1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SOUTHERN DIVISION 11

12 MARINE AND BOND INSURANCE AGENCY, INC., dba AMERICAN 13

MARINE INSURANCE,

Case No.: 8:20-cv-00067-JVS-JDEx 14 Plaintiff,

STIPULATED PROTECTIVE ORDER

15 v. Magistrate Judge: Early 16 CLAYTON HUBBELL, et al., 17 Defendants.

18 Pursuant to the parties’ Stipulation (Dkt. 17), and good cause appearing there- 19 for, the Court hereby FINDS and ORDERS as follows: 20 1. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, proprie- 22 tary, or private information for which special protection from public disclosure and 23 from use for any purpose other than pursuing this litigation may be warranted. Accord- 24 ingly, the parties stipulate to and petition the Court to enter the following Stipulated 25 Protective Order. The parties acknowledge this Order does not confer blanket protec- 26 tions on all disclosures or responses to discovery and that the protection it affords from 27 1 public disclosure and use extends only to the limited information or items entitled to 2 confidential treatment under the applicable legal principles. 3 2. GOOD CAUSE STATEMENT 4 This action is likely to involve trade secrets, confidential employment records, 5 customer and pricing lists and other valuable research, development, commercial, fi- 6 nancial, technical or proprietary information for which special protection from public 7 disclosure and from use for any purpose other than prosecution of this action is war- 8 ranted. Such confidential and proprietary materials and information consist of, among 9 other things, confidential employment records, confidential customer information, con- 10 fidential customer lists, confidential financial information, information regarding con- 11 fidential business practices, or other confidential research, development, or commercial 12 information (including information implicating privacy rights of third parties), infor- 13 mation otherwise generally unavailable to the public, or which may be privileged or 14 otherwise protected from disclosure under state or federal statutes, court rules, case 15 decisions, or common law. To expedite the flow of information, to facilitate the prompt 16 resolution of disputes over confidentiality of discovery materials, to adequately protect 17 information the parties may keep confidential, to ensure that the parties are permitted 18 reasonable necessary uses of such material to prepare for and in the conduct of trial, to 19 address their handling at the end of the litigation, and serve the ends of justice, a pro- 20 tective order for such information is justified. It is the intent of the parties that infor- 21 mation will not be designated as confidential for tactical reasons and that nothing be so 22 designated without a good faith belief it has been maintained in a confidential, non- 23 public manner, and there is good cause why it should not be part of the public record. 24 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 25 The parties further acknowledge, as set forth in Section 14.3, below, this Stipu- 26 lated Protective Order does not entitle them to file confidential information under seal; 27 Local Civil Rule 79-5 sets forth the procedures that must be followed and the standards 1 applied when a party seeks permission from the court to file material under seal. There 2 is a strong presumption that the public has a right of access to judicial proceedings and 3 records in civil cases. In non-dispositive motions, good cause must be shown to support 4 a filing under seal. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 5 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 6 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) 7 (even stipulated protective orders require good cause showing), and a specific showing 8 of good cause or compelling reasons with proper evidentiary support and legal justifi- 9 cation, must be made regarding Protected Material that a party seeks to file under seal. 10 The parties’ mere designation of Disclosure or Discovery Material as CONFIDEN- 11 TIAL does not— without the submission of competent evidence by declaration, estab- 12 lishing that the material sought to be filed under seal qualifies as confidential, privi- 13 leged, or otherwise protectable—constitute good cause. 14 Further, if a party requests sealing related to a dispositive motion or trial, then 15 compelling reasons, not only good cause, for the sealing must be shown, and the relief 16 sought shall be narrowly tailored to serve the specific interest to be protected. See Pin- 17 tos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or 18 type of information, document, or thing sought to be filed or introduced under seal, the 19 party seeking protection must articulate compelling reasons, supported by specific facts 20 and legal justification, for the requested sealing order. Again, competent evidence sup- 21 porting the application to file documents under seal must be provided by declaration. 22 Any document that is not confidential, privileged, or otherwise protectable in its 23 entirety will not be filed under seal if the confidential portions can be redacted. If doc- 24 uments can be redacted, then a redacted version for public viewing, omitting only the 25 confidential, privileged, or otherwise protectable portions of the document, shall be 26 filed. Any application that seeks to file documents under seal in their entirety should 27 include an explanation of why redaction is not feasible. 1 4. DEFINITIONS 2 4.1 Action: The above-captioned action, Case No. 8:20-cv-00067-JVS-JDEx. 3 4.2 Challenging Party: a Party or Non-Party that challenges the 4 designation of information or items under this Order. 5 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 6 is generated, stored or maintained) or tangible things that qualify for protection under 7 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause State- 8 ment. 9 4.4 “CONFIDENTIAL–ATTORNEYS’ EYES ONLY” Information or Items: 10 “extremely sensitive “Confidential Information or Items,” disclosure of which to an- 11 other Party or Non-Party would create a substantial risk of serious harm that could not 12 be avoided by less restrictive means. 13 4.5 Counsel: Outside Counsel of Record (and their support staff), and House 14 Counsel (and their support staff). 15 4.6 Designating Party: a Party or Non-Party that designates information or items 16 it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or 17 “CONFIDENTIAL–ATTORNEYS’ EYES ONLY.” 18 4.7 Disclosure or Discovery Material: all items or information, regardless of the 19 medium or manner in which it is generated, stored, or maintained (including testimony, 20 transcripts, and tangible things), that are produced or generated in disclosures or re- 21 sponses to discovery. 22 4.8 Expert: a person with specialized knowledge or experience in a matter per- 23 tinent to the litigation retained by a Party or its counsel to serve as an expert witness or 24 as a consultant in this Action. 25 4.9 House Counsel: attorneys who are employees of a party to this Action. 26 House Counsel does not include Outside Counsel of Record or any other outside coun- 27 sel. 1 4.10 Non-Party: any natural person, partnership, corporation, association, or 2 other legal entity not named as a Party to this action. 3 4.11 Outside Counsel of Record: attorneys who are not employees of a party to 4 this Action but are retained to represent a party to this Action and have appeared on 5 behalf of that party or are affiliated with a law firm that has appeared on behalf of that 6 party, and this includes all their support staff. 7 4.12 Party: any party to this Action, including all its officers, directors, employ- 8 ees, staff, affiliates, contractors, consultants, and retained experts. 9 4.13 Producing Party: any Party or Non-Party that produces Disclosure or Dis- 10 covery Material in this Action. 11 4.14 Professional Vendors: persons or entities that provide litigation support 12 services (e.g., e-discovery services, photocopying, videotaping, translating, preparing 13 exhibits or demonstrations, and organizing, storing, or retrieving data in any form or 14 medium) and their employees and subcontractors. 15 4.15 Protected Material: any Disclosure or Discovery Material designated as 16 “CONFIDENTIAL” or “CONFIDENTIAL–ATTORNEYS’ EYES ONLY.” 17 4.16 Receiving Party: any Party or Non-Party that receives Disclosure or Dis- 18 covery Material from a Producing Party. 19 5. SCOPE 20 The protections conferred by this Stipulation and Order cover not only Protected 21 Material (as defined above), but also (1) any information copied or extracted from Pro- 22 tected Material; (2) all copies, excerpts, summaries, or compilations of Protected Ma- 23 terial; and (3) any testimony, conversations, or presentations by Parties or their Counsel 24 that might reveal Protected Material. 25 Any use of Protected Material at trial shall be governed by the orders of the trial 26 judge and other applicable authorities. This Order does not govern the use of Protected 27 Material at trial. 1 6. DURATION 2 Once a case proceeds to trial, information designated as CONFIDENTIAL or 3 maintained pursuant to this protective order used or introduced as an exhibit at trial 4 becomes public and will be presumptively available to all members of the public, in- 5 cluding the press, unless compelling reasons supported by specific factual findings to 6 proceed otherwise are made to the trial judge before the trial. See Kamakana, 447 F.3d 7 at 1180-81 (distinguishing “good cause” showing for sealing documents produced in 8 discovery from “compelling reasons” standard when merits-related documents are part 9 of court record). The terms of this protective order do not extend beyond the com- 10 mencement of the trial. 11 7. DESIGNATING PROTECTED MATERIAL 12 7.1 Exercise of Restraint and Care in Designating Material for Protection. 13 Each Party or Non-Party that designates information or items for protection under this 14 Order must take care to limit any such designation to specific material that qualifies 15 under the appropriate standards. The Designating Party must designate for protection 16 only those parts of material, documents, items or oral or written communications that 17 qualify so other portions of the material, documents, items or communications for 18 which protection is not warranted are not swept unjustifiably within the ambit of this 19 Order. 20 Mass, indiscriminate, or routinized designations are prohibited. Designations 21 that are shown to be clearly unjustified or that have been made for an improper purpose 22 (e.g., to unnecessarily encumber the case development process or to impose unneces- 23 sary expenses and burdens on other parties) may expose the Designating Party to sanc- 24 tions. 25 If it comes to a Designating Party’s attention that information or items it desig- 26 nated for protection do not qualify for protection, that Designating Party must promptly 27 notify all other Parties it is withdrawing the inapplicable designation. 1 7.2 Manner and Timing of Designations. Except as otherwise provided in this 2 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that 3 qualifies for protection under this Order must be clearly so designated before the ma- 4 terial is disclosed or produced. 5 Designation in conformity with this Order requires: 6 (a) for information in documentary form (e.g., paper or electronic docu- 7 ments, but excluding transcripts of depositions or other pretrial or trial proceedings), 8 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (herein- 9 after “CONFIDENTIAL legend”) or “CONFIDENTIAL–ATTORNEYS’ EYES 10 ONLY” (hereinafter “CONFIDENTIAL–ATTORNEYS’ EYES ONLY legend”) to 11 each page that contains protected material. If only a portion of the material on a page 12 qualifies for protection, the Producing Party also must clearly identify the protected 13 portion(s) (e.g., by making appropriate markings in the margins). 14 A Party or Non-Party that provides original documents for inspection need not 15 designate them for protection until after the inspecting Party has indicated which doc- 16 uments it would like copied and produced. During the inspection and before the desig- 17 nation, the material provided for inspection shall be deemed “CONFIDENTIAL–AT- 18 TORNEYS’ EYES ONLY.” After the inspecting Party has identified the documents it 19 wants copied and produced, the Producing Party must determine which documents, or 20 portions thereof, qualify for protection under this Order. Then, before producing the 21 specified documents, the Producing Party must affix the “CONFIDENTIAL or CON- 22 FIDENTIAL–ATTORNEYS’ EYES ONLY legend” to each page that contains Pro- 23 tected Material. If only a portion of the material on a page qualifies for protection, the 24 Producing Party also must clearly identify the protected portion(s) (e.g., by making 25 appropriate markings in the margins). 26 27 1 (b) for testimony in depositions that the Designating Party identifies the Dis- 2 closure or Discovery Material on the record, before the close of the deposition all pro- 3 tected testimony. 4 (c) for information produced in some form other than documentary and for 5 any other tangible items, that the Producing Party affix in a prominent place on the 6 exterior of the container or containers in which the information is stored the legend 7 “CONFIDENTIAL” or “CONFIDENTIAL–ATTORNEYS’ EYES ONLY.” If only a 8 portion or portions of the information warrants protection, the Producing Party, to the 9 extent practicable, shall identify the protected portion(s). 10 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent fail- 11 ure to designate qualified information or items does not, standing alone, waive the Des- 12 ignating Party’s right to secure protection under this Order for such material. Upon 13 timely correction of a designation, the Receiving Party must make reasonable efforts 14 to assure that the material is treated in accordance with the provisions of this Order. 15 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation 17 of confidentiality at any time consistent with the Court’s Scheduling Order. 18 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 19 process under Local Rule 37-1 et seq. 20 8.3 Joint Stipulation. Any challenge submitted shall be via a joint stipulation 21 under Local Rule 37-2. 22 8.4 The burden of persuasion in any such challenge proceeding shall be on the 23 Designating Party. Unless the Designating Party has waived or withdrawn the confi- 24 dentiality designation, all parties shall continue to afford the material in question the 25 level of protection to which it is entitled under the Producing Party’s designation until 26 the Court rules on the challenge. 27 1 9. ACCESS TO AND USE OF PROTECTED MATERIAL 2 9.1 Basic Principles. A Receiving Party may use Protected Material that is dis- 3 closed or produced by another Party or by a Non-Party in this Action only for prose- 4 cuting, defending, or attempting to settle. Such Protected Material may be disclosed 5 only to the categories of persons and under the conditions described in this Order. 6 When the Action has been terminated, a Receiving Party must comply with section of 7 this Order titled below “FINAL DISPOSITION.” 8 Protected Material must be stored and maintained by a Receiving Party at a lo- 9 cation and in a secure manner that ensures that access is limited to the persons author- 10 ized under this Order. 11 9.2 Disclosure of “CONFIDENTIAL” Information or Items. a Receiving 12 Party may disclose any information or item designated “CONFIDENTIAL” to: 13 (a) the Receiving Party’s Outside Counsel of Record, and the staff and em- 14 ployees of the Outside Counsel of Record to whom it is reasonably necessary to dis- 15 close the information for this Action; 16 (b) the officers, directors, and employees (including House Counsel) of the 17 Receiving Party to whom disclosure is reasonably necessary for this Action; 18 (c) Professional Vendors and Experts (as defined in this Order) of the Re- 19 ceiving Party to whom disclosure is reasonably necessary for this Action and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (see Exhibit A) 21 (d) the court and its personnel; 22 (e) court reporters and their staff; 23 (f) professional jury or trial consultants, mock jurors, and other vendors to 24 whom disclosure is reasonably necessary for this Action and who have signed the “Ac- 25 knowledgment and Agreement to Be Bound” (see Exhibit A); 26 (g) the author or recipient of a document containing the information or a 27 custodian or other person who otherwise possessed or knew the information; 1 (h) during their depositions or when testifying under penalty of perjury in 2 other ways such as in declarations, non-party witnesses, and attorneys for non-party 3 witnesses, in the Action, to whom disclosure is reasonably necessary, will not be per- 4 mitted to access, view or keep any confidential information unless they sign the “Ac- 5 knowledgment and Agreement to Be Bound” (Exhibit A). Pages of transcribed depo- 6 sition testimony or exhibits to depositions that reveal Protected Material may be sepa- 7 rately bound by the court reporter and may not be disclosed to anyone except as per- 8 mitted under this Stipulated Protective Order; and 9 (i) any mediators or settlement officers and their supporting personnel mu- 10 tually agreed upon by the parties engaged in settlement discussions. 11 9.3 Disclosure of “CONFIDENTIAL–ATTORNEYS’ EYES ONLY” 12 Information or Items. Unless otherwise ordered by the court or permitted in writing 13 by the Designating Party, a Receiving Party may only disclose information or items 14 designated “CONFIDENTIAL–ATTORNEYS’ EYES ONLY” to: 15 (a) the Receiving Party’s Outside Counsel of Record, and the staff and employ- 16 ees of the Outside Counsel of Record to whom it is reasonably necessary to disclose 17 the information for this Action; 18 (b) Professional Vendors and Experts (as defined in this Order) of the Receiving 19 Party to whom disclosure is reasonably necessary for this Action and who have first 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A) prior to re- 21 ceiving any information or items. The Receiving Party must, within a reasonable time 22 frame following the formal engagement of services by a Professional Vendor or Expert, 23 send an email to the Designating Party’s outside counsel of record attaching a copy of 24 the signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (c) the court and its personnel; 26 (d) court reporters and their staff; 27 1 (e) professional jury or trial consultants, mock jurors, and other vendors to 2 whom disclosure is reasonably necessary for this Action and who have first signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (f) the author or recipient of a document containing the information or a custo- 5 dian or other person shown, in written or oral evidence, or foundation laid in deposi- 6 tion testimony, to have otherwise possessed or known the information; 7 (g) during their depositions, witnesses and attorneys for witnesses in the Action 8 to whom disclosure is reasonably necessary, provided: (1) no Party or Non-Party ob- 9 jects to the proposed disclosure to the witness or attorney for the witness; (2) the de- 10 posing party requests that the witness sign the form attached as Exhibit A; (3) prior to 11 any disclosure, the deposing party consults with the Designating Party and counsel 12 participating in the deposition to determine whether a Party or Non-Party objects to the 13 disclosure; and (4) the witness and his or her attorney may keep no confidential infor- 14 mation unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 15 A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of 16 transcribed deposition testimony or exhibits to depositions that reveal Protected Mate- 17 rial may be separately bound by the court reporter and may not be disclosed to anyone 18 except as permitted under this Stipulated Protective Order; and 19 (h) any mediator or settlement officer, and their supporting personnel, mutually 20 agreed upon by the parties engaged in settlement discussions. 21 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 22 PRODUCED IN OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation that 24 compels disclosure of any information or items designated as “CONFIDENTIAL,” that 25 Party must: 26 (a) promptly notify in writing the Designating Party. Such notification shall 27 include a copy of the subpoena or court order; 1 (b) promptly notify in writing the party who caused the subpoena or order to 2 issue in the other litigation that some or the material covered by the subpoena or order 3 is subject to this Protective Order. Such notification shall include a copy of this Stipu- 4 lated Protective Order; and 5 (c) cooperate regarding all reasonable procedures sought to be pursued by 6 the Designating Party whose Protected Material may be affected. If the Designating 7 Party timely seeks a protective order, the Party served with the subpoena or court order 8 shall produce no information designated as “CONFIDENTIAL” before a determination 9 by the court from which the subpoena or order issued, unless the Party has obtained the 10 Designating Party’s permission. The Designating Party shall bear the burden and ex- 11 pense of seeking protection in that court of its confidential material and nothing in these 12 provisions should be construed as authorizing or encouraging a Receiving Party in this 13 Action to disobey a lawful directive from another court. 14 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 15 PRODUCED IN THIS LITIGATION 16 (a) The terms of this Order apply to information produced by a Non-Party and 17 designated as “CONFIDENTIAL or “CONFIDENTIAL-ATTORNEYS’ EYES 18 ONLY.” Such information produced by Non-Parties in this litigation is protected by 19 the remedies and relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional protections. 21 (b) if a Party is required, by a valid discovery request, to produce a Non-Party’s 22 confidential information in its possession, and the Party is subject to an agreement with 23 the Non-Party not to produce the Non-Party’s confidential information, then the Party 24 shall: 25 (1) promptly notify in writing the Requesting Party and the Non-Party that 26 some or the information requested is subject to a confidentiality agreement with a Non- 27 Party; 1 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 2 Order, the discovery request(s), and a reasonably specific description of the infor- 3 mation requested; and 4 (3) make the information requested available for inspection by the Non- 5 Party, if requested. 6 (c) If the Non-Party fails to seek a protective order within 14 days of receiv- 7 ing the notice and information, the Receiving Party may produce the Non-Party’s con- 8 fidential information responsive to the discovery request. If the Non-Party timely seeks 9 a protective order, the Receiving Party shall produce no information in its possession 10 or control subject to the confidentiality agreement with the Non-Party before a deter- 11 mination by the court. Absent a court order to the contrary, the Non-Party shall bear 12 the burden and expense of seeking protection in this court of its Protected Material. 13 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 14 MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 Protected Material to any person or in any circumstance not authorized under this Stip- 17 ulated Protective Order, the Receiving Party must immediately (a) notify in writing the 18 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 19 unauthorized copies of the Protected Material, (c) inform the person or persons to 20 whom unauthorized disclosures were made of all the terms of this Order, and (d) re- 21 quest such person or persons to execute the “Acknowledgment an Agreement to Be 22 Bound” attached as Exhibit A. 23 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 24 OTHERWISE PROTECTED MATERIAL 25 When a Producing Party gives notice to Receiving Parties that certain inadvert- 26 ently produced material is subject to a claim of privilege or other protection, the obli- 27 gations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 1 26(b)(5)(B). This provision is not intended to modify whatever procedure may be es- 2 tablished in an e-discovery order that provides for production without prior privilege 3 review. Under Federal Rule of Evidence 502(d) and (e), insofar as the parties agree on 4 the effect of disclosure of a communication or information covered by the attorney- 5 client privilege or work product protection, the parties may incorporate their agreement 6 in the stipulated protective order submitted. 7 14. MISCELLANEOUS 8 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 person to seek its modification by the Court. 10 14.2 Right to Assert Other Objections. By stipulating to the entry of this Pro- 11 tective Order, no Party waives any right it otherwise would have to object to disclosing 12 or producing any information or item on any ground not addressed in this Stipulated 13 Protective Order. Similarly, no Party waives any right to object on any ground to use 14 in evidence of the material covered by this Protective Order. 15 14.3 Filing Protected Material. A Party that seeks to file under seal any Pro- 16 tected Material must comply with Local Civil Rule 79-5. Protected Material may only 17 be filed under seal under a court order authorizing sealing the specific Protected Mate- 18 rial. If a Party’s request to file Protected Material under seal is denied by the court, then 19 the Receiving Party may file the information in the public record unless otherwise in- 20 structed by the court. 21 15. FINAL DISPOSITION 22 After the final disposition of this Action, within 60 days of a written request by 23 the Designating Party, each Receiving Party must return all Protected Material to the 24 Producing Party or destroy such material. As used in this subdivision, “all Protected 25 Material” includes all copies, abstracts, compilations, summaries, and any other format 26 reproducing or capturing the Protected Material. Whether the Protected Material is re- 27 1 || turned or destroyed, the Receiving Party must submit a written certification to the Pro- 2 || ducing Party (and, if not the same person or entity, to the Designating Party) by the 60- 3 ||day deadline that (1) identifies (by category, where appropriate) all the Protected Ma- 4 terial returned or destroyed and (2) affirms that the Receiving Party has retained no 5 ||copies, abstracts, compilations, summaries or any other format reproducing or captur- 6 |}ing the Protected Material. Notwithstanding this provision, Counsel may retain an ar- 7 ||chival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 8 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attor- 9 ||ney work product, and consultant and expert work product, even if such materials con- 10 |}tain Protected Material. Any such archival copies that contain or constitute Protected 11 || Material remain subject to this Protective Order. 12 ||16. VIOLATION 13 Any violation of this Order may be punished by appropriate measures including, 14 || without limitation, contempt proceedings or monetary sanctions. 15 16 || For good cause shown, it is SO ORDERED. 17 io || Dated: June 11, 2020 hie OF

J D. EARLY

20 ited States Magistrate Judge 21 22 23 24 25 26 27 28 Marine and Bond Ins. v. Hubhel]l

1 Exhibit A 2 Acknowledgment and Agreement to be Bound 3 I,___________________________ [print or type name, business, full address, phone 4 number and email], declare under penalty of perjury I have read in its entirety and 5 understand the Stipulated Protective Order issued by the United States District Court 6 for the Central District of California in the lawsuit Marine and Bond Insurance Agency, 7 Inc., v. Hubble Case No. 8:20-cv-00067-JVS-(JDEx). I agree to comply with and to be 8 bound by this Stipulated Protective Order, and I understand and acknowledge that 9 failure to so comply could expose me to sanctions, punishment, and contempt of court. 10 11 I solemnly promise I will not disclose any information or item subject to this Stipulated 12 Protective Order to any person or entity except in strict compliance with this Order. I 13 further agree to submit to the jurisdiction of the United States District Court for the 14 Central District of California to enforce the terms of this Stipulated Protective Order, 15 even if such enforcement proceedings occur after termination, and I appoint 16 __________________________________ [print or type name, business, full address, 17 phone number and email] as my California agent for service of process in connection 18 with this action or any proceedings related to enforcement of this Stipulated Protective 19 Order. 20 21 Date: ______________________________________ 22 City and State where sworn and signed: ________________________ 23 Printed name: _______________________________ 24 25 Signature: __________________________________ 26 27