Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 1 of 16 Page ID #:137

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8 UNITED STATES DISTRICT COURT 9

CENTRAL DISTRICT OF CALIFORNIA

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SOUTHERN DIVISION

11 12 VERONICA RIVERA, an individual, Case No. 8:21-cv-01431-DOC-JDE 13 Plaintiff, STIPULATED PROTECTIVE 14 ORDER v. 15 MEDTRONIC USA, INC., a Trial Date: N/A 16 corporation; and DOES 1 through 50, Complaint Filed: July 30, 2021 17 Defendants. 18 19 20 Pursuant to the parties’ Stipulation (Dkt. 19), and for good cause shown, the 21 Court finds and orders as follows. 22 1. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, 24 proprietary or private information for which special protection from public 25 disclosure and from use for any purpose other than pursuing this litigation may be 26 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 27 enter the following Stipulated Protective Order. The parties acknowledge that this 28 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 2 of 16 Page ID #:138

1 Order does not confer blanket protections on all disclosures or responses to 2 discovery and that the protection it affords from public disclosure and use extends 3 only to the limited information or items that are entitled to confidential treatment 4 under the applicable legal principles. 5 2. GOOD CAUSE STATEMENT 6 This action is likely to involve confidential, non-public, sensitive, and/or 7 proprietary trade secrets, business, employment, tax, financial, and personally 8 identifiable information, documents and other materials for which special 9 protection from public disclosure and from use for any purpose other than 10 prosecution of this action is warranted. Such confidential and proprietary materials 11 and information consist of, among other things, confidential business or financial 12 information, information regarding confidential business practices, or other 13 confidential research, development, or commercial information (including 14 information implicating privacy rights of third parties), information otherwise 15 generally unavailable to the public, or which may be privileged or otherwise 16 protected from disclosure under state or federal statutes, court rules, case decisions, 17 or common law. Accordingly, to expedite the flow of information, to facilitate the 18 19 prompt resolution of disputes over confidentiality of discovery materials, to 20 adequately protect information the parties are entitled to keep confidential, to 21 ensure that the parties are permitted reasonable necessary uses of such material in 22 preparation for and in the conduct of trial, to address their handling at the end of 23 the litigation, and serve the ends of justice, a protective order for such information 24 is justified in this matter. It is the intent of the parties that information will not be 25 designated as confidential for tactical reasons and that nothing be so designated 26 without a good faith belief that it has been maintained in a confidential, non-public 27 manner, and there is good cause why it should not be part of the public record of 28 this case. 2 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 3 of 16 Page ID #:139

1 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 2

PROCEDURE

3 The parties further acknowledge, as set forth in Section 14.3, below, that this 4 Stipulated Protective Order does not entitle them to file confidential information 5 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 6 and the standards that will be applied when a party seeks permission from the court 7 to file material under seal. There is a strong presumption that the public has a right 8 of access to judicial proceedings and records in civil cases. In connection with non- 9 dispositive motions, good cause must be shown to support a filing under seal. See 10 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), 11 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar- 12 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even 13 stipulated protective orders require good cause showing), and a specific showing of 14 good cause or compelling reasons with proper evidentiary support and legal 15 justification, must be made with respect to Protected Material that a party seeks to 16 file under seal. The parties’ mere designation of Disclosure or Discovery Material 17 as CONFIDENTIAL does not— without the submission of competent evidence by 18 19 declaration, establishing that the material sought to be filed under seal qualifies as 20 confidential, privileged, or otherwise protectable—constitute good cause. 21 Further, if a party requests sealing related to a dispositive motion or trial, 22 then compelling reasons, not only good cause, for the sealing must be shown, and 23 the relief sought shall be narrowly tailored to serve the specific interest to be 24 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 25 2010). For each item or type of information, document, or thing sought to be filed 26 or introduced under seal, the party seeking protection must articulate compelling 27 reasons, supported by specific facts and legal justification, for the requested sealing 28 3 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 4 of 16 Page ID #:140

1 order. Again, competent evidence supporting the application to file documents 2 under seal must be provided by declaration. 3 Any document that is not confidential, privileged, or otherwise protectable 4 in its entirety will not be filed under seal if the confidential portions can be 5 redacted. If documents can be redacted, then a redacted version for public viewing, 6 omitting only the confidential, privileged, or otherwise protectable portions of the 7 document, shall be filed. Any application that seeks to file documents under seal in 8 their entirety should include an explanation of why redaction is not feasible. 9 4. DEFINITIONS 10 4.1 Action: Veronica Rivera v. Medtronic USA, Inc., and Does 1 through 11 50, inclusive, Case No. 8:21-cv-01431-DOC-JDE. 12 4.2 Challenging Party: a Party or Non-Party that challenges the 13 designation of information or items under this Order. 14 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for 16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 17 the Good Cause Statement. 18 19 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 20 their support staff). 21 4.5 Designating Party: a Party or Non-Party that designates information or 22 items that it produces in disclosures or in responses to discovery as 23 “CONFIDENTIAL.” 24 4.6 Disclosure or Discovery Material: all items or information, regardless 25 of the medium or manner in which it is generated, stored, or maintained (including, 26 among other things, testimony, transcripts, and tangible things), that are produced 27 or generated in disclosures or responses to discovery. 28 4 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 5 of 16 Page ID #:141

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2 4.7 Expert: a person with specialized knowledge or experience in a matter 3 pertinent to the litigation who has been retained by a Party or its counsel to serve 4 as an expert witness or as a consultant in this Action. 5 4.8 In House Counsel: attorneys who are employees of a party to this 6 Action. House Counsel does not include Outside Counsel of Record or any other 7 outside counsel. 8 4.9 Non-Party: any natural person, partnership, corporation, association or 9 other legal entity not named as a Party to this action. 10 4.10 Outside Counsel of Record: attorneys who are not employees of a 11 party to this Action but are retained to represent a party to this Action and have 12 appeared in this Action on behalf of that party or are affiliated with a law firm that 13 has appeared on behalf of that party, and includes support staff. 14 4.11 Party: any party to this Action, including all of its officers, directors, 15 employees, consultants, retained experts, and Outside Counsel of Record (and their 16 support staffs). 17 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 18 19 Discovery Material in this Action. 20 4.13 Professional Vendors: persons or entities that provide litigation 21 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. 24 4.14 Protected Material: any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL.” 26 4.15 Receiving Party: a Party that receives Disclosure or Discovery 27 Material from a Producing Party. 28 5 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 6 of 16 Page ID #:142

1 5. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the 8 trial judge and other applicable authorities. This Order does not govern the use of 9 Protected Material at trial. 10 6. DURATION 11 Even after final disposition of this litigation, the confidentiality 12 obligations imposed by this Stipulated Protective Order shall remain in effect until 13 a Designating Party agrees otherwise in writing or a court order otherwise directs. 14 Final disposition shall be deemed to be the later of (1) dismissal of all claims and 15 defenses in this Action, with or without prejudice; and (2) final judgment herein 16 after the completion and exhaustion of all appeals, rehearings, remands, trials, or 17 reviews of this Action, including the time limits for filing any motions or 18 19 applications for extension of time pursuant to applicable law. 20 7. DESIGNATING PROTECTED MATERIAL 21 7.1 Exercise of Restraint and Care in Designating Material for 22 Protection. Each Party or Non-Party that designates information or 23 items for protection under this Order must take care to limit any such designation 24 to specific material that qualifies under the appropriate standards. The Designating 25 Party must designate for protection only those parts of material, documents, items 26 or oral or written communications that qualify so that other portions of the 27 material, documents, items or communications for which protection is not 28 warranted are not swept unjustifiably within the ambit of this Order. 6 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 7 of 16 Page ID #:143

1 Mass, indiscriminate or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to 4 impose unnecessary expenses and burdens on other parties) may expose the 5 Designating Party to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 promptly notify all other Parties that it is withdrawing the inapplicable designation. 9 7.2 Manner and Timing of Designations. Except as otherwise provided in 10 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 11 that qualifies for protection under this Order must be clearly so designated before 12 the material is disclosed or produced. 13 Designation in conformity with this Order requires: 14 (a) for information in documentary form (e.g., paper or electronic 15 documents, but excluding transcripts of depositions or other pretrial or trial 16 proceedings), that the Producing Party affix at a minimum, the legend 17 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 18 19 contains protected material. If only a portion of the material on a page qualifies for 20 protection, the Producing Party also must clearly identify the protected portion(s) 21 (e.g., by making appropriate markings in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and 25 before the designation, all of the material made available for inspection shall be 26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 27 documents it wants copied and produced, the Producing Party must determine 28 which documents, or portions thereof, qualify for protection under this Order. 7 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 8 of 16 Page ID #:144

1 Then, before producing the specified documents, the Producing Party must affix 2 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 3 only a portion of the material on a page qualifies for protection, the Producing 4 Party also must clearly identify the protected portion(s) (e.g., by making 5 appropriate markings in the margins). 6 (b) for testimony given in depositions that the Designating Party 7 identifies the Disclosure or Discovery Material on the record, before the close of 8 the deposition all protected testimony. 9 (c) for information produced in some form other than documentary 10 and for any other tangible items, that the Producing Party affix in a prominent 11 place on the exterior of the container or containers in which the information is 12 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 13 information warrants protection, the Producing Party, to the extent practicable, 14 shall identify the protected portion(s). 15 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not, standing alone, waive 17 the Designating Party’s right to secure protection under this Order for such 18 19 material. Upon timely correction of a designation, the Receiving Party must make 20 reasonable efforts to assure that the material is treated in accordance with the 21 provisions of this Order. 22 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 24 designation of confidentiality at any time that is consistent with the Court’s 25 Scheduling Order. 26 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 27 resolution process under Local Rule 37-1 et seq. 28 8 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 9 of 16 Page ID #:145

1 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 2 joint stipulation pursuant to Local Rule 37-2. 3 8.4 The burden of persuasion in any such challenge proceeding shall be on 4 the Designating Party. Frivolous challenges, and those made for an improper 5 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 6 parties) may expose the Challenging Party to sanctions. Unless the Designating 7 Party has waived or withdrawn the confidentiality designation, all parties shall 8 continue to afford the material in question the level of protection to which it is 9 entitled under the Producing Party’s designation until the Court rules on the 10 challenge. 11 9. ACCESS TO AND USE OF PROTECTED MATERIAL 12 9.1 Basic Principles. A Receiving Party may use Protected Material that is 13 disclosed or produced by another Party or by a Non-Party in connection with this 14 Action only for prosecuting, defending or attempting to settle this Action. Such 15 Protected Material may be disclosed only to the categories of persons and under 16 the conditions described in this Order. When the Action has been terminated, a 17 Receiving Party must comply with the provisions of section 15 below (FINAL 18 19 DISPOSITION). 20 Protected Material must be stored and maintained by a Receiving Party at a 21 location and in a secure manner that ensures that access is limited to the persons 22 authorized under this Order. 23 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 24 otherwise ordered by the court or permitted in writing by the Designating Party, a 25 Receiving Party may disclose any information or item designated 26 “CONFIDENTIAL” only to: 27 / / / 28 / / / 9 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 10 of 16 Page ID #:146

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 In-House 5 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for 6 this Action; 7 (c) Experts (as defined in this Order) of the Receiving Party to whom 8 disclosure is reasonably necessary for this Action and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A): 10 (d) the court and its personnel; 11 (e) court reporters and their staff; 12 (f) professional jury or trial consultants, mock jurors, and Professional 13 Vendors to whom disclosure is reasonably necessary for this Action and who have 14 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (g) the author or recipient of a document containing the information or 16 a custodian or other person who otherwise possessed or knew the information; 17 (h) during their depositions, witnesses, and attorneys for witnesses, in 18 19 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 20 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 21 they will not be permitted to keep any confidential information unless they sign the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 23 agreed by the Designating Party or ordered by the court. Pages of transcribed 24 deposition testimony or exhibits to depositions that reveal Protected Material may 25 be separately bound by the court reporter and may not be disclosed to anyone 26 except as permitted under this Stipulated Protective Order; and 27 (i) any mediators or settlement officers and their supporting personnel, 28 mutually agreed upon by any of the parties engaged in settlement discussions. 10 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 11 of 16 Page ID #:147

1 10. 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 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification 7 shall include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or 9 order to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall 11 include a copy of this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be 13 pursued by the Designating Party whose Protected Material may be affected. If the 14 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 16 as “CONFIDENTIAL” before a determination by the court from which the 17 subpoena or order issued, unless the Party has obtained the Designating Party’s 18 19 permission. The Designating Party shall bear the burden and expense of seeking 20 protection in that court of its confidential material and nothing in these provisions 21 should be construed as authorizing or encouraging a Receiving Party in this Action 22 to disobey a lawful directive from another court. 23 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 24 BE PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by 26 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 27 information produced by Non-Parties in connection with this litigation is protected 28 by the remedies and relief provided by this Order. Nothing in these provisions 11 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 12 of 16 Page ID #:148

1 should be construed as prohibiting a Non-Party from seeking additional 2 protections. 3 (b) In the event that a Party is required, by a valid discovery request, 4 to produce a Non-Party’s confidential information in its possession, and the Party 5 is subject to an agreement with the Non-Party not to produce the Non-Party’s 6 confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the 8 Non-Party that some or all of the information requested is subject to a 9 confidentiality agreement with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the 11 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 12 reasonably specific description of the information requested; and 13 (3) make the information requested available for inspection by 14 the Non-Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court 16 within 14 days of receiving the notice and accompanying information, the 17 Receiving Party may produce the Non-Party’s confidential information responsive 18 19 to the discovery request. If the Non-Party timely seeks a protective order, the 20 Receiving Party shall not produce any information in its possession or control that 21 is subject to the confidentiality agreement with the Non-Party before a 22 determination by the court. Absent a court order to the contrary, the Non-Party 23 shall bear the burden and expense of seeking protection in this court of its 24 Protected Material. 25 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 26 MATERIAL 27 If a Receiving Party learns that, by inadvertence or otherwise, it has 28 disclosed Protected Material to any person or in any circumstance not authorized 12 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 13 of 16 Page ID #:149

1 under this Stipulated Protective Order, the Receiving Party must immediately (a) 2 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 3 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 4 the person or persons to whom unauthorized disclosures were made of all the terms 5 of this Order, and (d) request such person or persons to execute the 6 “Acknowledgment an Agreement to Be Bound” attached hereto as Exhibit A. 7 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 8

OTHERWISE PROTECTED MATERIAL

9 When a Producing Party gives notice to Receiving Parties that certain 10 inadvertently produced material is subject to a claim of privilege or other 11 protection, the obligations of the Receiving Parties are those set forth in Federal 12 Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to modify 13 whatever procedure may be established in an e-discovery order that provides for 14 production without prior privilege review. Pursuant to Federal Rule of Evidence 15 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 16 of a communication or information covered by the attorney-client privilege or 17 work product protection, the parties may incorporate their agreement in the 18 19 stipulated protective order submitted to the court. 20 14. MISCELLANEOUS 21 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 22 person to seek its modification by the Court in the future. 23 14.2 Right to Assert Other Objections. By stipulating to the entry of this 24 Protective Order, no Party waives any right it otherwise would have to object to 25 disclosing or producing any information or item on any ground not addressed in 26 this Stipulated Protective Order. Similarly, no Party waives any right to object on 27 any ground to use in evidence of any of the material covered by this Protective 28 Order. 13 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 14 of 16 Page ID #:150

1 14.3 Filing Protected Material. A Party that seeks to file under seal any 2 Protected Material must comply with Local Civil Rule 79-5. Protected Material 3 may only be filed under seal pursuant to a court order authorizing the sealing of the 4 specific Protected Material. If a Party’s request to file Protected Material under 5 seal is denied by the court, then the Receiving Party may file the information in the 6 public record unless otherwise instructed by the court. 7 15. FINAL DISPOSITION 8 After the final disposition of this Action, as defined in paragraph 6, within 9 60 days of a written request by the Designating Party, each Receiving Party must 10 return all Protected Material to the Producing Party or destroy such material. As 11 used in this subdivision, “all Protected Material” includes all copies, abstracts, 12 compilations, summaries, and any other format reproducing or capturing any of the 13 Protected Material. Whether the Protected Material is returned or destroyed, the 14 Receiving Party must submit a written certification to the Producing Party (and, if 15 not the same person or entity, to the Designating Party) by the 60-day deadline that 16 (1) identifies (by category, where appropriate) all the Protected Material that was 17 returned or destroyed and (2) affirms that the Receiving Party has not retained any 18 19 copies, abstracts, compilations, summaries or any other format reproducing or 20 capturing any of the Protected Material. Notwithstanding this provision, Counsel 21 are entitled to retain an archival copy of all pleadings, motion papers, trial, 22 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 23 and trial exhibits, expert reports, attorney work product, and consultant and expert 24 work product, even if such materials contain Protected Material. Any such archival 25 copies that contain or constitute Protected Material remain subject to this 26 Protective Order as set forth in Section 6 (DURATION). 27 16. VIOLATION 28 Any violation of this Order may be punished by appropriate measures 14 Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page150f16 Page ID #:151

I including, without limitation, contempt proceedings and/or monetary sanctions. > || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: March 18, 2022 / xh bp ee 9 ited States Magistrate Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15

Case 8:21-cv-01431-DOC-JDE Document 20 Filed 03/18/22 Page 16 of 16 Page ID #:152

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [full name], of 4 [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 March 18, 2022, in the 7 case of Veronica Rivera v. Medtronic USA, Inc., Does 1-50, Case No. 8:21-cv- 8 01431-DOC-JDE. I agree to comply with and to be bound by all the terms of this 9 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 12 is subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Stipulated Protective Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint [full name] 19 of [address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 24 Signature: 25 Printed Name: 26 Date: 27 City and State Where Sworn and Signed: 28 16