1

2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 GERALD MARVIN, an individual; Case No. 2:19-cv-05536 CJC (JCx) KINGSTON TRIO ARTISTS, LLC, a 12 Nevada Limited Liability Company; STIPULATED PROTECTIVE 13 TIMOTHY GORELANGTON, an ORDER individual; BARBARA L. 14 CHILDRESS, an individual; [CHANGES MADE BY COURT] ROBERT C. SHANE, an individual; 15 and KINGSTON TRIO, LLC, an Arizona Limited Liability Company, 16

17 Plaintiffs,

18 vs.

19 JOSHUA S. REYNOLDS, an 20 individual; SUSAN REYNOLDS, an individual; TRIDENT ARTISTS; and 21 DOES 1 through 10, inclusive,

22 Defendants.

23 JOSHUA S. REYNOLDS,

24 Cross-Complainant,

25 vs.

26 GERALD MARVIN,

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

(9th Cir. 2006), Phillips v. Gen. Motors 18 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 19

(E.D. Wis. 1999) (even stipulated protective orders require good 20 cause showing), and a specific showing of good cause or compelling reasons with 21 proper evidentiary support and legal justification, must be made with respect to 22 Protected Material that a party seeks to file under seal. The parties’ mere designation 23 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 24 submission of competent evidence by declaration, establishing that the material 25 sought to be filed under seal qualifies as confidential, privileged, or otherwise 26 protectable—constitute good cause. 27 Further, if a party requests sealing related to a dispositive motion or trial, then 1 relief sought shall be narrowly tailored to serve the specific interest to be protected. 2 See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For 3 each item or type of information, document, or thing sought to be filed or introduced 4 under seal in connection with a dispositive motion or trial, the party seeking 5 protection must articulate compelling reasons, supported by specific facts and legal 6 justification, for the requested sealing order. Again, competent evidence supporting 7 the application to file documents under seal must be provided by declaration. 8 Any document that is not confidential, privileged, or otherwise protectable in 9 its entirety will not be filed under seal if the confidential portions can be redacted. 10 If documents can be redacted, then a redacted version for public viewing, omitting 11 only the confidential, privileged, or otherwise protectable portions of the document, 12 shall be filed. Any application that seeks to file documents under seal in their 13 entirety should include an explanation of why redaction is not feasible. 14 2. DEFINITIONS 15 2.1 Action: Gerald Marvin, et al., v. Joshua S. Reynolds, et al. 16 (Case No. 2:19-cv-05536 CJC (JCx)), including related counterclaims filed by 17 Joshua S. Reynolds against Gerald Marvin. 18 2.2 Challenging Party: a Party or Non-Party that challenges the designation 19 of information or items under this Order. 20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 21 how it is generated, stored or maintained) or tangible things that qualify for 22 protection under Federal Rule of Civil Procedure 26(c), and as referenced above in 23 the Good Cause Statement. 24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 25 their support staff). 26 2.5 Designating Party: a Party or Non-Party that designates information or 27 items that it produces in disclosures or in responses to discovery as 1 2.6 Disclosure or Discovery Material: all items or information, regardless 2 of the medium or manner in which it is generated, stored, or maintained (including, 3 among other things, testimony, transcripts, and tangible things), that are produced or 4 generated voluntarily or in disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in a matter 6 pertinent to the litigation who has been retained by a Party or its counsel to serve as 7 an expert witness or as a consultant in this Action. 8 2.8 In-House Counsel: attorneys who are employees of a party to this Action. 9 In-House Counsel does not include Outside Counsel of Record or any other outside 10 counsel. 11 2.9 Non-Party: any natural person, partnership, corporation, association or 12 other legal entity not named as a Party to this action. 13 2.10 Outside Counsel of Record: attorneys who are not employees of a party 14 to this Action but are retained to represent or advise a party to this Action and have 15 appeared in this Action on behalf of that party or are affiliated with a law firm that 16 has appeared on behalf of that party, and includes support staff. 17 2.11 Party: any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, and Outside Counsel of Record (and their 19 support staffs). 20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 21 Discovery Material in this Action. 22 2.13 Professional Vendors: persons or entities that provide litigation support 23 services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) 25 and their employees and subcontractors. 26 2.14 Protected Material: any Disclosure or Discovery Material that is 27 designated as “CONFIDENTIAL.” 1 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 2 from a Producing Party. 3 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or extracted 6 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 7 Protected Material; and (3) any testimony, conversations, or presentations by Parties 8 or their Counsel that might reveal Protected Material, other than during a court 9 hearing or at trial. 10 Any use of Protected Material during a court hearing or at trial shall be 11 governed by the orders of the presiding judge. This Order does not govern the use 12 of Protected Material during a court hearing or at trial. 13 4. DURATION 14 Once a case proceeds to trial, information that was designated as 15 CONFIDENTIAL or maintained pursuant to this Protective Order used or introduced 16 as an exhibit at trial becomes public and will be presumptively available to all 17 members of the public, including the press, unless compelling reasons supported by 18 specific factual findings to proceed otherwise are made to the trial judge in advance 19 of the trial. See Kamakana,

(distinguishing “good cause” 20 showing for sealing documents produced in discovery from “compelling reasons” 21 standard when merits-related documents are part of court record). The terms of this 22 Protective Order expressly cover any disclosures, representations, or discussions that 23 occur during mediation or arbitration related to this dispute. The Parties shall meet 24 and confer regarding the procedures for use of any Confidential Information or 25 Items/Protected Materials at trial and shall have the right to move the Court for entry 26 of an appropriate order if determined to be necessary. This Stipulation and Protective 27 Order shall continue to be binding after the conclusion of this Action and all 1 written permission of the Designating Party or may move the Court for relief from the 2 provisions of this Stipulation and Protective Order. To the extent permitted by law, 3 the Court shall retain jurisdiction to enforce, modify, or reconsider this Stipulation 4 and Protective Order, even after the Action is terminated. 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. 7 Each Party or Non-Party that designates information or items for protection under 8 this Order must take care to limit any such designation to specific material that 9 qualifies under the appropriate standards. The Designating Party must designate for 10 protection only those parts of material, documents, items or oral or written 11 communications that qualify so that other portions of the material, documents, items 12 or communications for which protection is not warranted are not swept unjustifiably 13 within the ambit of this Order. 14 Mass, indiscriminate or routinized designations are prohibited. Designations 15 that are shown to be clearly unjustified or that have been made for an improper 16 purpose (e.g., to unnecessarily encumber the case development process or to impose 17 unnecessary expenses and burdens on other parties) may expose the Designating Party 18 to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 designated for protection do not qualify for protection, that Designating Party must 21 promptly notify all other Parties that it is withdrawing the inapplicable designation. 22 5.2 Manner and Timing of Designations. Except as otherwise provided in 23 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 24 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 25 under this Order must be clearly so designated before the material is disclosed or 26 produced. 27 /// 1 Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic 3 documents, but excluding transcripts of depositions or other pretrial or trial 4 proceedings), that the Producing Party affix at a minimum, the legend 5 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 6 contains protected material. If only a portion of the material on a page qualifies for 7 protection, the Producing Party also must clearly identify the protected portion(s) 8 (e.g., by making appropriate markings in the margins). 9 A Party or Non-Party that makes original documents available for inspection 10 need not designate them for protection until after the inspecting Party has indicated 11 which documents it would like copied and produced. During the inspection and 12 before the designation, all of the material made available for inspection shall be 13 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 14 documents it wants copied and produced, the Producing Party must determine which 15 documents, or portions thereof, qualify for protection under this Order. Then, 16 before producing the specified documents, the Producing Party must affix the 17 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 18 portion of the material on a page qualifies for protection, the Producing Party also 19 must clearly identify the protected portion(s) (e.g., by making appropriate markings 20 in the margins). 21 (b) for testimony given in depositions that the Designating Party identifies 22 the Disclosure or Discovery Material on the record, before the close of the 23 deposition all protected testimony. 24 (c) for information produced in some form other than documentary and for 25 any other tangible items, that the Producing Party affix in a prominent place on the 26 exterior of the container or containers in which the information is stored the legend 27 “CONFIDENTIAL.” If only a portion or portions of the information warrants 1 protection, the Producing Party, to the extent practicable, shall identify the protected

2 portion(s).

3 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

4 failure to designate qualified information or items does not, standing alone, waive

5 the Designating Party’s right to secure protection under this Order for such material. 6 Upon timely correction of a designation, the Receiving Party must make reasonable 7 efforts to assure that the material is treated in accordance with the provisions of this 8 Order. 9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 6.1 Timing of Challenges. Any Party or Non-Party may challenge 11 a designation of confidentiality at any time that is consistent with the Court’s 12 Scheduling Order. 13 6.2 Meet and Confer. The Challenging Party shall initiate the 14 dispute resolution process under Local Rule 37-1 et seq. 15 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 16 joint stipulation pursuant to Local Rule 37-2. 17 6.4 The burden of persuasion in any such challenge proceeding shall be 18 on the Designating Party. Frivolous challenges, and those made for an improper 19 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 20 parties) may expose the Challenging Party to sanctions. Unless the Designating 21 Party has waived or withdrawn the confidentiality designation, all parties shall 22 continue to afford the material in question the level of protection to which it is 23 entitled under the Producing Party’s designation until the Court rules on the 24 challenge. 25 7. ACCESS TO AND USE OF PROTECTED MATERIAL 26 7.1 Basic Principles. A Receiving Party may use Protected Material that is 27 disclosed or produced by another Party or by a Non-Party in connection with this 1 Protected Material may be disclosed only to the categories of persons and under the 2 conditions described in this Order. When the Action has been terminated, a Receiving 3 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 4 Protected Material must be stored and maintained by a Receiving Party at a 5 location and in a secure manner that ensures that access is limited to the persons 6 authorized under this Order. 7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 8 otherwise ordered by the court or permitted in writing by the Designating Party, a 9 Receiving Party may disclose any information or item designated 10 “CONFIDENTIAL” only to: 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 12 employees of said Outside Counsel of Record to whom it is reasonably necessary to 13 disclose the information for this Action; 14 (b) the officers, directors, and employees (including House Counsel) of the 15 Receiving Party to whom disclosure is reasonably necessary for this Action; 16 (c) Experts (as defined in this Order) of the Receiving Party to whom 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) the court and its personnel; 20 (e) court reporters and their staff; 21 (f) professional jury or trial consultants, mock jurors, and Professional 22 Vendors to whom disclosure is reasonably necessary for this Action and who have 23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (g) the author or recipient of a document containing the information or a 25 custodian or other person who otherwise possessed or knew the information; 26 (h) during their depositions, witnesses, and attorneys for witnesses, in the 27 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 1 not be permitted to keep any confidential information unless they sign the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 3 agreed by the Designating Party or ordered by the court. Pages of transcribed 4 deposition testimony or exhibits to depositions that reveal Protected Material may be 5 separately bound by the court reporter and may not be disclosed to anyone except as 6 permitted under this Stipulated Protective Order; and 7 (i) any mediator or settlement officer, and their supporting personnel, 8 mutually agreed upon by any of the parties engaged in settlement discussions. 9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 10 PRODUCED IN OTHER LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation 12 that compels disclosure of any information or items designated in this Action as 13 “CONFIDENTIAL,” that Party must: 14 (a) promptly notify in writing the Designating Party. Such notification 15 shall include a copy of the subpoena or court order; 16 (b) promptly notify in writing the party who caused the subpoena or order 17 to issue in the other litigation that some or all of the material covered by the subpoena 18 or order is subject to this Protective Order. Such notification shall include a copy of 19 this Stipulated Protective Order; and 20 (c) cooperate with respect to all reasonable procedures sought to be 21 pursued by the Designating Party whose Protected Material may be affected. 22 If the Designating Party timely seeks a protective order, the Party served with 23 the subpoena or court order shall not produce any information designated in this 24 action as “CONFIDENTIAL” before a determination by the court from which the 25 subpoena or order issued, unless the Party has obtained the Designating Party’s 26 permission or unless otherwise required by the law or court order. The Designating 27 Party shall bear the burden and expense of seeking protection in that court of its 1 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 2 directive from another court. 3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced by a 6 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 7 produced by Non-Parties in connection with this litigation is protected by the 8 remedies and relief provided by this Order. Nothing in these provisions should be 9 construed as prohibiting a Non-Party from seeking additional protections. 10 (b) In the event that a Party is required, by a valid discovery request, to 11 produce a Non-Party’s confidential information in its possession, and the Party is 12 subject to an agreement with the Non-Party not to produce the Non-Party’s 13 confidential information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non-Party 15 that some or all of the information requested is subject to a confidentiality agreement 16 with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 specific description of the information requested; and 20 (3) make the information requested available for inspection by the 21 Non-Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this court within 23 14 days of receiving the notice and accompanying information, the Receiving Party 24 may produce the Non-Party’s confidential information responsive to the discovery 25 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 26 not produce any information in its possession or control that is subject to the 27 confidentiality agreement with the Non-Party before a determination by the court 1 contrary, the Non-Party shall bear the burden and expense of seeking protection in 2 this court of its Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 9 persons to whom unauthorized disclosures were made of all the terms of this Order, 10 and (d) request such person or persons to execute the “Acknowledgment and 11 Agreement to Be Bound” that is attached hereto as Exhibit A. 12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 13 PROTECTED MATERIAL 14 When a Producing Party gives notice to Receiving Parties that certain 15 inadvertently produced material is subject to a claim of privilege or other 16 protection, the obligations of the Receiving Parties are those set forth in Federal 17 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 18 whatever procedure may be established in an e-discovery order that provides for 19 production without prior privilege review. Pursuant to Federal Rule of Evidence 20 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 21 of a communication or information covered by the attorney-client privilege or 22 work product protection, the parties may incorporate their agreement in the 23 stipulated protective order submitted to the court. 24 12. MISCELLANEOUS 25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 26 person to seek its modification by the Court in the future. 27 12.2 Right to Assert Other Objections. By stipulating to the entry of this 1 disclosing or producing any information or item on any ground not addressed in this 2 Stipulated Protective Order. Similarly, no Party waives any right to object on any 3 ground to use in evidence of any of the material covered by this Protective Order. 4 12.3 Filing Protected Material. A Party that seeks to file under seal any 5 Protected Material must comply with Local Civil Rule 79-5. Protected Material 6 may only be filed under seal pursuant to a court order authorizing the sealing of the 7 specific Protected Material at issue. If a Party’s request to file Protected Material 8 under seal is denied by the court, then the Receiving Party may file the information 9 in the public record unless otherwise instructed by the court. 10 13. FINAL DISPOSITION 11 After the final disposition of this Action, as defined in paragraph 4, within 60 12 days of a written request by the Designating Party, each Receiving Party must return 13 all Protected Material to the Producing Party or destroy such material. As used in 14 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 15 summaries, and any other format reproducing or capturing any of the Protected 16 Material. Whether the Protected Material is returned or destroyed, the Receiving 17 Party must submit a written certification to the Producing Party (and, if not the same 18 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 19 (by category, where appropriate) all the Protected Material that was returned or 20 destroyed and (2) affirms that the Receiving Party has not retained any copies, 21 abstracts, compilations, summaries or any other format reproducing or capturing any 22 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 23 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 24 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 25 reports, attorney work product, and consultant and expert work product, even if such 26 materials contain Protected Material. Any such archival copies that contain or 27 constitute Protected Material remain subject to this Protective Order as set forth in 1 Section 4 (DURATION). To the extent permitted by law the Court shall retain 2 continuing jurisdiction with regard to any issues arising under this Order. 3 14. VIOLATION 4 Any violation of this Order may be punished by appropriate measures 5 including, without limitation, contempt proceedings and/or monetary sanctions. 6 7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 9 Dated: March 20, 2020 TROPE LAW GROUP, P.C.

10

11 By: //s// Konrad L. Trope Konrad L. Trope 12

13 Attorneys for Plaintiffs 14 GERALD MARVIN; KINGSTON TRIO ARTISTS, LLC; and TIMOTHY 15 GORELANGTON

16 Dated: March 20, 2020 HARTMAN TITUS PLC 17 18 By: //s// Joseph Mott 19 Joseph Mott 20 Attorneys for Plaintiffs 21 BARBARA L. CHILDRESS; ROBERT C. SHANE; and KINGSTON TRIO, LLC 22

23 /// 24 /// 25 /// 26 /// 27 /// /// 1 In accordance with Civil Local Rule 5-4.3.4(a)(2), I hereby attest that all 2 signatories listed, and on whose behalf the filing is submitted, have concurred in the 3 filing’s content and have authorized this filing. 4 5 Dated: March 20, 2020 FARELLA BRAUN + MARTEL LLP

6

7 By: //s// Mark D. Petersen Mark D. Petersen 8 9 Attorneys for Defendant SUSAN REYNOLDS 10 and Defendant and Counter-Claimant 11 JOSHUA REYNOLDS

12

13 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED AS MODIFIED. 14

15 Dated: April 26, 2020 16

17 _________________/s/______________________ Honorable Jacqueline Chooljian 18 UNITED STATES MAGISTRATE JUDGE 19 20 21 22 23 24 25 26 27 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 April 26, 2020 in the case of Gerald Marvin, et al. v. Joshua S. Reynolds, et al. 8 (Case No. 2:19-cv-05536-CJC(JCx), including related counterclaims filed by Joshua 9 S. Reynolds against Gerald Marvin. I agree to comply with and to be bound by all 10 the terms of this Stipulated Protective Order and I understand and acknowledge that 11 failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 or item that is subject to this Stipulated Protective Order to any person or entity 14 except in strict compliance with the provisions of this Order. I further agree to 15 submit to the jurisdiction of the United States District Court for the Central District 16 of California for enforcing the terms of this Stipulated Protective Order, even if such 17 enforcement proceedings occur after termination of this action. I hereby appoint 18 __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________