Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 1 of 14 Page ID #:243

1 V. James DeSimone (SBN: 119668) 2 [email protected] Ryann E. Hall (SBN: 306080) Of-Counsel 3 [email protected] 4 V. JAMES DESIMONE LAW 13160 Mindanao Way, Suite 280 5 Marina del Rey, California 90292 6 Telephone: 310.693.5561 Facsimile: 323.544.6880 7 Email: [email protected] 8 Attorneys for Plaintiff, 9 GUSTAVO FLORES 10 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 11

12 GUSTAVO FLORES Case No.: 2:21-cv-05387 CJC(GJSx)

13 Plaintiff, 14 STIPULATED PROTECTIVE ORDER1 v. 15 CITY OF LOS ANGELES, a municipal 16 entity; CHIEF MICHEL MOORE, in his 17 individual and official capacity; and 18 DOES 1 through 100, inclusive,

19 Defendants. 20

21

22

23 24 25

26 27 28 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Gail J. Standish’s Procedures. Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 2 of 14 Page ID #:244

1. A. PURPOSES AND LIMITATIONS 1 Discovery in this action is likely to involve production of confidential, 2 proprietary or private information for which special protection from public disclosure 3 and from use for any purpose other than prosecuting this litigation may be warranted. 4 Accordingly, the parties hereby stipulate to and petition the Court to enter the 5 following Stipulated Protective Order. The parties acknowledge that this Order does 6 not confer blanket protections on all disclosures or responses to discovery and that the 7 protection it affords from public disclosure and use extends only to the limited 8 information or items that are entitled to confidential treatment under the applicable 9 legal principles. 10 B. GOOD CAUSE STATEMENT 11 This action is likely to involve official information from law enforcement 12 records, relating to ongoing criminal and administrative investigations; and HIPPA 13 protected medical records, (including information implicating privacy rights of third parties), which is information otherwise generally unavailable to the public, or which 14 may be privileged or otherwise protected from disclosure under state or federal 15 statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow 16 of information, to facilitate the prompt resolution of disputes over confidentiality of 17 discovery materials, to adequately protect information the parties are entitled to keep 18 confidential, to ensure that the parties are permitted reasonable necessary uses of such 19 material in preparation for and in the conduct of trial, to address their handling at the 20 end of the litigation, and serve the ends of justice, a protective order for such 21 information is justified in this matter. It is the intent of the parties that information will 22 not be designated as confidential for tactical reasons and that nothing be so designated 23 without a good faith belief that it has been maintained in a confidential, non-public 24 manner, and there is good cause why it should not be part of the public record of this 25 case. 26 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 27 The parties further acknowledge, as set forth in Section 12.3, below, that this 28 Stipulated Protective Order does not entitle them to file confidential information under 2 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 3 of 14 Page ID #:245

seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 1 standards that will be applied when a party seeks permission from the court to file 2 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, Inc., 8

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

(9th Cir. 2010). For each item 19 or type of information, document, or thing sought to be filed or introduced under seal 20 in connection with a dispositive motion or trial, the party seeking protection must 21 articulate compelling reasons, supported by specific facts and legal justification, for the 22 requested sealing order. Again, competent evidence supporting the application to file 23 documents under seal must be provided by declaration. 24 Any document that is not confidential, privileged, or otherwise protectable in its 25 entirety will not be filed under seal if the confidential portions can be redacted. If 26 documents can be redacted, then a redacted version for public viewing, omitting only 27 the confidential, privileged, or otherwise protectable portions of the document, shall be 28 filed. Any application that seeks to file documents under seal in their entirety should 3 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 4 of 14 Page ID #:246

include an explanation of why redaction is not feasible. 1 2. DEFINITIONS 2 2.1 Action: this pending federal lawsuit 3 2.2 Challenging Party: a Party or Non-Party that challenges the designation 4 of information or items under this Order. 5 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 6 how it is generated, stored or maintained) or tangible things that qualify for protection 7 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 8 Statement. 9 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 10 support staff). 11 2.5 Designating Party: a Party or Non-Party that designates information or 12 items that it produces in disclosures or in responses to discovery as 13 “CONFIDENTIAL.” 2.6 Disclosure or Discovery Material: all items or information, regardless of 14 the medium or manner in which it is generated, stored, or maintained (including, 15 among other things, testimony, transcripts, and tangible things), that are produced or 16 generated in disclosures or responses to discovery in this matter. 17 2.7 Expert: a person with specialized knowledge or experience in a matter 18 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 19 expert witness or as a consultant in this Action. 20 2.8 House Counsel: attorneys who are employees of a party to this Action. 21 House Counsel does not include Outside Counsel of Record or any other outside 22 counsel. 23 2.9 Non-Party: any natural person, partnership, corporation, association or 24 other legal entity not named as a Party to this action. 25 2.10 Outside Counsel of Record: attorneys who are not employees of a party 26 to this Action but are retained to represent or advise a party to this Action and have 27 appeared in this Action on behalf of that party or are affiliated with a law firm that has 28 appeared on behalf of that party, and includes support staff. 4 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 5 of 14 Page ID #:247

2.11 Party: any party to this Action, including all of its officers, directors, 1 employees, consultants, retained experts, and Outside Counsel of Record (and their 2 support staffs). 3 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 4 Discovery Material in this Action. 5 2.13 Professional Vendors: persons or entities that provide litigation support 6 services (e.g., photocopying, videotaping, translating, preparing exhibits or 7 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 8 their employees and subcontractors. 9 2.14 Protected Material: any Disclosure or Discovery Material that is 10 designated as “CONFIDENTIAL.” 11 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 12 from a Producing Party. 13 3. SCOPE The protections conferred by this Stipulation and Order cover not only Protected 14 Material (as defined above), but also (1) any information copied or extracted from 15 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 16 Material; and (3) any testimony, conversations, or presentations by Parties or their 17 Counsel that might reveal Protected Material. 18 Any use of Protected Material at trial shall be governed by the orders of the trial 19 judge. This Order does not govern the use of Protected Material at trial. 20 4. DURATION 21 FINAL DISPOSITION of the action is defined as the conclusion of any 22 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 23 has run. Except as set forth below, the terms of this protective order apply through 24 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 25 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, but 26 will have to file a separate action for enforcement of the agreement once all 27 proceedings in this case are complete. 28 /// 5 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 6 of 14 Page ID #:248

Once a case proceeds to trial, information that was designated as 1 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 2 an exhibit at trial becomes public and will be presumptively available to all members 3 of the public, including the press, unless compelling reasons supported by specific 4 factual findings to proceed otherwise are made to the trial judge in advance of the trial. 5 See Kamakana,

(distinguishing “good cause” showing for sealing 6 documents produced in discovery from “compelling reasons” standard when merits- 7 related documents are part of court record). Accordingly, for such materials, the terms 8 of this protective order do not extend beyond the commencement of the trial. 9 5. DESIGNATING PROTECTED MATERIAL 10 5.1 Exercise of Restraint and Care in Designating Material for Protection. 11 Each Party or Non-Party that designates information or items for protection under this 12 Order must take care to limit any such designation to specific material that qualifies 13 under the appropriate standards. The Designating Party must designate for protection only those parts of material, documents, items or oral or written communications that 14 qualify so that other portions of the material, documents, items or communications for 15 which protection is not warranted are not swept unjustifiably within the ambit of this 16 Order. 17 Mass, indiscriminate or routinized designations are prohibited. Designations 18 that are shown to be clearly unjustified or that have been made for an improper purpose 19 (e.g., to unnecessarily encumber the case development process or to impose 20 unnecessary expenses and burdens on other parties) may expose the Designating Party 21 to sanctions. 22 If it comes to a Designating Party’s attention that information or items that it 23 designated for protection do not qualify for protection, that Designating Party must 24 promptly notify all other Parties that it is withdrawing the inapplicable designation. 25 5.2 Manner and Timing of Designations. Except as otherwise provided in this 26 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 27 or ordered, Disclosure or Discovery Material that qualifies for protection under this 28 Order must be clearly so designated before the material is disclosed or produced. 6 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 7 of 14 Page ID #:249

Designation in conformity with this Order requires: 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains protected material. If only a portion of the material on a page qualifies for 6 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 7 by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and before 11 the designation, all of the material made available for inspection shall be deemed 12 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 13 copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under this Order. Then, before producing the 14 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 15 each page that contains Protected Material. If only a portion of the material on a page 16 qualifies for protection, the Producing Party also must clearly identify the protected 17 portion(s) (e.g., by making appropriate markings in the margins). 18 (b) for testimony given in depositions that the Designating Party identifies 19 the Disclosure or Discovery Material on the record, before the close of the deposition 20 all protected testimony. 21 (c) for information produced in some form other than documentary and for 22 any other tangible items, that the Producing Party affix in a prominent place on the 23 exterior of the container or containers in which the information is stored the legend 24 “CONFIDENTIAL.” If only a portion or portions of the information warrants 25 protection, the Producing Party, to the extent practicable, shall identify the protected 26 portion(s). 27 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 28 failure to designate qualified information or items does not, standing alone, waive the 7 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 8 of 14 Page ID #:250

Designating Party’s right to secure protection under this Order for such material. Upon 1 timely correction of a designation, the Receiving Party must make reasonable efforts to 2 assure that the material is treated in accordance with the provisions of this Order. 3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time that is consistent with the Court’s Scheduling 6 Order. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 resolution process under Local Rule 37.1 et seq. 9 6.3 The burden of persuasion in any such challenge proceeding shall be on the 10 Designating Party. Frivolous challenges, and those made for an improper purpose 11 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 12 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 13 withdrawn the confidentiality designation, all parties shall continue to afford the material in question the level of protection to which it is entitled under the Producing 14 Party’s designation until the Court rules on the challenge. 15 7. ACCESS TO AND USE OF PROTECTED MATERIAL 16 7.1 Basic Principles. A Receiving Party may use Protected Material that is 17 disclosed or produced by another Party or by a Non-Party in connection with this 18 Action only for prosecuting, defending or attempting to settle this Action. Such 19 Protected Material may be disclosed only to the categories of persons and under the 20 conditions described in this Order. When the Action has been terminated, a Receiving 21 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 22 Protected Material must be stored and maintained by a Receiving Party at a 23 location and in a secure manner that ensures that access is limited to the persons 24 authorized under this Order. 25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 26 otherwise ordered by the court or permitted in writing by the Designating Party, a 27 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 28 only to: 8 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 9 of 14 Page ID #:251

(a) the Receiving Party’s Outside Counsel of Record in this Action, as well 1 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 2 disclose the information for this Action; 3 (b) the officers, directors, and employees (including House Counsel) of the 4 Receiving Party to whom disclosure is reasonably necessary for this Action; 5 (c) Experts (as defined in this Order) of the Receiving Party to whom 6 disclosure is reasonably necessary for this Action and who have signed the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) the court and its personnel; 9 (e) court reporters and their staff; 10 (f) professional jury or trial consultants, mock jurors, and Professional 11 Vendors to whom disclosure is reasonably necessary for this Action and who have 12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 14 (h) during their depositions or at trial, witnesses, and attorneys for witnesses, 15 in the Action to whom disclosure is reasonably necessary provided they will not be 16 permitted to keep any confidential information unless they sign the “Acknowledgment 17 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 18 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to 19 depositions that reveal Protected Material may be separately bound by the court 20 reporter and may not be disclosed to anyone except as permitted under this Stipulated 21 Protective Order; and 22 (i) any mediator or settlement officer, and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 25 OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation that 27 compels disclosure of any information or items designated in this Action as 28 “CONFIDENTIAL,” that Party must: 9 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 10 of 14 Page ID #:252

(a) promptly notify in writing the Designating Party. Such notification shall 1 include a copy of the subpoena or court order; 2 (b) promptly notify in writing the party who caused the subpoena or order to 3 issue in the other litigation that some or all of the material covered by the subpoena or 4 order is subject to this Protective Order. Such notification shall include a copy of this 5 Stipulated Protective Order; and 6 (c) cooperate with respect to all reasonable procedures sought to be pursued 7 by the Designating Party whose Protected Material may be affected. 8 If the Designating Party timely seeks a protective order, the Party served with 9 the subpoena or court order shall not produce any information designated in this action 10 as “CONFIDENTIAL” before a determination by the court from which the subpoena 11 or order issued, unless the Party has obtained the Designating Party’s permission. The 12 Designating Party shall bear the burden and expense of seeking protection in that court 13 of its confidential material and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 14 directive from another court. 15 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 16 IN THIS LITIGATION 17 (a) The terms of this Order are applicable to information produced by a Non- 18 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 19 by Non-Parties in connection with this litigation is protected by the remedies and relief 20 provided by this Order. Nothing in these provisions should be construed as prohibiting 21 a Non-Party from seeking additional protections. 22 (b) In the event that a Party is required, by a valid discovery request, to 23 produce a Non-Party’s confidential information in its possession, and the Party is 24 subject to an agreement with the Non-Party not to produce the Non-Party’s 25 confidential information, then the Party shall: 26 (1) promptly notify in writing the Requesting Party and the Non-Party 27 that some or all of the information requested is subject to a confidentiality agreement 28 with a Non-Party; 10 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 11 of 14 Page ID #:253

(2) promptly provide the Non-Party with a copy of the Stipulated 1 Protective Order in this Action, the relevant discovery request(s), and a reasonably 2 specific description of the information requested; and 3 (3) make the information requested available for inspection by the Non- 4 Party, if requested. 5 (c) If the Non-Party fails to seek a protective order from this court within 14 6 days of receiving the notice and accompanying information, the Receiving Party may 7 produce the Non-Party’s confidential information responsive to the discovery request. 8 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 9 any information in its possession or control that is subject to the confidentiality 10 agreement with the Non-Party before a determination by the court. Absent a court 11 order to the contrary, the Non-Party shall bear the burden and expense of seeking 12 protection in this court of its Protected Material. 13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 16 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 17 all unauthorized copies of the Protected Material, (c) inform the person or persons to 18 whom unauthorized disclosures were made of all the terms of this Order, and (d) 19 request such person or persons to execute the “Acknowledgment and Agreement to Be 20 Bound” that is attached hereto as Exhibit A. 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 22 PROTECTED MATERIAL 23 When a Producing Party gives notice to Receiving Parties that certain 24 inadvertently produced material is subject to a claim of privilege or other protection, 25 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 26 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 27 may be established in an e-discovery order that provides for production without prior 28 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 11 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 12 of 14 Page ID #:254

parties reach an agreement on the effect of disclosure of a communication or 1 information covered by the attorney-client privilege or work product protection, the 2 parties may incorporate their agreement in the stipulated protective order submitted to 3 the court. 4 12. MISCELLANEOUS 5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 6 person to seek its modification by the Court in the future. 7 12.2 Right to Assert Other Objections. By stipulating to the entry of this 8 Protective Order, no Party waives any right it otherwise would have to object to 9 disclosing or producing any information or item on any ground not addressed in this 10 Stipulated Protective Order. Similarly, no Party waives any right to object on any 11 ground to use in evidence of any of the material covered by this Protective Order. 12 12.3 Filing Protected Material. A Party that seeks to file under seal any 13 Protected Material must comply with Local Civil Rule 79-5. Protected Material may only be filed under seal pursuant to a court order authorizing the sealing of the specific 14 Protected Material at issue. If a Party’s request to file Protected Material under seal is 15 denied by the court, then the Receiving Party may file the information in the public 16 record unless otherwise instructed by the court. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 4, within 60 19 days of a written request by the Designating Party, each Receiving Party must return 20 all Protected Material to the Producing Party or destroy such material. As used in this 21 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected 23 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 24 must submit a written certification to the Producing Party (and, if not the same person 25 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 26 category, where appropriate) all the Protected Material that was returned or destroyed 27 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 28 compilations, summaries or any other format reproducing or capturing any of the 12 Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 130f14 Page ID #:255

Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, ° attorney work product, and consultant and expert work product, even if such materials ‘ contain Protected Material. Any such archival copies that contain or constitute ° Protected Material remain subject to this Protective Order as set forth in Section 4 6 || (DURATION). 7 14. VIOLATION 8 || Any violation of this Order may be punished by appropriate measures including, 9 || without limitation, contempt proceedings and/or monetary sanctions. 10 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 11 12 DATED: May 26, 2022 13 14 || 44 V. James DeSimone 15 || Attorneys for Plaintiff 16 17_|| DATED: May 26, 2022 18 19 /s/: Farid Sharaby 50 Attorneys for Defendant

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

ll DATED: June 15, 2022 24 25 26 Hp J. STANDISH 27 || United States Magistrate District Judge 28 13

Case 2:21-cv-05387-CJC-GJS Document 44 Filed 06/15/22 Page 14 of 14 Page ID #:256

EXHIBIT A 1 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

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 [date] in the case of ___________ [insert formal name of the case and the 8 number and initials assigned to it by the court]. I agree to comply with and to be 9 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 for the 15 Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. I 17 hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24

25 Printed name: _______________________________ 26

27 Signature: __________________________________ 28 14