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6 7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9 10 Jane Doe 2, et al., Plaintiffs, Case No. 5:21-cv-00771-DMG-RAO

11 v. STIPULATED PROTECTIVE 12 ORDER1 Officer S. Merrill, et al., Defendants. 13

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15 16 1. A. PURPOSES AND LIMITATIONS 17 Discovery in this action is likely to involve production of confidential, 18 proprietary or private information for which special protection from public 19 disclosure and from use for any purpose other than prosecuting this litigation may 20 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 21 enter the following Stipulated Protective Order. The parties acknowledge that this 22 Order does not confer blanket protections on all disclosures or responses to 23 discovery and that the protection it affords from public disclosure and use extends 24 only to the limited information or items that are entitled to confidential treatment 25 under the applicable legal principles. 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Rozella A. Oliver’s Procedures. It has been 1 B. GOOD CAUSE STATEMENT 2 This action is likely to involve materials which concerns or relates to the 3 processes, operations or work of the California Department of Corrections and 4 Rehabilitation and its employees and agents (collectively “CDCR”), the disclosure 5 of which may have the effect of causing harm or endangering the safety of CDCR 6 staff, inmates, or third persons. Additionally, Plaintiffs are currently in CDCR 7 custody, and providing them access to certain sensitive information creates safety 8 and security concerns. Such confidential materials and information consist of, 9 among other things, information about confidential informants, prison procedures 10 for investigating staff accused of misconduct, prison procedures for investigating 11 inmates accused of misconduct, and other information that is only available to staff 12 on a need-to-know basis, not provided to inmates, and which may be privileged or 13 otherwise protected from disclosure under state or federal statutes, court rules, case 14 decisions, or common law. Accordingly, to expedite the flow of information, to 15 facilitate the prompt resolution of disputes over confidentiality of discovery 16 materials, to adequately protect information the parties are entitled to keep 17 confidential, to ensure that the parties are permitted reasonable necessary uses of 18 such material in preparation for and in the conduct of trial, to address their handling 19 at the end of the litigation, and serve the ends of justice, a protective order for such 20 information is justified in this matter. It is the intent of the parties that information 21 will not be designated as Confidential or Attorneys’ Eyes Only for tactical reasons 22 and that nothing be so designated without a good faith belief that it has been 23 maintained in a confidential, non-public manner, and there is good cause why it 24 should not be part of the public record of this case. 25 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 26 The parties further acknowledge, as set forth in Section 12.3, below, that this 27 Stipulated Protective Order does not entitle them to file confidential information 1 and the standards that will be applied when a party seeks permission from the court 2 to file material under seal. 3 There is a strong presumption that the public has a right of access to judicial 4 proceedings and records in civil cases. In connection with non-dispositive motions, 5 good cause must be shown to support a filing under seal. See Kamakana v. City and 6 County of Honolulu,

(9th Cir. 2006); Phillips v. Gen. Motors 7 Corp.,

, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 8 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 9 require good cause showing), and a specific showing of good cause or compelling 10 reasons with proper evidentiary support and legal justification, must be made with 11 respect to Protected Material that a party seeks to file under seal. The parties’ mere 12 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 13 without the submission of competent evidence by declaration, establishing that the 14 material sought to be filed under seal qualifies as confidential, privileged, or 15 otherwise protectable—constitute good cause. 16 Further, if a party requests sealing related to a dispositive motion or trial, then 17 compelling reasons, not only good cause, for the sealing must be shown, and the 18 relief sought shall be narrowly tailored to serve the specific interest to be protected. 19 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For 20 each item or type of information, document, or thing sought to be filed or introduced 21 under seal in connection with a dispositive motion or trial, the party seeking 22 protection must articulate compelling reasons, supported by specific facts and legal 23 justification, for the requested sealing order. Again, competent evidence supporting 24 the application to file documents under seal must be provided by declaration. 25 Any document that is not confidential, privileged, or otherwise protectable in 26 its entirety will not be filed under seal if the confidential portions can be redacted. 27 If documents can be redacted, then a redacted version for public viewing, omitting 1 shall be filed. Any application that seeks to file documents under seal in their 2 entirety should include an explanation of why redaction is not feasible. 3 2. DEFINITIONS 4 2.1 Action: this pending federal lawsuit. 5 2.2 Challenging Party: a Party or Non-Party that challenges the 6 designation of information or items under this Order. 7 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 8 how it is generated, stored or maintained) or tangible things that qualify for 9 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 10 the Good Cause Statement. 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 12 their support staff). 13 2.5 Designating Party: a Party or Non-Party that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 2.6 Disclosure or Discovery Material: all items or information, regardless 17 of the medium or manner in which it is generated, stored, or maintained (including, 18 among other things, testimony, transcripts, and tangible things) that are produced or 19 generated in disclosures or responses to discovery in this matter. 20 2.7 Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel to serve as 22 an expert witness or as a consultant in this Action. 23 2.8 House Counsel: attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 2.9 Non-Party: any natural person, partnership, corporation, association or 27 other legal entity not named as a Party to this action. 1 party to this Action but are retained to represent or advise a party to this Action and 2 have appeared in this Action on behalf of that party or are affiliated with a law firm 3 that has appeared on behalf of that party, and includes support staff. 4 2.11 Party: any party to this Action, including all of its officers, directors, 5 employees, consultants, retained experts, and Outside Counsel of Record (and their 6 support staffs). 7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 8 Discovery Material in this Action. 9 2.13 Professional Vendors: persons or entities that provide litigation 10 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 11 demonstrations, and organizing, storing, or retrieving data in any form or medium) 12 and their employees and subcontractors. 13 2.14 Protected Material: any Disclosure or Discovery Material that is 14 designated as “CONFIDENTIAL.” 15 2.15 Receiving Party: a Party that receives Disclosure or Discovery 16 Material from a Producing Party. 17 2.16 CONFIDENTIAL ATTORNEYS’ EYES ONLY: information 18 (regardless of how it is generated, stored or maintained) or tangible things that 19 qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified 20 above in the Good Cause Statement. Additionally, the information concerns 21 CDCR’s internal affairs, investigatory tactics, and third parties which is not 22 provided to inmates for safety and security reasons. Thus, information designated 23 Attorneys’ Eyes Only, shall only be disclosed as delineated in paragraph 7.2. 24 3. SCOPE 25 The protections conferred by this Stipulation and Order cover not only 26 Protected Material (as defined above), but also (1) any information copied or 27 extracted from Protected Material; (2) all copies, excerpts, summaries, or 1 compilations of Protected Material; and (3) any testimony, conversations, or 2 presentations by Parties or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the 4 trial judge. This Order does not govern the use of Protected Material at trial. 5 4. DURATION 6 Once a case proceeds to trial, information that was designated as 7 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 8 as an exhibit at trial becomes public and will be presumptively available to all 9 members of the public, including the press, unless compelling reasons supported by 10 specific factual findings to proceed otherwise are made to the trial judge in advance 11 of the trial. See Kamakana,

(distinguishing “good cause” 12 showing for sealing documents produced in discovery from “compelling reasons” 13 standard when merits-related documents are part of court record). Accordingly, the 14 terms of this protective order do not extend beyond the commencement of the trial. 15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for Protection. 17 Each Party or Non-Party that designates information or items for protection under 18 this Order must take care to limit any such designation to specific material that 19 qualifies under the appropriate standards. The Designating Party must designate for 20 protection only those parts of material, documents, items or oral or written 21 communications that qualify so that other portions of the material, documents, items 22 or communications for which protection is not warranted are not swept unjustifiably 23 within the ambit of this Order. 24 Mass, indiscriminate or routinized designations are prohibited. Designations 25 that are shown to be clearly unjustified or that have been made for an improper 26 purpose (e.g., to unnecessarily encumber the case development process or to impose 27 unnecessary expenses and burdens on other parties) may expose the Designating 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 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 under this Order must be clearly so designated before the material is disclosed or 8 produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party affix at a minimum, the legend 13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), or 14 “CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (hereinafter “ATTORNEYS’ 15 EYES only legend), to each page that contains protected material. If only a portion 16 of the material on a page qualifies for protection, the Producing Party also must 17 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 18 margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection shall be 23 deemed “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” After the 24 inspecting Party has identified the documents it wants copied and produced, the 25 Producing Party must determine which documents, or portions thereof, qualify for 26 protection under this Order. Then, before producing the specified documents, the 27 Producing Party must affix the “CONFIDENTIAL legend” or “ATTORNEYS’ 1 portion of the material on a page qualifies for protection, the Producing Party also 2 must clearly identify the protected portion(s) (e.g., by making appropriate markings 3 in the margins). 4 (b) for testimony given in depositions that the Designating Party identifies 5 the Disclosure or Discovery Material on the record, before the close of the 6 deposition all 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” or “ATTORNEYS’ EYES ONLY.” If only a portion or 11 portions of the information warrants protection, the Producing Party, to the extent 12 practicable, shall identify the protected portion(s). 13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 14 failure to designate qualified information or items does not, standing alone, waive 15 the Designating Party’s right to secure protection under this Order for such material. 16 Upon timely correction of a designation, the Receiving Party must make reasonable 17 efforts to assure that the material is treated in accordance with the provisions of this 18 Order. 19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 21 designation of confidentiality at any time that is consistent with the Court’s 22 Scheduling Order. 23 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 24 resolution process under Local Rule 37.1 et seq. 25 6.3 The burden of persuasion in any such challenge proceeding shall be on 26 the Designating Party. Frivolous challenges, and those made for an improper 27 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 1 Party has waived or withdrawn the confidentiality designation, all parties shall 2 continue to afford the material in question the level of protection to which it is 3 entitled under the Producing Party’s designation until the Court rules on the 4 challenge. 5 7. ACCESS TO AND USE OF PROTECTED MATERIAL 6 7.1 Basic Principles. A Receiving Party may use Protected Material that is 7 disclosed or produced by another Party or by a Non-Party in connection with this 8 Action only for prosecuting, defending or attempting to settle this Action. Such 9 Protected Material may be disclosed only to the categories of persons and under the 10 conditions described in this Order. When the Action has been terminated, a 11 Receiving Party must comply with the provisions of section 13 below (FINAL 12 DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at a 14 location and in a secure manner that ensures that access is limited to the persons 15 authorized under this Order. 16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 17 otherwise ordered by the court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated 19 “CONFIDENTIAL” only to: 20 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 21 well as employees of said Outside Counsel of Record to whom it is reasonably 22 necessary to disclose the information for this Action; 23 (b) the officers, directors, and employees (including House Counsel) of 24 the Receiving Party to whom disclosure is reasonably necessary for this Action; 25 (c) Experts (as defined in this Order) of the Receiving Party to whom 26 disclosure is reasonably necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1 (e) court reporters and their staff; 2 (f) professional jury or trial consultants, mock jurors, and Professional 3 Vendors to whom disclosure is reasonably necessary for this Action and who have 4 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 5 (g) the author or recipient of a document containing the information or a 6 custodian or other person who otherwise possessed or knew the information; 7 (h) during their depositions, witnesses, and attorneys for witnesses, in the 8 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 9 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 10 will not be permitted to keep any confidential information unless they sign the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 12 agreed by the Designating Party or ordered by the court. Pages of transcribed 13 deposition testimony or exhibits to depositions that reveal Protected Material may 14 be separately bound by the court reporter and may not be disclosed to anyone except 15 as permitted under this Stipulated Protective Order; and 16 (i) any mediator or settlement officer, and their supporting personnel, 17 mutually agreed upon by any of the parties engaged in settlement discussions. 18 7.2 Disclosure of “CONFIDENTIAL – ATTORNEYS’-EYES ONLY” 19 Information or Items. Attorneys’ Eyes Only Material, and the information 20 contained therein, shall be disclosed to the qualified persons listed in subparagraphs 21 7.1(a) through (i) above, but shall not be disclosed to a party, including Plaintiffs 22 who are currently incarcerated, or any other inmate or third person, unless 23 previously agreed or ordered. If disclosure of Attorneys’ Eyes Only Material is 24 made pursuant to this paragraph, all other provisions in this Order with respect to 25 confidentiality shall apply, including but not limited to, signing and serving a non- 26 disclosure agreement in the form of Exhibit A. 27 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 1 If a Party is served with a subpoena or a court order issued in other litigation 2 that compels disclosure of any information or items designated in this Action as 3 “CONFIDENTIAL,” or “ATTORNEYS’ EYES ONLY” that Party must: 4 (a) promptly notify in writing the Designating Party. Such notification 5 shall include a copy of the subpoena or court order; 6 (b) promptly notify in writing the party who caused the subpoena or order 7 to issue in the other litigation that some or all of the material covered by the 8 subpoena or order is subject to this Protective Order. Such notification shall include 9 a copy of this Stipulated Protective Order; and 10 (c) cooperate with respect to all reasonable procedures sought to be 11 pursued by the Designating Party whose Protected Material may be affected. 12 If the Designating Party timely seeks a protective order, the Party served with 13 the subpoena or court order shall not produce any information designated in this 14 action as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” before a 15 determination by the court from which the subpoena or order issued, unless the 16 Party has obtained the Designating Party’s permission. The Designating Party shall 17 bear the burden and expense of seeking protection in that court of its confidential 18 material and nothing in these provisions should be construed as authorizing or 19 encouraging a Receiving Party in this Action to disobey a lawful directive from 20 another court. 21 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 22 PRODUCED IN THIS LITIGATION 23 (a) The terms of this Order are applicable to information produced by a 24 Non-Party in this Action and designated as “CONFIDENTIAL” or “ATTORNEYS’ 25 EYES ONLY.” Such information produced by Non-Parties in connection with this 26 litigation is protected by the remedies and relief provided by this Order. Nothing in 27 these provisions should be construed as prohibiting a Non-Party from seeking 1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is 3 subject to an agreement with the Non-Party not to produce the Non-Party’s 4 confidential information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non-Party 6 that some or all of the information requested is subject to a confidentiality 7 agreement with a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery request(s), and a reasonably 10 specific description of the information requested; and 11 (3) make the information requested available for inspection by the 12 Non-Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this court within 14 14 days of receiving the notice and accompanying information, the Receiving Party 15 may produce the Non-Party’s confidential information responsive to the discovery 16 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 17 not produce any information in its possession or control that is subject to the 18 confidentiality agreement with the Non-Party before a determination by the court. 19 Absent a court order to the contrary, the Non-Party shall bear the burden and 20 expense of seeking protection in this court of its Protected Material. 21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 25 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 26 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 27 persons to whom unauthorized disclosures were made of all the terms of this Order, 1 Agreement to Be Bound” that is attached hereto as Exhibit A. 2 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 3 PROTECTED MATERIAL 4 When a Producing Party gives notice to Receiving Parties that certain 5 inadvertently produced material is subject to a claim of privilege or other protection, 6 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 7 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 8 procedure may be established in an e-discovery order that provides for production 9 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 10 (e), insofar as the parties reach an agreement on the effect of disclosure of a 11 communication or information covered by the attorney-client privilege or work 12 product protection, the parties may incorporate their agreement in the stipulated 13 protective order submitted to the court. 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order, no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Local Civil Rule 79-5. Protected Material 24 may only be filed under seal pursuant to a court order authorizing the sealing of the 25 specific Protected Material at issue. If a Party’s request to file Protected Material 26 under seal is denied by the court, then the Receiving Party may file the information 27 in the public record unless otherwise instructed by the court. 1 After the final disposition of this Action, as defined in paragraph 4, within 60 2 days of a written request by the Designating Party, each Receiving Party must return 3 all Protected Material to the Producing Party or destroy such material. As used in 4 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 5 summaries, and any other format reproducing or capturing any of the Protected 6 Material. Whether the Protected Material is returned or destroyed, the Receiving 7 Party must submit a written certification to the Producing Party (and, if not the same 8 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 9 (by category, where appropriate) all the Protected Material that was returned or 10 destroyed and (2) affirms that the Receiving Party has not retained any copies, 11 abstracts, compilations, summaries or any other format reproducing or capturing any 12 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 13 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 14 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 15 reports, attorney work product, and consultant and expert work product, even if such 16 materials contain Protected Material. Any such archival copies that contain or 17 constitute Protected Material remain subject to this Protective Order as set forth in 18 Section 4 (DURATION). 19 // 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 1 || 14. VIOLATION 2 || Any violation of this Order may be punished by appropriate measures including, 3 || without limitation, contempt proceedings and/or monetary sanctions. 4 5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 || Dated: October 7, 2021 ROB BONTA Attorney General of California 8 WILLIAM C. KWONG Supervising Deputy Attorney General 9 10 /s/ Lyndsay Crenshaw 11 12 13 LYNDSAY CRENSHAW Deputy Attorney General 14 Attorneys for Defendant J. Spinney 15 16 17 || Dated: October 7, 2021 /s/ Edward Lyman 18 Brian Dunn Edward Lyman □ 19 The Cochran Firm - California Attorney for Plaintiffs Jane Doe 2 and 20 Jane Doe 3 21 22 53 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 || DATED: October 18, 2021 S| Repel a, QC 26 || HON. ROZELLA A. OLIVER United States Magistrate Judge 28

1 SIGNATURE CERTIFICATION 2 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I hereby certify that the content of this 3 document is acceptable to all persons required to sign the document 4 and have obtained authorization for the electronic signatures of all parties on the 5 document. 6 Dated: October 7, 2021 Respectfully submitted,

7 ROB BONTA Attorney General of California 8 WILLIAM C. KWONG Supervising Deputy Attorney General 9 10 /s/ Lyndsay Crenshaw 11

12 LYNDSAY CRENSHAW Deputy Attorney General Attorneys for Defendant 13 J. Spinney

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20 21 22 23 24 25 26 27 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of Jane Doe 2 et al., v. Merrill et al., Case No. 5:21-cv-00771- 9 DMG-RAO. I agree to comply with and to be bound by all the terms of this 10 Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that 13 is subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Central District of California for enforcing the terms of this Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint __________________________ [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 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27