Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 1 of 15 Page ID #:538

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7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 PROCESSSERVERWORLD, LLC, a Case No.: 2:21-cv-09184-JFW-PLAx limited liability company, 12 Assigned to: Hon. John F. Walter 13 Plaintiff, United States District Judge 14 v. Referred to: Hon. Paul L. Abrams 15 United States Magistrate Judge 16 NATIONWIDE LEGAL, LLC; ASAP Legal, LLC; IDISCOVER, LLC; [PROPOSED] STIPULATED 17 HOOMAN DAVOODI, an individual; PROTECTIVE ORDER 18 JOE CAAMAL, an individual; LUIS 19 FERNANDEZ, an individual; VICTOR Case Filed: November 23, 2021 ROMO, an individual; LOUIS Trial Date: March 14, 2023 20 MARTINEZ, an individual; BITA

21 IMANI, an individual; and DOES 1 through 10, inclusive, 22

23 Defendants. 24 1. GENERAL 25 1.1 Purposes and Limitations. 26 Discovery in this action is likely to involve production of confidential, 27 proprietary, or private information for which special protection from public 28 -1- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 2 of 15 Page ID #:539

1 disclosure and from use for any purpose other than prosecuting this litigation may be 2 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 3 the following Stipulated Protective Order. The parties acknowledge that this Order 4 does not confer blanket protections on all disclosures or responses to discovery and 5 that the protection it affords from public disclosure and use extends only to the 6 limited information or items that are entitled to confidential treatment under the 7 applicable legal principles. The parties further acknowledge, as set forth in Section 8 12.3, below, that this Stipulated Protective Order does not entitle them to file 9 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 10 that must be followed and the standards that will be applied when a party seeks 11 permission from the court to file material under seal. 12 1.2 Good Cause Statement. 13 This action is likely to involve trade secrets, customer and pricing lists and 14 other valuable research, development, commercial, financial, technical and/or 15 proprietary information for which special protection from public disclosure and from 16 use for any purpose other than prosecution of this action is warranted. Such 17 confidential and proprietary materials and information consist of, among other 18 19 things, confidential business or financial information, information regarding 20 confidential business practices, or other confidential research, development, or 21 commercial information (including information implicating privacy rights of third 22 parties), information otherwise generally unavailable to the public, or which may be 23 privileged or otherwise protected from disclosure under state or federal statutes, 24 court rules, case decisions, or common law. Accordingly, to expedite the flow of 25 information, to facilitate the prompt resolution of disputes over confidentiality of 26 discovery materials, to adequately protect information the parties are entitled to keep 27 confidential, to ensure that the parties are permitted reasonable necessary uses of 28 -2- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 3 of 15 Page ID #:540

1 such material in preparation for and in the conduct of trial, to address their handling 2 at the end of the litigation, and serve the ends of justice, a protective order for such 3 information is justified in this matter. It is the intent of the parties that information 4 will not be designated as confidential for tactical reasons and that nothing be so 5 designated without a good faith belief that it has been maintained in a confidential, 6 non-public manner, and there is good cause why it should not be part of the public 7 record of this case. 8

9 2. DEFINITIONS 10 2.1 Action: PROCESSSERVERWORLD, LLC v. NATIONWIDE LEGAL, 11 LLC, et al., Case No. 2:21-cv-09184-JFW-PLAx. 12 2.2 Challenging Party: a Party or Non-Party that challenges the designation 13 of information or items under this Order. 14 2.3 “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 the 17 Good Cause Statement. 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 19 their support staff). 20 2.5 Designating Party: a Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 2.6 Disclosure or Discovery Material: all items or information, regardless 24 of the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced or 26 generated in disclosures or responses to discovery in this matter. 27 28 -3- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 4 of 15 Page ID #:541

1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.9 Non-Party: any natural person, partnership, corporation, association or 8 other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm that 12 has appeared on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 25 from a Producing Party. 26 27 28 -4- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 5 of 15 Page ID #:542

3. SCOPE 1 The protections conferred by this Stipulation and Order cover not only 2 Protected Material (as defined above), but also (1) any information copied or 3 extracted from Protected Material; (2) all copies, excerpts, summaries, or 4 compilations of Protected Material; and (3) any testimony, conversations, or 5 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. 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 court-filed information to be 12 introduced that was previously designated as confidential or maintained pursuant to 13 this protective order becomes public and will be presumptively available to all 14 members of the public, including the press, unless compelling reasons supported by 15 specific factual findings to proceed otherwise are made to the trial judge in advance 16 of the trial. See Kamakana v. City and Cty of Honolulu, 447 F.3d 1172, at 1180-81 17 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents 18 produced in discovery from “compelling reasons” standard when merits-related 19 documents are part of court record). Accordingly, the terms of this protective order 20 do not extend beyond the commencement of the trial. 21 22 5. DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for Protection. 24 Each Party or Non-Party that designates information or items for protection under 25 this Order must take care to limit any such designation to specific material that 26 qualifies under the appropriate standards. The Designating Party must designate for 27 protection only those parts of material, documents, items or oral or written 28 communications that qualify so that other portions of the material, documents, items -5- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 6 of 15 Page ID #:543

1 or communications for which protection is not warranted are not swept unjustifiably 2 within the ambit of this Order. 3 Mass, indiscriminate or routinized designations are prohibited. Designations 4 that are shown to be clearly unjustified or that have been made for an improper 5 purpose (e.g., to unnecessarily encumber the case development process or to impose 6 unnecessary expenses and burdens on other parties) may expose the Designating 7 Party to sanctions. 8 If it comes to a Designating Party’s attention that information or items that it 9 designated for protection do not qualify for protection, that Designating Party must 10 promptly notify all other Parties that it is withdrawing the inapplicable designation. 11 5.2 Manner and Timing of Designations. Except as otherwise provided in 12 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 14 under this Order must be clearly so designated before the material is disclosed or 15 produced. 16 Designation in conformity with this Order requires: 17 (a) for information in documentary form (e.g., paper or electronic documents, 18 but excluding transcripts of depositions or other pretrial or trial proceedings), that 19 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 20 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 21 portion of the material on a page qualifies for protection, the Producing Party also 22 must clearly identify the protected portion(s) (e.g., by making appropriate markings 23 in the margins). 24 A Party or Non-Party that makes original documents available for inspection 25 need not designate them for protection until after the inspecting Party has indicated 26 which documents it would like copied and produced. During the inspection and 27 before the designation, all of the material made available for inspection shall be 28 -6- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 7 of 15 Page ID #:544

1 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 2 documents it wants copied and produced, the Producing Party must determine which 3 documents, or portions thereof, qualify for protection under this Order. Then, before 4 producing the specified documents, the Producing Party must affix the 5 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 6 portion or portions of the material on a page qualifies for protection, the Producing 7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 8 markings in the margins). 9 (b) for testimony given in depositions that the Designating Party identifies the 10 Disclosure or Discovery Material on the record, before the close of the deposition all 11 protected testimony. 12 (c) for information produced in some form other than documentary and for 13 any other tangible items, that the Producing Party affix in a prominent place on the 14 exterior of the container or containers in which the information is stored the legend 15 “CONFIDENTIAL.” If only a portion or portions of the information warrants 16 protection, the Producing Party, to the extent practicable, shall identify the protected 17 portion(s). 18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 failure to designate qualified information or items does not, standing alone, waive 20 the Designating Party’s right to secure protection under this Order for such material. 21 Upon timely correction of a designation, the Receiving Party must make reasonable 22 efforts to assure that the material is treated in accordance with the provisions of this 23 Order. 24 25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 26 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 27 designation of confidentiality at any time that is consistent with the Court’s 28 Scheduling Order. -7- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 8 of 15 Page ID #:545

1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly 3 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 4 6.3 Burden. The burden of persuasion in any such challenge proceeding 5 shall be on the Designating Party. Frivolous challenges, and those made for an 6 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 7 other parties) may expose the Challenging Party to sanctions. Unless the 8 Designating Party has waived or withdrawn the confidentiality designation, all 9 parties shall continue to afford the material in question the level of protection to 10 which it is entitled under the Producing Party’s designation until the Court rules on 11 the challenge. 12

13 7. ACCESS TO AND USE OF PROTECTED MATERIAL 14 7.1 Basic Principles. A Receiving Party may use Protected Material that is 15 disclosed or produced by another Party or by a Non-Party in connection with this 16 Action only for prosecuting, defending or attempting to settle this Action. Such 17 Protected Material may be disclosed only to the categories of persons and under the 18 conditions described in this Order. When the Action has been terminated, a 19 Receiving Party must comply with the provisions of section 13 below (FINAL 20

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 25 otherwise ordered by the court or permitted in writing by the Designating Party, a 26 Receiving Party may disclose any information or item designated 27 “CONFIDENTIAL” only to: 28 -8- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 9 of 15 Page ID #:546

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 7 disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and 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 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (g) the author or recipient of a document containing the information or a 15 custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, witnesses, and attorneys for witnesses, in the 17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 18 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 19 will not be permitted to keep any confidential information unless they sign the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 21 agreed by the Designating Party or ordered by the court. Pages of transcribed 22 deposition testimony or exhibits to depositions that reveal Protected Material may be 23 separately bound by the court reporter and may not be disclosed to anyone except as 24 permitted under this Stipulated Protective Order; and 25 (i) any mediator or settlement officer, and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 28 -9- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 10 of 15 Page ID #:547

1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 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 shall 7 include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order to 9 issue in the other litigation that some or all of the material covered by the subpoena 10 or order is subject to this Protective Order. Such notification shall include a copy of 11 this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with 15 the subpoena or court order shall not produce any information designated in this 16 action 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 permission. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this Action 21 to disobey a lawful directive from another court. 22 23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a Non- 26 Party in this Action and designated as “CONFIDENTIAL.” Such information 27 produced by Non-Parties in connection with this litigation is protected by the 28 -10- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 11 of 15 Page ID #:548

1 remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 produce a Non-Party’s confidential information in its possession, and the Party is 5 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 Non-Party 8 that some or all of the information requested is subject to a confidentiality agreement 9 with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and 13 (3) make the information requested available for inspection by the 14 Non-Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 14 16 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party shall bear the burden and 22 expense of seeking protection in this 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 28 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts -11- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 12 of 15 Page ID #:549

1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the “Acknowledgment and 4 Agreement to Be Bound” 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 9 inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 12 may be established in an e-discovery order that provides for production without prior 13 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 14 parties reach an agreement on the effect of disclosure of a communication or 15 information covered by the attorney-client privilege or work product protection, the 16 parties may incorporate their agreement in the stipulated protective order submitted 17 to the court. 18 19 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 21 person to seek its modification by the Court in the future. 22 12.2 Right to Assert Other Objections. By stipulating to the entry of this 23 Protective Order, no Party waives any right it otherwise would have to object to 24 disclosing or producing any information or item on any ground not addressed in this 25 Stipulated Protective Order. Similarly, no Party waives any right to object on any 26 ground to use in evidence of any of the material covered by this Protective Order. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 28 Protected Material must comply with Civil Local Rule 79-5. Protected Material may -12- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 13 of 15 Page ID #:550

1 only be filed under seal pursuant to a court order authorizing the sealing of the 2 specific Protected Material at issue; good cause must be shown in the request to file 3 under seal. If a Party’s request to file Protected Material under seal is denied by the 4 court, then the Receiving Party may file the information in the public record unless 5 otherwise instructed by the court. 6 7 13. FINAL DISPOSITION 8 After the final disposition of this Action, as defined in paragraph 4, within 60 9 days of a written request by the Designating Party, each Receiving Party must return 10 all Protected Material to the Producing Party or destroy such material. As used in 11 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 12 summaries, and any other format reproducing or capturing any of the Protected 13 Material. Whether the Protected Material is returned or destroyed, the Receiving 14 Party must submit a written certification to the Producing Party (and, if not the same 15 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 16 (by category, where appropriate) all the Protected Material that was returned or 17 destroyed and (2) affirms that the Receiving Party has not retained any copies, 18 abstracts, compilations, summaries or any other format reproducing or capturing any 19 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 20 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 21 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 22 reports, attorney work product, and consultant and expert work product, even if such 23 materials contain Protected Material. Any such archival copies that contain or 24 constitute Protected Material remain subject to this Protective Order as set forth in 25 Section 4 (DURATION). 26 27 28 -13- [PROPOSED] STIPULATED PROTECTIVE ORDER Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page14o0f15 Page ID#:551

1 VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 |}including, without limitation, contempt proceedings and/or monetary sanctions. 5 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 || DATED: October 19, 2022 9 ||/s/ Morgan E. Pietz Morgan E. Pietz 10 || PIETZ & SHAHRIARI, LLP 1 Attorneys for Plaintiff; PROCESSERVERWORLD, LLC 12 13 ||} DATED: October 19, 2022 14 /s/ Saul Reiss ISISAULREISS ss—“C:S~™~™OCC 16 || LAW OFFICES OF SAUL REISS dnorneys for Defendants 17 | NATIONWIDE LEGAL, LLC; ASAP LEGAL, LLC; IDISCOVER, LLC; HOOMAN DAVOODL an individual; JOE CAAMAL, an individual; LUIS FERNANDEZ, an 1g || individual; VICTOR ROMO, an individual; LOUIS MARTINEZ, an individual 19 20 5, | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 3 DATED: October 20, 2022 4 ROK. ramet 25 ||

HON. PAUL L. ABRAMS

26 || United States Magistrate Judge 27 28

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Case 2:21-cv-09184-JFW-PLA Document 106 Filed 10/20/22 Page 15 of 15 Page ID #:552

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on _________________ [date] in the case of PROCESSSERVERWORLD, LLC v. 9 NATIONWIDE LEGAL, LLC, et al., Case No. 2:21-cv-09184-JFW-PLAx. I agree to 10 comply with and to be bound by all the terms of this Stipulated Protective Order and 11 I understand and acknowledge that failure to so comply could expose me to 12 sanctions and punishment in the nature of contempt. I solemnly promise that I will 13 not disclose in any manner any information or item that is subject to this Stipulated 14 Protective Order to any person or entity except in strict compliance with the 15 provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court for the 17 Central District of California for enforcing the terms of this Stipulated Protective 18 Order, even if such enforcement proceedings occur after termination of this action. I 19 hereby appoint __________________________ [print or type full name] of 20 _______________________________________ [print or type full address and 21 telephone number] as my California agent for service of process in connection with 22 this action or any proceedings related to enforcement of this Stipulated Protective 23 Order. 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28 -15- [PROPOSED] STIPULATED PROTECTIVE ORDER