1 BbkEiNmJ@AnMixIoNn pJ.e KabIoMd y(.ScBomN 233856) 2 IRENE SCHOLL-TATEVOSYAN (SBN 301568) itatevosyan@nixonpeabody.com 3 ANDREA CHAVEZ (SBN 318297) andrea.chavez@nixonpeabody.com 4 NIXON PEABODY LLP 300 S. Grand Avenue, Suite 4100 5 Los Angeles, CA 90071-3151 Tel: 213-629-6000 6 Fax: 213-629-6001 7 Attorneys for Defendant

LABORATORY CORPORATION OF AMERICA

8 Norman B. Blumenthal (SBN: 068687) 9 Kyle R. Nordrehaug (SBN: 205975) Aparajit Bhowmik (SBN: 248066) 10 BLUMENTHAL NORDREHAUG BHOWMIK DE

BLOUW LLP

11 2255 Calle Clara La Jolla, CA 92037 12 Tel: (858) 551-1223 Fax: (858) 551-1232 13 Attorneys for Plaintiff 14 Michael Ignacio

15 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 19 MICHAEL IGNACIO, an individual, on Case No. 2:19-cv-06079-AB-RAO behalf of himself and on behalf of all 20 persons similarly situated, STIPULATED PROTECTIVE

ORDER1

21 Plaintiff,

22 vs.

23 LABORATORY CORPORATION OF AMERICA, a Delaware Corporation; 24 and DOES 1 through 50, inclusive,

25 Defendants. Complaint Filed: June 24, 2019 Trial Date: None Set 26 27

1 This Stipulated Protective Order is substantially based on the model protective 28 order provided under Magistrate Judge Rozella A. Oliver’s Procedures. 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action is likely to involve private third-party information of non- 13 percipient witness employees and other individuals, trade secrets, customer and 14 pricing lists and other valuable research, development, commercial, financial, 15 technical and/or proprietary information for which special protection from public 16 disclosure and from use for any purpose other than prosecution of this action is 17 warranted. Such confidential and proprietary materials and information consist of, 18 among other things, confidential business or financial information, information 19 regarding confidential business practices, or other confidential research, 20 development, or commercial information (including information implicating 21 privacy rights of third parties), information otherwise generally unavailable to the 22 public, or which may be privileged or otherwise protected from disclosure under 23 state or federal statutes, court rules, case decisions, or common law. Accordingly, 24 to expedite the flow of information, to facilitate the prompt resolution of disputes 25 over confidentiality of discovery materials, to adequately protect information the 26 parties are entitled to keep confidential, to ensure that the parties are permitted 27 reasonable necessary uses of such material in preparation for and in the conduct of 28 trial, to address their handling at the end of the litigation, and serve the ends of 1 justice, a protective order for such information is justified in this matter. It is the 2 intent of the parties that information will not be designated as confidential for 3 tactical reasons and that nothing be so designated without a good faith belief that it 4 has been maintained in a confidential, non-public manner, and there is good cause 5 why it should not be part of the public record of this case. 6 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

SEAL

7 8 The parties further acknowledge, as set forth in Section 12.3, below, that this 9 Stipulated Protective Order does not entitle them to file confidential information 10 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 11 and the standards that will be applied when a party seeks permission from the court 12 to file material under seal. 13 There is a strong presumption that the public has a right of access to judicial 14 proceedings and records in civil cases. In connection with non-dispositive motions, 15 good cause must be shown to support a filing under seal. See Kamakana v. City 16 and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. 17 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 18 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective 19 orders require good cause showing), and a specific showing of good cause or 20 compelling reasons with proper evidentiary support and legal justification, must be 21 made with respect to Protected Material that a party seeks to file under seal. The 22 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL 23 does not—without the submission of competent evidence by declaration, 24 establishing that the material sought to be filed under seal qualifies as confidential, 25 privileged, or otherwise protectable—constitute good cause. 26 Further, if a party requests sealing related to a dispositive motion or trial, 27 then compelling reasons, not only good cause, for the sealing must be shown, and 28 the relief sought shall be narrowly tailored to serve the specific interest to be 1 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2 2010). For each item or type of information, document, or thing sought to be filed 3 or introduced under seal in connection with a dispositive motion or trial, the party 4 seeking protection must articulate compelling reasons, supported by specific facts 5 and legal justification, for the requested sealing order. Again, competent evidence 6 supporting the application to file documents under seal must be provided by 7 declaration. 8 Any document that is not confidential, privileged, or otherwise protectable in 9 its entirety will not be filed under seal if the confidential portions can be redacted. 10 If documents can be redacted, then a redacted version for public viewing, omitting 11 only the confidential, privileged, or otherwise protectable portions of the document, 12 shall be filed. Any application that seeks to file documents under seal in their 13 entirety should include an explanation of why redaction is not feasible. 14 2. DEFINITIONS 15 2.1 Action: Michael Ignacio v. Laboratory Corporation of America, Case 16 No. 2:19-cv-06079-AB-RAO. 17 2.2 Challenging Party: a Party or Non-Party that challenges the 18 designation of information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for 21 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 22 the Good Cause Statement. 23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 24 their support staff). 25 2.5 Designating Party: a Party or Non-Party that designates information or 26 items that it produces in disclosures or in responses to discovery as 27 “CONFIDENTIAL.” 28 2.6 Disclosure or Discovery Material: all items or information, regardless 1 of the medium or manner in which it is generated, stored, or maintained (including, 2 among other things, testimony, transcripts, and tangible things), that are produced 3 or generated in disclosures or responses to discovery in this matter. 4 2.7 Expert: a person with specialized knowledge or experience in a matter 5 pertinent to the litigation who has been retained by a Party or its counsel to serve as 6 an expert witness or as a consultant in this Action. 7 2.8 House Counsel: attorneys who are employees of a party to this Action. 8 House Counsel does not include Outside Counsel of Record or any other outside 9 counsel. 10 2.9 Non-Party: any natural person, partnership, corporation, association or 11 other legal entity not named as a Party to this action. 12 2.10 Outside Counsel of Record: attorneys who are not employees of a 13 party to this Action but are retained to represent or advise a party to this Action and 14 have appeared in this Action on behalf of that party or are affiliated with a law firm 15 that has appeared on behalf of that party, and includes support staff. 16 2.11 Party: any party to this Action, including all of its officers, directors, 17 employees, consultants, retained experts, and Outside Counsel of Record (and their 18 support staffs). 19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 2.13 Professional Vendors: persons or entities that provide litigation 22 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 demonstrations, and organizing, storing, or retrieving data in any form or medium) 24 and their employees and subcontractors. 25 2.14 Protected Material: any Disclosure or Discovery Material that is 26 designated as “CONFIDENTIAL.” 27 2.15 Receiving Party: a Party that receives Disclosure or Discovery 28 Material from a Producing Party. 1 3. 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. This Order does not govern the use of Protected Material at trial. 9 4. DURATION 10 Once a case proceeds to trial, information that was designated as 11 CONFIDENTIAL or maintained pursuant to this protective order used or 12 introduced as an exhibit at trial becomes public and will be presumptively available 13 to all members of the public, including the press, unless compelling reasons 14 supported by specific factual findings to proceed otherwise are made to the trial 15 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing 16 “good cause” showing for sealing documents produced in discovery from 17 “compelling reasons” standard when merits-related documents are part of court 18 record). Accordingly, the terms of this protective order do not extend beyond the 19 commencement of the trial. 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 Exercise of Restraint and Care in Designating Material for Protection. 22 Each Party or Non-Party that designates information or items for protection under 23 this Order must take care to limit any such designation to specific material that 24 qualifies under the appropriate standards. The Designating Party must designate for 25 protection only those parts of material, documents, items or oral or written 26 communications that qualify so that other portions of the material, documents, 27 items or communications for which protection is not warranted are not swept 28 unjustifiably within the ambit of this Order. 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 5.2 Manner and Timing of Designations. Except as otherwise provided in 10 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 12 under this Order must be clearly so designated before the material is disclosed or 13 produced. 14 Designation in conformity with this Order requires: 15 (a) for information in documentary form (e.g., paper or electronic 16 documents, but excluding transcripts of depositions or other pretrial or trial 17 proceedings), that the Producing Party affix at a minimum, the legend 18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 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. 1 Then, before producing the specified documents, the Producing Party must affix the 2 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 3 portion of the material on a page qualifies for protection, the Producing Party also 4 must clearly identify the protected portion(s) (e.g., by making appropriate markings 5 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 place 11 on the exterior of the container or containers in which the information is stored the 12 legend “CONFIDENTIAL.” If only a portion or portions of the information 13 warrants protection, the Producing Party, to the extent practicable, shall identify the 14 protected portion(s). 15 5.3 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 material. Upon timely correction of a designation, the Receiving Party must make 19 reasonable efforts to assure that the material is treated in accordance with the 20 provisions of this Order. 21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 23 designation of confidentiality at any time that is consistent with the Court’s 24 Scheduling Order. 25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 26 resolution process under Local Rule 37.1 et seq. 27 6.3 The burden of persuasion in any such challenge proceeding shall be on 28 the Designating Party. Frivolous challenges, and those made for an improper 1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 parties) may expose the Challenging Party to sanctions. Unless the Designating 3 Party has waived or withdrawn the confidentiality designation, all parties shall 4 continue to afford the material in question the level of protection to which it is 5 entitled under the Producing Party’s designation until the Court rules on the 6 challenge. 7 7. ACCESS TO AND USE OF PROTECTED MATERIAL 8 7.1 Basic Principles. A Receiving Party may use Protected Material that is 9 disclosed or produced by another Party or by a Non-Party in connection with this 10 Action only for prosecuting, defending or attempting to settle this Action. Such 11 Protected Material may be disclosed only to the categories of persons and under the 12 conditions described in this Order. When the Action has been terminated, a 13 Receiving Party must comply with the provisions of section 13 below (FINAL 14 DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 authorized under this Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 19 otherwise ordered by the court or permitted in writing by the Designating Party, a 20 Receiving Party may disclose any information or item designated 21 “CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, 23 as well as employees of said Outside Counsel of Record to whom it is reasonably 24 necessary to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House 26 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this 27 Action; 28 1 (c) Experts (as defined in this Order) of the Receiving Party to 2 whom disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) the court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and 7 Professional Vendors to whom disclosure is reasonably necessary for this Action 8 and who have signed the “Acknowledgment and Agreement to Be Bound” 9 (Exhibit A); 10 (g) the author or recipient of a document containing the information 11 or a custodian or other person who otherwise possessed or knew the information; 12 (h) during their depositions, witnesses, and attorneys for witnesses, 13 in the Action to whom disclosure is reasonably necessary provided: (1) the 14 deposing party requests that the witness sign the form attached as Exhibit 1 hereto; 15 and (2) they will not be permitted to keep any confidential information unless they 16 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 17 otherwise agreed by the Designating Party or ordered by the court. Pages of 18 transcribed deposition testimony or exhibits to depositions that reveal Protected 19 Material may be separately bound by the court reporter and may not be disclosed to 20 anyone except as permitted under this Stipulated Protective Order; and 21 (i) any mediator or settlement officer, and their supporting 22 personnel, mutually agreed upon by any of the parties engaged in settlement 23 discussions. 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 25 IN OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation 27 that compels disclosure of any information or items designated in this Action as 28 “CONFIDENTIAL,” that Party must: 1 (a) promptly notify in writing the Designating Party. Such 2 notification shall include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or 4 order to issue in the other litigation that some or all of the material covered by the 5 subpoena or order is subject to this Protective Order. Such notification shall 6 include a copy of this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be 8 pursued by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served with 10 the subpoena or court order shall not produce any information designated in this 11 action as “CONFIDENTIAL” before a determination by the court from which the 12 subpoena or order issued, unless the Party has obtained the Designating Party’s 13 permission. The Designating Party shall bear the burden and expense of seeking 14 protection in that court of its confidential material and nothing in these provisions 15 should be construed as authorizing or encouraging a Receiving Party in this Action 16 to disobey a lawful directive from another court. 17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced 20 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 21 information produced by Non-Parties in connection with this litigation is protected 22 by the remedies and relief provided by this Order. Nothing in these provisions 23 should be construed as prohibiting a Non-Party from seeking additional protections. 24 (b) In the event that a Party is required, by a valid discovery 25 request, to produce a Non-Party’s confidential information in its possession, and the 26 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 27 confidential information, then the Party shall: 28 1 (1) promptly notify in writing the Requesting Party and the 2 Non-Party that some or all of the information requested is subject to a 3 confidentiality agreement with a Non-Party; 4 (2) promptly provide the Non-Party with a copy of the 5 Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and 6 a reasonably specific description of the information requested; and 7 (3) make the information requested available for inspection 8 by the Non-Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this court 10 within 14 days of receiving the notice and accompanying information, the 11 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 13 Receiving Party shall not produce any information in its possession or control that 14 is subject to the confidentiality agreement with the Non-Party before a 15 determination by the court. Absent a court order to the contrary, the Non-Party 16 shall bear the burden and expense of seeking protection in this court of its Protected 17 Material. 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 22 writing the Designating Party of the unauthorized disclosures, (b) use its best 23 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 24 person or persons to whom unauthorized disclosures were made of all the terms of 25 this Order, and (d) request such person or persons to execute the “Acknowledgment 26 and Agreement to Be Bound” that is attached hereto as Exhibit A. 27 28 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other 5 protection, the obligations of the Receiving Parties are those set forth in Federal 6 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 7 whatever procedure may be established in an e-discovery order that provides for 8 production without prior privilege review. Pursuant to Federal Rule of Evidence 9 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 10 of a communication or information covered by the attorney-client privilege or work 11 product protection, the parties may incorporate their agreement in the stipulated 12 protective order submitted to the court. 13 12. MISCELLANEOUS 14 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 15 person to seek its modification by the Court in the future. 16 12.2 Right to Assert Other Objections. By stipulating to the entry of this 17 Protective Order, no Party waives any right it otherwise would have to object to 18 disclosing or producing any information or item on any ground not addressed in 19 this Stipulated Protective Order. Similarly, no Party waives any right to object on 20 any ground to use in evidence of any of the material covered by this Protective 21 Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Local Civil Rule 79-5. Protected Material 24 may only be filed under seal pursuant to a court order authorizing the sealing of the 25 specific Protected Material at issue. If a Party’s request to file Protected Material 26 under seal is denied by the court, then the Receiving Party may file the information 27 in the public record unless otherwise instructed by the court. 28 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must 4 return all Protected Material to the Producing Party or destroy such material. As 5 used in this subdivision, “all Protected Material” includes all copies, abstracts, 6 compilations, summaries, and any other format reproducing or capturing any of the 7 Protected Material. Whether the Protected Material is returned or destroyed, the 8 Receiving Party must submit a written certification to the Producing Party (and, if 9 not the same person or entity, to the Designating Party) by the 60 day deadline that 10 (1) identifies (by category, where appropriate) all the Protected Material that was 11 returned or destroyed and (2) affirms that the Receiving Party has not retained any 12 copies, abstracts, compilations, summaries or any other format reproducing or 13 capturing any of the Protected Material. Notwithstanding this provision, Counsel 14 are entitled to retain an archival copy of all pleadings, motion papers, trial, 15 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 16 and trial exhibits, expert reports, attorney work product, and consultant and expert 17 work product, even if such materials contain Protected Material. Any such archival 18 copies that contain or constitute Protected Material remain subject to this Protective 19 Order as set forth in Section 4 (DURATION). 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 // 1 |} 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 || including, without limitation, contempt proceedings and/or monetary sanctions. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD 6 Dated: November 1, 2019 BLUMENTHAL NORDREHAUG 7 BHOWMIK DE BLOUW, LLP 8 9 By:__/s/ Jeffrey Herman 10 Norman B. Blumenthal Aparajit Bhowmik I Jeffrey Herman Attorneys for Plaintiff 12 Michael Ignacio 13 || Dated: November 1, 2019 14 15 By:__/s/ Irene Scholl-Tatevosyan Benjamin J. Kim 16 Irene Scholl-Tatevosyan Andrea Chavez 7 Attorneys for Defendant

LABORATORY CORPORATION

18 OF AMERICA 19 I, Irene Scholl-Tatevosyan, attest that all other signatories listed, and on whose 909 || behalf this tiling is also being submitted, concur to the filing’s content and have authorized this filing. /s/ Irene Scholl-Tatevosyan 21 97 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 94 || DATED: November 5, 2019 Rapetis a. 26 || □□□□□□□□□□□□□□□□□□□□□□□□□□□□□ 6 HON. ROZELLA A. OLIVER 97 || United States Magistrate Judge 28 4841-6637-7899 1

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 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of Michael Ignacio v. Laboratory Corporation of America, 8 Case No. 2:19-cv-06079-AB-RAO. I agree to comply with and to be bound by all 9 the terms of this Stipulated Protective Order and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person 13 or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of 17 this action. 18 I hereby appoint _________________________ [print or type full name] of 19 _____________________________________ [print or type full 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 Date: 24 City and State where sworn and signed: 25 26 Printed name: 27 Signature: 28