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7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9 10 ERIKA VENEGAS, an individual, CASE NO. 2:19-cv-05755-PSG-GJS

11 Plaintiff, 12 vs. [PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER 13 RENAL TREATMENT CENTERS 14 CALIFORNIA, INC.; and DOES 1 through 50, inclusive, 15

16 Defendants. 17

18 1. A. PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, proprietary 20 or private information for which special protection from public disclosure and from use 21 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 22 parties hereby stipulate to and petition the Court to enter the following Stipulated 23 Protective Order. The parties acknowledge that this Order does not confer blanket 24 protections on all disclosures or responses to discovery and that the protection it affords 25 from public disclosure and use extends only to the limited information or items that are 26 entitled to confidential treatment under the applicable legal principles. 27 /// 28 B. GOOD CAUSE STATEMENT 2 This action is likely to involve commercial, technical and/or proprietary 3 information as well as personal medical information for which special protection from 4 public disclosure and from use for any purpose other than prosecution of this action is 5 warranted. Such confidential proprietary and medical materials and information consist 6 of, among other things, confidential business or financial information, information 7 regarding confidential business practices, (including information implicating privacy 8 rights of third parties), and confidential medical information otherwise generally 9 unavailable to the public, or which may be privileged or otherwise protected from 10 disclosure under state or federal statutes, court rules, case decisions, or common law. 11 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 12 disputes over confidentiality of discovery materials, to adequately protect information the 13 parties are entitled to keep confidential, to ensure that the parties are permitted reasonable 14 necessary uses of such material in preparation for and in the conduct of trial, to address 15 their handling at the end of the litigation, and serve the ends of justice, a protective order 16 for such information is justified in this matter. It is the intent of the parties that 17 information will not be designated as confidential for tactical reasons and that nothing be 18 so designated without a good faith belief that it has been maintained in a confidential, 19 non-public manner, and there is good cause why it should not be part of the public record 20 of this case. 21 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 22 The parties further acknowledge, as set forth in Section 12.3, below, that this 23 Stipulated Protective Order does not entitle them to file confidential information under 24 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 25 standards that will be applied when a party seeks permission from the court to file 26 material under seal. 27 There is a strong presumption that the public has a right of access to judicial 28 proceedings and records in civil cases. In connection with non-dispositive motions, good cause must be shown to support a filing under seal. See Kamakana v. City and County of 2 Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors Corp.,

1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,

, 4 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and 5 a specific showing of good cause or compelling reasons with proper evidentiary support 6 and legal justification, must be made with respect to Protected Material that a party seeks 7 to file under seal. The parties’ mere designation of Disclosure or Discovery Material as 8 CONFIDENTIAL does not—without the submission of competent evidence by 9 declaration, establishing that the material sought to be filed under seal qualifies as 10 confidential, privileged, or otherwise protectable—constitute good cause. 11 Further, if a party requests sealing related to a dispositive motion or trial, then 12 compelling reasons, not only good cause, for the sealing must be shown, and the relief 13 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 14 v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each item or type 15 of information, document, or thing sought to be filed or introduced under seal in 16 connection with a dispositive motion or trial, the party seeking protection must articulate 17 compelling reasons, supported by specific facts and legal justification, for the requested 18 sealing order. Again, competent evidence supporting the application to file documents 19 under seal must be provided by declaration. 20 Any document that is not confidential, privileged, or otherwise protectable in its 21 entirety will not be filed under seal if the confidential portions can be redacted. If 22 documents can be redacted, then a redacted version for public viewing, omitting only the 23 confidential, privileged, or otherwise protectable portions of the document, shall be filed. 24 Any application that seeks to file documents under seal in their entirety should include an 25 explanation of why redaction is not feasible. 26 2. DEFINITIONS 27 2.1 Action: Erika Venegas v. Renal Treatment Centers California, Inc. et al, 28 Case No. 2:19-cv-05755-PSG-GJS 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 2 information or items under this Order. 3 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 4 is generated, stored or maintained) or tangible things that qualify for protection under 5 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 6 Statement. 7 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 8 support staff). 9 2.5 Designating Party: a Party or Non-Party that designates information or 10 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 11 2.6 Disclosure or Discovery Material: all items or information, regardless of the 12 medium or manner in which it is generated, stored, or maintained (including, among 13 other things, testimony, transcripts, and tangible things), that are produced or generated in 14 disclosures or responses to discovery in this matter. 15 2.7 Expert: a person with specialized knowledge or experience in a matter 16 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 17 expert witness or as a consultant in this Action. 18 2.8 House Counsel: attorneys who are employees of a party to this Action. 19 House Counsel does not include Outside Counsel of Record or any other outside counsel. 20 2.9 Non-Party: any natural person, partnership, corporation, association or other 21 legal entity not named as a Party to this action. 22 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 23 this Action but are retained to represent or advise a party to this Action and have 24 appeared in this Action on behalf of that party or are affiliated with a law firm that has 25 appeared on behalf of that party, and includes support staff. 26 2.11 Party: any party to this Action, including all of its officers, directors, 27 employees, consultants, retained experts, and Outside Counsel of Record (and their 28 support staffs). 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 2 Discovery Material in this Action. 3 2.13 Professional Vendors: persons or entities that provide litigation support 4 services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 6 their employees and subcontractors. 7 2.14 Protected Material: any Disclosure or Discovery Material that is designated 8 as “CONFIDENTIAL.” 9 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 10 from a Producing Party. 11 3. SCOPE 12 The protections conferred by this Stipulation and Order cover not only Protected 13 Material (as defined above), but also (1) any information copied or extracted from 14 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 15 Material; and (3) any testimony, conversations, or presentations by Parties or their 16 Counsel that might reveal Protected Material. 17 Any use of Protected Material at trial shall be governed by the orders of the trial 18 judge. This Order does not govern the use of Protected Material at trial. 19 4. DURATION 20 FINAL DISPOSITION of the action is defined as the conclusion of any appellate 21 proceedings, or, if no appeal is taken, when the time for filing of an appeal has run. 22 Except as set forth below, the terms of this protective order apply through FINAL 23 DISPOSITION of the action. The parties may stipulate that the they will be contractually 24 bound by the terms of this agreement beyond FINAL DISPOSITION, but will have to 25 file a separate action for enforcement of the agreement once all proceedings in this case 26 are complete. 27 Once a case proceeds to trial, information that was designated as 28 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as an exhibit at trial becomes public and will be presumptively available to all members of 2 the public, including the press, unless compelling reasons supported by specific factual 3 findings to proceed otherwise are made to the trial judge in advance of the trial. See 4 Kamakana,

(distinguishing “good cause” showing for sealing 5 documents produced in discovery from “compelling reasons” standard when merits- 6 related documents are part of court record). Accordingly, for such materials, the terms of 7 this protective order do not extend beyond the commencement of the trial. 8 5. DESIGNATING PROTECTED MATERIAL 9 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 10 Party or Non-Party that designates information or items for protection under this Order 11 must take care to limit any such designation to specific material that qualifies under the 12 appropriate standards. The Designating Party must designate for protection only those 13 parts of material, documents, items or oral or written communications that qualify so that 14 other portions of the material, documents, items or communications for which protection 15 is not warranted are not swept unjustifiably within the ambit of this Order. 16 Mass, indiscriminate or routinized designations are prohibited. Designations that 17 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 18 to unnecessarily encumber the case development process or to impose unnecessary 19 expenses and burdens on other parties) may expose the Designating Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2 Manner and Timing of Designations. Except as otherwise provided in this 24 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 25 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 26 must be clearly so designated before the material is disclosed or produced. 27 Designation in conformity with this Order requires: 28 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 3 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 4 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 5 portion of the material on a page qualifies for protection, the Producing Party also must 6 clearly 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 need 9 not designate them for protection until after the inspecting Party has indicated which 10 documents it would like copied and produced. During the inspection and before the 11 designation, all of the material made available for inspection shall be deemed 12 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 13 copied and produced, the Producing Party must determine which documents, or portions 14 thereof, qualify for protection under this Order. Then, before producing the specified 15 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 16 that contains Protected Material. If only a portion of the material on a page qualifies for 17 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 18 by making appropriate markings in the margins). 19 (b) for testimony given in depositions that the Designating Party identifies 20 the Disclosure or Discovery Material on the record, before the close of the deposition all 21 protected testimony. 22 (c) for information produced in some form other than documentary and for 23 any other tangible items, that the Producing Party affix in a prominent place on the 24 exterior of the container or containers in which the information is stored the legend 25 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 26 the Producing Party, to the extent practicable, shall identify the protected portion(s). 27 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 28 to designate qualified information or items does not, standing alone, waive the Designating Party’s right to secure protection under this Order for such material. Upon 2 timely correction of a designation, the Receiving Party must make reasonable efforts to 3 assure that the material is treated in accordance with the provisions of this Order. 4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 6 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 8 process under Local Rule 37.1 et seq. 9 6.3 The burden of persuasion in any such challenge proceeding shall be on the 10 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 11 to harass or impose unnecessary expenses and burdens on other parties) may expose the 12 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 13 the confidentiality designation, all parties shall continue to afford the material in question 14 the level of protection to which it is entitled under the Producing Party’s designation until 15 the Court rules on the challenge. 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles. A Receiving Party may use Protected Material that is 18 disclosed or produced by another Party or by a Non-Party in connection with this Action 19 only for prosecuting, defending or attempting to settle this Action. Such Protected 20 Material may be disclosed only to the categories of persons and under the conditions 21 described in this Order. When the Action has been terminated, a Receiving Party must 22 comply with the provisions of section 13 below (FINAL DISPOSITION). 23 Protected Material must be stored and maintained by a Receiving Party at a 24 location and in a secure manner that ensures that access is limited to the persons 25 authorized under this Order. 26 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 27 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 28 may disclose any information or item designated “CONFIDENTIAL” only to: (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 2 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 3 disclose the information for this Action; 4 (b) the officers, directors, and management-level employees (including 5 House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for 6 this Action; 7 (c) Experts (as defined in this Order) of the Receiving Party to whom 8 disclosure is reasonably necessary for this Action and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (d) the court and its personnel; 11 (e) court reporters and their staff; 12 (f) professional jury or trial consultants, mock jurors, and Professional 13 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 14 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (g) the author or recipient of a document containing the information or a 16 custodian or other person who otherwise possessed or knew the information; 17 (h) during their depositions, witnesses, and attorneys for witnesses, in the 18 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 19 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not 20 be permitted to keep any confidential information unless they sign the “Acknowledgment 21 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 22 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to 23 depositions that reveal Protected Material may be separately bound by the court reporter 24 and may not be disclosed to anyone except as permitted under this Stipulated Protective 25 Order; and 26 (i) any mediator or settlement officer, and their supporting personnel, 27 mutually agreed upon by any of the parties engaged in settlement discussions. 28 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 2 OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation that 4 compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification shall 7 include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order to 9 issue in the other litigation that some or all of the material covered by the subpoena or 10 order is subject to this Protective Order. Such notification shall include a copy of this 11 Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with the 15 subpoena or court order shall not produce any information designated in this action as 16 “CONFIDENTIAL” before a determination by the court from which the subpoena or 17 order issued, unless the Party has obtained the Designating Party’s permission. The 18 Designating Party shall bear the burden and expense of seeking protection in that court of 19 its confidential material and nothing in these provisions should be construed as 20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 21 from another court. 22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 23 IN THIS LITIGATION 24 (a) The terms of this Order are applicable to information produced by a 25 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 26 produced by Non-Parties in connection with this litigation is protected by the remedies 27 and relief provided by this Order. Nothing in these provisions should be construed as 28 prohibiting a Non-Party from seeking additional protections. (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is subject 3 to an agreement with the Non-Party not to produce the Non-Party’s confidential 4 information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non- 6 Party that some or all of the information requested is subject to a confidentiality 7 agreement with a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery request(s), and a reasonably 10 specific description of the information requested; and 11 (3) make the information requested available for inspection by the 12 Non-Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this court within 14 14 days of receiving the notice and accompanying information, the Receiving Party may 15 produce the Non-Party’s confidential information responsive to the discovery request. If 16 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 17 information in its possession or control that is subject to the confidentiality agreement 18 with the Non-Party before a determination by the court. Absent a court order to the 19 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 20 court of its Protected Material. 21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 25 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 26 all unauthorized copies of the Protected Material, (c) inform the person or persons to 27 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 28 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 2 that is attached hereto as Exhibit A. 3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain inadvertently 6 produced material is subject to a claim of privilege or other protection, the obligations of 7 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 8 This provision is not intended to modify whatever procedure may be established in an e- 9 discovery order that provides for production without prior privilege review. 10 Pursuant to Rule 502 of the Federal Rules of Evidence, the inadvertent disclosure 11 of communications, documents, or information protected by the attorney-client privilege, 12 work product doctrine, or any other privilege (“Privileged Material”) shall not constitute 13 a waiver of any privilege or other protection if the Producing Party took reasonable steps 14 to prevent disclosure and also took reasonable steps to rectify the error in the event of an 15 inadvertent disclosure. The Producing Party will be deemed to have taken reasonable 16 steps to prevent Privileged Material from inadvertent disclosure if that party utilized 17 either attorney screening, keyword search term screening, advanced analytical software 18 applications and/or linguistic tools in screening for privilege, work product, or other 19 protection. In the event of the inadvertent disclosure of Privileged Material, the 20 Producing Party shall be deemed to have taken reasonable steps to rectify the error of the 21 disclosure if, within thirty (30) days from the date that the inadvertent disclosure was 22 discovered or brought to the attention of the Producing Party, the Producing Party notifies 23 the Receiving Party of the inadvertent disclosure and instructs the Receiving Party to 24 promptly sequester, return, delete, or destroy all copies of the inadvertently produced 25 Privileged Material (including any and all work product containing such Privileged 26 Material). The Receiving Party also has an affirmative obligation to notify the Producing 27 Party if it receives communications, documents, or information that appear to constitute 28 Privileged Material. Upon receiving such a request from the Producing Party, the Receiving Party shall promptly sequester, return, delete, or destroy all copies of such 2 inadvertently produced Privileged Material (including any and all work product 3 containing such Privileged Material), and shall make no further use of such Privileged 4 Material (or work product containing such Privileged Material). 5 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 7 person to seek its modification by the Court in the future. 8 12.2 Right to Assert Other Objections. By stipulating to the entry of this 9 Protective Order, no Party waives any right it otherwise would have to object to 10 disclosing or producing any information or item on any ground not addressed in this 11 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 12 to use in evidence of any of the material covered by this Protective Order. 13 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 14 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed 15 under seal pursuant to a court order authorizing the sealing of the specific Protected 16 Material at issue. If a Party’s request to file Protected Material under seal is denied by 17 the court, then the Receiving Party may file the information in the public record unless 18 otherwise instructed by the court. 19 13. FINAL DISPOSITION 20 After the final disposition of this Action, as defined in paragraph 4, within 60 days 21 of a written request by the Designating Party, each Receiving Party must return all 22 Protected Material to the Producing Party or destroy such material. As used in this 23 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 24 summaries, and any other format reproducing or capturing any of the Protected Material. 25 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 26 a written certification to the Producing Party (and, if not the same person or entity, to the 27 Designating Party) by the 60 day deadline that (1) identifies (by category, where 28 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or 2 any other format reproducing or capturing any of the Protected Material. Notwithstanding 3 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 4 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 5 deposition and trial exhibits, expert reports, attorney work product, and consultant and 6 expert work product, even if such materials contain Protected Material. Any such 7 archival copies that contain or constitute Protected Material remain subject to this 8 Protective Order as set forth in Section 4 (DURATION). 9 14. VIOLATION 10 Any violation of this Order may be punished by appropriate measures including, 11 without limitation, contempt proceedings and/or monetary sanctions. 12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 Dated: January 7, 2020 RISE LAW FIRM, P.C. 14

15 By: /s/ Lisa Watanabe-Peagler 16 Lisa Watanabe-Peagler, Esq. Nehemiah H. Choi, Esq. 17 Attorneys for Plaintiff 18 ERIKA VENEGAS

19 Dated: January 7, 2020 JACKSON LEWIS P.C. 20

21

22 By: /s/ Momo E. Takahashi Leila Nourani 23 Momo E.Takahashi

24 Attorneys for Defendant RENAL TREATMENT CENTERS – 25 CALIFORNIA, INC. /// 26

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/// 28 1 Attestation Per Local Rule 5-4.3.4(a)(2)(i) 2 I, Momo E. Takahashi, counsel for Defendant, obtained the concurrence of 3 || Plaintiff’s counsel regarding the content of this document and am authorized to file on 4 || Plaintiff’s behalf. 5 6 /s/ Momo E. Takahashi 7 Momo E. Takahashi 8 9 19 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 11 vy DATED: January 9, 2020 | 14 \GAILJ. STANDISH 16 |} UNITED STATES MAGISTRATE JUDGE 17 18 19 20 21 22 23 24 25 26 27 28

EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury that I 6 have read in its entirety and understand the Stipulated Protective Order that was issued by 7 the United States District Court for the Central District of California on _________ in the 8 case of Erika Venegas v. Renal Treatment Centers California - Inc., Case No. 2:19-cv- 9 05755-PSG-GJS. I agree to comply with and to be bound by all the terms of this 10 Stipulated Protective Order and I understand and acknowledge that failure to so comply 11 could expose me to sanctions and punishment in the nature of contempt. I solemnly 12 promise that I will not disclose in any manner any information or item that is subject to 13 this Stipulated Protective Order to any person or entity except in strict compliance with 14 the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for 16 the Central District of California for enforcing the terms of this Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. I 18 hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and telephone 20 number] as my California agent for service of process in connection with this action or 21 any proceedings related to enforcement of this Stipulated Protective Order. 22 Date: ______________________________________ 23 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28