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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

8 9 10 RIGO AMAVIZCA, Individually Case No. 8:20-cv-01324-RGK-MAA and on Behalf of All Others 11 Similarly-Situated, [CLASS ACTION] 12 13 Plaintiff, STIPULATED PROTECTIVE

ORDER1

14 v. 15 NUTRA MANUFACTURING, LLC Action Filed: July 22, 2020 and INTERNATIONAL VITAMIN Trial Date: Non set 16

CORPORATION,

17 Defendants. 18 19 1. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary, or private information for which special protection from public 22 disclosure and from use for any purpose other than prosecuting this litigation may 23 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 24 25 1 This Stipulated Protective Order is substantially based on the model protective 26 order provided by Magistrate Maria A. Audero. Pursuant to Judge Audero’s 27 standing order, a redline in Microsoft Word format has also been provided by e- mail to Chambers at MAA_Chambers@cacd.uscourts.gov showing all differences 28 between this Stipulated Protective Order and the model order. 1 enter the following Stipulated Protective Order. The parties acknowledge that this 2 Stipulated Protective Order does not confer blanket protections on all disclosures or 3 responses to discovery and that the protection it affords from public disclosure and 4 use extends only to the limited information or items that are entitled to confidential 5 treatment under the applicable legal principles. The parties further acknowledge, as 6 set forth in Section 13.3 below, that this Stipulated Protective Order does not entitle 7 them to file confidential information under seal; Local Rule 79-5 sets forth the 8 procedures that must be followed and the standards that will be applied when a 9 party seeks permission from the Court to file material under seal. 10 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve privileged, confidential, or nonpublic 13 information, including, but not limited to, trade secrets, customer and pricing lists 14 and other valuable research, development, commercial, financial, technical and/or 15 proprietary information, as such terms are used in the Federal Rules of Civil 16 Procedure (Fed. R. Civ.) and any applicable case law interpreting Fed. R. Civ. 17 26(c)(1)(G); contracts; non-public compilations of retail prices; proprietary 18 information; vendor agreements; personnel files; claim/litigation information; and 19 nonpublic policies and procedures, for which special protection from public 20 disclosure and from use for any purpose other than prosecution of this action is 21 warranted. Such confidential and proprietary materials and information consist of, 22 among other things, confidential business or financial information, information 23 regarding confidential business practices, or other confidential research, 24 development, or commercial information (including information implicating 25 privacy rights of third parties), information otherwise generally unavailable to the 26 public, or which may be privileged or otherwise protected from disclosure under 27 state or federal statutes, court rules, case decisions, or common law. Accordingly, 28 to expedite the flow of information, to facilitate the prompt resolution of disputes 1 over confidentiality of discovery materials, to adequately protect information the 2 parties are entitled to keep confidential, to ensure that the parties are permitted 3 reasonable necessary uses of such material in preparation for and in the conduct of 4 trial, to address their handling at the end of the litigation, and to serve the ends of 5 justice, a protective order for such information is justified in this matter. It is the 6 intent of the parties that information will not be designated as confidential for 7 tactical reasons and that nothing be so designated without a good faith belief that it 8 has been maintained in a confidential, non-public manner, and there is good cause 9 why it should not be part of the public record of this case. 10 11 3. DEFINITIONS 12 3.1. Action: This pending federal lawsuit – i.e., Case No. 8:20-cv-01324- 13 RGK-MAA pending in the Central District of the United States 14 District Court of California. 15 3.2. Challenging Party: A Party or Nonparty that challenges the 16 designation of information or items under this Stipulated Protective 17 Order. 18 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 19 how it is generated, stored or maintained) or tangible things that 20 qualify for protection under Federal Rule of Civil Procedure 26(c), and 21 as specified above in the Good Cause Statement. 22 3.4. Counsel: Outside Counsel of Record and In-House Counsel (as well 23 as their support staff). 24 3.5. Designating Party: A Party or Nonparty that designates information or 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 3.6. Disclosure or Discovery Material: All items or information, regardless 28 of the medium or manner in which it is generated, stored, or 1 maintained (including, among other things, testimony, transcripts, and 2 tangible things), that is produced or generated in disclosures or 3 responses to discovery in this matter. 4 3.7. Expert: A person with specialized knowledge or experience in a 5 matter pertinent to the litigation who has been retained by a Party or its 6 counsel to serve as an expert witness or as a consultant in this Action. 7 3.8. In-House Counsel: Attorneys who are employees of a party to this 8 Action. In-House Counsel does not include Outside Counsel of 9 Record or any other outside counsel. 10 3.9. Nonparty: Any natural person, partnership, corporation, association, 11 or other legal entity not named as a Party to this action. 12 3.10. 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 14 this Action and have appeared in this Action on behalf of that party or 15 are affiliated with a law firm which has appeared on behalf of that 16 party, and includes support staff. 17 3.11. Party: Any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, In-House Counsel, and 19 Outside Counsel of Record (and their support staffs). 20 3.12. Producing Party: A Party or Nonparty that produces Disclosure or 21 Discovery Material in this Action. 22 3.13. Professional Vendors: Persons or entities that provide litigation 23 support services (e.g., photocopying, videotaping, translating, 24 preparing exhibits or demonstrations, and organizing, storing, or 25 retrieving data in any form or medium) and their employees and 26 subcontractors. 27 3.14. Protected Material: Any Disclosure or Discovery Material that is 28 designated as “CONFIDENTIAL.” 1 3.15. Receiving Party: A Party that receives Disclosure or Discovery 2 Material from a Producing Party. 3 4 4. SCOPE 5 The protections conferred by this Stipulated Protective Order cover not only 6 Protected Material, but also (1) any information copied or extracted from Protected 7 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 8 and (3) any testimony, conversations, or presentations by Parties or their Counsel 9 that might reveal Protected Material. 10 Any use of Protected Material at trial shall be governed by the orders of the 11 trial judge. This Stipulated Protective Order does not govern the use of Protected 12 Material at trial. 13 14 5. DURATION 15 “Final Disposition” of the action is defined as the conclusion of any appellate 16 proceedings, or, if no appeal is taken, when the time for filing of an appeal has run. 17 Except as set forth below, the terms of this protective order apply through Final 18 Disposition of the action. The parties may stipulate that they will be contractually 19 bound by the terms of this agreement beyond Final Disposition, but will have to file 20 a separate action for enforcement of the agreement once all proceedings in this case 21 are complete. 22 Once a case proceeds to trial, all of the information that was designated as 23 confidential or maintained pursuant to this Stipulated Protective Order becomes 24 public and presumptively will be available to all members of the public, including 25 the press, unless compelling reasons supported by specific factual findings to 26 proceed otherwise are made to the trial judge in advance of the trial. See 27 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) 28 (distinguishing “good cause” showing for sealing documents produced in discovery 1 from “compelling reasons” standard when merits-related documents are part of 2 court record). Accordingly, the terms of this Stipulated Protective Order do not 3 extend beyond the commencement of the trial. 4 5 6 6. DESIGNATING PROTECTED MATERIAL 7 6.1. Exercise of Restraint and Care in Designating Material for Protection. 8 Each Party or Nonparty that designates information or items for 9 protection under this Stipulated Protective Order must take care to 10 limit any such designation to specific material that qualifies under the 11 appropriate standards. The Designating Party must designate for 12 protection only those parts of material, documents, items, or oral or 13 written communications that qualify so that other portions of the 14 material, documents, items, or communications for which protection is 15 not warranted are not swept unjustifiably within the ambit of this 16 Stipulated Protective Order. 17 Mass, indiscriminate, or routinized designations are prohibited. 18 Designations that are shown to be clearly unjustified or that have been 19 made for an improper purpose (e.g., to unnecessarily encumber the 20 case development process or to impose unnecessary expenses and 21 burdens on other parties) may expose the Designating Party to 22 sanctions. 23 6.2. Manner and Timing of Designations. 24 Except as otherwise provided in this Stipulated Protective Order 25 (see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered, 26 Disclosure or Discovery Material that qualifies for protection under 27 this Stipulated Protective Order must be clearly so designated before 28 the material is disclosed or produced. 1 Designation in conformity with this Stipulated Protective Order 2 requires the following: 3 (a) For information in documentary form (e.g., paper or electronic 4 documents, but excluding transcripts of depositions or other 5 pretrial or trial proceedings), that the Producing Party affix at a 6 minimum, the legend “CONFIDENTIAL” to each page that 7 contains protected material. If only a portion or portions of the 8 material on a page qualifies for protection, the Producing Party 9 also must clearly identify the protected portion(s) (e.g., by 10 making appropriate markings in the margins). 11 A Party or Nonparty that makes original documents 12 available for inspection need not designate them for protection 13 until after the inspecting Party has indicated which documents it 14 would like copied and produced. During the inspection and 15 before the designation, all of the material made available for 16 inspection shall be deemed “CONFIDENTIAL.” After the 17 inspecting Party has identified the documents it wants copied 18 and produced, the Producing Party must determine which 19 documents, or portions thereof, qualify for protection under this 20 Stipulated Protective Order. Then, before producing the 21 specified documents, the Producing Party must affix the legend 22 “CONFIDENTIAL” to each page that contains Protected 23 Material. If only a portion or portions of the material on a page 24 qualifies for protection, the Producing Party also must clearly 25 identify the protected portion(s) (e.g., by making appropriate 26 markings in the margins). 27 (b) For testimony given in depositions, that the Designating Party 28 either (1) identifies the Disclosure or Discovery Material on the 1 record, before the close of the deposition all protected testimony 2 or (2) designates information disclosed at the deposition as 3 confidential by notifying the court reporter and other parties in 4 writing, within fifteen (15) business days of receipt of the 5 transcript, of the specific pages and lines of the transcript which 6 are designated as confidential. The parties may agree to a 7 reasonable extension of the 15-business-day period for 8 designation. Designations of transcripts will apply to audio, 9 video, or other recordings of the testimony. During such 15- 10 business-day period, the entire transcript shall receive 11 confidential treatment. Upon such designation, the court reporter 12 and each party shall affix the CONFIDENTIAL Legend to the 13 designated pages and segregate them as appropriate.. 14 (c) For information produced in nondocumentary form, and for any 15 other tangible items, that the Producing Party affix in a 16 prominent place on the exterior of the container or containers in 17 which the information is stored the legend “CONFIDENTIAL.” 18 If only a portion or portions of the information warrants 19 protection, the Producing Party, to the extent practicable, shall 20 identify the protected portion(s). 21 6.3. Inadvertent Failure to Designate. 22 If timely corrected, an inadvertent failure to designate qualified 23 information or items does not, standing alone, waive the Designating 24 Party’s right to secure protection under this Stipulated Protective Order 25 for such material. Upon timely correction of a designation, the 26 Receiving Party must make reasonable efforts to assure that the 27 material is treated in accordance with the provisions of this Stipulated 28 Protective Order. 1 2 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 3 7.1. Timing of Challenges. 4 Any Party or Nonparty may challenge a designation of 5 confidentiality at any time that is consistent with the Court’s 6 Scheduling Order. 7 7.2. Meet and Confer. 8 The Challenging Party shall initiate the dispute resolution 9 process, which shall comply with Local Rule 37.1 et seq., and with 10 Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic 11 Conference for Discovery Disputes”).2 12 7.3. Burden of Persuasion. 13 The burden of persuasion in any such challenge proceeding shall 14 be on the Designating Party. Frivolous challenges, and those made for 15 an improper purpose (e.g., to harass or impose unnecessary expenses 16 and burdens on other parties) may expose the Challenging Party to 17 sanctions. Unless the Designating Party has waived or withdrawn the 18 confidentiality designation, all parties shall continue to afford the 19 material in question the level of protection to which it is entitled under 20 the Producing Party’s designation until the Court rules on the 21 challenge. 22 23 8. ACCESS TO AND USE OF PROTECTED MATERIALS 24 8.1. Basic Principles. 25 A Receiving Party may use Protected Material that is disclosed 26 27 2 Judge Audero’s Procedures are available at 28 https://www.cacd.uscourts.gov/honorable-maria-audero. 1 or produced by another Party or by a Nonparty in connection with this 2 Action only for prosecuting, defending, or attempting to settle this 3 Action. Such Protected Material may be disclosed only to the 4 categories of persons and under the conditions described in this 5 Stipulated Protective Order. When the Action reaches a Final 6 Disposition, a Receiving Party must comply with the provisions of 7 Section 14 below. 8 Protected Material must be stored and maintained by a 9 Receiving Party at a location and in a secure manner that ensures that 10 access is limited to the persons authorized under this Stipulated 11 Protective Order. 12 8.2. Disclosure of “CONFIDENTIAL” Information or Items. 13 Unless otherwise ordered by the Court or permitted in writing 14 by the Designating Party, a Receiving Party may disclose any 15 information or item designated “CONFIDENTIAL” only to: 16 (a) The Receiving Party’s Outside Counsel of Record, as well as 17 employees of said Outside Counsel of Record to whom it is 18 reasonably necessary to disclose the information for this Action; 19 (b) The officers, directors, and employees (including In-House 20 Counsel) of the Receiving Party to whom disclosure is 21 reasonably necessary for this Action; 22 (c) Experts of the Receiving Party to whom disclosure is reasonably 23 necessary for this Action and who have signed the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (d) The Court and its personnel; 26 (e) Court reporters and their staff; 27 (f) Professional jury or trial consultants, mock jurors, and 28 Professional Vendors to whom disclosure is reasonably 1 necessary or this Action and who have signed the 2 “Acknowledgment and Agreement to be Bound” (Exhibit A); 3 (g) The author or recipient of a document containing the 4 information or a custodian or other person who otherwise 5 possessed or knew the information; 6 (h) During their depositions, witnesses, and attorneys for witnesses, 7 in the Action to whom disclosure is reasonably necessary 8 provided: (i) the deposing party requests that the witness sign 9 the “Acknowledgment and Agreement to Be Bound” (Exhibit 10 A); and (ii) the witness will not be permitted to keep any 11 confidential information unless they sign the “Acknowledgment 12 and Agreement to Be Bound,” unless otherwise agreed by the 13 Designating Party or ordered by the Court. Pages of transcribed 14 deposition testimony or exhibits to depositions that reveal 15 Protected Material may be separately bound by the court 16 reporter and may not be disclosed to anyone except as permitted 17 under this Stipulated Protective Order; and 18 (i) Any mediator or settlement officer, and their supporting 19 personnel, mutually agreed upon by any of the parties engaged 20 in settlement discussions. 21 8.3. Restriction on Disclosure to Direct Competitors. 22 Notwithstanding the foregoing, Protected Material shall not be 23 disclosed to any current or former employees of, or current or former 24 consultants, advisors, or agents of, a direct competitor of any party 25 named in the litigation. If a Receiving Party is in doubt about whether 26 a particular entity is a direct competitor of a party named in this 27 lawsuit, then before disclosing any Protected Material to a current or 28 former employee, consultant, advisor, or agent of that entity, the 1 Receiving Party’s counsel must confer with counsel for the Producing 2 Party. 3 8.4. Persons Receiving Protected Information Must Sign Exhibit A. 4 Counsel for each party shall advise all persons to whom 5 Protected Material is disclosed pursuant to this Order of the existence 6 of this Order and shall provide all such persons (other than the Court 7 and its staff) with a copy of this Order. As required by Paragraph 8.2, 8 Counsel shall also require such persons to execute the Affidavit 9 attached as Exhibit A, prior to the disclosure of Protected Material. 10 8.5. Protected Material in Hearings and Trial. 11 The provisions of this Order shall not affect, and this Order does 12 not limit, the admissibility of Protected Material (or references to that 13 material) as evidence at trial, or during a hearing or similar proceeding 14 in this action. Prior to using Protected Material or the information 15 contained therein at any hearing that is open to the public, the party 16 seeking to use the Protected Material must give at least seven (7) days 17 advance notice to the producing party of the intent to use the Protected 18 Material so that the producing party may seek an appropriate Court 19 Order to protect the Protected Material. 20 21 9. 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 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL,” that Party must: 26 (a) Promptly notify in writing the Designating Party. Such notification 27 shall include a copy of the subpoena or court order; 28 (b) Promptly notify in writing the party who caused the subpoena or order 1 to issue in the other litigation that some or all of the material covered 2 by the subpoena or order is subject to this Stipulated Protective Order. 3 Such notification shall include a copy of this Stipulated Protective 4 Order; and 5 (c) Cooperate with respect to all reasonable procedures sought to be 6 pursued by the Designating Party whose Protected Material may be 7 affected. 8 If the Designating Party timely seeks a protective order, the Party served with 9 the subpoena or court order shall not produce any information designated in this 10 action as “CONFIDENTIAL” before a determination by the Court from which the 11 subpoena or order issued, unless the Party has obtained the Designating Party’s 12 permission. The Designating Party shall bear the burden and expense of seeking 13 protection in that court of its confidential material and nothing in these provisions 14 should be construed as authorizing or encouraging a Receiving Party in this Action 15 to disobey a lawful directive from another court. 16 17 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 10.1. Application. 20 The terms of this Stipulated Protective Order are applicable to 21 information produced by a Nonparty in this Action and designated as 22 “CONFIDENTIAL.” Such information produced by Nonparties in 23 connection with this litigation is protected by the remedies and relief 24 provided by this Stipulated Protective Order. Nothing in these 25 provisions should be construed as prohibiting a Nonparty from seeking 26 additional protections. 27 10.2. Notification. 28 In the event that a Party is required, by a valid discovery 1 request, to produce a Nonparty’s confidential information in its 2 possession, and the Party is subject to an agreement with the Nonparty 3 not to produce the Nonparty’s confidential information, then the Party 4 shall: 5 (a) Promptly notify in writing the Requesting Party and the 6 Nonparty that some or all of the information requested is subject 7 to a confidentiality agreement with a Nonparty; 8 (b) Promptly provide the Nonparty with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery 10 request(s), and a reasonably specific description of the 11 information requested; and 12 (c) Make the information requested available for inspection by the 13 Nonparty, if requested. 14 10.3. Conditions of Production. 15 If the Nonparty fails to seek a protective order from this Court 16 within fourteen (14) days after receiving the notice and accompanying 17 information, the Receiving Party may produce the Nonparty’s 18 confidential information responsive to the discovery request. If the 19 Nonparty timely seeks a protective order, the Receiving Party shall not 20 produce any information in its possession or control that is subject to 21 the confidentiality agreement with the Nonparty before a 22 determination by the Court. Absent a court order to the contrary, the 23 Nonparty shall bear the burden and expense of seeking protection in 24 this Court of its Protected Material. 25 26 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 27 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 28 Protected Material to any person or in any circumstance not authorized under this 1 Stipulated Protective Order, the Receiving Party immediately must (1) notify in 2 writing the Designating Party of the unauthorized disclosures, (2) use its best 3 efforts to retrieve all unauthorized copies of the Protected Material, (3) inform the 4 person or persons to whom unauthorized disclosures were made of all the terms of 5 this Stipulated Protective Order, and (4) request such person or persons to execute 6 the “Acknowledgment and Agreement to be Bound” (Exhibit A). 7 8 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 9 PROTECTED MATERIAL 10 When a Producing Party gives notice to Receiving Parties that certain 11 inadvertently produced material is subject to a claim of privilege or other 12 protection, the obligations of the Receiving Parties are those set forth in Federal 13 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 14 whatever procedure may be established in an e-discovery order that provides for 15 production without prior privilege review. Pursuant to Federal Rule of Evidence 16 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 17 of a communication or information covered by the attorney-client privilege or work 18 product protection, the parties may incorporate their agreement in the Stipulated 19 Protective Order submitted to the Court. 20 21 13. MISCELLANEOUS 22 13.1. Right to Further Relief. 23 Nothing in this Stipulated Protective Order abridges the right of 24 any person to seek its modification by the Court in the future. 25 13.2. Right to Assert Other Objections. 26 By stipulating to the entry of this Stipulated Protective Order, no 27 Party waives any right it otherwise would have to object to disclosing 28 or producing any information or item on any ground not addressed in 1 this Stipulated Protective Order. Similarly, no Party waives any right 2 to object on any ground to use in evidence of any of the material 3 covered by this Stipulated Protective Order. 4 13.3. Filing Protected Material. 5 A Party that seeks to file under seal any Protected Material must 6 comply with Local Rule 79-5. Protected Material may only be filed 7 under seal pursuant to a court order authorizing the sealing of the 8 specific Protected Material at issue. If a Party's request to file 9 Protected Material under seal is denied by the Court, then the 10 Receiving Party may file the information in the public record unless 11 otherwise instructed by the Court. 12 13.3. Persons with Knowledge of Protected Material. 13 Persons having knowledge of Protected Material and 14 information due to their participation in the conduct of this litigation 15 shall use such knowledge and information only as permitted herein, 16 and shall not disclose such Protected Material, their contents or any 17 portion or summary thereof to any person(s) not involved in the 18 conduct of this litigation. 19 20 14. FINAL DISPOSITION 21 After the final disposition of this Action, within sixty (60) days of a written 22 request by the Designating Party, each Receiving Party must return all Protected 23 Material to the Producing Party or destroy such material. As used in this 24 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 25 summaries, and any other format reproducing or capturing any of the Protected 26 Material. Whether the Protected Material is returned or destroyed, the Receiving 27 Party must submit a written certification to the Producing Party (and, if not the 28 same person or entity, to the Designating Party) by the 60-day deadline that 1 (1) identifies (by category, where appropriate) all the Protected Material that was 2 returned or destroyed and (2) affirms that the Receiving Party has not retained any 3 copies, abstracts, compilations, summaries or any other format reproducing or 4 capturing any of the Protected Material. Notwithstanding this provision, Counsel is 5 entitled to retain an archival copy of all pleadings; motion papers; trial, deposition, 6 and hearing transcripts; legal memoranda; correspondence; deposition and trial 7 exhibits; expert reports; attorney work product; and consultant and expert work 8 product, even if such materials contain Protected Material. Any such archival 9 copies that contain or constitute Protected Material remain subject to this Stipulated 10 Protective Order as set forth in Section 5. 11 12 15. VIOLATION 13 Any violation of this Stipulated Order may be punished by any and all 14 appropriate measures including, without limitation, contempt proceedings and/or 15 monetary sanctions. 16 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

18 19 Dated: 1/28/21 /s/ Matthew Insley-Pruitt (w/permission) Attorney(s) for Plaintiff(s) 20 21 Dated: 1/28/21 /s/ Simren K. Gill 22 Attorney(s) for Defendant(s) 23

24 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 25

26 Dated: January 29, 2021 /s/ 27 Maria A. Audero United States Magistrate Judge 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [full name], of 4 [address], declare under penalty of perjury that I have read in its 5 entirety and understand the Stipulated Protective Order that was issued by the 6 United States District Court for the Central District of California on 7 [date] in the case of 8 [case name and number]. I agree to comply with and to be bound by all the terms 9 of this Stipulated Protective Order, and I understand and acknowledge that failure 10 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 Stipulated Protective 14 Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint [full name] 19 of [address and telephone number] 20 as my California agent for service of process in connection with this action or any 21 proceedings related to enforcement of this Stipulated Protective Order. 22 23 Signature: 24 Printed Name: 25 Date: 26 City and State Where Sworn and Signed: 27 28