John M. Kim (Bar No. 188997) 1 jkim@ipla.com Benjamin S. White (Bar No. 279796) 2 bwhite@ipla.com Zayde J. Khalil (Bar No. 323547) 3 zkhalil@ipla.com

4 IPLA, LLP 4445 Eastgate Mall, Suite 200 5 San Diego, CA 92101 Tel: 858-272-0220 6 Fax: 858-272-0221

7 Attorneys for Plaintiff Amarte USA Holdings, Inc. 8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10

AMARTE USA HOLDINGS, INC.,

11 a Delaware Corporation, Case No. 2:24-cv-02461-SPG-AJR

12 Plaintiff, [proposed] STIPULATED 13 v.

PROTECTIVE ORDER

14 CALDERA + LAB, INC., a Delaware Corporation, 15 Defendant. 16 17 18 1. GENERAL 19 1.1 Purposes and Limitations. Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special 20 protection from public disclosure and from use for any purpose other than prosecuting 21 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 22 petition the Court to enter the following Stipulated Protective Order. The parties 23 acknowledge that this Order does not confer blanket protections on all disclosures or 24 responses to discovery and that the protection it affords from public disclosure and 25 use extends only to the limited information or items that are entitled to confidential 26 treatment under the applicable legal principles. The parties further acknowledge, as 27 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle 1 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 2 procedures that must be followed and the standards that will be applied when a party 3 seeks permission from the court to file material under seal. 4 1.2 Good Cause Statement. This action is likely to involve trade secrets, customer and pricing lists and 5 other valuable research, development, commercial, financial, technical and/or 6 proprietary information for which special protection from public disclosure and from 7 use for any purpose other than prosecution of this action is warranted. Such 8 confidential and proprietary materials and information consist of, among other things, 9 confidential business or financial information, information regarding confidential 10 business practices, or other confidential research, development, or commercial 11 information (including information implicating privacy rights of third parties), 12 information otherwise generally unavailable to the public, or which may be privileged 13 or otherwise protected from disclosure under state or federal statutes, court rules, case 14 decisions, or common law. Accordingly, to expedite the flow of information, to 15 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 16 to adequately protect information the parties are entitled to keep confidential, to 17 ensure that the parties are permitted reasonable necessary uses of such material in 18 preparation for and in the conduct of trial, to address their handling at the end of the 19 litigation, and serve the ends of justice, a protective order for such information is 20 justified in this matter. It is the intent of the parties that information will not be 21 designated as confidential for tactical reasons and that nothing be so designated 22 without a good faith belief that it has been maintained in a confidential, non-public 23 manner, and there is good cause why it should not be part of the public record of this 24 case. 25 2. DEFINITIONS 26 2.1 Action: This pending federal lawsuit. 27 2.2 Challenging Party: a Party or Non-Party that challenges the designation 1 2.3a “CONFIDENTIAL” Information or Items: information (regardless of 2 how it is generated, stored or maintained) or tangible things that qualify for protection 3 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 4 Cause Statement. 2.3b “CONFIDENTIAL – FOR COUNSEL ONLY” Information or Items: 5 information (regardless of how it is generated, stored or maintained) or tangible things 6 that qualify for protection under Federal Rule of Civil Procedure 26(c), and as 7 specified above in the Good Cause Statement. Furthermore, such information and 8 items shall be designated “CONFIDENTIAL – FOR COUNSEL ONLY,” only if, in 9 the good faith belief of such party and its counsel, the information is among that 10 considered to be most sensitive by the party including, but not limited to, trade secret 11 or other confidential research, development, financial or other commercial 12 information. 13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 14 support staff). 15 2.5 Designating Party: a Party or Non-Party that designates information or 16 items that it produces in disclosures or in responses to discovery as 17 “CONFIDENTIAL.” 18 2.6 Disclosure or Discovery Material: all items or information, regardless 19 of the medium or manner in which it is generated, stored, or maintained (including, 20 among other things, testimony, transcripts, and tangible things), that are produced or 21 generated in disclosures or responses to discovery in this matter. 22 2.7 Expert: a person with specialized knowledge or experience in a matter 23 pertinent to the litigation who has been retained by a Party or its counsel to serve as 24 an expert witness or as a consultant in this Action. 25 2.8 House Counsel: attorneys who are employees of a party to this Action. 26 House Counsel does not include Outside Counsel of Record or any other outside 27 counsel. 1 2.9 Non-Party: any natural person, partnership, corporation, association, or 2 other legal entity not named as a Party to this action. 3 2.10 Outside Counsel of Record: attorneys who are not employees of a party 4 to this Action but are retained to represent or advise a party to this Action and have appeared in this Action on behalf of that party or are affiliated with a law firm that 5 has appeared on behalf of that party, including support staff. 6 2.11 Party: any party to this Action, including all of its officers, directors, 7 employees, consultants, retained experts, and Outside Counsel of Record (and their 8 support staffs). 9 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 10 Discovery Material in this Action. 11 2.13 Professional Vendors: persons or entities that provide litigation support 12 services (e.g., photocopying, videotaping, translating, preparing exhibits or 13 demonstrations, and organizing, storing, or retrieving data in any form or medium) 14 and their employees and subcontractors. 15 2.14 Protected Material: any Disclosure or Discovery Material that is 16 designated as “CONFIDENTIAL” or “CONFIDENTIAL – FOR COUNSEL 17

ONLY.”

18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 19 from a Producing Party. 20 3. SCOPE 21 The protections conferred by this Stipulation and Order cover not only 22 Protected Material (as defined above), but also (1) any information copied or extracted 23 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 24 Protected Material; and (3) any testimony, conversations, or presentations by Parties 25 or their Counsel that might reveal Protected Material. 26 Any use of Protected Material at trial shall be governed by the orders of the 27 trial judge. This Order does not govern the use of Protected Material at trial. 1 4. DURATION 2 Once a case proceeds to trial, all of the court-filed information to be introduced 3 that was previously designated as confidential or maintained pursuant to this 4 protective order becomes public and will be presumptively available to all members of the public, including the press, unless compelling reasons supported by specific 5 factual findings to proceed otherwise are made to the trial judge in advance of the 6 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 7 2006) (distinguishing “good cause” showing for sealing documents produced in 8 discovery from “compelling reasons” standard when merits-related documents are 9 part of court record). Accordingly, the terms of this protective order do not extend 10 beyond the commencement of the trial. 11

12 5. DESIGNATING PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Non-Party that designates information or items for protection under this 15 Order must take care to limit any such designation to specific material that qualifies 16 under the appropriate standards. The Designating Party must designate for protection 17 only those parts of material, documents, items, or oral or written communications that 18 qualify so that other portions of the material, documents, items, or communications 19 for which protection is not warranted are not swept unjustifiably within the ambit of 20 this Order. 21 Mass, indiscriminate, or routinized designations are prohibited. Designations 22 that are shown to be clearly unjustified or that have been made for an improper 23 purpose (e.g., to unnecessarily encumber the case development process or to impose 24 unnecessary expenses and burdens on other parties) may expose the Designating Party 25 to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 designated for protection do not qualify for protection, that Designating Party must 1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the material is disclosed or produced. 5 Designation in conformity with this Order requires: 6 (a) Designation as "CONFIDENTIAL": Any party may designate 7 information as "CONFIDENTIAL" only if, in the good faith belief of such party and 8 its counsel, the unrestricted disclosure of such information could be potentially 9 prejudicial to the business or operations of such party. 10 (b) Designation as "CONFIDENTIAL - FOR COUNSEL ONLY": Any 11 party may designate information as "CONFIDENTIAL - FOR COUNSEL ONLY" 12 only if, in the good faith belief of such party and its counsel, the information is among 13 that considered to be most sensitive by the party, including but not limited to trade 14 secret or other confidential research, development, financial or other commercial 15 information. 16 (c) A Party or Non-Party that makes original documents available for 17 inspection need not designate them for protection until after the inspecting Party has 18 indicated which documents it would like copied and produced. During the inspection 19 and before the designation, all of the material made available for inspection shall be 20 deemed “CONFIDENTIAL – FOR COUNSEL ONLY.” After the inspecting Party 21 has identified the documents it wants copied and produced, the Producing Party must 22 determine which documents, or portions thereof, qualify for protection under this 23 Order. Then, before producing the specified documents, the Producing Party must 24 affix the “CONFIDENTIAL legend” to each page that contains Protected Material. 25 If only a portion or portions of the material on a page qualifies for protection, the 26 Producing Party also must clearly identify the protected portion(s) (e.g., by making 27 appropriate markings in the margins). 1 (d) for testimony given in depositions that the Designating Party identify the 2 Disclosure or Discovery Material on the record, before the close of the deposition. but 3 a party may designate portions of depositions as containing confidential information 4 after transcription of the proceedings; [A] party will have until fourteen (14) days after receipt of the deposition transcript to inform, in writing, the other party or parties 5 to the action of the portions of the transcript to be designated "CONFIDENTIAL" or 6 "CONFIDENTIAL - FOR COUNSEL ONLY.” The disclosing party will have the 7 right to exclude from attendance at the deposition, during such time as the confidential 8 information is to be disclosed, any person other than the deponent, counsel (including 9 their staff and associates), the court reporter, and the person(s) agreed upon pursuant 10 to paragraph 7.3 below; and, the originals of the deposition transcripts and all copies 11 of the deposition must bear the legend "CONFIDENTIAL" or "CONFIDENTIAL - 12 FOR COUNSEL ONLY," as appropriate, and the original or any copy ultimately 13 presented to a court for filing must not be filed unless it can be accomplished under 14 seal, identified as being subject to this Order, and protected from being opened except 15 by order of this Court. 16 (e) for information produced in some form other than documentary and for 17 any other tangible items, that the Producing Party affix in a prominent place on the 18 exterior of the container or containers in which the information is stored the legend 19 “CONFIDENTIAL” or “CONFIDENTIAL – FOR COUNSEL ONLY.” If only a 20 portion or portions of the information warrants protection, the Producing Party, to the 21 extent practicable, shall identify the protected portion(s). 22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive the 24 Designating Party’s right to secure protection under this Order for such material. 25 Upon timely correction of a designation, the Receiving Party must make reasonable 26 efforts to assure that the material is treated in accordance with the provisions of this 27 Order. 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 Scheduling Order. 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 5 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly 6 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 7 6.3 Burden. The burden of persuasion in any such challenge proceeding 8 shall be on the Designating Party. Frivolous challenges, and those made for an 9 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 10 other parties) may expose the Challenging Party to sanctions. Unless the Designating 11 Party has waived or withdrawn the confidentiality designation, all parties shall 12 continue to afford the material in question the level of protection to which it is entitled 13 under the Producing Party’s designation until the Court rules on the challenge. 14

15 7. ACCESS TO AND USE OF PROTECTED MATERIAL 16 7.1 Basic Principles. A Receiving Party may use Protected Material that is 17 disclosed or produced by another Party or by a Non-Party in connection with this 18 Action only for prosecuting, defending, or attempting to settle this Action. Such 19 Protected Material may be disclosed only to the categories of persons and under the 20 conditions described in this Order. When the Action has been terminated, a Receiving 21 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 22 Protected Material must be stored and maintained by a Receiving Party at a 23 location and in a secure manner that ensures that access is limited to the persons 24 authorized under this Order. 25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 26 otherwise ordered by the Court or permitted in writing by the Designating Party, a 27 Receiving Party may disclose any information or item designated 1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 2 well as employees of said Outside Counsel of Record to whom it is reasonably 3 necessary to disclose the information for this Action; 4 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; 5 (c) Experts (as defined in this Order) of the Receiving Party to whom 6 disclosure is reasonably necessary for this Action and who have signed the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) the Court and its personnel; 9 (e) court reporters and their staff; 10 (f) professional jury or trial consultants, mock jurors, and Professional 11 Vendors to whom disclosure is reasonably necessary for this Action and who have 12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (g) the author or recipient of a document containing the information or 14 a custodian or other person who otherwise possessed or knew the information; 15 (h) during their depositions, witnesses, and attorneys for witnesses, in 16 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 17 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 18 will not be permitted to keep any confidential information unless they sign the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 20 agreed by the Designating Party or ordered by the Court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material may be 22 separately bound by the court reporter and may not be disclosed to anyone except as 23 permitted under this Stipulated Protective Order; and 24 (i) any mediator or settlement officer, and their supporting personnel, 25 mutually agreed upon by any of the parties engaged in settlement discussions. 26 7.3 Disclosure of “CONFIDENTIAL – FOR COUNSEL ONLY” Information 27 or Items. Unless otherwise ordered by the Court or permitted in writing by the 1 Designating Party, a Receiving Party may disclose any information or item designated 2 “CONFIDENTIAL – FOR COUNSEL ONLY” only to: 3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 4 well as employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this Action; 5 (b) Experts (as defined in this Order) of the Receiving Party to whom 6 disclosure is reasonably necessary for this Action and who have signed the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) the Court and its personnel; 9 (e) court reporters and their staff; 10 (f) professional jury or trial consultants, mock jurors, and Professional 11 Vendors to whom disclosure is reasonably necessary for this Action and who have 12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (g) the author or recipient of a document containing the information or 14 a custodian or other person who otherwise possessed or knew the information; 15 (h) during their depositions, witnesses, and attorneys for witnesses, in 16 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 17 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 18 will not be permitted to keep any confidential information unless they sign the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 20 agreed by the Designating Party or ordered by the Court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material may be 22 separately bound by the court reporter and may not be disclosed to anyone except as 23 permitted under this Stipulated Protective Order; and 24 (i) any mediator or settlement officer, and their supporting personnel, 25 mutually agreed upon by any of the parties engaged in settlement discussions. 26 27 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that Party must: 5 (a) promptly notify in writing the Designating Party. Such notification shall 6 include a copy of the subpoena or court order; 7 (b) promptly notify in writing the party who caused the subpoena or order to 8 issue in the other litigation that some or all of the material covered by the subpoena 9 or order is subject to this Protective Order. Such notification shall include a copy of 10 this Stipulated Protective Order; and 11 (c) cooperate with respect to all reasonable procedures sought to be pursued 12 by the Designating Party whose Protected Material may be affected. 13 If the Designating Party timely seeks a protective order, the Party served with 14 the subpoena or court order shall not produce any information designated in this action 15 as “CONFIDENTIAL” or “CONFIDENTIAL – FOR COUNSEL ONLY” before a 16 determination by the court from which the subpoena or order issued, unless the Party 17 has obtained the Designating Party’s permission. The Designating Party shall bear 18 the burden and expense of seeking protection in that court of its confidential material 19 and nothing in these provisions should be construed as authorizing or encouraging a 20 Receiving Party in this Action to disobey a lawful directive from another court. 21 22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 23 PRODUCED IN THIS LITIGATION 24 (a) The terms of this Order are applicable to information produced by a Non- 25 Party in this Action and designated as “CONFIDENTIAL” or “CONFIDENTIAL – 26 FOR COUNSEL ONLY.” Such information produced by Non-Parties in connection 27 with this litigation is protected by the remedies and relief provided by this Order. 1 Nothing in these provisions should be construed as prohibiting a Non-Party from 2 seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to produce 4 a Non-Party’s Protected Material in its possession, and the Party is subject to an agreement with the Non-Party not to produce the Non-Party’s Protected Material, then 5 the Party shall: 6 (1) promptly notify in writing the Requesting Party and the Non-Party 7 that some or all of the information requested is subject to a confidentiality agreement 8 with a Non-Party; 9 (2) promptly provide the Non-Party with a copy of the Stipulated 10 Protective Order in this Action, the relevant discovery request(s), and a reasonably 11 specific description of the information requested; and 12 (3) make the information requested available for inspection by the Non- 13 Party, if requested. 14 (c) If the Non-Party fails to seek a protective order from this Court within 14 15 days of receiving the notice and accompanying information, the Receiving Party may 16 produce the Non-Party’s Protected Material responsive to the discovery request. If 17 the Non-Party timely seeks a protective order, the Receiving Party shall not produce 18 any information in its possession or control that is subject to the confidentiality 19 agreement with the Non-Party before a determination by the Court. Absent a court 20 order to the contrary, the Non-Party shall bear the burden and expense of seeking 21 protection in this Court of its Protected Material. 22 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 27 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 1 persons to whom unauthorized disclosures were made of all the terms of this Order, 2 and (d) request such person or persons to execute the “Acknowledgment and 3 Agreement to Be Bound” that is attached hereto as Exhibit A. 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5

PROTECTED MATERIAL

6 When a Producing Party gives notice to Receiving Parties that certain 7 inadvertently produced material is subject to a claim of privilege or other protection, 8 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 9 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 10 may be established in an e-discovery order that provides for production without prior 11 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 13 information covered by the attorney-client privilege or work product protection, the 14 parties may incorporate their agreement in the stipulated protective order submitted 15 to the Court. 16

17 12. MISCELLANEOUS 18 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 19 person to seek its modification by the Court in the future. 20 12.2 Right to Assert Other Objections. By stipulating to the entry of this 21 Protective Order, no Party waives any right it otherwise would have to object to 22 disclosing or producing any information or item on any ground not addressed in this 23 Stipulated Protective Order. Similarly, no Party waives any right to object on any 24 ground to use in evidence of any of the material covered by this Protective Order. 25 12.3 Filing Protected Material. A Party that seeks to file under seal any 26 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 27 only be filed under seal pursuant to a court order authorizing the sealing of the specific 1 seal. If a Party’s request to file Protected Material under seal is denied by the Court, 2 then the Receiving Party may file the information in the public record unless 3 otherwise instructed by the Court. 4 13. FINAL DISPOSITION 5 After the final disposition of this Action, within 60 days of a written request by 6 the Designating Party, each Receiving Party must return all Protected Material to the 7 Producing Party or destroy such material. As used in this subdivision, “all Protected 8 Material” includes all copies, abstracts, compilations, summaries, and any other 9 format reproducing or capturing any of the Protected Material. Whether the Protected 10 Material is returned or destroyed, the Receiving Party must submit a written 11 certification to the Producing Party (and, if not the same person or entity, to the 12 Designating Party) by the 60 day deadline that (1) identifies (by category, where 13 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms 14 that the Receiving Party has not retained any copies, abstracts, compilations, 15 summaries or any other format reproducing or capturing any of the Protected Material. 16 Notwithstanding this provision, counsel are entitled to retain an archival copy of all 17 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 18 correspondence, deposition and trial exhibits, expert reports, attorney work product, 19 and consultant and expert work product, even if such materials contain Protected 20 Material. Any such archival copies that contain or constitute Protected Material 21 remain subject to this Protective Order as set forth in Section 4 (DURATION). 22 \\ 23 \\ 24 \\ 25 \\ 26 \\ 27 \\ 1 || 14. VIOLATION OF ORDER 2 Any violation of this Order may be punished by any and all appropriate 3 || measures including, without limitation, contempt proceedings and/or monetary 4 || sanctions. 5 6 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 || DATED: June 19, 2024 /s/ Benjamin S. White Benjamin S. White g IPLA, LLP Attorney for Plaintiff, 9 AMARTE USA HOLDINGS, INC. 19 || DATED: June 19, 2024 /s/ BenT. Lila Ben T. Lila (SBN 246808) 1] Email: blila@mandourlaw.com 2 Attorneys for Defendant Caldera + Lab, Inc. 13 14 Pursuant to Local Rule 5-4.3.4, Benjamin S. White of the law firm IPLA, LLP 15 || counsel for the filing party, attests that all signatories listed, and on whose behalf this 16 || filing is submitted, concur in the filing’s content and have authorized the filing. 17 18 || PURSUANT TO STIPULATION, IT IS SO ORDERED. 19 20 || DATED: 6/20/24 Rl 21 □□□□□□□□□□□□□□□□□□□□□□□□□□□□ Hon. A. Joel Richlin U.S. Magistrate Judge 23 24 25 26 27 28 16

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, __________________ [print or type full name], of __________________ 4 [print or type full address], declare under penalty of perjury that I have read in its 5 entirety and understand the Stipulated Protective Order that was issued by the United 6 States District Court for the Central District of California on _______ [date] in the case 7 of _________________ [insert formal name of the case and the number and initials 8 assigned to it by the court]. I agree to comply with and to be bound by all the terms of 9 this Stipulated Protective Order and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that is 12 subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of this 17 action. 18 I hereby appoint _________________ [print or type full name] of 19 ___________________________________ [print or type full address and telephone 20 number] as my California agent for service of process in connection with this action or 21 any proceedings related to enforcement of this Stipulated Protective Order. 22 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27