Daniel Kim et al v. Daniel Y. Kim

Filing 23

PROTECTIVE ORDER by Magistrate Judge Frederick F. Mumm re Stipulation for Protective Order 22 . (see document for details) (hr)

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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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DANIEL KIM, an individual, and THE
LAW OFFICES OF DANIEL KIM,
CORPORATION, a California
corporation,

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Plaintiffs,
vs.

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DANIEL Y. KIM dba THE LAW
OFFICES OF DANIEL KIM, an
individual,

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Defendant.

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DANIEL Y. KIM, an individual,

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Counterclaimant,

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v.
DANIEL KIM, an individual; THE
LAW OFFICES OF DANIEL KIM, a
California corporation,
Counter-Defendants.

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Case No.: 8:19−cv−00755 JVS (FFM)
Honorable James V. Selna
PROTECTIVE ORDER PURSUANT
TO STIPULATION

[Discovery Document:
Referred to Magistrate Judge
Frederick F. Mumm]

-1Stipulated Protective Order

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1.

A. PURPOSES AND LIMITATIONS

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

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proprietary, or private information for which special protection from public

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

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

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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

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discovery and that the protection it affords from public disclosure and use extends

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

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under the applicable legal principles. The parties further acknowledge, as set forth

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in Section 12.3, below, that this Stipulated Protective Order does not entitle them

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to file confidential information under seal; Civil Local Rule 79-5 sets forth the

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procedures that must be followed and the standards that will be applied when a party

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seeks permission from the court to file material under seal.

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B. GOOD CAUSE STATEMENT

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In discovery in this case, the parties will be required to exchange

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competitively sensitive information about the opposing parties’ business activities

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to which they and third parties would not otherwise have access, including, but not

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limited to, the parties’ business proprietary and/or confidential business or financial

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information, information regarding confidential business practices, or other

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confidential research, development, or commercial information (including

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information implicating privacy rights of third parties), customer and pricing lists

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and other valuable research, information otherwise generally unavailable to the

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public, or which may be privileged or otherwise protected from disclosure under

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state or federal statutes, court rules, case decisions, or common law. Allowing the

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parties or third parties to use such competitively sensitive information would cause

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harm to the competitive position of the disclosing party. The parties seek the entry

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///

-2Stipulated Protective Order

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of this Protective Order to prevent the unauthorized use or dissemination of

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confidential information produced in discovery during this action by competitors.
a.

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No document, information, or thing shall be designated

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“CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY”

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unless good cause exists for such designation under the standards set forth in

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Phillips v. G.M. Corp., 307 F.2d 1206, 1209 (9th Cir. 2002) and other relevant

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authority.

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“CONFIDENTIAL – ATTORNEYS’ EYES ONLY” when the information has not

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been made public and falls into one of the categories identified in paragraph 5.2(b)

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Good cause exists for the designation of information as

hereof.
b.

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Good cause exists for the designation of information as

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“CONFIDENTIAL” when the information has not been revealed to the public and

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the information falls into one of the categories identified in paragraph 5.2(a) hereof.
c.

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The Parties shall use reasonable efforts to minimize the amount

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of material designated as “CONFIDENTIAL” or “CONFIDENTIAL –

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ATTORNEYS’ EYES ONLY.”
d.

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This Protective Order applies to such “CONFIDENTIAL” and

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“CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information furnished in this

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litigation regardless of the form in which it is transmitted and regardless whether

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the information is furnished by a party or third party. Such information may be

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contained in documents, written discovery responses, declarations, deposition

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testimony, exhibits, and other materials or deposition testimony provided by any

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Party.

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2.

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DEFINITIONS
2.1

Action: This above-captioned federal law suit, entitled Daniel Kim, et

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al. v. Daniel Y. Kim, et al., U.S. District Court for the Central District of California,

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Case No. 8:19-cv-00755-JVS-FFM, including any counterclaims, cross-claims,

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consolidated actions, or related actions.

-3Stipulated Protective Order

2.2

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Challenging Party:

a Party or Non-Party that challenges the

designation of information or items under this Order.
2.3

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“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), and as specified above in

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the Good Cause Statement.
2.4

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Counsel: Outside Counsel of Record and House Counsel (as well as

their support staff).
2.5

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

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

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“CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
2.6

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Disclosure or Discovery Material: all items or information, regardless

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of the 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

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or generated in disclosures or responses to discovery in this matter.
2.7

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

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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.
2.8

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

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House Counsel does not include Outside Counsel of Record or any other outside

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counsel.
2.9

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

or other legal entity not named as a Party to this action.

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

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

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have appeared in this Action on behalf of that party or are affiliated with a law firm

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which has appeared on behalf of that party, and includes support staff.

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-4Stipulated Protective Order

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

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

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

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Discovery Material in this Action.
2.13 Professional Vendors:

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persons or entities that provide litigation

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support 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.

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2.14 Protected Material: any Disclosure or Discovery Material that is

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designated as “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY.”
2.15 Receiving Party:

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a Party that receives Disclosure or Discovery

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Material from a Producing Party.

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3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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

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

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compilations of Protected Material; and (3) any testimony, conversations, or

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presentations by Parties or their Counsel that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders of the

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trial judge. This Order does not govern the use of Protected Material at trial.

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4.

DURATION

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Even after final disposition of this litigation, the confidentiality obligations

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

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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,

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with or without prejudice; and (2) final judgment herein after the completion and

-5Stipulated Protective Order

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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

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pursuant to applicable law.

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5.

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DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

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

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

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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

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

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

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unjustifiably within the ambit of this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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

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

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

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Party to sanctions.

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

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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 inapplicable designation.

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5.2

Manner and Timing of Designations. Except as otherwise provided in

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this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material

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that qualifies for protection under this Order must be clearly so designated before

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the material is disclosed or produced.

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Designation in conformity with this Order requires:

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a.

Any

Producing

Party

may

designate

any

material

as

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“CONFIDENTIAL” if such producing party in good faith believes that such

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Protected Material contains confidential or proprietary information, including

-6Stipulated Protective Order

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information in written, oral, electronic, graphic, pictorial, audiovisual, or other

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form, whether it is a document, information contained in a document, item produced

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for inspection, information revealed during a deposition, information revealed in an

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interrogatory answer, or otherwise.

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b.

Any

Producing

Party

may

designate

any

material

as

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“CONFIDENTIAL—ATTORNEYS’ EYES ONLY” if such producing party in

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good faith believes that such Protected Material contains confidential,

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commercially sensitive, or proprietary information related to any of the following:

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technical data, research and development information, marketing or other business

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plans, product or service information, customer information, trade secrets,

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competitive information, or financial information of the Producing Party, including,

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without limitation, sales and cost information or any other information of such

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sensitivity to warrant “Confidential—Attorneys’ Eyes Only” treatment, including,

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information in written, oral, electronic, graphic, pictorial, audiovisual, or other

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form, whether it is a document, information contained in a document, item produced

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for inspection, information revealed during a deposition, information revealed in an

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interrogatory answer, or otherwise.

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c.

A Producing Party may designate any document or other tangible

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information or thing as “Confidential” or “Confidential—Attorneys’ Eyes Only” by

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stamping a conspicuous place thereof with the legend CONFIDENTIAL or

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CONFIDENTIAL—ATTORNEYS’ EYES ONLY, respectively. For example, in

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the case of a document, a producing party may so mark the first page of a multipage

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document and each page thereafter that actually contains Protected Material. In the

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case of other tangible items, a producing party may so mark any appropriate

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location. For example, in the case of a computer disk, a producing party may so

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mark the disk cover.

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d.
produced

The terms of this Protective Order are applicable to Protected Material
by

a

non-party

and

designated

-7Stipulated Protective Order

“CONFIDENTIAL”

or

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“CONFIDENTIAL—ATTORNEYS’ EYES ONLY” only when the producing

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non-party has a proprietary interest or other right in such Protected Material, or

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where the producing non-party is contractually obligated to maintain the

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confidentiality of such Protected Material. A producing party may designate

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documents, information, or things disclosed at a deposition of a producing party or

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one of its present or former officers, directors, employees, agents, or independent

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experts retained for purposes of this litigation as “Confidential” or “Confidential—

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Attorneys’ Eyes Only” on the record during the deposition; or by notifying all

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parties in writing of the specific item so designated, within twenty one (21) days

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of receiving a copy of the deposition transcript, of the specific exhibits or lines and

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pages of the transcript that are believed in good faith to contain Protected Material.

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i.

If a producing party designates such materials as “Confidential”

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or “Confidential—Attorneys’ Eyes Only” on the record, the court reporter

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shall indicate on the cover page of the transcript that the transcript includes

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Confidential or Confidential—Attorneys’ Eyes Only information, shall list

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the pages and lines numbers and/or exhibits of the transcript on or in which

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such information is contained, and shall bind the transcript in separate

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portions containing Confidential, Confidential—Attorneys’ Eyes Only, and

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non-Confidential material.

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Confidential or Confidential—Attorneys’ Eyes Only information is

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discussed during the deposition, any person present during the deposition

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who is not a Qualified Person, as defined below, or the court reporter, shall

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be excluded from that portion of the deposition.

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ii.

Further, during the period in which such

A deposition transcript and the exhibits thereto shall be

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presumed Confidential—Attorneys’ Eyes Only in their entirety until twenty

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one (21) days after receipt of the transcript by the producing party. If, after

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the deposition is taken, the producing party designates any portion of the

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deposition transcript or exhibits as “Confidential” or “Confidential—

-8Stipulated Protective Order

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Attorneys’ Eyes Only” by giving written notice as described above, all

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persons receiving notice of such designation shall affix the same to the face

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of their copy or copies of the transcript. At the expiration of the twenty one

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(21) day period, the transcript and exhibits shall automatically revert to non-

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Confidential status, except those portions that have been designated on the

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record or in writing as “Confidential” or “Confidential—Attorneys’ Eyes

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Only.” Nothing in this paragraph is intended to restrict any Party’s right to

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attend depositions in this action.
iii.

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A non-producing party may designate documents, information,

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or things disclosed at a deposition as “Confidential” or “Confidential—

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Attorneys’ Eyes Only” in the same manner as a producing party if it has a

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good faith basis for claiming a proprietary interest or other right in the

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Confidential Material.
e.

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Material designated as confidential under this Protective Order, the

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information contained therein, and any summaries, copies, abstracts, or other

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documents derived in whole or in part from material designated as Protected

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Material shall be used only for the purpose of the prosecution, defense, or settlement

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of this action, and for no other purpose, except that a Party may seek permission

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from another court to use Protected Material produced under this Protective Order

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provided said Party gives advance notice to the parties whose materials are sought

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to be used and provided no disclosure of such Protected Material is made until such

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other court grants the request for permission. The restrictions contained in this

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paragraph may be modified by written agreement of the parties, but such

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modifications will not be considered part of this order unless approved by the Court.

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Nothing in this paragraph shall operate to bar motions in limine or similar motion

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to exclude the use of any document in any action between the Parties on any

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appropriate and available basis.

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-9Stipulated Protective Order

5.3

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Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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the 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 of this

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Order.

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6.

6.1

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

designation of confidentiality at any time that is consistent with the Court’s
Scheduling Order.
6.2

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CHALLENGING CONFIDENTIALITY DESIGNATIONS

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.
6.3

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

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

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purpose (e.g., to harass or impose unnecessary expenses and burdens on other

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parties) may expose the Challenging Party to sanctions. Unless the Designating

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Party has waived or withdrawn the confidentiality designation, all parties shall

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continue to afford the material in question the level of protection to which it is

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entitled under the Producing Party’s designation until the Court rules on the

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challenge.

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7.

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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

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

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disclosed or produced by another Party or by a Non-Party in connection with this

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Action only for prosecuting, defending, or attempting to settle this Action. Such

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Protected Material may be disclosed only to the categories of persons and under the

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conditions described in this Order. When the Action has been terminated, a

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Receiving Party must comply with the provisions of section 13 below (FINAL

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DISPOSITION).

-10Stipulated Protective Order

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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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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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otherwise ordered by the court or permitted in writing by the Designating Party, a

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Receiving

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“CONFIDENTIAL” only to “qualified persons” below:

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Party

may

disclose

any

information

or

item

designated

(a) any Party, including any officers, directors, and employees (including
House Counsel) to whom disclosure is reasonably necessary for this Action;

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

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

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to disclose the information for this Action;

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

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

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

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(d) the court and its personnel;

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(e) court reporters and their staff;

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

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

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

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

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

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

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requests that the witness sign the form attached as Exhibit A hereto; and (2) they

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will not be permitted to keep any confidential information unless they sign the

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

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

-11Stipulated Protective Order

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deposition testimony or exhibits to depositions that reveal Protected Material may

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be separately bound by the court reporter and may not be disclosed to anyone except

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as permitted under this Stipulated Protective Order; and
(i)

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5

any mediator or settlement officer, and their supporting personnel,

mutually agreed upon by any of the parties engaged in settlement discussions.
7.3

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Disclosure of “CONFIDENTIAL – ATTORNEYS’ EYES ONLY”

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Information or Items. Unless otherwise ordered by the court or permitted in writing

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by the Designating Party, a Receiving Party may disclose any information or item

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designated “CONFIDENTIAL – ATTORNEYS’ EYES ONLY” to the “qualified

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persons” listed in sub-paragraphs 7.2(b) through (i) above, but shall not be disclosed

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to a Party, or to an officer, director or employee of a Party, except as provided above

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or unless otherwise agreed in writing or ordered by the Court. If disclosure of

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Attorneys’ Eyes Only Material is made pursuant to this paragraph, all other

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provisions in this order with respect to confidentiality shall also apply.

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8.

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PRODUCED IN OTHER LITIGATION

PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

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

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that compels disclosure of any information or items designated in this Action as

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“CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” that

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Party must:

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

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

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

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

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this Stipulated Protective Order; and

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(c) cooperate with respect to all reasonable procedures sought to be pursued
by the Designating Party whose Protected Material may be affected.

-12Stipulated Protective Order

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If the Designating Party timely seeks a protective order, the Party served with

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the subpoena or court order shall not produce any information designated in this

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action as “CONFIDENTIAL” of “CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY,” before a determination by the court from which the subpoena or order

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issued, unless the Party has obtained the Designating Party’s permission. The

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Designating Party shall bear the burden and expense of seeking protection in that

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court of its confidential material and nothing in these provisions should be

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construed as authorizing or encouraging a Receiving Party in this Action to disobey

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a lawful directive from another court.

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9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

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PRODUCED IN THIS LITIGATION

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

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Party in this Action and designated as “CONFIDENTIAL” of “CONFIDENTIAL

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– ATTORNEYS’ EYES ONLY.” Such information produced by Non-Parties in

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connection with this litigation is protected by the remedies and relief provided by

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this Order. Nothing in these provisions should be construed as prohibiting a Non-

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Party from seeking additional protections.

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

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produce a Non-Party’s confidential information in its possession, and the Party is

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subject to an agreement with the Non-Party not to produce the Non-Party’s

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confidential information, then the Party shall:

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(1) promptly notify in writing the Requesting Party and the Non-Party

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

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agreement with a Non-Party;

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

26

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

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specific description of the information requested; and

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-13Stipulated Protective Order

(3) make the information requested available for inspection by the

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2

Non-Party, if requested.

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

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days of receiving the notice and accompanying information, the Receiving Party

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may produce the Non-Party’s confidential information responsive to the discovery

6

request. If the Non-Party timely seeks a protective order, the Receiving Party shall

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not produce any information in its possession or control that is subject to the

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confidentiality agreement with the Non-Party before a determination by the court.

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Absent a court order to the contrary, the Non-Party shall bear the burden and

10

expense of seeking protection in this court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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to retrieve all unauthorized copies of the Protected Material, (c) inform the person

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or persons to whom unauthorized disclosures were made of all the terms of this

18

Order, and (d) request such person or persons to execute the “Acknowledgment and

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Agreement to Be Bound” that is attached hereto as Exhibit A.

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11.

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OTHERWISE PROTECTED MATERIAL

INADVERTENT

PRODUCTION

OF

PRIVILEGED

OR

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When a Producing Party gives notice to Receiving Parties that certain

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

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

25

Procedure 26(b)(5)(B). This provision is not intended to modify whatever

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procedure may be established in an e-discovery order that provides for production

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without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

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(e), insofar as the parties reach an agreement on the effect of disclosure of a

-14Stipulated Protective Order

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communication or information covered by the attorney-client privilege or work

2

product protection, the parties may incorporate their agreement in the stipulated

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protective order submitted to the court.

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12.

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

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6

MISCELLANEOUS

person to seek its modification by the Court in the future.

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

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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

10

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

11

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

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

13

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

14

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

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specific Protected Material at issue. If a Party's request to file Protected Material

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under seal is denied by the court, then the Receiving Party may file the information

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in the public record unless otherwise instructed by the court.

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13.

FINAL DISPOSITION

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

20

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

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

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

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compilations, summaries, and any other format reproducing or capturing any of the

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

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Receiving Party must submit a written certification to the Producing Party (and, if

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not the same person or entity, to the Designating Party) by the 60 day deadline that

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(1) identifies (by category, where appropriate) all the Protected Material that was

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returned or destroyed and (2) affirms that the Receiving Party has not retained any

-15Stipulated Protective Order

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copies, abstracts, compilations, summaries or any other format reproducing or

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capturing any of the Protected Material. Notwithstanding this provision, Counsel

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are entitled to retain an archival copy of all pleadings, motion papers, trial,

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deposition, and hearing transcripts, legal memoranda, correspondence, deposition

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and trial exhibits, expert reports, attorney work product, and consultant and expert

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work product, even if such materials contain Protected Material. Any such archival

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copies that contain or constitute Protected Material remain subject to this Protective

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Order as set forth in Section 4 (DURATION).

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED,

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DATED: October 4, 2019

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/S/ Frederick F. Mumm
FREDERICK F. MUMM
United States Magistrate Judge

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-16Stipulated Protective Order

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

_____________________________

[print

or

type

full

name],

of

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_________________ [print or type full address], declare under penalty of perjury

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that I have read in its entirety and understand the Stipulated Protective Order that

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was issued by the United States District Court for the Central District of California

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on [date] in the case of Daniel Kim, et al. v. Daniel Y. Kim, et al., U.S. District Court

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for the Central District of California, Case No. 8:19-cv-00755-JVS-FFM. I agree to

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comply with and to be bound by all the terms of this Stipulated Protective Order

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and I understand and acknowledge that failure to so comply could expose me to

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sanctions and punishment in the nature of contempt. I solemnly promise that I will

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not disclose in any manner any information or item that is subject to this Stipulated

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Protective Order to any person or entity except in strict compliance with the

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provisions of this Order.

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I further agree to submit to the jurisdiction of the United States District Court

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for the Central District of California for the purpose of enforcing the terms of this

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action. I hereby appoint __________________________ [print

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or type full name] of _______________________________________ [print or type

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full address and telephone number] as my California agent for service of process in

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connection with this action or any proceedings related to enforcement of this

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Stipulated Protective Order.

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Date:

City and State where executed:____________________

Printed name: _______________________________
Signature: __________________________________

-17Stipulated Protective Order