Villalobos et al v. Home Depot U.S.A., Inc. et al

Filing 10

STIPULATED PROTECTIVE ORDER signed by Magistrate Judge Carolyn K. Delaney on 2/17/2021. (Huang, H)

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1 2 3 4 5 6 7 Michael J. Terhar [State Bar No. 89491] Jonathan E. Hembree [State Bar No. 274051] CUNNINGHAM SWAIM, LLP 2 North Lake Avenue, Suite 550 Pasadena, California 91101 Telephone: (626) 765-3000 Facsimile: (626) 765-3030 Email: Attorneys for Defendants, WERNER CO. (erroneously sued and served as “WERNERCO LLC”) and HOME DEPOT U.S.A., INC. 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 ROBERT VILLALOBOS and MARIE 11 VILLALOBOS, 12 Plaintiffs, 13 vs. 14 HOME DEPOT U.S.A., INC., WERNERCO 15 LLC, and DOES 1 through 100, inclusive, Defendants. 16 17 18 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 2:20-cv-02251-WBS-CKD STIPULATED PROTECTIVE ORDER Assigned To: Hon. William B. Shubb; Magistrate Judge Carolyn K. Delaney 19 1. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, proprietary, or private 21 information for which special protection from public disclosure and from use for any purpose other 22 than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and 23 petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that 24 this Order does not confer blanket protections on all disclosures or responses to discovery and that 25 the protection it affords from public disclosure and use extends only to the limited information or 26 items that are entitled to confidential treatment under the applicable legal principles. The parties 27 further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does 28 STIPULATED PROTECTIVE ORDER 512.3572 1 not entitle them to file confidential information under seal; Local Rule 141.1 sets forth the procedures 2 that must be followed and the standards that will be applied when a party seeks permission from the 3 court to file material under seal. 4 B. GOOD CAUSE STATEMENT 5 This action is likely to involve trade secrets, and other valuable research, development, 6 commercial, financial, technical and/or proprietary information for which special protection from 7 public disclosure and from use for any purpose other than prosecution of this action is warranted. 8 Such confidential and proprietary materials and information includes Werner Co.’s ladder 9 engineering drawings and test reports. A court-ordered protective order for such private, proprietary 10 information is justified in this matter (as opposed to a private agreement between or among the 11 parties) to expedite the flow of information, to facilitate the prompt resolution of disputes over 12 confidentiality of discovery materials, to adequately protect information the parties are entitled to 13 keep confidential, to ensure that the parties are permitted reasonable necessary uses of such material 14 in preparation for and in the conduct of trial, to address their handling at the end of the litigation, 15 and serve the ends of justice. 16 It is the intent of the parties that information will not be designated as confidential for tactical 17 reasons and that nothing be so designated without a good faith belief that it has been maintained in a 18 confidential, non-public manner, and there is good cause why it should not be part of the public 19 record of this case. 20 2. DEFINITIONS 21 2.1 Action: This pending federal lawsuit, Robert Villalobos, et al. v Home Depot 22 U.S.A., Inc., et al., Case No. 2:20-cv-02251-WBS-CKD. 23 2.2 Challenging Party: A Party or Non-Party that challenges the designation of 24 information or items under this Order. 25 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of how it is 26 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 27 Civil Procedure 26(c), and as specified above in the Good Cause Statement. 28 2 STIPULATED PROTECTIVE ORDER 512.3572 1 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support 2.5 Designating Party: A Party or Non-Party that designates information or items that it 2 staff). 3 4 produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 5 2.6 Disclosure or Discovery Material: All items or information, regardless of the medium 6 or manner in which it is generated, stored, or maintained (including, among other things, testimony, 7 transcripts, and tangible things), that are produced or generated in disclosures or responses to 8 discovery in this matter. 9 2.7 Expert: A person with specialized knowledge or experience in a matter pertinent to 10 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 11 consultant in this Action. 12 2.8 House Counsel: Attorneys who are employees of a party to this Action. House 13 Counsel does not include Outside Counsel of Record or any other outside counsel. 14 2.9 Non-Party: Any natural person, partnership, corporation, association, or other legal 15 entity not named as a Party to this action. 16 2.10 Outside Counsel of Record: Attorneys who are not employees of a party to this 17 Action but are retained to represent or advise a party to this Action and have appeared in this Action 18 on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party 19 and includes support staff. 20 2.11 Party: Any party to this Action, including all of its officers, directors, employees, 21 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 22 2.12 Producing Party: A Party or Non-Party that produces Disclosure or discovery Material 23 in this Action. 24 2.13 Professional Vendors: Persons or entities that provide litigation support services (e.g., 25 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 26 storing, or retrieving data in any form or medium) and their employees and subcontractors. 27 2.14 Protected Material: Any Disclosure or Discovery Material that is designated as 28 “CONFIDENTIAL.” 3 STIPULATED PROTECTIVE ORDER 512.3572 1 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material from a 2 Producing Party. 3 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only Protected Material (as 5 defined above), but also (1) any information copied or extracted from Protected Material; (2) all 6 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 7 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 8 However, the protections conferred by this Stipulation and Order do not cover the following 9 information: (a) any information that is in the public domain at the time of disclosure to a Receiving 10 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 11 publication not involving a violation of this Order, including becoming part of the public record 12 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 13 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 14 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 15 Protected Material at trial shall be governed by a separate agreement or order. 16 4. DURATION 17 Even after final disposition of this litigation, the confidentiality obligations imposed by this 18 Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 19 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and 20 defenses in this Action, with or without prejudice; and (2) final judgment herein after the completion 21 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, including the 22 time limits for filing any motions or applications for extension of time pursuant to applicable law. 23 5. DESIGNATING PROTECTED MATERIAL 24 5.1 25 Each Party or Non-Party that designates information or items for protection under this Order Exercise of Restraint and Care in Designating Material for Protection. 26 must take care to limit any such designation to specific material that qualifies under the appropriate 27 standards. The Designating Party must designate for protection only those parts of material, 28 documents, items, or oral or written communications that qualify so that other portions of the 4 STIPULATED PROTECTIVE ORDER 512.3572 1 material, documents, items, or communications for which protection is not warranted are not swept 2 unjustifiably within the ambit of this Order. 3 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown 4 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 5 encumber the case development process or to impose unnecessary expenses and burdens on other 6 parties) may expose the Designating Party to sanctions. If it comes to a Designating Party’s attention that information or items that it designated for 7 8 protection do not qualify for protection, that Designating Party must promptly notify all other Parties 9 that it is withdrawing the inapplicable designation. 10 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, 11 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 12 Discovery Material that qualifies for protection under this Order must be clearly so designated before 13 the material is disclosed or produced. 14 Designation in conformity with this Order requires: 15 (a) for information in documentary form (e.g., paper or electronic documents, but 16 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing 17 Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 18 “CONFIDENTIAL legend”), to each page that contains protected material. If only a portion or 19 portions of the material on a page qualifies for protection, the Producing Party also must clearly 20 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 21 A Party or Non-Party that makes original documents available for inspection need not designate 22 them for protection until after the inspecting Party has indicated which documents it would like 23 copied and produced. During the inspection and before the designation, all of the material made 24 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 25 identified the documents it wants copied and produced, the Producing Party must determine which 26 documents, or portions thereof, qualify for protection under this Order. Then, before producing the 27 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 28 that contains Protected Material. If only a portion or portions of the material on a page qualifies for 5 STIPULATED PROTECTIVE ORDER 512.3572 1 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making 2 appropriate markings in the margins). 3 (b) for testimony given in depositions that the Designating Party identify the Disclosure or 4 Discovery Material on the record, before the close of the deposition all protected testimony. 5 (c) for information produced in some form other than documentary and for any other tangible 6 items, that the Producing Party affix in a prominent place on the exterior of the container or containers 7 in which the information is stored the legend “CONFIDENTIAL.” If only a portion or portions of 8 the information warrants protection, the Producing Party, to the extent practicable, shall identify the 9 protected portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 11 designate qualified information or items does not, standing alone, waive the Designating Party’s right 12 to secure protection under this Order for such material. Upon timely correction of a designation, the 13 Receiving Party must make reasonable efforts to assure that the material is treated in accordance with 14 the provisions of this Order. 15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 17 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 18 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, 19 or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a 20 confidentiality designation by electing not to mount a challenge promptly after the original 21 designation is disclosed. 22 23 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 24 by providing written notice of each designation it is challenging and describing the basis for each 25 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 26 recite that the challenge to confidentiality is being made in accordance with this specific paragraph 27 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must 28 begin the process by conferring directly (in voice to voice dialogue; other forms of communication 6 STIPULATED PROTECTIVE ORDER 512.3572 1 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging Party 2 must explain the basis for its belief that the confidentiality designation was not proper and must give 3 the Designating Party an opportunity to review the designated material, to reconsider the 4 circumstances, and, if no change in designation is offered, to explain the basis for the chosen 5 designation. A Challenging Party may proceed to the next stage of the challenge process only if it 6 has engaged in this meet and confer process first or establishes that the Designating Party is unwilling 7 to participate in the meet and confer process in a timely manner. 8 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 9 intervention, the Designating Party shall file and serve a motion to retain confidentiality under Civil 10 Local Rule 141.1 within 21 days of the initial notice of challenge or within 14 days of the parties 11 agreeing that the meet and confer process will not resolve their dispute, whichever is earlier. Each 12 such motion must be accompanied by a competent declaration affirming that the movant has 13 complied with the meet and confer requirements imposed in the preceding paragraph. Failure by the 14 Designating Party to make such a motion including the required declaration within 21 days (or 14 15 days, if applicable) shall automatically waive the confidentiality designation for each challenged 16 designation. In addition, the Challenging Party may file a motion challenging a confidentiality 17 designation at any time if there is good cause for doing so, including a challenge to the designation 18 of a deposition transcript or any portions thereof. Any motion brought pursuant to this provision must 19 be accompanied by a competent declaration affirming that the movant has complied with the meet 20 and confer requirements imposed by the preceding paragraph. 21 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. 22 Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary 23 expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the 24 Designating Party has waived the confidentiality designation by failing to file a motion to retain 25 confidentiality as described above, all parties shall continue to afford the material in question the 26 level of protection to which it is entitled under the Producing Party’s designation until the court rules 27 on the challenge. 28 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 STIPULATED PROTECTIVE ORDER 512.3572 1 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 2 produced by another Party or by a Non-Party in connection with this Action only for prosecuting, 3 defending, or attempting to settle this Action. Such Protected Material may be disclosed only to the 4 categories of persons and under the conditions described in this Order. When the Action has been 5 terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 6 DISPOSITION). 7 Protected Material must be stored and maintained by a Receiving Party at a location and in a 8 secure manner that ensures that access is limited to the persons authorized under this Order. 9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 10 ordered by the court or permitted in writing by the Designating Party, a Receiving Party may disclose 11 any information or item designated “CONFIDENTIAL” only to: 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as employees 13 of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for 14 this Action; 15 (b) the officers, directors, and employees (including House Counsel) of the Receiving 16 Party to whom disclosure is reasonably necessary for this Action; 17 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 18 reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to 19 Be Bound” (Exhibit A); 20 (d) the court and its personnel; 21 (e) court reporters and their staff; 22 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to whom 23 disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and 24 Agreement to Be Bound” (Exhibit A); 25 (g) the author or recipient of a document containing the information or a custodian or other 26 person who otherwise possessed or knew the information; 27 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action to whom 28 disclosure is reasonably necessary provided: (1) the deposing party requests that the witness sign the 8 STIPULATED PROTECTIVE ORDER 512.3572 1 form attached as Exhibit A hereto; and (2) they will not be permitted to keep any confidential 2 information unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 3 otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed deposition 4 testimony or exhibits to depositions that reveal Protected Material may be separately bound by the 5 court reporter and may not be disclosed to anyone except as permitted under this Stipulated Protective 6 Order; and 7 (i) any mediator or settlement officer, and their supporting personnel, mutually agreed 8 upon by any of the parties engaged in settlement discussions. 9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 10 LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation that compels 12 disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that Party 13 must: 14 (a) promptly notify in writing the Designating Party. Such notification shall include a 15 copy of the subpoena or court order; 16 (b) promptly notify in writing the party who caused the subpoena or order to issue in the 17 other litigation that some or all of the material covered by the subpoena or order is subject to this 18 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 20 Designating Party whose Protected Material may be affected. 21 If the Designating Party timely seeks a protective order, the Party served with the subpoena 22 or court order shall not produce any information designated in this action as “CONFIDENTIAL” 23 before a determination by the court from which the subpoena or order issued, unless the Party has 24 obtained the Designating Party’s permission. The Designating Party shall bear the burden and 25 expense of seeking protection in that court of its confidential material and nothing in these provisions 26 should be construed as authorizing or encouraging a Receiving Party in this Action to disobey a 27 lawful directive from another court. 28 9 STIPULATED PROTECTIVE ORDER 512.3572 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS 2 LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non-Party in this 4 Action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 5 connection with this litigation is protected by the remedies and relief provided by this Order. Nothing 6 in these provisions should be construed as prohibiting a Non-Party from seeking additional 7 protections. 8 (b) In the event that a Party is required, by a valid discovery request, to produce a Non- 9 Party’s confidential information in its possession, and the Party is subject to an agreement with the 10 Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 11 (1) promptly notify in writing the Requesting Party and the Non-Party that some or 12 all of the information requested is subject to a confidentiality agreement with a Non-Party; 13 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 14 in this Action, the relevant discovery request(s), and a reasonably specific description of the 15 information requested; and 16 (3) 17 requested. 18 (c) If the Non-Party fails to seek a protective order from this court within 14 days of receiving make the information requested available for inspection by the Non-Party, if 19 the notice and accompanying information, the Receiving Party may produce the Non-Party’s 20 confidential information responsive to the discovery request. If the Non-Party timely seeks a 21 protective order, the Receiving Party shall not produce any information in its possession or control 22 that is subject to the confidentiality agreement with the Non-Party before a determination by the 23 court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense 24 of seeking protection in this court of its Protected Material. 25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 27 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 28 the Receiving Party must immediately (a) notify in writing the Designating Party of the 10 STIPULATED PROTECTIVE ORDER 512.3572 1 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected 2 Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the 3 terms of this Order, and (d) request such person or persons to execute the “Acknowledgment 4 and Agreement to Be Bound” that is attached hereto as Exhibit A. 5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 6 MATERIAL 7 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced 8 material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties 9 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to 10 modify whatever procedure may be established in an e-discovery order that provides for production 11 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 12 parties reach an agreement on the effect of disclosure of a communication or information covered by 13 the attorney-client privilege or work product protection, the parties may incorporate their agreement 14 in the stipulated protective order submitted to the court. 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek 17 its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order 19 no Party waives any right it otherwise would have to object to disclosing or producing any 20 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 21 Party waives any right to object on any ground to use in evidence of any of the material covered by 22 this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material 24 must comply with Civil Local Rule 141. Protected Material may only be filed under seal pursuant to 25 a court order authorizing the sealing of the specific Protected Material at issue. If a Receiving Party's 26 request to file Protected Material under seal is denied by the court, then the Receiving Party may file 27 the information in the public record unless otherwise instructed by the court. 28 13. FINAL DISPOSITION 11 STIPULATED PROTECTIVE ORDER 512.3572 1 After the final disposition of this Action, as defined in paragraph 4, within 60 days of a written 2 request by the Designating Party, each Receiving Party must return all Protected Material to the 3 Producing Party or destroy such material. As used in this subdivision, “all Protected Material” 4 includes all copies, abstracts, compilations, summaries, and any other format reproducing or 5 capturing any of the Protected Material. Whether the Protected Material is returned or destroyed, the 6 Receiving Party must submit a written certification to the Producing Party (and, if not the same 7 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category, 8 where appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 9 the Receiving Party has not retained any copies, abstracts, compilations, summaries or any other 10 format reproducing or capturing any of the Protected Material. Notwithstanding this provision, 11 Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 12 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, 13 attorney work product, and consultant and expert work product, even if such materials contain 14 Protected Material. Any such archival copies that contain or constitute Protected Material remain 15 subject to this Protective Order as set forth in Section 4 (DURATION). 16 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 19 Dated: February 17, 2021 CUNNINGHAM SWAIM, LLP 20 By: 21 22 23 24 25 Dated: February 17, 2021 /s/ Michael J. Terhar Michael J. Terhar, Esq. Jonathan E. Hembree, Esq. Attorneys for Defendants, WERNER CO. erroneously sued and served as “WERNERCO LLC”) and HOME DEPOT U.S.A., INC. CUTTER LAW P.C. 26 By: 27 28 /s/ John G. Roussas John G. Roussas, Esq. C. Brooks Cutter, Esq. Attorneys for Plaintiffs, 12 STIPULATED PROTECTIVE ORDER 512.3572 ROBERT VILLALOBOS and MARIE VILLALOBOS 1 2 3 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 4 5 Dated: February 17, 2021 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 13 STIPULATED PROTECTIVE ORDER 512.3572 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, ___________________ , of [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California on [date] in the 7 case of Timothy Marlowe v. Delta Air Lines, et al, 2:18-cv-02569-DMG-AFM. I agree to comply 8 with and to be bound by all the terms of this Stipulated Protective Order and I understand and 9 acknowledge that failure to so comply could expose me to sanctions and punishment in the nature 10 of contempt. I solemnly promise that I will not disclose in any manner any information or item that 11 is subject to this Stipulated Protective Order to any person or entity except in strict compliance with 12 the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for the Central 14 District of California for enforcing the terms of this Stipulated Protective Order, even if such 15 enforcement proceedings occur after termination of this action. I hereby appoint 16 ___________________ of 17 18 19 20 [print or type full address and telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. Date: ________________________ 21 22 City and State where sworn and signed: __________________________________ 23 24 25 Printed name: _______________________________________ Signature: ___________________________________________ 26 27 28 14 STIPULATED PROTECTIVE ORDER 512.3572

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