing Party or destroy such material. 5 As used in this subdivision, “all Protected Material” includes all copies, abstracts, 6 compilations, summaries, and any other format reproducing or capturing any of 7 the Protected Material. Whether the Protected Material is returned or destroyed, 8 the Receiving Party must submit a written certification to the Producing Party 9 (and, if not the same person or entity, to the Designating Party) by the 60 day 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 2 deadline that (1) identifies (by category, where appropriate) all the Protected 11 Material that was returned or destroyed and (2) affirms that the Receiving Party 12 has not retained any copies, abstracts, compilations, summaries or any other 13 format reproducing or capturing any of the Protected Material. Notwithstanding 14 this provision, Counsel are entitled to retain an archival copy of all pleadings, 15 motion papers, trial, deposition, and hearing transcripts, legal memoranda, 16 correspondence, deposition and trial exhibits, expert reports, attorney work 17 product, and consultant and expert work product, even if such materials contain 18 Protected Material. Any such archival copies that contain or constitute Protected 19 Material remain subject to this Protective Order as set forth in Section 4 20 (DURATION). 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 // -14- 1 14. 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. Any violation of this Order may be punished by any and all appropriate 4 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. DATED 7 8 9 Attorneys for Plaintiff Grupo Salinas Inc. dba Salinas Wheels & Tires 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 10 11 DATED 12 13 Attorneys for Defendants J R Salinas Wheels & Tires Inc., JJTS, Inc., and Salinas Wheels & Tires 14 15 16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 DATED: February 08, 2017 18 19 20 21 Karen E. Scott United States Magistrate Judge 22 23 24 25 26 27 28 -15- 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of 7 California on [date] in the case of ___________ [insert formal name of the case 8 and the number and initials assigned to it by the court]. I agree to comply with 9 and to be bound by all the terms of this Stipulated Protective Order and 10 655 North Central Avenue Suite 2300 Glendale, CA 91203-1445 3 I understand and acknowledge that failure to so comply could expose me to 11 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 14 with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms 17 of this Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. I hereby appoint __________________________ 19 [print or type full name] of _______________________________________ 20 [print or type full address and telephone number] as my California agent for 21 service of process in connection with this action or any proceedings related to 22 enforcement of this Stipulated Protective Order. 23 Date: 24 City and State where sworn and signed: 25 Printed name: 26 27 Signature: 28 LBOLTER PAS1461021.3-*-02/7/17 2:43 PM -16-

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