1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA

11 GALIA RITA CHARUKIAN dba CASE NO. 2:25-cv-01292 RGK (KSx) MORRISON STUDIOS, LTD., L.P. Judge R. Gary Klausner- Crtm 850 12 Hon. Karen L. Stevenson – Ctrm. 580 13 Plaintiff,

14 vs.

STIPULATED PROTECTIVE

CITY OF LOS ANGELES, UNITED

15 STATES OF AMERICA, DOES 1 to 100 ORDER Inclusive, 16

17 Defendants.

18

19 1. A. PURPOSES AND LIMITATIONS 20

21 Discovery in this action is likely to involve production of confidential, proprietary, 22 or private information for which special protection from public disclosure and from use 23 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 24 parties hereby stipulate to and petition the Court to enter the following Stipulated 25 Protective Order. The parties acknowledge that this Order does not confer blanket 26 protections on all disclosures or responses to discovery and that the protection it affords 27 from public disclosure and use extends only to the limited information or items that are 1 entitled to confidential treatment under the applicable legal principles. The parties further 2 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 3 does not entitle them to file confidential information under seal; Civil Local Rule 79-5 4 sets forth the procedures that must be followed and the standards that will be applied 5 when a party seeks permission from the court to file material under seal. 6 7 B. GOOD CAUSE STATEMENT 8 This action involves employees of the City of Los Angeles (the “City”) which 9 include members of the City’s Los Angeles Police Department (“LAPD”). The nature of 10 the incident that gives rise to Plaintiff’s suit and Plaintiff’s claims and allegations, will 11 result in discovery production that includes: police reports and evidence; investigation 12 reports and evidence; potentially peace officer personnel materials; information 13 implicating the privacy rights of third parties (i.e., bystander witnesses, emergency 14 personnel information); and other private and confidential materials for which require 15 special protection from public disclosure. 16 Specifically, Plaintiff is seeking materials and information that Defendant 17 maintains as confidential such as personnel files of the police and/or sworn officers 18 involved in this incident, Internal Affairs materials and information, video recordings, 19 audio recordings, photographs, and information and other administrative materials and 20 information currently in the possession of the City and which Defendant believes need 21 special protection from public disclosure and from use for any purpose other than 22 prosecuting this litigation. Plaintiff may also seek official information contained in the 23 personnel files of the police and/or sworn officers involved in the subject incident, which 24 are maintained as strictly confidential and which Defendants believe need special 25 protection from public disclosure and from use for any purpose other than prosecuting 26 this litigation. 27 Defendant asserts that the confidentiality of the materials and information sought 1 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., 2 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). Defendant has not publicly 3 released the materials and information referenced above except under protective order or 4 pursuant to a court order, if at all. The personnel materials and information are of the type 5 that has been used to initiate disciplinary action against the City’s respective employees, 6 and has been used as evidence in disciplinary proceedings, where the employee conduct 7 was considered to be contrary to policy. 8 Defendant contends that absent a protective order delineating the responsibilities 9 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary 10 and undue disclosure by one or more of the many attorneys, secretaries, law clerks, 11 paralegals and expert witnesses involved in this case, as well as the corollary risk of 12 embarrassment, harassment and professional and legal harm on the part of the City’s 13 employees referenced in the materials and information. 14 Defendant also contends that the unfettered disclosure of the materials and 15 information, absent a protective order, would allow the media to share this information 16 with potential jurors in the area, impacting the rights of Defendant herein to receive a fair 17 trial. 18 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 19 of disputes over confidentiality of discovery materials, to adequately protect information 20 the parties are entitled to keep confidential, to ensure that the parties are permitted 21 reasonable necessary uses of such material in preparation for and in the conduct of trial, 22 to address their handling at the end of the litigation, and serve the ends of justice, a 23 protective order for such information is justified in this matter. It is the intent of the 24 parties that information will not be designated as confidential for tactical reasons and that 25 nothing be so designated without a good faith belief that it has been maintained in a 26 confidential, non-public manner, and there is good cause why it should not be part of the 27 public record of this case. 1 Plaintiff agrees that there is Good Cause for a Protective Order so as to preserve 2 the respective interests of the parties while streamlining the process of resolving any 3 disagreements. 4 The parties therefore stipulate that there is Good Cause for, and hereby jointly 5 request that the honorable Court issue a Protective Order regarding confidential 6 documents consistent with the terms and provisions of this Stipulation. However, the 7 entry of a Protective Order by the Court pursuant to this Stipulation shall not be construed 8 as any ruling by the Court on the aforementioned legal statements or privilege claims in 9 this section, no shall this section be construed as part of any such Court Order. 10 11 2. DEFINITIONS 2.1 Action: Charukian v. City of Los Angeles, et al., case no. 2:25-cv-01292 RGK (KSx). 12

13 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 14 information or items under this Order. 15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is 16 generated, stored or maintained) or tangible things that qualify for protection under 17 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 18 Statement. 19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 20 support staff). 21 2.5 Designating Party: a Party or Non-Party that designates information or items 22 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 23 2.6 Disclosure or Discovery Material: all items or information, regardless of the 24 medium or manner in which it is generated, stored, or maintained (including, among other 25 things, testimony, transcripts, and tangible things), that are produced or generated in 26 disclosures or responses to discovery in this matter. 27 1 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent 2 to the litigation who has been retained by a Party or its counsel to serve as an expert 3 witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. House 5 Counsel does not include Outside Counsel of Record or any other outside counsel. 6 2.9 Non-Party: any natural person, partnership, corporation, association, or other 7 legal entity not named as a Party to this action. 8 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this 9 Action but are retained to represent or advise a party to this Action and have appeared in 10 this Action on behalf of that party or are affiliated with a law firm which has appeared on 11 behalf of that party, and includes support staff. 12 2.11 Party: any party to this Action, including all of its officers, directors, 13 employees, consultants, retained experts, and Outside Counsel of Record (and their 14 support staffs). 15 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 16 Material in this Action. 17 2.13 Professional Vendors: persons or entities that provide litigation support 18 services (e.g., photocopying, videotaping, translating, preparing exhibits or 19 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 20 their employees and subcontractors. 21 2.14 Protected Material: any Disclosure or Discovery Material that is designated 22 as “CONFIDENTIAL.” 23 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 24 a Producing Party. 25 /// 26 /// 27 /// 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only Protected 3 Material (as defined above), but also (1) any information copied or extracted from 4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 5 Material; and (3) any testimony, conversations, or presentations by Parties or their 6 Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the trial 8 judge. This Order does not govern the use of Protected Material at trial. 9 10 4. DURATION 11 Once a case proceeds to trial, all of the information that was designated as 12 confidential or maintained pursuant to this protective order becomes public and will be 13 presumptively available to all members of the public, including the press, unless 14 compelling reasons supported by specific factual findings to proceed otherwise are made 15 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu, 16 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing 17 documents produced in discovery from “compelling reasons” standard when merits- 18 related documents are part of court record). Accordingly, the terms of this protective 19 order do not extend beyond the commencement of the trial. 20 Even after final disposition of this litigation, the confidentiality obligations 21 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 22 in writing or a court order otherwise directs. Final disposition shall be deemed to be the 23 later of (1) dismissal of all claims and defenses in this Action, with or without prejudice; 24 and (2) final judgment herein after the completion and exhaustion of all appeals, 25 rehearings, remands, trials, or reviews of this Action, including the time limits for filing 26 any motions or applications for extension of time pursuant to applicable law. 27 /// 1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 3 Party or Non-Party that designates information or items for protection under this Order 4 must take care to limit any such designation to specific material that qualifies under the 5 appropriate standards. The Designating Party must designate for protection only those 6 parts of material, documents, items, or oral or written communications that qualify so that 7 other portions of the material, documents, items, or communications for which protection 8 is not warranted are not swept unjustifiably within the ambit of this Order. 9 Mass, indiscriminate, or routinized designations are prohibited. Designations that 10 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 11 to unnecessarily encumber the case development process or to impose unnecessary 12 expenses and burdens on other parties) may expose the Designating Party to sanctions. 13 If it comes to a Designating Party’s attention that information or items that it 14 designated for protection do not qualify for protection, that Designating Party must 15 promptly notify all other Parties that it is withdrawing the inapplicable designation. 16 5.2 Manner and Timing of Designations. Except as otherwise provided in this 17 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 18 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 19 must be clearly so designated before the material is disclosed or produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic documents, but 22 excluding transcripts of depositions or other pretrial or trial proceedings), that the 23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 24 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 25 portion or portions of the material on a page qualifies for protection, the Producing Party 26 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 27 in the margins). 1 A Party or Non-Party that makes original documents available for inspection need 2 not designate them for protection until after the inspecting Party has indicated which 3 documents it would like copied and produced. During the inspection and before the 4 designation, all of the material made available for inspection shall be deemed 5 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 6 copied and produced, the Producing Party must determine which documents, or portions 7 thereof, qualify for protection under this Order. Then, before producing the specified 8 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 9 that contains Protected Material. If only a portion or portions of the material on a page 10 qualifies for protection, the Producing Party also must clearly identify the protected 11 portion(s) (e.g., by making appropriate markings in the margins). 12 (b) for testimony given in depositions that the Designating Party identify the 13 Disclosure or Discovery Material on the record, before the close of the deposition all 14 protected testimony. 15 (c) for information produced in some form other than documentary and for any 16 other tangible items, that the Producing Party affix in a prominent place on the exterior 17 of the container or containers in which the information is stored the legend 18 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 19 the Producing Party, to the extent practicable, shall identify the protected portion(s). 20 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 21 designate qualified information or items does not, standing alone, waive the Designating 22 Party’s right to secure protection under this Order for such material. Upon timely 23 correction of a designation, the Receiving Party must make reasonable efforts to assure 24 that the material is treated in accordance with the provisions of this Order. 25 /// 26 /// 27 /// 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 3 confidentiality at any time that is consistent with the Court’s Scheduling Order. 4 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 5 process under Local Rule 37.1 et seq. 6 6.3 The burden of persuasion in any such challenge proceeding shall be on the 7 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 8 to harass or impose unnecessary expenses and burdens on other parties) may expose the 9 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 10 the confidentiality designation, all parties shall continue to afford the material in question 11 the level of protection to which it is entitled under the Producing Party’s designation until 12 the Court rules on the challenge. 13 14 7. ACCESS TO AND USE OF PROTECTED MATERIAL 15 7.1 Basic Principles. A Receiving Party may use Protected Material that is 16 disclosed or produced by another Party or by a Non-Party in connection with this Action 17 only for prosecuting, defending, or attempting to settle this Action. Such Protected 18 Material may be disclosed only to the categories of persons and under the conditions 19 described in this Order. When the Action has been terminated, a Receiving Party must 20 comply with the provisions of section 13 below (FINAL DISPOSITION). 21 Protected Material must be stored and maintained by a Receiving Party at a 22 location and in a secure manner that ensures that access is limited to the persons 23 authorized under this Order. 24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 25 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 26 may disclose any information or item designated “CONFIDENTIAL” only to: 27 1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 2 employees of said Outside Counsel of Record to whom it is reasonably necessary to 3 disclose the information for this Action; 4 (b) the officers, directors, and employees (including House Counsel) of the 5 Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 7 reasonably necessary for this Action and who have signed the “Acknowledgment and 8 Agreement to Be Bound” (Exhibit A); 9 (d) the court and its personnel; 10 (e) court reporters and their staff; 11 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to 12 whom disclosure is reasonably necessary for this Action and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (g) the author or recipient of a document containing the information or a custodian 15 or other person who otherwise possessed or knew the information; 16 (h) during their depositions, witnesses ,and attorneys for witnesses, in the Action 17 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that 18 the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be permitted 19 to keep any confidential information unless they sign the “Acknowledgment and 20 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party 21 or ordered by the court. Pages of transcribed deposition testimony or exhibits to 22 depositions that reveal Protected Material may be separately bound by the court reporter 23 and may not be disclosed to anyone except as permitted under this Stipulated Protective 24 Order; and 25 (i) any mediator or settlement officer, and their supporting personnel, mutually 26 agreed upon by any of the parties engaged in settlement discussions. 27 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 2 OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation that 4 compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification shall include 7 a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order to issue 9 in the other litigation that some or all of the material covered by the subpoena or order is 10 subject to this Protective Order. Such notification shall include a copy of this Stipulated 11 Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 13 Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with the 15 subpoena or court order shall not produce any information designated in this action as 16 “CONFIDENTIAL” before a determination by the court from which the subpoena or 17 order issued, unless the Party has obtained the Designating Party’s permission. The 18 Designating Party shall bear the burden and expense of seeking protection in that court 19 of its confidential material and nothing in these provisions should be construed as 20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 21 from another court. 22 23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 24 IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a Non-Party 26 in this Action and designated as “CONFIDENTIAL.” Such information produced by 27 Non-Parties in connection with this litigation is protected by the remedies and relief 1 provided by this Order. Nothing in these provisions should be construed as prohibiting a 2 Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to produce a 4 Non-Party’s confidential information in its possession, and the Party is subject to an 5 agreement with the Non-Party not to produce the Non-Party’s confidential information, 6 then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non-Party that some 8 or all of the information requested is subject to a confidentiality agreement with a Non- 9 Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 11 in this Action, the relevant discovery request(s), and a reasonably specific description of 12 the information requested; and 13 (3) make the information requested available for inspection by the Non-Party, if 14 requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 14 days 16 of receiving the notice and accompanying information, the Receiving Party may produce 17 the Non-Party’s confidential information responsive to the discovery request. If the Non- 18 Party timely seeks a protective order, the Receiving Party shall not produce any 19 information in its possession or control that is subject to the confidentiality agreement 20 with the Non-Party before a determination by the court. Absent a court order to the 21 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 22 court of its Protected Material. 23 24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 1 all unauthorized copies of the Protected Material, (c) inform the person or persons to 2 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 3 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 4 that is attached hereto as Exhibit A. 5 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain inadvertently 9 produced material is subject to a claim of privilege or other protection, the obligations of 10 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 11 This provision is not intended to modify whatever procedure may be established in an e- 12 discovery order that provides for production without prior privilege review. Pursuant to 13 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 14 effect of disclosure of a communication or information covered by the attorney-client 15 privilege or work product protection, the parties may incorporate their agreement in the 16 stipulated protective order submitted to the court. 17 18 12. MISCELLANEOUS 19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person 20 to seek its modification by the Court in the future. 21 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 22 Order no Party waives any right it otherwise would have to object to disclosing or 23 producing any information or item on any ground not addressed in this Stipulated 24 Protective Order. Similarly, no Party waives any right to object on any ground to use in 25 evidence of any of the material covered by this Protective Order. 26 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 27 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 1 Material at issue. If a Party's request to file Protected Material under seal is denied by the 2 court, then the Receiving Party may file the information in the public record unless 3 otherwise instructed by the court. 4 5 13. FINAL DISPOSITION 6 After the final disposition of this Action, as defined in paragraph 4, within 60 days 7 of a written request by the Designating Party, each Receiving Party must return all 8 Protected Material to the Producing Party or destroy such material. As used in this 9 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 10 summaries, and any other format reproducing or capturing any of the Protected Material. 11 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 12 a written certification to the Producing Party (and, if not the same person or entity, to the 13 Designating Party) by the 60 day deadline that (1) identifies (by category, where 14 appropriate) all the Protected Material that was returned or destroyed and (2)affirms that 15 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 16 any other format reproducing or capturing any of the Protected Material. Notwithstanding 17 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 18 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 19 deposition and trial exhibits, expert reports, attorney work product, and consultant and 20 expert work product, even if such materials contain Protected Material. Any such archival 21 copies that contain or constitute Protected Material remain subject to this Protective Order 22 as set forth in Section 4 (DURATION). 23 /// 24 /// 25 /// 26 /// 27 /// 1 14. Any violation of this Order may be punished by any and all appropriate measures 2 including, without limitation, contempt proceedings and/or monetary sanctions. 3 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 Dated: August 18, 2025 Respectfully submitted, 7 MGDESYAN LAW FIRM 8 /s/ Araksya Boyadzhyan 9

GEORGE G. MGDESYAN, ESQ.

10 ARAKSYA BOYADZHYAN, ESQ. Attorneys for Plaintiff, GALIA RITA CHARUKIAN 11

Dated: August 18, 2025 HYDEE FELDSTEIN SOTO, City Attorney 12 DENISE C. MILLS, Chief Deputy City Attorney 13 KATHLEEN KENEALY, Chief Assistant City Attorney CORY M. BRENTE, Senior Assistant City Attorney 14 15 By: /s/ Rebecca E. Hunter REBECCA E. HUNTER, Deputy City Attorney 16 Attorneys for Defendant, CITY OF LOS ANGELES 17 18 ATTESTATION 19 Pursuant to L.R. 5-4.3.4(a)(2)(i), I hereby attest that Thomas C. Seabaugh, counsel 20 for Plaintiff Boston Moreland, concur in the content of this filing and has authorized this 21 filing.

22 Dated: August 8, 2025 HYDEE FELDSTEIN SOTO, City Attorney DENISE C. MILLS, Chief Deputy City Attorney 23 KATHLEEN KENEALY, Chief Assistant City Attorney CORY M. BRENTE, Senior Assistant City Attorney 24 25 By: /s/ Rebecca E. Hunter 26 REBECCA E. HUNTER, Deputy City Attorney Attorneys for Defendant, CITY OF LOS ANGELES 27 2 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 4 ||DATED: August 25, 2025 5 (Zan AZ: finssnsrn_ Karen L. Stevenson 7 || United States Magistrate Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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 entirety 5 and understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on ______________[date] in the case 7 of Charukian v. City of Los Angeles, et al., case no. 2:25-cv-01292 RGK (KSx). I agree 8 to comply with and to be bound by all the terms of this Stipulated Protective Order and I 9 understand and acknowledge that failure to so comply could expose me to sanctions and 10 punishment in the nature of contempt. I solemnly promise that I will not disclose in any 11 manner any information or item that is subject to this Stipulated Protective Order to any 12 person or entity except in strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for the 14 Central District of California for the purpose of enforcing the terms of this Stipulated 15 Protective Order, even if such enforcement proceedings occur after termination of this 16 action. I hereby appoint __________________________ [print or type full name] of 17 _______________________________________ [print or type full address and telephone 18 number] as my California agent for service of process in connection with this action or 19 any proceedings related to enforcement of this Stipulated Protective Order. 20 Date: ______________________________________ 21 City and State where sworn and signed: _________________________________ 22 23 Printed name: _______________________________ 24 25 Signature: __________________________________ 26 27