1 JJHuluies sLe.y H@upsesrekyi,n Bscaor iNe.oco. m237711 2 Julian Feldbein-Vinderman, Bar No. 307838 [email protected] 3 PERKINS COIE LLP 11452 El Camino Real, Suite 300 4 San Diego, CA 92130-2594 Telephone: 858.720.5700 5 Facsimile: 858.720.5799 6 Attorneys for Defendant Amazon.com, Inc. 7 Christopher Brennan, SBN 220072 8 Matthew E. Delinko, SBN 302832 BAUMAN LOEWE WITT & MAXWELL, 9 PLLC 8765 E. Bell Road, Ste. 210 10 Scottsdale, AZ 85260 Telephone: (480) 502-4664, Ext. 4217 11 Fax: (480) 502-4774 12 Attorneys for Plaintiff Hartford Underwriters Insurance Company 13 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 17 HARTFORD UNDERWRITERS Case No. 2:19-cv-07480 AB (RAOx) INSURANCE COMPANY, a 18 foreign corporation, individually and STIPULATED PROTECTIVE ORDER as subrogee for its insured, Josephine AND [PROPOSED] ORDER 19 & Ignazio Vivirito THEREON1 20 Plaintiff, Magistrate Judge: Hon. Rozella A. Oliver 21 v. 22 TERA-POWER ENERGY COMPANY, a foreign entity; 23 GOOD TIME CO., a foreign entity; HONG KONG UNI-SUN 24 TECHNOLOGY LIMITED, a foreign entity; AMAZON.COM, 25 INC., a Delaware corporation; and DOES 1 – 20, inclusive, 26 27 1 This Stipulated Protective Order is substantially based on the model 28 protective order provided under Magistrate Judge Rozella A. Oliver’s Procedures. 1 Defendants. 2 3 4 1. A. PURPOSES AND LIMITATIONS 5 Discovery in this action is likely to involve production of confidential, 6 proprietary or private information for which special protection from public 7 disclosure and from use for any purpose other than prosecuting this litigation may 8 be warranted. Accordingly, the parties hereby stipulate to and petition the Court 9 to enter the following Stipulated Protective Order. The parties acknowledge that 10 this Order does not confer blanket protections on all disclosures or responses to 11 discovery and that the protection it affords from public disclosure and use extends 12 only to the limited information or items that are entitled to confidential treatment 13 under the applicable legal principles. 14 B. GOOD CAUSE STATEMENT 15 This action is likely to involve confidential and proprietary materials and 16 information including, confidential or competitively sensitive business or 17 financial information, information regarding confidential business practices, or 18 other confidential research, development, or commercial information (including 19 information implicating privacy rights of third parties), information otherwise 20 generally unavailable to the public, or which may be privileged or otherwise 21 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 24 materials, to adequately protect information the parties are entitled to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of 26 such material in preparation for and in the conduct of trial, to address their 27 handling at the end of the litigation, and serve the ends of justice, a protective 28 order for such information is justified in this matter. It is the intent of the parties 1 that information will not be designated as confidential for tactical reasons and that 2 nothing be so designated without a good faith belief that it has been maintained in 3 a confidential, non-public manner, and there is good cause why it should not be 4 part of the public record of this case. 5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 6 The parties further acknowledge, as set forth in Section 12.3, below, that 7 this Stipulated Protective Order does not entitle them to file confidential 8 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 9 be followed and the standards that will be applied when a party seeks permission 10 from the court to file material under seal. 11 There is a strong presumption that the public has a right of access to 12 judicial proceedings and records in civil cases. In connection with non-dispositive 13 motions, good cause must be shown to support a filing under seal. See Kamakana 14 v. City and County of Honolulu,

(9th Cir. 2006), Phillips v. 15 Gen. Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. 16 Sony Electrics, Inc.,

(E.D. Wis. 1999) (even stipulated 17 protective orders require good cause showing), and a specific showing of good 18 cause or compelling reasons with proper evidentiary support and legal 19 justification, must be made with respect to Protected Material that a party seeks to 20 file under seal. The parties’ mere designation of Disclosure or Discovery Material 21 as CONFIDENTIAL does not— without the submission of competent evidence 22 by declaration, establishing that the material sought to be filed under seal 23 qualifies as confidential, privileged, or otherwise protectable—constitute good 24 cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, 26 then compelling reasons, not only good cause, for the sealing must be shown, and 27 the relief sought shall be narrowly tailored to serve the specific interest to be 28 protected. See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 1 2010). For each item or type of information, document, or thing sought to be filed 2 or introduced under seal in connection with a dispositive motion or trial, the party 3 seeking protection must articulate compelling reasons, supported by specific facts 4 and legal justification, for the requested sealing order. Again, competent evidence 5 supporting the application to file documents under seal must be provided by 6 declaration. 7 Any document that is not confidential, privileged, or otherwise protectable 8 in its entirety will not be filed under seal if the confidential portions can be 9 redacted. If documents can be redacted, then a redacted version for public 10 viewing, omitting only the confidential, privileged, or otherwise protectable 11 portions of the document, shall be filed. Any application that seeks to file 12 documents under seal in their entirety should include an explanation of why 13 redaction is not feasible. 14 2. DEFINITIONS 15 2.1 Action: This pending federal lawsuit entitled Hartford Underwriters 16 Insurance Company v. Tera-Power Energy Company et al., Case No. 2:19-cv- 17 07480 AB (RAOx). 18 2.2 Challenging Party: a Party or Non-Party that challenges the 19 designation 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 specified above in 23 the Good Cause Statement. 24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 25 each of 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 28 “CONFIDENTIAL.” 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 4 or generated 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 House Counsel: attorneys who are employees of a party to this Action. 9 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 14 party to this Action but are retained to represent or advise a party to this Action and 15 have appeared in this Action on behalf of that party or are affiliated with a law firm 16 that 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 23 support 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” or “FOR ATTORNEYS’ EYES ONLY.” 28 1 2.15 Receiving Party: a Party that receives Disclosure or Discovery 2 Material from a Producing Party. 3 2.16 Attorneys’ Eyes Only. The label “Attorneys’ Eyes Only” shall be 4 used in the manner proscribed in subparagraph 5.4 below and means that the only 5 person(s) allowed to view information so labeled are counsel for the Receiving 6 Party which requests the information, or an expert or consultant of the Receiving 7 Party. 8 3. SCOPE 9 The protections conferred by this Stipulation and Order cover not only 10 Protected Material (as defined above), but also (1) any information copied or 11 extracted from Protected Material; (2) all copies, excerpts, summaries, or 12 compilations of Protected Material; and (3) any testimony, conversations, or 13 presentations by Parties or their Counsel that might reveal Protected Material. 14 Any use of Protected Material at trial shall be governed by the orders of the 15 trial judge. This Order does not govern the use of Protected Material at trial. 16 4. HANDLING DURING TRIAL 17 Confidential Information that is subject to this Protective Order may be marked 18 and used as trial exhibits by any party, subject to terms and conditions imposed by 19 the Court. 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 Exercise of Restraint and Care in Designating Material for Protection. 22 Each Party or Non-Party that designates information or items for protection under 23 this Order must take care to limit any such designation to specific material that 24 qualifies under the appropriate standards. The Designating Party must designate for 25 protection only those parts of material, documents, items or oral or written 26 communications that qualify so that other portions of the material, documents, 27 items or communications for which protection is not warranted are not swept 28 unjustifiably within the ambit of this Order. 1 If it comes to a Designating Party’s attention that information or items that it 2 designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in 5 this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material 6 that qualifies for protection under this Order must be clearly so designated before 7 the material is disclosed or produced. 8 Designation in conformity with this Order requires: 9 (a)for information in documentary form (e.g., paper or electronic 10 documents, but excluding transcripts of depositions or other pretrial or trial 11 proceedings), that the Producing Party affix the following legend 12 CONFIDENTIAL: Subject to Protective Order in Case No. 13 2:19-cv-07480 AB(RAOx) 14 (hereinafter “CONFIDENTIAL legend”), to each page that contains Protected 15 Material. If only a portion of the material on a page qualifies for protection, the 16 Producing Party also must clearly identify the protected portion(s) (e.g., by making 17 appropriate markings in the margins). 18 A Party or Non-Party that makes original documents available for inspection 19 need not designate them for protection until after the inspecting Party has indicated 20 which documents it would like copied and produced. During the inspection and 21 before the designation, all of the material made available for inspection shall be 22 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 23 it wants copied and produced, the Producing Party must determine which documents, 24 or portions thereof, qualify for protection under this Order. Then, before producing 25 the specified documents, the Producing Party must affix the “CONFIDENTIAL 26 legend” to each page that contains Protected Material. If only a portion of the material 27 28 1 on a page qualifies for protection, the Producing Party also must clearly identify the 2 protected portion(s) (e.g., by making appropriate markings in the margins). 3 (b)Within 30 days after receiving a deposition transcript, a party may 4 inform the other Parties if portions of it are designated as “CONFIDENTIAL.” All 5 persons and Parties in possession of a copy of a designated deposition transcript 6 shall appropriately mark it as containing protected testimony. 7 (c)for information produced in some form other than documentary and 8 for any other tangible items, that the Producing Party affix in a prominent place on 9 the exterior of the container or containers in which the information is stored the 10 legend “CONFIDENTIAL.” If only a portion or portions of the information 11 warrants protection, the Producing Party, to the extent practicable, shall identify the 12 protected portion(s). 13 (d)If a document containing Protected Material is produced in native 14 format, the file name shall contain the term “CONFIDENTIAL” or otherwise 15 clearly indicate that it contains information subject to this Protective Order. 16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive 18 the Designating Party’s right to secure protection under this Order for such 19 material. Upon timely correction of a designation, the Receiving Party must make 20 reasonable efforts to assure that the material is treated in accordance with the 21 provisions of this Order. 22 5.4 Highly Sensitive Information. Certain documents to be produced by 23 the Parties may be highly sensitive, proprietary, commercial, or personal 24 information. Such highly sensitive information shall be labeled, in addition to the 25 marking described in subparagraph 5.2, as “FOR ATTORNEYS’ EYES ONLY” 26 and such information will be disclosed only to counsel for the requesting party, 27 subject to subparagraph 7.2(a), or to an expert or consultant, subject to 28 subparagraph 7.2(c), and not to the Parties or any other person. A party producing 1 documents that it believes constitute highly sensitive information shall label the 2 documents with the following legend or something substantially similar: 3 CONFIDENTIAL - FOR ATTORNEYS’ EYES ONLY: Subject to 4 Protective Order in Case No. 2:19-cv-07480 AB(RAOx) 5 Documents labeled “FOR ATTORNEYS’ EYES ONLY” are subject to all of 6 the provisions of this Protective Order governing the use, disclosure, and 7 destruction of Protected Material, as well as the additional restrictions contained in 8 this subparagraph 5.4. 9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 11 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 dispute 14 resolution process under Local Rule 37.1 et seq. 15 6.3 The burden of persuasion in any such challenge proceeding shall be on 16 the Designating Party. Frivolous challenges and those made for an improper purpose 17 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 18 expose the Challenging Party to sanctions. Unless the Designating Party has waived 19 or withdrawn the confidentiality designation, all parties shall continue to afford the 20 material in question the level of protection to which it is entitled under the Producing 21 Party’s designation until the Court rules on the challenge. 22 7. ACCESS TO AND USE OF PROTECTED MATERIAL 23 7.1 Basic Principles. A Receiving Party may use Protected Material that is 24 disclosed or produced by another Party or by a Non-Party in connection with this 25 Action only for prosecuting, defending or attempting to settle this Action. Such 26 Protected Material may be disclosed only to the categories of persons and under the 27 conditions described in this Order. When the Action has been terminated, a 28 1 Receiving Party must comply with the provisions of section 13 below (FINAL 2 DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 otherwise ordered by the court or permitted in writing by the Designating Party, a 8 Receiving Party may disclose any information or item designated 9 “CONFIDENTIAL” only to: 10 (a)the Receiving Party’s Outside Counsel of Record in this Action, as 11 well as employees of said Outside Counsel of Record to whom it is reasonably 12 necessary to disclose the information for this Action; 13 (b)the officers, directors, and employees (including House Counsel) of 14 the Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c)Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d)the court and its personnel; 19 (e)court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 Vendors to whom disclosure is reasonably necessary for this Action and who have 22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (g)the author or recipient of a document containing the information or a 24 custodian or other person who otherwise possessed or knew the information; 25 (h)during their depositions, witnesses, and attorneys for witnesses, in the 26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 27 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they 28 will not be permitted to keep any confidential information unless they sign the 1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 2 agreed by the Designating Party or ordered by the court. Pages of transcribed 3 deposition testimony or exhibits to depositions that reveal Protected Material may 4 be separately bound by the court reporter and may not be disclosed to anyone 5 except as permitted under this Stipulated Protective Order; and 6 (i) any mediator or settlement officer, and their supporting personnel, 7 mutually agreed upon by any of the parties engaged in settlement discussions. 8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 9 IN OTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation 11 that compels disclosure of any information or items designated in this Action as 12 “CONFIDENTIAL,” that Party must: 13 (a)promptly notify in writing the Designating Party. Such notification 14 shall include a copy of the subpoena or court order; 15 (b)promptly notify in writing the party who caused the subpoena or order 16 to issue in the other litigation that some or all of the material covered by the 17 subpoena or order is subject to this Protective Order. Such notification shall include 18 a copy of this Stipulated Protective Order; and 19 (c)cooperate with respect to all reasonable procedures sought to be 20 pursued by the Designating Party whose Protected Material may be affected. 21 If the Designating Party timely seeks a protective order, the Party served with 22 the subpoena or court order shall not produce any information designated in this 23 action as “CONFIDENTIAL” before a determination by the court from which the 24 subpoena or order issued, unless the Party has obtained the Designating Party’s 25 permission. The Designating Party shall bear the burden and expense of seeking 26 protection in that court of its confidential material and nothing in these provisions 27 should be construed as authorizing or encouraging a Receiving Party in this Action 28 to disobey a lawful directive from another court. 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a)The terms of this Order are applicable to information produced by a 4 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, to 9 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 Non- 13 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 Stipulated 16 Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 specific description of the information requested; and 18 (3) make the information requested available for inspection by the 19 Non-Party, if requested. 20 (c)If the Non-Party fails to seek a protective order from this court within 21 14 days of receiving the notice and accompanying information, the Receiving Party 22 may produce the Non-Party’s confidential information responsive to the discovery 23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 not produce any information in its possession or control that is subject to the 25 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 27 expense 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 When a Producing Party gives notice to Receiving Parties that certain 12 inadvertently produced material is subject to a claim of privilege or other 13 protection, the obligations of the Receiving Parties are those set forth in Federal 14 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 15 whatever procedure may be established in an e-discovery order that provides for 16 production without prior privilege review. Pursuant to Federal Rule of Evidence 17 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 18 of a communication or information covered by the attorney-client privilege or work 19 product protection, the parties may incorporate their agreement in the stipulated 20 protective order submitted to the court. 21 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 28 this Stipulated Protective Order. Similarly, no Party waives any right to object on 1 any ground to use in evidence of any of the material covered by this Protective 2 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 5 may 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 8 in the public record unless otherwise instructed by the court. 9 13. FINAL DISPOSITION 10 Within 90 days after the final disposition of this Action, as defined in 11 paragraph 4, each Receiving Party must return all Protected Material to the Producing 12 Party or destroy such material. As used in this subdivision, “all Protected Material” 13 includes all copies, abstracts, compilations, summaries, and any other format 14 reproducing or capturing any of the Protected Material. Whether the Protected 15 Material is returned or destroyed, the Receiving Party must submit a written 16 certification to the Producing Party (and, if not the same person or entity, to the 17 Designating Party) by the 90 day deadline that (1) identifies (by category, where 18 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 19 that the Receiving Party has not retained any copies, abstracts, compilations, 20 summaries or any other format reproducing or capturing any of the Protected 21 Material. 22 // 23 // 24 // 25 // 26 // 27 // 28 // 1] 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 | including, without limitation, contempt proceedings and/or monetary sanctions. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD 6 | DATED: May 19, 2020 PERKINS COIE LLP 7 By:/s/ Julian Feldbein-Vinderman 8 Julie L. Hussey, Bar No. 237711 J Hussey C perkinscoie.com 9 Julian Feldbein-Vinderman, Bar No. 307838 10 JFeldbein Vinderman @ perkinscoie.com Attorneys for Defendant 11 Amazon.com, Inc. 12 | DATED: May 19, 2020 BAUMAN LOEWE WITT & MAXWELL, PLLC 13 14 By:/s/ Matthew E. Delinko 1s Matthew E. Delinko mdelinko @ blwmlawfirm.com 16 Christopher J. Brennan cbrennan@ blwmlawfirm.com M7 Attorneys for Plaintiff 18 Hartford Underwriters Insurance Company 19 20 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

22 Raped, a, □□ DATE: May 20, 2020 23 Honorable Rozella A. Oliver United States Magistrate Judge 25 26 27 28 -14- STIPULATED PROTECTIVE ORDEI CASE NQO 23-1O0_-cev_N7ARN AR(RAQOY

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 in the case of Hartford Underwriters Insurance Company v. Tera-Power Energy 8 Company, et al., Case No. 2:19-cv-07480-AB (RAO). I agree to comply with and to 9 be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. 18 I 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 21 or any proceedings related to enforcement of this Stipulated Protective Order. 22 23 Date: ________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 Signature: __________________________________ 28