James Troja v. Surfside Solutions, Inc. et al

Filing 30

STIPULATED PROTECTIVE ORDER by Magistrate Judge Douglas F. McCormick re Stipulation for Protective Order 29 . (See document for further details). (et)

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Christopher M. Engels, Esq (Bar No. 304855)
Sean B. Janzen (SBN 293426)
ENGELS LAW APC
JANZEN LAW
555 Anton Blvd, Ste. 150
Costa Mesa CA 92626
[phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff James Troja
[attorneys continued on next page]

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

[phone]

COSTA MESA CA 92626

TELEPHONE:

555 ANTON BLVD., STE.150

ENGELS LAW

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JAMES TROJA, an individual,
Plaintiff,

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Case No.: 8:23-cv-01137-CJC-DFM

STIPULATED PROTECTIVE
ORDER

vs.
SURFSIDE SOLUTIONS, INC. a New
York Corporation; MICHAEL BLANCHE,
an individual; JON LOWEN, an individual;
and DOES 1 through 30, inclusive,

Hon. Cormac J. Carney

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Defendants.
___________________________________
___________________________________

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-1DB2/ 47713936.3

STIPULATED PROTECTIVE ORDER

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[phone]

COSTA MESA CA 92626

TELEPHONE:

555 ANTON BLVD., STE.150

ENGELS LAW

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MORGAN, LEWIS & BOCKIUS LLP
Jennifer B. Zargarof Bar No. 204382
[e-mail]
Daniel R. Rodriguez, Bar No. 323955
[e-mail]
300 South Grand Avenue
Twenty-Second Floor
Los Angeles, CA 90071-3132
Tel: [phone]
Fax: [phone]
Adam E. Wagmeister, Bar No. 287534
[e-mail]
2049 Century Park East, Suite 700
Los Angeles, CA 90067-3109
Tel: [phone]
Fax: [phone]
Attorneys for Defendants
SURFSIDE SOLUTIONS, INC., MICHAEL
BLANCHE and JONATHON LOWEN

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STIPULATED PROTECTIVE ORDER

[phone]

COSTA MESA CA 92626

TELEPHONE:

555 ANTON BLVD., STE.150

ENGELS LAW

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A. PURPOSES AND LIMITATIONS

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Discovery in this action and any efforts by the parties to resolve this action

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are likely to involve production of confidential, proprietary, or private information

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for which special protection from public disclosure and from use for any purpose

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other than prosecuting or attempting to resolve this litigation may be warranted.

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Accordingly, the parties hereby stipulate to and petition the Court to enter the

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following Stipulated Protective Order. The parties acknowledge that this Order does

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not confer blanket protections on all disclosures or responses to discovery and that

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the protection it affords from public disclosure and use extends only to the limited

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information or items that are entitled to confidential treatment under the applicable

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legal principles. The parties further acknowledge, as set forth in Section 12.3,

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

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information under seal; Civil Local Rule 79-5 sets forth the procedures that must be

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followed and the standards that will be applied when a party seeks permission from

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the court to file material under seal.

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B. GOOD CAUSE STATEMENT

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This action is likely to involve claims of trade secrets, customer and pricing

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lists and other valuable research, development, commercial, financial, technical

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and/or proprietary information for which special protection from public disclosure

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and from use for any purpose other than prosecution of this action is warranted.

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Such confidential and proprietary materials and information consist of, among

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other things, confidential business or financial information, information regarding

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confidential business practices, or other confidential research, development, or

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commercial information (including information implicating privacy rights of third

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parties), information otherwise generally unavailable to the public, or which may

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be privileged or otherwise protected from disclosure under state or federal statutes,

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STIPULATED PROTECTIVE ORDER

[phone]

COSTA MESA CA 92626

TELEPHONE:

555 ANTON BLVD., STE.150

ENGELS LAW

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court rules, case decisions, or common law. Accordingly, to expedite the flow of

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information, to facilitate the prompt resolution of disputes over confidentiality of

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discovery materials, to adequately protect information the parties are entitled to

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keep confidential, to ensure that the parties are permitted reasonable necessary uses

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of such material in preparation for and in the conduct of trial, to address their

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handling at the end of the litigation, and serve the ends of justice, a protective order

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for such information is justified in this matter. It is the intent of the parties that

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

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nothing be so designated without a good faith belief that it has been maintained in

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a confidential, non-public manner, and there is good cause why it should not be part

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of the public record of this case.

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2.

DEFINITIONS

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2.1

Action: this pending federal lawsuit in the Central District of

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California, entitled Troja v. Surfside Solutions, Inc., et al., Case No. 8:23-cv-01137.
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

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of 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.

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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

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or items that it produces in disclosures or

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY.”

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in

responses

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STIPULATED PROTECTIVE ORDER

to

discovery

as

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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, depositions, or responses to discovery in this matter, or

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that is exchanged in the course of any case resolution efforts.

[phone]

COSTA MESA CA 92626

TELEPHONE:

2.7

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.

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555 ANTON BLVD., STE.150

Disclosure or Discovery Material: all items or information, regardless

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ENGELS LAW

2.6

2.8

“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”

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Information or Items: CONFIDENTIAL information (regardless of how it is

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generated, stored or maintained) or tangible things the disclosure of which is likely

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to cause competitive or commercial injury to the Producing Party or a Non-Party.

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2.9

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.

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

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

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

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

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

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2.12 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).

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2.13 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.

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STIPULATED PROTECTIVE ORDER

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2.14 Professional Vendors: persons or entities that provide litigation

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

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

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medium) and their employees and subcontractors.

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designated

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ATTORNEYS’ EYES ONLY.”

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[phone]

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TELEPHONE:

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ENGELS LAW

2.15 Protected Material: any Disclosure or Discovery Material that is
as

“CONFIDENTIAL”

2.16 Receiving Party:

or

“HIGHLY

CONFIDENTIAL

–

A Party that receives Disclosure or Discovery

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

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use of Protected Material at trial shall be governed by the orders of the trial judge.

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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

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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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STIPULATED PROTECTIVE ORDER

[phone]

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TELEPHONE:

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ENGELS LAW

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5. DESIGNATING PROTECTED MATERIAL

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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 materials, documents, items, or parts of oral or written

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communications that qualify so that material, documents, items, or communications

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for which protection is not warranted are not swept unjustifiably within the ambit

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of this Order. Mass, indiscriminate, or routinized designations are prohibited.

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

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

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to impose unnecessary expenses and burdens on other parties) may expose the

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Designating Party to sanctions. If it comes to a Designating Party’s attention that

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information or items that it designated for protection do not qualify for protection,

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that Designating Party must promptly notify all other Parties that it is withdrawing

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the inapplicable designation.

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5.2

Manner and Timing of Designations. Except as otherwise provided

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in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

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

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produced. Designation in conformity with this Order requires:

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(a)

for information in documentary form (e.g., paper or electronic

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

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proceedings), that the Producing Party affix

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY,” to each page of each document that contains protected material. A Party

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at

a

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STIPULATED PROTECTIVE ORDER

minimum,

the

legend

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or Non-Party that makes original documents available for

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designate them for protection until after the inspecting Party has indicated which

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documents it would like copied and produced. During the inspection and before the

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

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“CONFIDENTIAL.” After the inspecting Party has identified the documents, it

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

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qualify for protection under this Order. Then, before producing the specified

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documents, the Producing Party must affix the “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY” legend to each page of each

[phone]

COSTA MESA CA 92626

TELEPHONE:

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ENGELS LAW

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inspection need not

document that contains Protected Material.

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(b) for testimony given in depositions that the Designating Party either

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identify the Disclosure or Discovery Material on the record before the close of the

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deposition all protected testimony or provide written designations within ten days

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of receiving the final deposition transcript. Prior to the expiration of this ten day

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post-transcript

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CONFIDENTIAL.

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(c)

period,

the

deposition

testimony

shall

be

treated

as

for information produced in some form other than documentary and

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for any other tangible items, that the Producing Party affix in a prominent place on

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the exterior of the container or containers in which the information is stored the

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legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’

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EYES ONLY” If only a portion or portions of the information warrants protection,

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the Producing Party, to the extent practicable, shall identify the protected portion(s).

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5.3

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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STIPULATED PROTECTIVE ORDER

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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. CHALLENGING CONFIDENTIALITY DESIGNATIONS

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6.1

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designation of confidentiality at any time that is consistent with the Court’s

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Scheduling Order.

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[phone]

COSTA MESA CA 92626

TELEPHONE:

555 ANTON BLVD., STE.150

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ENGELS LAW

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

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 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. ACCESS TO AND USE OF PROTECTED MATERIAL

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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).

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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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STIPULATED PROTECTIVE ORDER

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[phone]

COSTA MESA CA 92626

or Items. Unless

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Receiving

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“CONFIDENTIAL” only to:
(a)

Party may disclose

any

information or

item

designated

the Receiving Party’s Outside Counsel of Record in this Action, as

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

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necessary to disclose the information for this Action.

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TELEPHONE:

Disclosure of “CONFIDENTIAL” Information

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

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555 ANTON BLVD., STE.150

7.2

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ENGELS LAW

authorized under this Order.

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(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

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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.
(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 1 hereto; and (2) they

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

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

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

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STIPULATED PROTECTIVE ORDER

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transcribed deposition testimony or exhibits to depositions that reveal Protected

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

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anyone except as permitted under this Stipulated Protective Order; and

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(i)

any mediator or settlement officer, and their supporting personnel,

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

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(j)

any other person that the Producing Party agrees to in writing.

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7.3

Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY” Information

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permitted in writing by the Designating Party, a Receiving

or Items. Unless otherwise ordered by the court or

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disclose

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ATTORNEYS’ EYES ONLY” only to:

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(a)

any

Party may

information or item designated “HIGHLY CONFIDENTIAL –

the Receiving Party’s Outside Counsel of Record in this Action, as

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

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necessary to disclose the information for this Action.

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(b)

House Counsel provided that House Counsel does not share the

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documents, the contents, thereof, or information derived from the documents with

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officers, directors, and employees.

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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, provided, however, that each non-

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lawyer given access to HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY documents shall be advised that such materials are being disclosed pursuant

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to, and are subject to the terms of this Stipulated Protective Order.

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(f)

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professional jury or trial consultants, mock jurors, and Professional
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STIPULATED PROTECTIVE ORDER

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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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[phone]

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TELEPHONE:

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the author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information.
(h)

any mediator or settlement officer, and their supporting personnel,

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

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(i)

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8.

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ENGELS LAW

(g)

any other person that the Producing Party agrees to in writing.
PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

PRODUCED IN OTHER LITIGATION

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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 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY,” that 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

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pursued by the Designating Party whose Protected Material may be affected. If the

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

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

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as “CONFIDENTIAL” or “HIGHLY 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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STIPULATED PROTECTIVE ORDER

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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
PRODUCED IN THIS LITIGATION
(a)

The terms of this Order are applicable to information produced by a

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Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by

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Non-Parties in connection with this litigation is protected by the remedies and relief

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provided by this Order. Nothing in these provisions should be construed as

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prohibiting a Non-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 that

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

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with a Non-Party.

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(2)

promptly provide the Non-Party with a copy of the Stipulated

21

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

22

specific description of the information requested; and

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(3)

make the information requested available for inspection by the Non-

Party, if requested.

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

26

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

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STIPULATED PROTECTIVE ORDER

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

2

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

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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

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

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

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

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this Order, and (d)

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“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

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A.

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18

11.

request

INADVERTENT

such

person

or

PRODUCTION

persons

OF

to

execute

PRIVILEGED

the

OR

OTHERWISE PROTECTED MATERIAL

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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

22

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

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may be established in an e-discovery order that provides for production without

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prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar

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as the parties reach an agreement on the effect of disclosure of a communication or

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information covered by the attorney-client privilege or work product protection, the

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STIPULATED PROTECTIVE ORDER

1

parties may incorporate their agreement in the stipulated protective order submitted

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to the court.

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12.

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

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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

7

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

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

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ENGELS LAW

MISCELLANEOUS

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

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

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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.

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

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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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FINAL DISPOSITION

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COSTA MESA CA 92626

TELEPHONE:

555 ANTON BLVD., STE.150

ENGELS LAW

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

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

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

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

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

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

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

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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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STIPULATED PROTECTIVE ORDER

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14.

Any violation of this Order may be punished by any and all appropriate

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measures including, without limitation, contempt proceedings and/or monetary

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sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: March 25, 2024,

ENGELS LAW APC

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/s/ Sean B. Janzen_____________
Christopher Engels, Esq.
Sean B. Janzen, Esq.
Attorneys for Plaintiff James Troja

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[phone]

COSTA MESA CA 92626

TELEPHONE:

555 ANTON BLVD., STE.150

ENGELS LAW

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Dated: March 25, 2024,

MORGAN, LEWIS & BOCKIUS

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/s/ Daniel R. Rodriguez_________
Jennifer B. Zargarof
Adam E. Wagmeister
Daniel R. Rodriguez
Attorneys for Defendants,
Surfside Solutions, Inc., Michael
Blanche and Jonathon Lowen

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
Dated: March 26, 2024
__________________________
Hon. Douglas F. McCormick
United States Magistrate Judge

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COSTA MESA CA 92626

TELEPHONE:

555 ANTON BLVD., STE.150

ENGELS LAW

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, ________________, of_______________________, declare under penalty

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

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Order that was issued by the United States District Court for the Central District of

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California on ___________2024 in the case of Troja v. Surfside, et al. Case No.

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8:23-cv-01137. I agree to comply with and to be bound by all the terms of this

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Stipulated Protective Order and I understand and acknowledge that failure to so

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comply could expose me to sanctions and punishment in the nature of contempt. I

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solemnly promise that I will not disclose in any manner any information or item

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that is subject to this Stipulated Protective Order to any person or entity except in

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strict compliance with the provisions of this Order. I further agree to submit to the

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jurisdiction of the United States District Court for the Central District of California

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for the purpose of enforcing the terms of this Stipulated Protective Order, even if

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such enforcement proceedings occur after termination of this action.

I hereby

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appoint _________________of ______________________[Address]

as

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California agent for service of process in connection with this action or any

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proceedings related to enforcement of this Stipulated Protective Order.

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Date:

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City and State where sworn and signed:

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Printed name:

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Signature:

_

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STIPULATED PROTECTIVE ORDER

my