1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10! kB HOME, etal. CASE NO.: 8:20-cv-00278-JLS-JDE Plaintiffs, STIPULATED AND PROPOSED 12 PROTECTIVE ORDER 3 VS. ILLINOIS UNION INSURANCE 14 | COMPANY, et al., 18 Defendants. 16 17 Per the Stipulation (Dkt. 24), the Court finds and orders as follows. 48 1. PURPOSES AND LIMITATIONS 49 Discovery in this action is likely to involve production of confidential, 20 proprietary or private information for which special protection from public 24 disclosure and from use for any purpose other than pursuing this litigation 22 may be warranted. Accordingly, the parties hereby stipulate to and petition 23 the Court to enter the following Stipulated Protective Order. The parties DA acknowledge that this Order does not confer blanket protections on all 25 disclosures or responses to discovery and that the protection it affords from 26 public disclosure and use extends only to the limited information or items 97 that are entitled to confidential treatment under the applicable legal 28 principles. STIPULATED PROTECTIVE ORDE|

1 2. GOOD CAUSE STATEMENT 2 This action is likely to involve valuable commercial, financial and/or 3 || proprietary information for which special protection from public disclosure 4 || and from use for any purpose other than prosecution of this action is 5 || warranted. Such confidential and proprietary materials and information 6 || consist of, among other things, confidential business or financial 7 | information, information regarding confidential business practices, or other 8 || confidential commercial information, information otherwise generally 9 || unavailable to the public, or which may be privileged or otherwise protected 10 || from disclosure under state or federal statutes, court rules, case decisions, 11 || or common law. For example, Plaintiffs will produce documents containing 12 || information regarding “hard costs” and “soft costs” incurred as a result of the 13 || 2017 rainstorm that is the subject of this action, excerpts from financial 14 || statements, documents containing operational information regarding certain 15 || residential homebuilding projects, and other proprietary and/or confidential 16 || information regarding Plaintiffs’ business practices. Similarly, Defendant will 17 || produce documents from the claim and underwriting files for Plaintiffs’ 18 || insurance policy that reveal costing analyses and other proprietary and/or 19 || confidential information regarding Defendant’s business practices. Plaintiffs 20 || and Defendant agree that public disclosure of such information could harm 21 || their businesses by portraying them unfavorably to potential customers and 22 || providing information that could benefit their competitors. Accordingly, to 23 || expedite the flow of information, to facilitate the prompt resolution of 24 || disputes over confidentiality of discovery materials, to adequately protect 25 || information the parties are entitled to keep confidential, to ensure that the 26 || parties are permitted reasonable necessary uses of such material in 27 || preparation for and in the conduct of trial, to address their handling at the 28 || end of the litigation, and serve the ends of justice, a protective order for -2- STIPULATED PROTECTIVE ORDEF

1 || such information is justified in this matter. It is the intent of the parties that 2 || information will not be designated as confidential for tactical reasons and 3 || that nothing be so designated without a good faith belief that it has been 4 || maintained in a confidential, non-public manner, and there is good cause 5 || why it should not be part of the public record of this case. 6 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 7 || PROCEDURE 8 The parties further acknowledge, as set forth in Section 14.3, below, 9 || that this Stipulated Protective Order does not entitle them to file confidential 10 || information under seal; Local Civil Rule 79-5 sets forth the procedures that 11 || must be followed and the standards that will be applied when a party seeks 12 || permission from the court to file material under seal. There is a strong 13 || presumption that the public has a right of access to judicial proceedings and 14 || records in civil cases. In connection with non-dispositive motions, good 15 || cause must be shown to support a filing under seal. See Kamakana v. City 16 || and County of Honolulu,

(9th Cir. 2006), Phillips v. 17 || Gen. Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon 18 || v. Sony Electrics, Inc.,

(E.D. Wis. 1999) (even 19 || stipulated protective orders require good cause showing), and a specific 20 || showing of good cause or compelling reasons with proper evidentiary 21 || support and legal justification, must be made with respect to Protected 22 || Material that a party seeks to file under seal. The parties’ mere designation 23 || of Disclosure or Discovery Material as CONFIDENTIAL does not— without 24 || the submission of competent evidence by declaration, establishing that the 25 || material sought to be filed under seal qualifies as confidential, privileged, or 26 || otherwise protectable—constitute good cause. 27 Further, if a party requests sealing related to a dispositive motion or 28 || trial, then compelling reasons, not only good cause, for the sealing must be -3- STIPULATED PROTECTIVE ORDEF

1 || shown, and the relief sought shall be narrowly tailored to serve the specific 2 || interest to be protected. See Pintos v. Pacific Creditors Ass’n.,

|| 665, 677-79 (9th Cir. 2010). For each item or type of information, document, 4 | or thing sought to be filed or introduced under seal, the party seeking 5 || protection must articulate compelling reasons, supported by specific facts 6 || and legal justification, for the requested sealing order. Again, competent 7 || evidence supporting the application to file documents under seal must be 8 || provided by declaration. 9 Any document that is not confidential, privileged, or otherwise 10 || protectable in its entirety will not be filed under seal if the confidential 11 || portions can be redacted. If documents can be redacted, then a redacted 12 || version for public viewing, omitting only the confidential, privileged, or 13 || otherwise protectable portions of the document, shall be filed. Any 14 || application that seeks to file documents under seal in their entirety should 15 || include an explanation of why redaction is not feasible. 16 4. DEFINITIONS 17 4.1. Action: KB Home, et al. v. Illinois Union Insurance Company, et 18 || al., U.S.D.C. Case No. 8:20-CV-0278-JLS-JDE. 19 4.2 Challenging Party: A Party or Non-Party that challenges the 20 || designation of information or items under this Order. 21 4.3. “CONFIDENTIAL” Information or Items: information (regardless 22 || of how it is generated, stored or maintained) or tangible things that qualify 23 || for protection under Federal Rule of Civil Procedure 26(c), and as specified 24 || above in the Good Cause Statement. 25 4.4 Counsel: Outside Counsel of Record and House Counsel (as 26 || well as their support staff). 27 4.5 Designating Party: a Party or Non-Party that designates 28 || information or items that it produces in disclosures or in responses to -4- STIPULATED PROTECTIVE ORDEF

1 || discovery as “CONFIDENTIAL.” 2 4.6 Disclosure or Discovery Material: All items or information, 3 || regardless of the medium or manner in which it is generated, stored, or 4 || maintained (including, among other things, testimony, transcripts, and 5 || tangible things), that are produced or generated in disclosures or responses 6 || to discovery. 7 4.7 Expert: A person with specialized knowledge or experience ina 8 || matter pertinent to the litigation who has been retained by a Party or its 9 || counsel to serve as an expert witness or as a consultant in this Action. 10 4.8 House Counsel: Attorneys who are employees of a party to this 11 |) Action. House Counsel does not include Outside Counsel of Record or any 12 || other outside counsel. 13 4.9 Non-Party: Any natural person, partnership, corporation, 14 || association or other legal entity not named as a Party to this action. 15 4.10 Outside Counsel of Record: Attorneys who are not employees of 16 || a party to this Action but are retained to represent a party to this Action and 17 || have appeared in this Action on behalf of that party or are affiliated with a 18 || law firm that has appeared on behalf of that party, and includes support 19 || staff. 20 4.11 Party: Any party to this Action, including all of its officers, 21 || directors, employees, consultants, retained experts, and Outside Counsel of 22 || Record (and their support staffs). 23 4.12 Producing Party: A Party or Non-Party that produces Disclosure 24 || or Discovery Material in this Action. 25 4.13 Professional Vendors: Persons or entities that provide litigation 26 || support services (e.g., photocopying, videotaping, translating, preparing 27 || exhibits or demonstrations, and organizing, storing, or retrieving data in any 28 || form or medium) and their employees and subcontractors. -5- STIPULATED PROTECTIVE ORDEF

1 4.14 Protected Material: Any Disclosure or Discovery Material that is 2 || designated as “CONFIDENTIAL.” 3 4.15 Receiving Party: A Party that receives Disclosure or Discovery 4 || Material from a Producing Party. 5 5. SCOPE 6 The protections conferred by this Stipulation and Order cover not only 7 || Protected Material (as defined above), but also (1) any information copied 8 || or extracted from Protected Material; (2) all copies, excerpts, summaries, or 9 || compilations of Protected Material; and (3) any testimony, conversations, or 10 || presentations by Parties or their Counsel that might reveal Protected 11 || Material. 12 Any use of Protected Material at trial shall be governed by the orders 13 || of the trial judge and other applicable authorities. This Order does not 14 || govern the use of Protected Material at trial. 15 6. DURATION 16 Once a case proceeds to trial, information that was designated as 17 || CONFIDENTIAL or maintained pursuant to this protective order used or 18 || introduced as an exhibit at trial becomes public and will be presumptively 19 || available to all members of the public, including the press, unless 20 || compelling reasons supported by specific factual findings to proceed 21 || otherwise are made to the trial judge in advance of the trial. See Kamakana, 22 ||

(distinguishing “good cause” showing for sealing 23 || documents produced in discovery from “compelling reasons” standard when 24 || merits-related documents are part of court record). Accordingly, the terms of 25 | this protective order do not extend beyond the commencement of the trial. 26 7. DESIGNATING PROTECTED MATERIAL 27 7.1 Exercise of Restraint and Care in Designating Material for 28 || Protection. Each Party or Non-Party that designates information or items -6- STIPULATED PROTECTIVE ORDEF

1 || for protection under this Order must take care to limit any such designation 2 || to specific material that qualifies under the appropriate standards. The 3 || Designating Party must designate for protection only those parts of material, 4 || documents, items or oral or written communications that qualify so that 5 || other portions of the material, documents, items or communications for 6 || which protection is not warranted are not swept unjustifiably within the ambit 7 || of this Order. 8 Mass, indiscriminate or routinized designations are prohibited. 9 || Designations that are shown to be clearly unjustified or that have been 10 || made for an improper purpose (e.g., to unnecessarily encumber the case 11 || development process or to impose unnecessary expenses and burdens on 12 || other parties) may expose the Designating Party to sanctions. 13 If it comes to a Designating Party’s attention that information or items 14 || that it designated for protection do not qualify for protection, that 15 || Designating Party must promptly notify all other Parties that it is withdrawing 16 || the inapplicable designation. 17 7.2 Manner and Timing of Designations. Except as otherwise 18 || provided in this Order, or as otherwise stipulated or ordered, Disclosure of 19 || Discovery Material that qualifies for protection under this Order must be 20 || clearly so designated before the material is disclosed or produced. 21 Designation in conformity with this Order requires: 22 (a) for information in documentary form (e.g., paper or electronic 23 || documents, but excluding transcripts of depositions or other pretrial or trial 24 || proceedings), that the Producing Party affix at a minimum, the legend 25 | “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 26 || contains protected material. If only a portion of the material on a page 27 || qualifies for protection, the Producing Party also must clearly identify the 28 || protected portion(s) (e.g., by making appropriate markings in the margins). -7- STIPULATED PROTECTIVE ORDEF

1 A Party or Non-Party that makes original documents available for 2 || inspection need not designate them for protection until after the inspecting 3 || Party has indicated which documents it would like copied and produced. 4 || During the inspection and before the designation, all of the material made 5 || available for inspection shall be deemed “CONFIDENTIAL.” After the 6 || inspecting Party has identified the documents it wants copied and 7 || produced, the Producing Party must determine which documents, or 8 || portions thereof, qualify for protection under this Order. Then, before 9 | producing the specified documents, the Producing Party must affix the 10 || “CONFIDENTIAL legend” to each page that contains Protected Material. If 11 || only a portion of the material on a page qualifies for protection, the 12 || Producing Party also must clearly identify the protected portion(s) (e.g., by 13 || 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 16 || close of the deposition all protected testimony. 17 (c) for information produced in some form other than 18 || documentary and for any other tangible items, that the Producing Party affix 19 || in a prominent place on the exterior of the container or containers in which 20 || the information is stored the legend “CONFIDENTIAL.” If only a portion or 21 || portions of the information warrants protection, the Producing Party, to the 22 || extent practicable, shall identify the protected portion(s). 23 7.3 Inadvertent Failures to Designate. If timely corrected, an 24 || inadvertent failure to designate qualified information or items does not, 25 || standing alone, waive the Designating Party’s right to secure protection 26 || under this Order for such material. Upon timely correction of a designation, 27 || the Receiving Party must make reasonable efforts to assure that the 28 || material is treated in accordance with the provisions of this Order. -8- STIPULATED PROTECTIVE ORDEF

1 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 8.1. 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 8.2 Meet Confer. The Challenging Party shall initiate the 6 || dispute resolution process under Local Rule 37-1 et seq. 7 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via 8 || a joint stipulation pursuant to Local Rule 37-2. 9 8.4 The burden of persuasion in any such challenge proceeding shall 10 || be on the Designating Party. Frivolous challenges, and those made for an 11 || improper purpose (e.g., to harass or impose unnecessary expenses and 12 || burdens on other parties) may expose the Challenging Party to sanctions. 13 || Unless the Designating Party has waived or withdrawn the confidentiality 14 || designation, all parties shall continue to afford the material in question the 15 || level of protection to which it is entitled under the Producing Party’s 16 || designation until the Court rules on the challenge. 17 9. ACCESS TO AND USE OF PROTECTED MATERIAL 18 9.1 Basic Principles. A Receiving Party may use Protected Material 19 || that is disclosed or produced by another Party or by a Non-Party in 20 || connection with this Action only for prosecuting, defending or attempting to 21 || settle this Action and or any reinsurance matter relating to the underlying claims 22 || which are the subject of this action. Such Protected Material may be disclosed 23 || only to the categories of persons and under the conditions described in this 24 || Order. When the Action has been terminated, a Receiving Party must 25 || comply with the provisions of section 15 below (FINAL DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving 27 || Party at a location and in a secure manner that ensures that access is 28 || limited to the persons authorized under this Order. -9- STIPULATED PROTECTIVE ORDEF

1 2 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 3 || otherwise ordered by the court or permitted in writing by the Designating 4 || Party, a Receiving Party may disclose any information or item designated 5 || “CONFIDENTIAL” only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this 7 || Action, as well as employees of said Outside Counsel of Record to whom it 8 || is reasonably necessary to disclose the information for this Action; 9 (b) the officers, directors, and employees (including House 10 || Counsel) of the Receiving Party to whom disclosure is reasonably 11 || necessary for this Action; 12 (c) Experts (as defined in this Order) of the Receiving Party to 13 || whom disclosure is reasonably necessary for this Action and who have 14 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (d) the court and its personnel; 16 (e) court reporters and their staff; 17 (f) professional jury or trial consultants, mock jurors, and 18 || Professional Vendors to whom disclosure is reasonably necessary for this 19 || Action and who have signed the “Acknowledgment and Agreement to Be 20 || Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the 22 || information or a custodian or other person who otherwise possessed or 23 || knew the information; 24 (h) during their depositions, witnesses, and attorneys for 25 || witnesses, in the Action to whom disclosure is reasonably necessary 26 || provided: (1) the deposing party requests that the witness sign the form 27 || attached as Exhibit A hereto; and (2) they will not be permitted to keep any 28 || confidential information unless they sign the “Acknowledgment and -10- STIPULATED PROTECTIVE ORDEF

1 || Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the 2 || Designating Party or ordered by the court. Pages of transcribed deposition 3 || testimony or exhibits to depositions that reveal Protected Material may be 4 || separately bound by the court reporter and may not be disclosed to anyone 5 || except as permitted under this Stipulated Protective Order; 6 (i) any mediators or settlement officers and their supporting 7 || personnel, mutually agreed upon by any of the parties engaged in 8 || settlement discussions; 9 (j) Any reinsurer, retrocessionaire, auditor, regulator or other entity or person 10 || to whom any party or its counsel is contractually or legally obligated to make such 11 || disclosure; and 12 (k) Any other person agreed to by the parties; 13 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 14 PRODUCED IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other 16 || litigation that compels disclosure of any information or items designated in 17 || this Action as “CONFIDENTIAL,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such 19 || notification shall include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena 21 || or order to issue in the other litigation that some or all of the material 22 || covered by the subpoena or order is subject to this Protective Order. Such 23 || notification shall include a copy of this Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought 25 || to be pursued by the Designating Party whose Protected Material may be 26 || affected. If the Designating Party timely seeks a protective order, the Party 27 || served with the subpoena or court order shall not produce any information 28 || designated in this action as “CONFIDENTIAL” before a determination by the -11- STIPULATED PROTECTIVE ORDEF

1 || court from which the subpoena or order issued, unless the Party has 2 || obtained the Designating Party’s permission. The Designating Party shall 3 || bear the burden and expense of seeking protection in that court of its 4 || confidential material and nothing in these provisions should be construed as 5 || authorizing or encouraging a Receiving Party in this Action to disobey a 6 || lawful directive from another court. 7 11. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 8 || PRODUCED IN THIS LITIGATION 9 (a) The terms of this Order are applicable to information 10 || produced by a Non-Party in this Action and designated as 11 | “CONFIDENTIAL.” Such information produced by Non-Parties in connection 12 || with this litigation is protected by the remedies and relief provided by this 13 || Order. Nothing in these provisions should be construed as prohibiting a 14 || Non-Party from seeking additional protections. 15 (b) In the event that a Party is required, by a valid discovery 16 || request, to produce a Non-Party’s confidential information in its possession, 17 || and the Party is subject to an agreement with the Non-Party not to produce 18 || the Non-Party’s confidential information, then the Party shall: 19 (1) promptly notify in writing the Requesting Party and the Non- 20 || Party that some or all of the information requested is subject toa 21 || confidentiality agreement with a Non-Party; 22 (2) promptly provide the Non-Party with a copy of the Stipulated 23 || Protective Order in this Action, the relevant discovery request(s), and a 24 || reasonably specific description of the information requested; and 25 (3) make the information requested available for inspection by 26 || the Non-Party, if requested. 27 (c) If the Non-Party fails to seek a protective order from this 28 || court within 14 days of receiving the notice and accompanying information, -12- STIPULATED PROTECTIVE ORDEF

1 || the Receiving Party may produce the Non-Party’s confidential information 2 || responsive to the discovery request. If the Non-Party timely seeks a 3 || protective order, the Receiving Party shall not produce any information in its 4 || possession or control that is subject to the confidentiality agreement with 5 || the Non-Party before a determination by the court. Absent a court order to 6 || the contrary, the Non-Party shall bear the burden and expense of seeking 7 || protection in this court of its Protected Material. 8 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 9 If a Receiving Party learns that, by inadvertence or otherwise, it has 10 || disclosed Protected Material to any person or in any circumstance not 11 || authorized under this Stipulated Protective Order, the Receiving Party must 12 || immediately (a) notify in writing the Designating Party of the unauthorized 13 || disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 14 || Protected Material, (c) inform the person or persons to whom unauthorized 15 || disclosures were made of all the terms of this Order, and (d) request such 16 || person or persons to execute the “Acknowledgment an Agreement to Be 17 || Bound” attached hereto as Exhibit A. 18 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 19 | OTHERWISE PROTECTED MATERIAL 20 || When a Producing Party gives notice to Receiving Parties that certain 21 || inadvertently produced material is subject to a claim of privilege or other 22 || protection, the obligations of the Receiving Parties are those set forth in 23 || Federal Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended 24 || to modify whatever procedure may be established in an e-discovery order 25 || that provides for production without prior privilege review. Pursuant to 26 || Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an 27 || agreement on the effect of disclosure of a communication or information 28 || covered by the attorney-client privilege or work product protection, the -13- STIPULATED PROTECTIVE ORDEF

1 || parties may incorporate their agreement in the stipulated protective order 2 || submitted to the court. 3 14. MISCELLANEOUS 4 14.1. Right to Further Relief. Nothing in this Order abridges the right 5 || of any person to seek its modification by the Court in the future. 6 14.2 Right to Assert Other Objections. By stipulating to the entry of 7 || this Protective Order, no Party waives any right it otherwise would have to 8 || object to disclosing or producing any information or item on any ground not 9 || addressed in this Stipulated Protective Order. Similarly, no Party waives any 10 || right to object on any ground to use in evidence of any of the material 11 || covered by this Protective Order. 12 14.3 Filing Protected Material. A Party that seeks to file under seal 13 || any Protected Material must comply with Local Civil Rule 79-5. Protected 14 || Material may only be filed under seal pursuant to a court order authorizing 15 || the sealing of the specific Protected Material. If a Party’s request to file 16 || Protected Material under seal is denied by the court, then the Receiving 17 || Party may file the information in the public record unless otherwise 18 || instructed by the court. 19 15. FINAL DISPOSITION 20 After the final disposition of this Action, as defined in paragraph 6, 21 || within 60 days of a written request by the Designating Party, each Receiving 22 || Party must return all Protected Material to the Producing Party or destroy 23 || such material. As used in this subdivision, “all Protected Material” includes 24 || all copies, abstracts, compilations, summaries, and any other format 25 || reproducing or capturing any of the Protected Material. Whether the 26 || Protected Material is returned or destroyed, the Receiving Party must 27 || submit a written certification to the Producing Party (and, if not the same 28 || person or entity, to the Designating Party) by the 60-day deadline that (1) -14- STIPULATED PROTECTIVE ORDEF

1 || identifies (by category, where appropriate) all the Protected Material that 2 || was returned or destroyed and (2) affirms that the Receiving Party has not 3 || retained any copies, abstracts, compilations, summaries or any other format 4 || reproducing or capturing any of the Protected Material. Notwithstanding this 5 || provision, Counsel are entitled to retain an archival copy of all pleadings, 6 || motion papers, trial, deposition, and hearing transcripts, legal memoranda, 7 || correspondence, deposition and trial exhibits, expert reports, attorney work 8 || product, and consultant and expert work product, even if such materials 9 || contain Protected Material. Any such archival copies that contain or 10 || constitute Protected Material remain subject to this Protective Order as set 11 || forth in Section 6 (DURATION). 12 16. VIOLATION 13 Any violation of this Order may be punished by appropriate measures 14 || including, without limitation, contempt proceedings and/or monetary 15 || sanctions. 16 47 || FOR GOOD CAUSE SHOWN (see Dkt. 24), IT IS SO ORDERED. 18 19 || DATED: October 29, 2020 20 ff 21 Liha fee AG 22 J D. EARLY ited States Magistrate Judge 23 24 25 26 27 28 -15- STIPULATED PROTECTIVE ORDEF

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 5 || perjury that | have read in its entirety and understand the Stipulated 6 || Protective Order that was issued by the United States District Court for the 7 || Central District of California on October 29, 2020 in the case of KB Home, g || etal. v. Illinois Union Insurance Company, et al., U.S.D.C. Case No. 8:20- g || cv-00278-JLS-JDE. | agree to comply with and to be bound by all the terms 10 || of this Stipulated Protective Order and | understand and acknowledge that 11 || failure to so comply could expose me to sanctions and punishment in the 42 || nature of contempt. | solemnly promise that | will not disclose in any manner 13 || any information or item that is subject to this Stipulated Protective Order to 14 || any person or entity except in strict compliance with the provisions of this 15 || Order. 16 | further agree to submit to the jurisdiction of the United States District 17 || Court for the Central District of California for the purpose of enforcing the 18 || terms of this Stipulated Protective Order, even if such enforcement 49 || proceedings occur after termination of this action. 20 || | hereby appoint [print or type full name] of 1 [print or type full address 22 || and telephone number] as my California agent for service of process in 23 || connection with this action or any proceedings related to enforcement of this 24 || Stipulated Protective Order. 25 Date: City and State where sworn and signed: 2000 - 16 - STIPULATED PROTECTIVE ORDEF

1 2 || Printedname: 3 4 | Signature: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -17- STIPULATED PROTECTIVE ORDEF