1 Mark Holscher (SBN 139582) [email protected] 2 Jeff Sinek (SBN 135508) [email protected] 3 James Rapore (SBN 278925) [email protected] 4 KIRKLAND & ELLIS LLP 555 South Flower Street 5 Los Angeles, CA 90071 Telephone: (213) 680-8400 6 Facsimile: (213) 680-8500

7 David Klein (SBN 273925) [email protected] 8 KIRKLAND & ELLIS LLP 2049 Century Park East 9 Los Angeles, CA 90067 Telephone: (310) 552-4200 10 Facsimile: (310) 552-5900

11 Attorneys for Defendant Eric Pulier

12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA 14

15 SECURITIES AND EXCHANGE ) CASE NO. 17-CV-07124-PSG-RAO 16 COMMISSION, ) ) STIPULATED PROTECTIVE 17 Plaintiff, ) ORDER1 ) 18 v. ) ) 19 ERIC PULIER, ) ) 20 Defendant. ) ) 21 22 23 24 25 26

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

(9th Cir. 2006), Phillips v. Gen. Motors 16 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 17

(E.D. Wis. 1999) (even stipulated protective orders require good 18 cause showing), and a specific showing of good cause or compelling reasons with 19 proper evidentiary support and legal justification, must be made with respect to 20 Protected Material that a party seeks to file under seal. The parties’ mere designation 21 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 22 submission of competent evidence by declaration, establishing that the material sought 23 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 24 constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, then 26 compelling reasons, not only good cause, for the sealing must be shown, and the relief 27 sought shall be narrowly tailored to serve the specific interest to be protected. See 28 Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each item 1 or type of information, document, or thing sought to be filed or introduced under seal 2 in connection with a dispositive motion or trial, the party seeking protection must 3 articulate compelling reasons, supported by specific facts and legal justification, for 4 the requested sealing order. Again, competent evidence supporting the application to 5 file documents under seal must be provided by declaration. 6 Any document that is not confidential, privileged, or otherwise protectable in its 7 entirety will not be filed under seal if the confidential portions can be redacted. If 8 documents can be redacted, then a redacted version for public viewing, omitting only 9 the confidential, privileged, or otherwise protectable portions of the document, shall 10 be filed. Any application that seeks to file documents under seal in their entirety 11 should include an explanation of why redaction is not feasible. 12 2. DEFINITIONS 13 2.1 Action: Securities and Exchange Commission v. Eric Pulier, Case No. 14 2:17-cv-07124-PSG-RAO (C.D. Cal. filed September 27, 2017). 15 2.2 Challenging Party: a Party or Non-Party that challenges the designation 16 of information or items under this Order. 17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 18 how it is generated, stored or maintained) or tangible things that qualify for protection 19 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 20 Cause Statement. 21 2.4 Counsel: attorneys who are retained or employed to represent or advise a 22 Party in this action, or are affiliated with a law firm retained to represent or advise a 23 Party in this action, as well as their support staff. 24 2.5 Designating Party: a Party or Non-Party that designates information or 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 2.6 Disclosure or Discovery Material: all items or information, regardless of 28 the medium or manner in which it is generated, stored, or maintained (including, 1 among other things, testimony, transcripts, and tangible things), that are produced or 2 generated in disclosures or responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 5 expert witness or as a consultant in this Action. 6 2.8 Non-Party: any natural person, partnership, corporation, association or 7 other legal entity not named as a Party to this action. 8 2.9 Party: any party to this Action, including all of its officers, directors, 9 employees, consultants, retained experts, and Counsel (and their support staffs). 10 2.10 Producing Party: a Party or Non-Party that produces Disclosure or 11 Discovery Material in this Action. 12 2.11 Professional Vendors: persons or entities that provide litigation support 13 services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 and their employees and subcontractors. 16 2.12 Protected Material: any Disclosure or Discovery Material that is 17 designated as “CONFIDENTIAL.” 18 2.13 Receiving Party: a Party that receives Disclosure or Discovery Material 19 from a Producing Party. 20 3. SCOPE 21 The protections conferred by this Stipulation and Order cover not only 22 Protected Material (as defined above), but also (1) any information copied or extracted 23 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 24 Protected Material; and (3) any testimony, conversations, or presentations by Parties 25 or their Counsel that might reveal Protected Material. 26 However, the protections conferred by this Protective Order do not cover the 27 following information: (a) any information that is in the public domain at the time of 28 disclosure to a Receiving Party or becomes part of the public domain after its 1 disclosure to a Receiving Party as a result of publication not involving a violation of 2 this Protective Order, including becoming part of the public record through trial or 3 otherwise; (b) any information known to the Receiving Party prior to the disclosure or 4 obtained by the Receiving Party after the disclosure from a source who obtained the 5 information lawfully and under no obligation of confidentiality to the Designating 6 Party; and (c) any information that has come into the possession of a Receiving Party 7 prior to the entry of this Protective Order. 8 Any use of Protected Material at trial shall be governed by the orders of the trial 9 judge. This Order does not govern the use of Protected Material at trial. 10 4. DURATION 11 Once a case proceeds to trial, information that was designated as 12 CONFIDENTIAL or maintained pursuant to this protective order that is used or 13 introduced as an exhibit at trial becomes public and will be presumptively available to 14 all members of the public, including the press, unless compelling reasons supported 15 by specific factual findings to proceed otherwise are made to the trial judge in advance 16 of the trial. See Kamakana,

(distinguishing “good cause” 17 showing for sealing documents produced in discovery from “compelling reasons” 18 standard when merits-related documents are part of court record). Accordingly, the 19 terms of this protective order do not extend beyond the commencement of the trial as 20 to all such information that becomes public. 21 5. DESIGNATING PROTECTED MATERIAL 22 5.1 Exercise of Restraint and Care in Designating Material for Protection. 23 Each Party or Non-Party that designates information or items for protection under this 24 Order must take care to limit any such designation to specific material that qualifies 25 under the appropriate standards. The Designating Party must designate for protection 26 only those parts of material, documents, items or oral or written communications that 27 qualify so that other portions of the material, documents, items or communications for 28 1 which protection is not warranted are not swept unjustifiably within the ambit of this 2 Order. 3 Mass, indiscriminate or routinized designations are prohibited; provided that, if 4 a Party or Non-Party re-produces documents in this Action that were produced by a 5 Non-Party in a related action or investigation and were designated as confidential or 6 highly confidential in connection with that related action or investigation, the Party or 7 Non-Party does not need to re-review and re-designate such documents before 8 production in this Action. Designations that are shown to be clearly unjustified or that 9 have been made for an improper purpose (e.g., to unnecessarily encumber the case 10 development process or to impose unnecessary expenses and burdens on other parties) 11 may expose the Designating Party to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic 22 documents, but excluding transcripts of depositions or other pretrial or trial 23 proceedings), that the Producing Party affix at a minimum, the legend 24 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page, unless 25 they are documents produced by DXC Technology Company, Computer Sciences 26 Corporation, or any of their affiliates in connection with any investigation related to 27 this Action, which need only have the label “FOIA Confidential Treatment Requested 28 1 by Computer Sciences Corporation” affixed to each page and, if so, it shall be treated 2 as though DXC designated them using the CONFIDENTIAL legend. 3 A Party or Non-Party that makes original documents available for inspection 4 need not designate them for protection until after the inspecting Party has indicated 5 which documents it would like copied and produced. During the inspection and before 6 the designation, all of the material made available for inspection shall be deemed 7 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 8 copied and produced, the Producing Party must determine which documents, or 9 portions thereof, qualify for protection under this Order. Then, before producing the 10 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 11 to each page that contains Protected Material. If only a portion of the material on a 12 page qualifies for protection, the Producing Party also must clearly identify the 13 protected portion(s) (e.g., by making appropriate markings in the margins). 14 (b) for testimony given in depositions that the Designating Party 15 identifies the Disclosure or Discovery Material on the record, before the close of the 16 deposition all protected testimony. 17 (c) for information produced in some form other than documentary 18 and for any other tangible items, that the Producing Party affix in a prominent place 19 on the exterior of the container or containers in which the information is stored the 20 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 21 protection, the Producing Party, to the extent practicable, shall identify the protected 22 portion(s). 23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 24 failure to designate qualified information or items does not, standing alone, waive the 25 Designating Party’s right to secure protection under this Order for such material. 26 Upon timely correction of a designation, the Receiving Party must make reasonable 27 efforts to assure that the material is treated in accordance with the provisions of this 28 Order. 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 37-1 et seq. 7 6.3 The burden of persuasion in any such challenge proceeding shall be on 8 the Designating Party. Frivolous challenges, and those made for an improper purpose 9 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 10 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 11 withdrawn the confidentiality designation, all parties shall continue to afford the 12 material in question the level of protection to which it is entitled under the Producing 13 Party’s designation until the Court rules on the challenge. 14 7. ACCESS TO AND USE OF PROTECTED MATERIAL 15 7.1 Basic Principles. A Receiving Party may use Protected Material that is 16 disclosed or produced by another Party or by a Non-Party in connection with this 17 Action only for prosecuting, defending or attempting to settle this Action. Such 18 Protected Material may be disclosed only to the categories of persons and under the 19 conditions described in this Order. When the Action has been terminated, a Receiving 20 Party must comply with the provisions of section 13 below. 21 Protected Material must be stored and maintained by a Receiving Party at a 22 location and in a secure manner that ensures that access is limited to the persons 23 authorized under this Order. 24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 25 otherwise ordered by the court or permitted in writing by the Designating Party, a 26 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 27 only to: 28 1 (a) the Receiving Party’s Counsel of Record, as well as employees of 2 said Counsel of Record to whom it is reasonably necessary to disclose the information 3 for this Action; 4 (b) the officers, directors, and employees of the Receiving Party to 5 whom disclosure is reasonably necessary for this Action; 6 (c) Experts (as defined in this Order) of the Receiving Party to whom 7 disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (d) the court and its personnel; 10 (e) court reporters and their staff; 11 (f) professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (g) the author or recipient of a document containing the information or 15 a custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, witnesses, and attorneys for witnesses, in 17 the Action to whom disclosure is reasonably necessary provided they will not be 18 permitted to keep any confidential information unless they sign the 19 “Acknowledgement and Agreement to Be Bound” (Exhibit A), unless otherwise 20 agreed by the Designating Party or ordered by the court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material may be 22 separately bound by the court reporter and may not be disclosed to anyone except as 23 permitted under this Stipulated Protective Order; 24 (i) potential witnesses interviewed by a Receiving Party’s counsel, in 25 connection with the action to whom Counsel determines that disclosure is reasonably 26 necessary provided they sign the “Acknowledgment and Agreement to Be Bound” 27 (Exhibit A). Potential witnesses may be shown information and documents designated 28 1 “CONFIDENTIAL” for purposes of an interview but shall not be given a copy of such 2 document(s) to keep permanently; and 3 (j) any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by any of the parties engaged in settlement discussions. 5 8. PROTECTED MATERIAL FROM THIS ACTION THAT IS SUBPOENAED 6 OR ORDERED PRODUCED IN OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 (a) promptly notify in writing the Designating Party. Such notification 11 shall include a copy of the subpoena or court order; 12 (b) promptly notify in writing the party who caused the subpoena or 13 order to issue in the other litigation that some or all of the material covered by the 14 subpoena or order is subject to this Protective Order. Such notification shall include a 15 copy of this Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be 17 pursued by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with 19 the subpoena or court order shall not produce any information designated in this 20 action as “CONFIDENTIAL” before a determination by the court from which the 21 subpoena or order issued, unless the Party has obtained the Designating Party’s 22 permission. The Designating Party shall bear the burden and expense of seeking 23 protection in that court of its confidential material and nothing in these provisions 24 should be construed as authorizing or encouraging a Receiving Party in this Action to 25 disobey a lawful directive from another court. 26 27 28 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 2 IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by 4 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the 6 remedies and relief provided by this Order. Nothing in these provisions should be 7 construed as prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, 9 to produce a Non-Party’s confidential information in its possession, and the Party is 10 subject to an agreement with the Non-Party not to produce the Non-Party’s 11 confidential information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the 13 Non-Party that some or all of the information requested is subject to a confidentiality 14 agreement with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the 16 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 17 reasonably specific description of the information requested; and 18 (3) make the information requested available for inspection by 19 the Non-Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court 21 within 14 days of receiving the notice and accompanying information, the Receiving 22 Party may produce the Non-Party’s confidential information responsive to the 23 discovery request. If the Non-Party timely seeks a protective order, the Receiving 24 Party shall not produce any information in its possession or control that is subject to 25 the confidentiality agreement with the Non-Party before a determination by the court. 26 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 27 of seeking protection in this court of its Protected Material. 28 1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 7 persons to whom unauthorized disclosures were made of all the terms of this Order, 8 and (d) request such person or persons to execute the “Acknowledgment and 9 Agreement to Be Bound” that is attached hereto as Exhibit A. 10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain 13 inadvertently produced material is subject to a claim of privilege or other protection, 14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 16 may be established in an e-discovery order that provides for production without prior 17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 18 parties reach an agreement on the effect of disclosure of a communication or 19 information covered by the attorney-client privilege or work product protection, the 20 parties may incorporate their agreement in the stipulated protective order submitted to 21 the court. 22 12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order, no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in this 28 1 Stipulated Protective Order. Similarly, no Party waives any right to object on any 2 ground to the use in evidence of any of the material covered by this Protective Order. 3 12.3 Filing Protected Material. A Party that seeks to file under seal any 4 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 5 only be filed under seal pursuant to a court order authorizing the sealing of the 6 specific Protected Material at issue. If a Party’s request to file Protected Material 7 under seal is denied by the court, then the Receiving Party may file the information in 8 the public record unless otherwise instructed by the court. 9 13. FINAL DISPOSITION 10 Within 60 days after the conclusion of the Action, including all appeals, and 11 subject to the procedures set forth below, any and all originals and copies of 12 Discovery Materials maintaining a CONFIDENTIAL designation shall, at the option 13 of the Producing Party, be returned to the Producing Party or destroyed. 14 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 15 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 16 correspondence, deposition and trial exhibits, expert reports, attorney work product, 17 and consultant and expert work product, even if such materials contain Protected 18 Material. Any such archival copies that contain or constitute Protected Material 19 remain subject to this Protective Order except as set forth in Section 4 (DURATION). 20 Pursuant to Section 1226.14(e) of Title 36 of the Code of Federal Regulations, 21 Plaintiff Securities and Exchange Commission (the “SEC”) shall notify the National 22 Archives and Records Administration (“NARA”) that records are to be destroyed in 23 response to this Order. Accordingly, within 10 days after the conclusion of the Action, 24 the SEC will so notify NARA and provide a copy of this Order. If NARA does not 25 object to the destruction of these records within 60 days after the conclusion of the 26 Action, the SEC will comply with this Order. If NARA objects to destruction of these 27 records, the SEC will maintain the records in accordance with its routine document 28 retention practices, unless the Court orders otherwise, either sua sponte or upon 1 || application by the Defendants. Upon request from any party to this Action or 2 || Producing Party, a party shall provide written certification that it has complied with this Paragraph. After the conclusion of the Action, the provisions of this Protective Order shall continue to be binding until further order of this Court, and this Court 5 || shall retain jurisdiction over the parties and any other person who has had access to 6 || Protected Material pursuant to this Protective Order, in order to enforce the provisions 7 || of this Protective Order. 8|| 14. VIOLATION 9 Any violation of this Order may be punished by appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. 11 12|| ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 DATED: February 4, 2020 15 /s/ Douglas M. Miller 16|| Attorneys for Plaintiff Securities and Exchange Commission DATED: February 4, 2020 18 19 /s/ James Rapore Attorneys for Defendant Eric Pulier 20 91 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 23 DATED: February 10, 2020 24 2 ° ° Rapelis, OQ, QC. 26 HON. ROZELLA A. OLIVER United States Magistrate Judge 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], 4 of [print or type full address], declare under penalty of 5 perjury that I have read in its entirety and understand the Stipulated Protective Order 6 that was issued by the United States District Court for the Central District of 7 California on [date] in the case of Securities and Exchange Commission v. Eric Pulier, 8 Case No. 2:17-cv-07124-PSG-RAO (C.D. Cal. filed September 27, 2017). I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order and I 10 understand and acknowledge that failure to so comply could expose me to sanctions 11 and punishment in the nature of contempt. I solemnly promise that I will not disclose 12 in any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of this 17 action. I hereby appoint [print or type full name] 18 of [print or type full address and telephone number] as 19 my California agent for service of process in connection with this action or any 20 proceedings related to enforcement of this Stipulated Protective Order. 21 22 Date: 23 City and State where sworn and signed: 24 25 Printed name: 26 27 28 Signature: