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7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 DAVID ABITBOL, individually and on 11 behalf of all others similarly situated, Case No. 2:20-cv-03109VAP GJS

12 Plaintiff,

STIPULATED PROTECTIVE

13 v. ORDER1

14 MERCURY INSURANCE

COMPANY, AUTO INSURANCE

15 SPECIALISTS, LLC and

QUOTELAB, LLC,

16 Defendant. 17 18

19 20 21 22 23 24 25 26 27 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 trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and 15 from use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties and personal identifier information), information otherwise generally 21 unavailable to the public, or which may be privileged or otherwise protected from 22 disclosure under state or federal statutes, court rules, case decisions, or common 23 law. Accordingly, to expedite the flow of information, to facilitate the prompt 24 resolution of disputes over confidentiality of discovery materials, to adequately 25 protect information the parties are entitled to keep confidential, to ensure that the 26 parties are permitted reasonable necessary uses of such material in preparation for 27 and in the conduct of trial, to address their handling at the end of the litigation, and 1 matter. It is the intent of the parties that information will not be designated as 2 confidential for tactical reasons and that nothing be so designated without a good 3 faith belief that it has been maintained in a confidential, non-public manner, and 4 there is good cause why it should not be part of the public record of this case. 5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 6 The parties further acknowledge, as set forth in Section 12.3, below, that this 7 Stipulated Protective Order does not entitle them to file confidential information 8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 9 and the standards that will be applied when a party seeks permission from the court 10 to file material under seal. 11 There is a strong presumption that the public has a right of access to judicial 12 proceedings and records in civil cases. In connection with non-dispositive motions, 13 good cause must be shown to support a filing under seal. See Kamakana v. City and 14 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 15 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 16 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 17 require good cause showing), and a specific showing of good cause or compelling 18 reasons with proper evidentiary support and legal justification, must be made with 19 respect to Protected Material that a party seeks to file under seal. The parties’ mere 20 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 21 without the submission of competent evidence by declaration, establishing that the 22 material sought to be filed under seal qualifies as confidential, privileged, or 23 otherwise protectable—constitute good cause. 24 Further, if a party requests sealing related to a dispositive motion or trial, then 25 compelling reasons, not only good cause, for the sealing must be shown, and the 26 relief sought shall be narrowly tailored to serve the specific interest to be protected. 27 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 1 under seal in connection with a dispositive motion or trial, the party seeking 2 protection must articulate compelling reasons, supported by specific facts and legal 3 justification, for the requested sealing order. Again, competent evidence supporting 4 the application to file documents under seal must be provided by declaration. 5 Any document that is not confidential, privileged, or otherwise protectable in 6 its entirety will not be filed under seal if the confidential portions can be redacted. 7 If documents can be redacted, then a redacted version for public viewing, omitting 8 only the confidential, privileged, or otherwise protectable portions of the document, 9 shall be filed. Any application that seeks to file documents under seal in their 10 entirety should include an explanation of why redaction is not feasible. 11 2. DEFINITIONS 12 2.1 Action: Abitbol v. Mercury Insurance, et. al., Case No. 2:20-cv-03109- 13 VAP-CJS 14 2.2 Challenging Party: a Party or Non-Party that challenges the 15 designation of information or items under this Order. 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for 18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 19 the Good Cause Statement. 20 2.4 “CONFIDENTIAL-ATTORNEY’S EYES ONLY” Information or 21 Items: information (regardless of how it is generated, stored or maintained) or 22 tangible things that qualify for protection under Federal Rule of Civil Procedure 23 26(c), and as specified above in the Good Cause Statement, and that the Designating 24 Party believes, in good faith, contains information, the disclosure of which is likely 25 to cause harm to its competitive position, or which materials meet the definition of a 26 trade secret set forth in section §3426.1(d) of the California Civil Code or other 27 applicable trade secret statutes. 1 their support staff). 2 2.6 Designating Party: a Party or Non-Party that designates information or 3 items that it produces in disclosures or in responses to discovery as 4 “CONFIDENTIAL.” 5 2.7 Disclosure or Discovery Material: all items or information, regardless 6 of the medium or manner in which it is generated, stored, or maintained (including, 7 among other things, testimony, transcripts, and tangible things), that are produced or 8 generated in disclosures or responses to discovery in this matter. 9 2.8 Expert: a person with specialized knowledge or experience in a matter 10 pertinent to the litigation who has been retained by a Party or its counsel to serve as 11 an expert witness or as a consultant in this Action. 12 2.9 House Counsel: attorneys who are employees of a party to this Action. 13 House Counsel does not include Outside Counsel of Record or any other outside 14 counsel. 15 2.10 Non-Party: any natural person, partnership, corporation, association or 16 other legal entity not named as a Party to this action. 17 2.11 Outside Counsel of Record: attorneys who are not employees of a 18 party to this Action but are retained to represent or advise a party to this Action and 19 have appeared in this Action on behalf of that party or are affiliated with a law firm 20 that has appeared on behalf of that party, and includes support staff. 21 2.12 Party: any party to this Action, including all of its officers, directors, 22 employees, consultants, retained experts, and Outside Counsel of Record (and their 23 support staffs). 24 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 25 Discovery Material in this Action. 26 2.14 Professional Vendors: persons or entities that provide litigation 27 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 1 and their employees and subcontractors. 2 2.14 Protected Material: any Disclosure or Discovery Material that is 3 designated as “CONFIDENTIAL.” 4 2.15 Receiving Party: a Party that receives Disclosure or Discovery 5 Material from a Producing Party. 6 3. SCOPE 7 The protections conferred by this Stipulation and Order cover not only 8 Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 compilations of Protected Material; and (3) any testimony, conversations, or 11 presentations by Parties or their Counsel that might reveal Protected Material. 12 Any use of Protected Material at trial shall be governed by the orders of the 13 trial judge. This Order does not govern the use of Protected Material at trial. 14 4. DURATION 15 FINAL DISPOSITION of the action is defined as the conclusion of any 16 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 17 has run. Except as set forth below, the terms of this protective order apply through 18 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 19 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 20 but will have to file a separate action for enforcement of the agreement once all 21 proceedings in this case are complete. 22 Once a case proceeds to trial, information that was designated as 23 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 24 as an exhibit at trial becomes public and will be presumptively available to all 25 members of the public, including the press, unless compelling reasons supported by 26 specific factual findings to proceed otherwise are made to the trial judge in advance 27 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 1 standard when merits-related documents are part of court record). Accordingly, for 2 such materials, the terms of this protective order do not extend beyond the 3 commencement of the trial. 4 5. DESIGNATING PROTECTED MATERIAL 5 5.1 Exercise of Restraint and Care in Designating Material for Protection. 6 Each Party or Non-Party that designates information or items for protection under 7 this Order must take care to limit any such designation to specific material that 8 qualifies under the appropriate standards. The Designating Party must designate for 9 protection only those parts of material, documents, items or oral or written 10 communications that qualify so that other portions of the material, documents, items 11 or communications for which protection is not warranted are not swept unjustifiably 12 within the ambit of this Order. 13 Mass, indiscriminate or routinized designations are prohibited. Designations 14 that are shown to be clearly unjustified or that have been made for an improper 15 purpose (e.g., to unnecessarily encumber the case development process or to impose 16 unnecessary expenses and burdens on other parties) may expose the Designating 17 Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 designated for protection do not qualify for protection, that Designating Party must 20 promptly notify all other Parties that it is withdrawing the inapplicable designation. 21 5.2 Manner and Timing of Designations. Except as otherwise provided in 22 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 23 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 24 under this Order must be clearly so designated before the material is disclosed or 25 produced. 26 Designation in conformity with this Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 1 proceedings), that the Producing Party affix at a minimum, the legend 2 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEY’S EYES ONLY” 3 (hereinafter “CONFIDENTIAL or CONFIDENTIAL-ATTORNEY’S EYES ONLY 4 legend”), to each page that contains protected material. If only a portion of the 5 material on a page qualifies for protection, the Producing Party also must clearly 6 identify the protected portion(s) (e.g., by making appropriate markings in the 7 margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and 11 before the designation, all of the material made available for inspection shall be 12 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 13 documents it wants copied and produced, the Producing Party must determine which 14 documents, or portions thereof, qualify for protection under this Order. Then, 15 before producing the specified documents, the Producing Party must affix the 16 “CONFIDENTIAL or CONFIDENTIAL-ATTORNEY’S EYES ONLY legend” to 17 each page that contains Protected Material. If only a portion of the material on a 18 page qualifies for protection, the Producing Party also must clearly identify the 19 protected portion(s) (e.g., by making appropriate markings in the margins). 20 (b) for testimony given in depositions that the Designating Party identifies 21 the Disclosure or Discovery Material on the record, before the close of the 22 deposition all protected testimony. 23 (c) for information produced in some form other than documentary and 24 for any other tangible items, that the Producing Party affix in a prominent place on 25 the exterior of the container or containers in which the information is stored the 26 legend “CONFIDENTIAL or CONFIDENTIAL-ATTORNEY’S EYES ONLY.” If 27 only a portion or portions of the information warrants protection, the Producing 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive 3 the Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 9 designation of confidentiality at any time that is consistent with the Court’s 10 Scheduling Order. 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 12 resolution process under Local Rule 37.1 et seq. 13 6.3 The burden of persuasion in any such challenge proceeding shall be on 14 the Designating Party. Frivolous challenges, and those made for an improper 15 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 16 parties) may expose the Challenging Party to sanctions. Unless the Designating 17 Party has waived or withdrawn the confidentiality designation, all parties shall 18 continue to afford the material in question the level of protection to which it is 19 entitled under the Producing Party’s designation until the Court rules on the 20 challenge. 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a Non-Party in connection with this 24 Action only for prosecuting, defending or attempting to settle this Action. Such 25 Protected Material may be disclosed only to the categories of persons and under the 26 conditions described in this Order. When the Action has been terminated, a 27 Receiving Party must comply with the provisions of section 13 below (FINAL 1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 otherwise ordered by the court or permitted in writing by the Designating Party, a 6 Receiving Party may disclose any information or item designated 7 “CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 9 well as employees of said Outside Counsel of Record to whom it is reasonably 10 necessary to disclose the information for this Action; 11 (b) the officers, directors, and employees (including House Counsel) of 12 the Receiving Party to whom disclosure is reasonably necessary for this Action; 13 (c) Experts (as defined in this Order) of the Receiving Party to whom 14 disclosure is reasonably necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) the court and its personnel; 17 (e) court reporters and their staff; 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 Vendors to whom disclosure is reasonably necessary for this Action and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the information or a 22 custodian or other person who otherwise possessed or knew the information; 23 (h) during their depositions, witnesses, and attorneys for witnesses, in the 24 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 25 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 26 not be permitted to keep any confidential information unless they sign the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 1 deposition testimony or exhibits to depositions that reveal Protected Material may 2 be separately bound by the court reporter and may not be disclosed to anyone except 3 as permitted under this Stipulated Protective Order; and 4 (i) any mediator or settlement officer, and their supporting personnel, 5 mutually agreed upon by any of the parties engaged in settlement discussions. 6 7.3 Disclosure of “CONFIDENTIAL-ATTORNEY’S EYES ONLY” 7 Information or Items. Unless otherwise ordered by the court or permitted in writing 8 by the Designating Party, a Receiving Party may disclose any information or item 9 designated “CONFIDENTIAL-ATTORNEY’S EYES ONLY” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 11 well as employees of said Outside Counsel of Record to whom it is reasonably 12 necessary to disclose the information for this Action; 13 (b) Experts (as defined in this Order) of the Receiving Party to whom 14 disclosure is reasonably necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (c) the court and its personnel; 17 (d) court reporters and their staff; 18 (e) professional jury or trial consultants, mock jurors, and Professional 19 Vendors to whom disclosure is reasonably necessary for this Action and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (f) the author or recipient of a document containing the information or a 22 custodian or other person who otherwise possessed or knew the information; 23 (g) any mediator or settlement officer, and their supporting personnel, 24 mutually agreed upon by any of the parties engaged in settlement discussions. 25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 26 IN OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation 1 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEY’S EYES ONLY,” that 2 Party must: 3 (a) promptly notify in writing the Designating Party. Such notification 4 shall include a copy of the subpoena or court order; 5 (b) promptly notify in writing the party who caused the subpoena or order 6 to issue in the other litigation that some or all of the material covered by the 7 subpoena or order is subject to this Protective Order. Such notification shall include 8 a copy of this Stipulated Protective Order; and 9 (c) cooperate with respect to all reasonable procedures sought to be 10 pursued by the Designating Party whose Protected Material may be affected. 11 If the Designating Party timely seeks a protective order, the Party served with 12 the subpoena or court order shall not produce any information designated in this 13 action as “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEY’S EYES 14 ONLY,” before a determination by the court from which the subpoena or order 15 issued, unless the Party has obtained the Designating Party’s permission. The 16 Designating Party shall bear the burden and expense of seeking protection in that 17 court of its confidential material and nothing in these provisions should be construed 18 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 19 directive from another court. 20 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 21 PRODUCED IN THIS LITIGATION 22 (a) The terms of this Order are applicable to information produced by a 23 Non-Party in this Action and designated as “CONFIDENTIAL” or 24 “CONFIDENTIAL-ATTORNEY’S EYES ONLY.” Such information produced by 25 Non-Parties in connection with this litigation is protected by the remedies and relief 26 provided by this Order. Nothing in these provisions should be construed as 27 prohibiting a Non-Party from seeking additional protections. 1 produce a Non-Party’s confidential information in its possession, and the Party is 2 subject to an agreement with the Non-Party not to produce the Non-Party’s 3 confidential information, then the Party shall: 4 (1) promptly notify in writing the Requesting Party and the Non-Party 5 that some or all of the information requested is subject to a confidentiality 6 agreement with a Non-Party; 7 (2) promptly provide the Non-Party with a copy of the Stipulated 8 Protective Order in this Action, the relevant discovery request(s), and a reasonably 9 specific description of the information requested; and 10 (3) make the information requested available for inspection by the 11 Non-Party, if requested. 12 (c) If the Non-Party fails to seek a protective order from this court within 13 14 days of receiving the notice and accompanying information, the Receiving Party 14 may produce the Non-Party’s confidential information responsive to the discovery 15 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 16 not produce any information in its possession or control that is subject to the 17 confidentiality agreement with the Non-Party before a determination by the court. 18 Absent a court order to the contrary, the Non-Party shall bear the burden and 19 expense of seeking protection in this court of its Protected Material. 20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 21 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 22 Protected Material to any person or in any circumstance not authorized under this 23 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 24 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 25 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 26 persons to whom unauthorized disclosures were made of all the terms of this Order, 27 and (d) request such person or persons to execute the “Acknowledgment and 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 protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 7 procedure may be established in an e-discovery order that provides for production 8 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 9 (e), insofar as the parties reach an agreement on the effect of disclosure of a 10 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 this 19 Stipulated Protective Order. Similarly, no Party waives any right to object on any 20 ground to use in evidence of any of the material covered by this Protective Order. 21 12.3 Filing Protected Material. A Party that seeks to file under seal any 22 Protected Material must comply with Local Civil Rule 79-5. Protected Material 23 may only be filed under seal pursuant to a court order authorizing the sealing of the 24 specific Protected Material at issue. If a Party’s request to file Protected Material 25 under seal is denied by the court, then the Receiving Party may file the information 26 in the public record unless otherwise instructed by the court. 27 13. FINAL DISPOSITION 1 days of a written request by the Designating Party, each Receiving Party must return 2 all Protected Material to the Producing Party or destroy such material. As used in 3 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 4 summaries, and any other format reproducing or capturing any of the Protected 5 Material. Whether the Protected Material is returned or destroyed, the Receiving 6 Party must submit a written certification to the Producing Party (and, if not the same 7 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 8 (by category, where appropriate) all the Protected Material that was returned or 9 destroyed and (2) affirms that the Receiving Party has not retained any copies, 10 abstracts, compilations, summaries or any other format reproducing or capturing any 11 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 12 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 13 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 14 reports, attorney work product, and consultant and expert work product, even if such 15 materials contain Protected Material. Any such archival copies that contain or 16 constitute Protected Material remain subject to this Protective Order as set forth in 17 Section 4 (DURATION). 18 14. VIOLATION 19 Any violation of this Order may be punished by appropriate measures including, 20 without limitation, contempt proceedings and/or monetary sanctions. 21 22 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 23 24 DATED _July 30, 2020______________ 25 26 __/s/ Rachel Kaufman_______________ Attorneys for Plaintiff 27 DAVID ABITBOL 1 || DATED:__ July 30, 2020 2 3 /s/ Justin Penn Attorneys for Defendants 4 MERCURY INSURANCE COMPANY and 5 |} AUTO INSURANCE SPECIALISTS, LLC 6 DATED:__ July 30, 2020 7 8 /s/ Dawn Utsumi 9 || Attorneys for Defendant 10 QUOTELAB, LLC || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. '2 || DATED: July 31, 2020 13

15 16 || GAIL J. STANDISH

UNITED STATES MAGISTRATE JUDGE

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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 ___________ [insert formal name of the case and the 8 number and initials assigned to it by the court]. I agree to comply with and to be 9 bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person 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 the 15 Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. 17 I hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24

25 Printed name: _______________________________ 26

27 Signature: __________________________________