1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 Frank Menyhart, 11 Case No.: 2:24-cv-04836-HDV-SSCx Plaintiff, 12

v. 13 STIPULATED PROTECTIVE

Los Angeles Police Department, et al.,

ORDER1

14 Defendant(s). 15 16 1. INTRODUCTION 17 1.1 Purposes and Limitations. Discovery in this action is likely to involve 18 production of confidential, proprietary, or private information for which special 19 protection from public disclosure and from use for any purpose other than prosecuting 20 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 21 petition the court to enter the following Stipulated Protective Order. The parties 22 acknowledge that this Order does not confer blanket protections on all disclosures or 23 responses to discovery and that the protection it affords from public disclosure and use 24 extends only to the limited information or items that are entitled to confidential 25 treatment under the applicable legal principles. 26

27 1 This Stipulated Protective Order is substantially based on the model protective 1 1.2 Good Cause Statement. 2 WHEREAS Plaintiff is seeking materials and information that Defendant CITY 3 OF LOS ANGELES (“City”) maintains as confidential, including but limited to, video 4 recordings, audio recordings, other confidential information and documents regarding 5 these incident, and other administrative materials and information currently in the 6 possession of the City and which the City believes need special protection from public 7 disclosure and from use for any purpose other than prosecuting this litigation. 8 The City asserts that the confidentiality of the materials and information sought 9 by Plaintiffs is recognized by California and federal law, as evidenced inter alia by 10 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., 11 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City has not publicly 12 released the materials and information referenced above except under protective order 13 or pursuant to a court order, if at all. These materials and information are of the type 14 that has been used to initiate disciplinary action against Los Angeles Police Department 15 (“LAPD”) officers, and has been used as evidence in disciplinary proceedings, where 16 the officers’ conduct was considered to be contrary to LAPD policy. 17 The City contends that absent a protective order delineating the responsibilities 18 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary 19 and undue disclosure as well as the corollary risk of embarrassment, harassment and 20 professional and legal harm on the part of the LAPD officers referenced in the materials 21 and information otherwise generally unavailable to the public, or which may 22 be privileged or otherwise protected from disclosure under state or federal 23 statutes, court rules, case decisions, or common law. The unfettered disclosure 24 of the materials and information, absent a protective order, would allow the media to 25 share this information with potential jurors in the area, impacting the rights of 26 Defendant herein to receive a fair trial. 27 Accordingly, to expedite the flow of information, to facilitate the prompt 1 resolution of disputes over confidentiality of discovery materials, to adequately protect 2 information the parties are entitled to keep confidential, to ensure that the parties are 3 permitted reasonable necessary uses of such material in preparation for and in the 4 conduct of trial, to address their handling at the end of the litigation, and serve the ends 5 of justice, a protective order for such information is justified in this matter. It is the 6 intent of the parties that information will not be designated as confidential for tactical 7 reasons and that nothing be so designated without a good faith belief that it has been 8 maintained in a confidential, non-public manner, and there is good cause why it should 9 not be part of the public record of this case. 10 The parties therefore stipulate that there is Good Cause for, and hereby jointly 11 request that the honorable Court issue a Protective Order regarding confidential 12 documents consistent with the terms and provisions of this Stipulation. However, the 13 entry of a Protective Order by the Court pursuant to this Stipulation shall not be 14 construed as any ruling by the Court on the aforementioned legal statements or privilege 15 claims in this section, no shall this section be construed as part of any such Court Order. 16 The City has not publicly released the documents, video or information 17 referenced above except under protective order or pursuant to court order, if at all. 18 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties further 19 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 20 does not entitle them to file confidential information under seal; Local Rule 79-5 sets 21 forth the procedures that must be followed and the standards that will be applied when 22 a party seeks permission from the court to file material under seal. 23 There is a strong presumption that the public has a right of access to judicial 24 proceedings and records in civil cases. In connection with non-dispositive motions, 25 good cause must be shown to support a filing under seal. See Kamakana v. City and 26 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. 27 Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 1 require good cause showing), and a specific showing of good cause or compelling 2 reasons with proper evidentiary support and legal justification, must be made with 3 respect to Protected Material that a party seeks to file under seal. The parties’ mere 4 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 5 without the submission of competent evidence by declaration, establishing that the 6 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 7 protectable—constitute good cause. 8 Further, if a party requests sealing related to a dispositive motion or trial, then 9 compelling reasons, not only good cause, for the sealing must be shown, and the relief 10 sought shall be narrowly tailored to serve the specific interest to be protected. See 11 Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or 12 type of information, document, or thing sought to be filed or introduced under seal in 13 connection with a dispositive motion or trial, the party seeking protection must 14 articulate compelling reasons, supported by specific facts and legal justification, for the 15 requested sealing order. Again, competent evidence supporting the application to file 16 documents under seal must be provided by declaration. 17 Any document that is not confidential, privileged, or otherwise protectable in its 18 entirety will not be filed under seal if the confidential portions can be redacted. If 19 documents can be redacted, then a redacted version for public viewing, omitting only 20 the confidential, privileged, or otherwise protectable portions of the document, shall be 21 filed. Any application that seeks to file documents under seal in their entirety should 22 include an explanation of why redaction is not feasible. 23 24 2. DEFINITIONS 25 2.1 Action: Frank Menyhart v. City of Los Angeles, et. al, United States 26 Central District Court, 24-CV-04836-HDV-SSCx. 27 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 1 information or items under this Order. 2 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 3 it is generated, stored or maintained) or tangible things that qualify for protection under 4 Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in the Good 5 Cause Statement. 6 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 7 support staff). 8 2.5 Designating Party: a Party or Non-Party that designates information or 9 items that it produces in disclosures or in responses to discovery as 10 “CONFIDENTIAL.” 11 2.6 Disclosure or Discovery Material: all items or information, regardless of 12 the medium or manner in which it is generated, stored, or maintained (including, among 13 other things, testimony, transcripts, and tangible things), that are produced or generated 14 in disclosures or responses to discovery in this matter. 15 2.7 Expert: a person with specialized knowledge or experience in a matter 16 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 17 expert witness or as a consultant in this Action. 18 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 19 this Action, with or without prejudice; and (2) final judgment herein after the 20 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this 21 Action, including the time limits for filing any motions or applications for extension of 22 time pursuant to applicable law. 23 2.9 In-House Counsel: attorneys who are employees of a party to this Action. 24 In-House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 2.10 Non-Party: any natural person, partnership, corporation, association, or 27 other legal entity not named as a Party to this action. 1 2.11 Outside Counsel of Record: attorneys who are not employees of a party to 2 this Action but are retained to represent or advise a party to this Action and have 3 appeared in this Action on behalf of that party or are affiliated with a law firm which 4 has appeared on behalf of that party, and includes support staff. 5 2.12 Party: any party to this Action, including all of its officers, directors, 6 employees, consultants, retained experts, and Outside Counsel of Record (and their 7 support staffs). 8 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 9 Discovery Material in this Action. 10 2.14 Professional Vendors: persons or entities that provide litigation- support 11 services (e.g., photocopying, videotaping, translating, preparing exhibits or 12 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 13 their employees and subcontractors. 14 2.15 Protected Material: any Disclosure or Discovery Material that is 15 designated as “CONFIDENTIAL.” 16 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 17 from a Producing Party. 18 19 3. SCOPE 20 The protections conferred by this Stipulation and Order cover not only Protected 21 Material (as defined above), but also (1) any information copied or extracted from 22 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 23 Material; and (3) any testimony, conversations, or presentations by Parties or their 24 Counsel that might reveal Protected Material. 25 Any use of Protected Material at trial shall be governed by the orders of the trial 26 judge. This Stipulated Protective Order does not govern the use of Protected Material 27 at trial. 1 4. TRIAL AND DURATION 2 The terms of this Stipulated Protective Order apply through Final Disposition of 3 the Action. 4 Once a case proceeds to trial, information that was designated as 5 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and used 6 or introduced as an exhibit at trial becomes public and will be presumptively available 7 to all members of the public, including the press, unless compelling reasons supported 8 by specific factual findings to proceed otherwise are made to the trial judge in advance 9 of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing 10 for sealing documents produced in discovery from “compelling reasons” standard when 11 merits-related documents are part of court record). Accordingly, for such materials, the 12 terms of this Stipulated Protective Order do not extend beyond the commencement of 13 the trial. 14 Even after Final Disposition of this litigation, the confidentiality obligations 15 imposed by this Stipulated Protective Order shall remain in effect until a Designating 16 Party agrees otherwise in writing or a court order otherwise directs. 17

18 5. DESIGNATING PROTECTED MATERIAL 19 5.1 Exercise of Restraint and Care in Designating Material for Protection. 20 Each Party or Non-Party that designates information or items for protection under this 21 Order must take care to limit any such designation to specific material that qualifies 22 under the appropriate standards. The Designating Party must designate for protection 23 only those parts of material, documents, items, or oral or written communications that 24 qualify so that other portions of the material, documents, items, or communications for 25 which protection is not warranted are not swept unjustifiably within the ambit of this 26 Order. 27 1 are shown to be clearly unjustified or that have been made for an improper purpose 2 (e.g., to unnecessarily encumber the case development process or to impose 3 unnecessary expenses and burdens on other parties) may expose the Designating Party 4 to sanctions. 5 If it comes to a Designating Party’s attention that information or items that it 6 designated for protection do not qualify for protection, that Designating Party must 7 promptly notify all other Parties that it is withdrawing the inapplicable designation. 8 5.2 Manner and Timing of Designations. Except as otherwise provided in this 9 Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), or as 10 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 11 protection under this Stipulated Protective Order must be clearly so designated before 12 the material is disclosed or produced. 13 Designation in conformity with this Stipulated Protective Order requires: 14 (a) for information in documentary form (e.g., paper or electronic documents, 15 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 16 Producing Party affix at a minimum, the legend “CONFIDENTIAL” to each page that 17 contains protected material. If only a portion or portions of the material on a page 18 qualifies for protection, the Producing Party also must clearly identify the protected 19 portion(s) (e.g., by making appropriate markings in the margins). 20 A Party or Non-Party that makes original documents available for inspection 21 need not designate them for protection until after the inspecting Party has indicated 22 which documents it would like copied and produced. During the inspection and before 23 the designation, all of the material made available for inspection shall be deemed 24 CONFIDENTIAL. After the inspecting Party has identified the documents it wants 25 copied and produced, the Producing Party must determine which documents, or portions 26 thereof, qualify for protection under this Stipulated Protective Order. Then, before 27 producing the specified documents, the Producing Party must affix the 1 portion or portions of the material on a page qualifies for protection, the Producing Party 2 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 3 in the margins). 4 (b) for testimony given in depositions that the Designating Party identify the 5 Disclosure or Discovery Material on the record, before the close of the deposition all 6 protected testimony. 7 (c) for information produced in some form other than documentary and for 8 any other tangible items, that the Producing Party affix in a prominent place on the 9 exterior of the container or containers in which the information is stored the 10 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants 11 protection, the Producing Party, to the extent practicable, shall identify the protected 12 portion(s). 13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 14 failure to designate qualified information or items does not, standing alone, waive the 15 Designating Party’s right to secure protection under this Order for such material. Upon 16 timely correction of a designation, the Receiving Party must make reasonable efforts to 17 assure that the material is treated in accordance with the provisions of this Stipulated 18 Protective Order. 19

20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 21 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 22 designation of confidentiality at any time that is consistent with the court’s Scheduling 23 Order. 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 26 27 1 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2 2 6.3 The burden of persuasion in any such challenge proceeding shall be on the 3 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 4 to harass or impose unnecessary expenses and burdens on other parties) may expose the 5 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 6 the confidentiality designation, all parties shall continue to afford the material in 7 question the level of protection to which it is entitled under the Producing Party’s 8 designation until the court rules on the challenge. 9 10 7. ACCESS TO AND USE OF PROTECTED MATERIAL 11 7.1 Basic Principles. A Receiving Party may use Protected Material that is 12 disclosed or produced by another Party or by a Non-Party in connection with this Action 13 only for prosecuting, defending, or attempting to settle this Action. Such Protected 14 Material may be disclosed only to the categories of persons and under the conditions 15 described in this Order. When the Action reaches a Final Disposition, a Receiving Party 16 must comply with the provisions of section 13 below. 17 Protected Material must be stored and maintained by a Receiving Party at a 18 location and in a secure manner that ensures that access is limited to the persons 19 authorized under this Stipulated Protective Order. 20 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 21 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 22 may disclose any information or item designated “CONFIDENTIAL” only: 23 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as well 24 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 25 disclose the information for this Action; 26

27 2 Judge Christensen’s Procedures are available at 1 (b) to the officers, directors, and employees (including House Counsel) of the 2 Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) to Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) to the court and its personnel; 7 (e) to court reporters and their staff; 8 (f) to professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) to the author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, to witnesses, and attorneys for witnesses, in the 14 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party 15 requests that the witness sign the “Acknowledgment and Agreement to Be Bound” 16 (Exhibit A); and (2) the witness will not be permitted to keep any confidential 17 information unless they sign the “Acknowledgment and Agreement to Be Bound” 18 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. 19 Pages of transcribed deposition testimony or exhibits to depositions that reveal 20 Protected Material may be separately bound by the court reporter and may not be 21 disclosed to anyone except as permitted under this Stipulated Protective Order; and 22 (i) to any mediator or settlement officer, and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 26 IN OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation that 1 compels disclosure of any information or items designated in this Action as 2 “CONFIDENTIAL,” that Party must: 3 (a) promptly notify in writing the Designating Party. Such notification shall 4 include a copy of the subpoena or court order; 5 (b) promptly notify in writing the party who caused the subpoena or order to 6 issue in the other litigation that some or all of the material covered by the subpoena or 7 order is subject to this Protective Order. Such notification shall include a copy of this 8 Stipulated Protective Order; and 9 (c) cooperate with respect to all reasonable procedures sought to be pursued 10 by the Designating Party whose Protected Material may be affected. 11 If the Designating Party timely seeks a protective order, the Party served with 12 the subpoena or court order shall not produce any information designated in this action 13 as “CONFIDENTIAL” before a determination by the court from which the subpoena 14 or order issued, unless the Party has obtained the Designating Party’s permission. The 15 Designating Party shall bear the burden and expense of seeking protection in that court 16 of its confidential material and nothing in these provisions should be construed as 17 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 18 from another court. 19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 20 PRODUCED IN THIS LITIGATION 21 9.1 Application. The terms of this Stipulated Protective Order are applicable 22 to information produced by a Non-Party in this Action and designated as 23 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with 24 this litigation is protected by the remedies and relief provided by this Order. Nothing 25 in these provisions should be construed as prohibiting a Non-Party from seeking 26 additional protections. 27 9.2 Notification. In the event that a Party is required, by a valid discovery 1 request, to produce a Non-Party’s confidential information in its possession, and the 2 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 3 confidential information, then the Party shall: 4 (a) promptly notify in writing the Requesting Party and the Non-Party that 5 some or all of the information requested is subject to a confidentiality agreement with 6 a Non-Party; 7 (b) make the information requested available for inspection by the Non-Party, 8 if requested. 9 9.3 Conditions of Production. If the Non-Party fails to seek a protective order 10 from this court within 14 days of receiving the notice and accompanying information, 11 the Receiving Party may produce the Non-Party’s confidential information responsive 12 to the discovery request. If the Non-Party timely seeks a protective order, the Receiving 13 Party shall not produce any information in its possession or control that is subject to the 14 confidentiality agreement with the Non-Party before a determination by the court. 15 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 16 of seeking protection in this court of its Protected Material. 17 18 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 20 Protected Material to any person or in any circumstance not authorized under this 21 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 22 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 23 all unauthorized copies of the Protected Material, (c) inform the person or persons to 24 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 25 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 26 (Exhibit A). 27 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 4 When a Producing Party gives notice to Receiving Parties that certain 5 inadvertently produced material is subject to a claim of privilege or other protection, 6 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 7 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 8 procedure may be established in an e-discovery order that provides for production 9 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules 10 of Evidence, insofar as the parties reach an agreement on the effect of disclosure of a 11 communication or information covered by the attorney-client privilege or work product 12 protection, the parties may incorporate their agreement in the stipulated protective order 13 submitted to the court.

14 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 17 abridges the right of any person to seek its modification by the court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Stipulated Protective Order no Party waives any right it otherwise would have to object 20 to disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use in evidence of any of the material covered by this Stipulated Protective 23 Order. 24 12.3 Filing Protected Material. A Party that seeks to file under seal any 25 Protected Material must comply with Local Rule 79-5. Protected Material may only be 26 filed under seal pursuant to a court order authorizing the sealing of the specific Protected 27 Material at issue. If a Party's request to file Protected Material under seal is denied by 1 otherwise instructed by the court. 2 3 13. FINAL DISPOSITION 4 After the Final Disposition of this Action, as defined in paragraph 4, within 60 5 days of a written request by the Designating Party, each Receiving Party must return all 6 Protected Material to the Producing Party or destroy such material. As used in this 7 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 8 summaries, and any other format reproducing or capturing any of the Protected 9 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 10 must submit a written certification to the Producing Party (and, if not the same person 11 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 12 category, where appropriate) all the Protected Material that was returned or destroyed 13 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 14 compilations, summaries or any other format reproducing or capturing any of the 15 Protected Material. Notwithstanding this provision, Counsel is entitled to retain an 16 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 17 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 18 work product, and consultant and expert work product, even if such materials contain 19 Protected Material. Any such archival copies that contain or constitute Protected 20 Material remain subject to this Protective Order as set forth in Section 4. 21 /// 22 /// 23 24 /// 25 /// 26 /// 27 /// ! || 14. VIOLATION 2 . . . . . . Any violation of this Stipulated Protective Order may be punished by any and ¢ ; appropriate measures including, without limitation, contempt proceedings and/ 4 . monetary sanctions. 5 ° | ITISSO STIPULATED, THROUGH COUNSEL OF RECORD.

MGDESYAN LAW FIRM

8 ? || DATED: April 17, 2025 Lrahya Boyadghyan 10 ARAKSYA BOYADZHYAN 11 Attorneys for Plaintiff

FRANK MENYHART

13 14 Office of the Los Angeles City Attorney

HYDEE FELDSTEIN-SOTO,

I5 City Attorney 16 17 DATED: April 17, 2025 Is!) SShant Jaslshian 18 SHANT TASLAKIAN 19 Attorney(s) for Defendant

CITY OF LOS ANGELES

20 21 22 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. Z— 24 || DATED: April 21, 2025 25 STEPHANIE S. CHRISTENSEN United States Magistrate Judge 27 28

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

2

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