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7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 SEMPRA Case No. 2:23-cv-10544-JLS-SSC 12 Plaintiff, Judge Josephine L. Staton 13 v. Magistrate Judge Stephanie S. Christensen 14 ASSOCIATED ELECTRIC & GAS INSURANCE SERVICES LIMITED, [PROPOSED] STIPULATED 15 Defendant. PROTECTIVE ORDER1 16

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18 Having reviewed the Parties’ Stipulated Protective Order, and for good cause 19 appearing, the Court hereby enters a Stipulated Protective Order (“Protective Order”) 20 as follows: 21 1. INTRODUCTION 22 1.1 Purposes and Limitations. Discovery in this action is likely to involve 23 production of confidential, proprietary, or private information for which special 24 protection from public disclosure and from use for any purpose other than prosecuting 25 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. Christensen’s Procedures as of 24 July 1 petition the court to enter the following Protective Order. The parties acknowledge 2 that this Order does not confer blanket protections on all disclosures or responses to 3 discovery and that the protection it affords from public disclosure and use extends 4 only to the limited information or items that are entitled to confidential treatment 5 under the applicable legal principles. 6 1.2 Good Cause Statement. 7 This action is likely to involve commercial, financial, technical and/or 8 proprietary information for which special protection from public disclosure and from 9 use for any purpose other than prosecution of this action is warranted. Such 10 confidential and proprietary materials and information consist of, among other things, 11 confidential business or financial information, information regarding confidential 12 business practices, or other confidential commercial information, information 13 otherwise generally unavailable to the public, or which may be privileged or otherwise 14 protected from disclosure under state or federal statutes, court rules, case decisions, 15 or common law. Accordingly, to expedite the flow of information, to facilitate the 16 prompt resolution of disputes over confidentiality of discovery materials, to 17 adequately protect information the parties are entitled to keep confidential, to ensure 18 that the parties are permitted reasonable necessary uses of such material in preparation 19 for and in the conduct of trial, to address their handling at the end of the litigation, 20 and serve the ends of justice, a protective order for such information is justified in this 21 matter. It is the intent of the parties that information will not be designated as 22 confidential for tactical reasons and that nothing be so designated without a good faith 23 belief that it has been maintained in a confidential, non-public manner, and there is 24 good cause why it should not be part of the public record of this case. 25 1.3 Acknowledgment of Procedure for Filing Under Seal. 26 The parties further acknowledge, as set forth in Section 12.3, below, that this 27 Protective rder does not entitle them to file confidential information under seal; Local 1 Rule 79-5 sets forth the procedures that must be followed and the standards that will 2 be applied when a party seeks permission from the court 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 Cnty. of Honolulu,

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd 7 v. Gen. Motors Corp.,

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

(E.D. Wis. 1999) (even stipulated protective 9 orders require good cause showing), and a specific showing of good cause or 10 compelling reasons with proper evidentiary support and legal justification, must be 11 made with respect to Protected Material that a party seeks to file under seal. The 12 parties’ mere designation of Disclosure or Discovery Material as 13 “CONFIDENTIAL” does not—without the submission of competent evidence by 14 declaration, establishing that the material sought to be filed under seal qualifies as 15 confidential, privileged, or 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. Pac. Creditors Ass’n,

, 677–79 (9th Cir. 2010). For each 20 item or type of information, document, or thing sought to be filed or introduced under 21 seal in connection with a dispositive motion or trial, the party seeking protection 22 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 entirety 2 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 designation 6 of information or items under this Protective 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 protection 9 under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in 10 the Good Cause Statement. 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 12 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 of 17 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 Final Disposition: the later of (1) dismissal of all claims and defenses in 24 this Action, with or without prejudice; and (2) final judgment herein after the 25 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 26 this Action, including the time limits for filing any motions or applications for 27 extension of time pursuant to applicable law. 1 In-House Counsel does not include Outside Counsel of Record or any other outside 2 counsel. 3 2.10 Non-Party: any natural person, partnership, corporation, association, or 4 other legal entity not named as a Party to this action. 5 2.11 Outside Counsel: attorneys who are not employees of a party to this 6 Action but are retained to consult or advise a party to this Action but are not Outside 7 Counsel of Record. 8 2.12 Outside Counsel of Record: attorneys who are not employees of a party 9 to this Action but are retained to represent or advise a party to this Action and have 10 appeared in this Action on behalf of that party or are affiliated with a law firm which 11 has appeared on behalf of that party, and includes support staff. 12 2.13 Party: any party to this Action, including all of its officers, directors, 13 employees, consultants, retained experts, Outside Counsel, and Outside Counsel of 14 Record (and their support staffs). 15 2.14 Producing Party: a Party or Non-Party that produces Disclosure or 16 Discovery Material in this Action. 17 2.15 Professional Vendors: persons or entities that provide litigation- support 18 services (e.g., photocopying, videotaping, transcribing, translating, preparing exhibits 19 or demonstrations, and organizing, storing, or retrieving data in any form or medium) 20 and their employees and subcontractors. 21 2.16 Protected Material: any Disclosure or Discovery Material that is 22 designated as “CONFIDENTIAL.” 23 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material 24 from a Producing Party. 25 3. SCOPE 26 The protections conferred by this Protective Order cover not only Protected 27 Material (as defined above), but also (1) any information copied or extracted from 1 Material; and (3) any testimony, conversations, or presentations by Parties or their 2 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 Protective Order does not govern the use of Protected Material at 5 trial. 6 4. TRIAL AND DURATION 7 Once a case proceeds to trial, information that was designated as 8 CONFIDENTIAL or maintained pursuant to this Protective Order and used or 9 introduced as an exhibit at trial becomes public and will be presumptively available 10 to all members of the public, including the press, unless compelling reasons 11 supported by specific factual findings to proceed otherwise are made to the trial 12 judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing 13 “good cause” showing for sealing documents produced in discovery from 14 “compelling reasons” standard when merits-related documents are part of court 15 record). Accordingly, for such materials, the terms of this Stipulated Protective 16 Order do not extend beyond the commencement of the trial. 17 Even after Final Disposition of this litigation, the confidentiality obligations 18 imposed by this Protective Order shall remain in effect as to all Protected Material 19 not used or introduced as an exhibit at trial, until a Designating Party agrees 20 otherwise in writing or a court order otherwise directs. 21 5. DESIGNATING PROTECTED MATERIAL 22 5.1 Exercise of Restraint and Care in Designating Material for Protection. 23 Each Party or Non-Party that designates information or items for protection under 24 this Protective Order must take care to limit any such designation to specific material 25 that qualifies under the appropriate standards. The Designating Party must designate 26 for protection only those parts of material, documents, items, or oral or written 27 communications that qualify so that other portions of the material, documents, items, 1 or communications for which protection is not warranted are not swept unjustifiably 2 within the ambit of this Protective Order. 3 Mass, indiscriminate, or routinized designations are prohibited. Designations 4 that are shown to be clearly unjustified or that have been made for an improper 5 purpose (e.g., to unnecessarily encumber the case development process or to impose 6 unnecessary expenses and burdens on the other party) may expose the Designating 7 Party to sanctions. 8 If it comes to a Designating Party’s attention that information or items that it 9 designated for protection do not qualify for protection, that Designating Party must 10 promptly notify all other Parties that it is withdrawing the inapplicable designation. 11 5.2 Manner and Timing of Designations. Except as otherwise provided in 12 this Protective Order (see, e.g., second paragraph of section 5.2(a) below), or as 13 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 14 protection under this Protective Order must be clearly so designated before the 15 material is disclosed or produced. 16 Designation in conformity with this Protective Order requires: 17 (a) for information in documentary form (e.g., paper or electronic 18 documents, but excluding transcripts of depositions or other pretrial or trial 19 proceedings), that the Producing Party affix at a minimum, the legend 20 “CONFIDENTIAL” to each page that contains protected material. If only a portion 21 or portions of the material on a page qualifies for protection, the Producing Party 22 also must clearly identify the protected portion(s) (e.g., by making appropriate 23 markings in the margins). 24 A Party or Non-Party that makes original documents available for inspection 25 need not designate them for protection until after the inspecting Party has indicated 26 which documents it would like copied and produced. During the inspection and 27 before the designation, all of the material made available for inspection shall be 1 documents it wants copied and produced, the Producing Party must determine which 2 documents, or portions thereof, qualify for protection under this Protective Order. 3 Then, before producing the specified documents, the Producing Party must affix the 4 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 5 portion or portions of the material on a page qualifies for protection, the Producing 6 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 7 markings in the margins). 8 (b) for testimony given in depositions that the Designating Party identify 9 the Disclosure or Discovery Material on the record, before the close of the deposition 10 all protected testimony. Alternatively, any Party may, no later than five (5) business 11 days after receipt of a deposition transcript, designate by page and line, and/or exhibit 12 number, all or any portion thereof as “CONFIDENTIAL” under the terms of this 13 Protective Order by providing notice in writing to the other Party. All copies of 14 deposition transcripts that contain Confidential Information shall be prominently 15 marked “CONFIDENTIAL” on the cover thereof. 16 (c) for information produced in some form other than documentary and for 17 any other tangible items, that the Producing Party affix in a prominent place on the 18 exterior of the container or containers in which the information is stored the 19 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants 20 protection, the Producing Party, to the extent practicable, shall identify the protected 21 portion(s). 22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive 24 the Designating Party’s right to secure protection under this Protective Order for 25 such material. Upon timely correction of a designation, the Receiving Party must 26 make reasonable efforts to assure that the material is treated in accordance with the 27 provisions of this Protective Order. 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 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 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 7 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2 8 6.3 The burden of persuasion in any such challenge proceeding shall be on 9 the Designating Party. Frivolous challenges, and those made for an improper purpose 10 (e.g., to harass or impose unnecessary expenses and burdens on the other party) may 11 expose the Challenging Party to sanctions. Unless the Designating Party has waived 12 or withdrawn the confidentiality designation, the Receiving Party and any Non-Party 13 shall continue to afford the material in question the level of protection to which it is 14 entitled under the Producing Party’s designation until the court rules on the 15 challenge. 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles. A Receiving Party may use Protected Material that is 18 disclosed or produced by the other Party or by a Non-Party in connection with this 19 Action only for prosecuting, defending, or attempting to settle this Action. Such 20 Protected Material may be disclosed only to the categories of persons and under the 21 conditions described in this Protective Order. When the Action reaches a Final 22 Disposition, a Receiving Party must comply with the provisions of section 13 below. 23 Protected Material must be stored and maintained by a Receiving Party at a 24 location and in a secure manner that ensures that access is limited to the persons 25 authorized under this Protective Order. 26 27 2 Judge Christensen’s Procedures are available at 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 otherwise ordered by the court or permitted in writing by the Designating Party, a 3 Receiving Party may disclose any information or item designated 4 “CONFIDENTIAL” only: 5 (a) to the Receiving Party’s Outside Counsel and Outside Counsel of 6 Record in this Action, as well as employees of said Outside Counsel and Outside 7 Counsel of Record to whom it is reasonably necessary to disclose the information for 8 this Action; 9 (b) to the officers, directors, and employees (including House Counsel) of 10 the Receiving Party to whom disclosure is reasonably necessary for this Action; 11 (c) to Experts (as defined in this Protective Order) of the Receiving Party 12 to whom disclosure is reasonably necessary for this Action and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (d) to the Court and its personnel; 15 (e) to court reporters and their staff; 16 (f) to professional jury or trial consultants, mock jurors, and Professional 17 Vendors to whom disclosure is reasonably necessary for this Action and who have 18 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (g) to the author or recipient of a document containing the information or a 20 custodian or other person who otherwise possessed or knew the information; 21 (h) during their depositions, witnesses, and attorneys for witnesses to whom 22 disclosure is reasonably necessary, provided: (1) the deposing party requests that the 23 witness sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A); and 24 (2) the witness will not be permitted to keep any Confidential Information unless 25 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 26 otherwise agreed by the Designating Party or ordered by the Court. Pages of 27 transcribed deposition testimony or exhibits to depositions that reveal Protected 1 on the cover, and may not be disclosed to anyone except as permitted under this 2 Protective Order; and 3 (i) to any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by either of the Parties engaged in settlement discussions; 5 (j) to Defendant’s reinsurers or regulators and representatives of such 6 reinsurers or regulators; 7 (k) to Plaintiff’s regulators and representatives of such regulators; and 8 (l) to other persons who may be later designated by written agreement of 9 the Parties, or by order of the Court obtained on noticed motion (or on shortened time 10 as allowed by the Court) permitting such disclosure, or who otherwise obtain 11 authorization to receive Protected Material in accordance with this Protective Order. 12 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 13 PRODUCED IN OTHER LITIGATION 14 If a Party is served with a subpoena or a court order issued in other litigation 15 that compels disclosure of any information or items designated in this Action as 16 “CONFIDENTIAL,” that Party must: 17 (a) promptly notify in writing the Designating Party. Such notification shall 18 include a copy of the subpoena or court order; 19 (b) promptly notify in writing the party who caused the subpoena or order 20 to issue in the other litigation that some or all of the material covered by the subpoena 21 or order is subject to this Protective Order. Such notification shall include a copy of 22 this Protective Order; and 23 (c) cooperate with respect to all reasonable procedures sought to be pursued 24 by the Designating Party whose Protected Material may be affected. 25 If the Designating Party timely seeks a protective order, the Party served with 26 the subpoena or court order shall not produce any information designated in this 27 action as “CONFIDENTIAL” before a determination by the court from which the 1 permission. The Designating Party shall bear the burden and expense of seeking 2 protection in that court of its “CONFIDENTIAL” material and nothing in these 3 provisions should be construed as authorizing or encouraging a Receiving Party in 4 this Action to disobey a lawful directive from another court. 5 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 6 PRODUCED IN THIS LITIGATION 7 9.1 Application. The terms of this Protective Order are applicable to 8 information produced by a Non-Party in this Action, or in the underlying Aliso 9 Canyon D&O Lawsuits, and designated as “CONFIDENTIAL.” Such information 10 produced by Non-Parties in connection with this Action, or produced in the Aliso 11 Canyon D&O Lawsuits, is protected by the remedies and relief provided by this 12 Protective Order. Nothing in these provisions should be construed as prohibiting a 13 Non-Party from seeking additional protections. 14 9.2 Notification. In the event that a Party is required, by a valid discovery 15 request, to produce a Non-Party’s Protected Material in its possession, and the Party 16 is subject to an agreement with the Non-Party not to produce the Non-Party’s 17 Protected Material, then the Party shall: 18 (a) promptly notify in writing the Requesting Party and the Non-Party that 19 some or all of the information requested is subject to a confidentiality agreement with 20 a Non-Party; 21 (b) Promptly provide the Non-Party with a copy of the Protective Order in 22 this Action, with the relevant discovery request(s), and a reasonably specific 23 description of the information requested; and 24 (c) make the information requested available for inspection by the Non- 25 Party, if requested. 26 9.3 Conditions of Production. If the Non-Party fails to seek a protective 27 order from this Court within 14 days of receiving the notice and accompanying 1 responsive to the discovery request. If the Non-Party timely seeks a protective order, 2 the Receiving Party shall not produce any information in its possession or control 3 that is subject to the confidentiality agreement with the Non-Party before a 4 determination by the Court. Absent a court order to the contrary, the Non-Party shall 5 bear the burden and expense of seeking protection in this Court of its Protected 6 Material. 7 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 8 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 9 Protected Material to any person or in any circumstance not authorized under this 10 Protective Order, the Receiving Party must immediately (a) notify in writing the 11 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 12 all unauthorized copies of the Protected Material, (c) inform the person or persons to 13 whom unauthorized disclosures were made of all the terms of this Protective Order, 14 and (d) request such person or persons to execute the “Acknowledgment and 15 Agreement to Be Bound” (Exhibit A). 16 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 17 PROTECTED MATERIAL 18 When a Producing Party gives notice to the Receiving Party that certain 19 inadvertently produced material is subject to a claim of privilege or other protection, 20 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 21 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 22 procedure may be established in an e-discovery order that provides for production 23 without prior privilege review. 24 12. MISCELLANEOUS 25 12.1 Right to Further Relief. Nothing in this Protective Order abridges the 26 right of any person to seek its modification by the Court in the future. 27 12.2 Right to Assert Other Objections. By stipulating to the entry of this 1 disclosing or producing any information or item on any ground not addressed in this 2 Protective Order. Similarly, no Party waives any right to object on any ground to 3 use in evidence of any of the Protected Material covered by this Protective Order. 4 12.3 Filing Protected Material. A Party that seeks to file under seal any 5 Protected Material must comply with Local Rule 79-5. Protected Material may only 6 be filed under seal pursuant to a court order authorizing the sealing of the specific 7 Protected Material at issue. If a Party's request to file Protected Material under seal 8 is denied by the Court, then the Receiving Party may file the information in the public 9 record unless otherwise instructed by the Court. 10 13. FINAL DISPOSITION 11 After the Final Disposition of this Action, as defined in paragraph 4, within 12 60 days of a written request by the Designating Party, each Receiving Party must 13 return all Protected Material to the Producing Party or destroy such material. As 14 used in this subdivision, “all Protected Material” includes all copies, abstracts, 15 compilations, summaries, and any other format reproducing or capturing any of the 16 Protected Material. Whether the Protected Material is returned or destroyed, the 17 Receiving Party must submit a written certification to the Producing Party (and, if 18 not the same person or entity, to the Designating Party) by the 60 day deadline that 19 (1) identifies (by category, where appropriate) all the Protected Material that was 20 returned or destroyed and (2) affirms that the Receiving Party has not retained any 21 copies, abstracts, compilations, summaries or any other format reproducing or 22 capturing any of the Protected Material. Notwithstanding this provision, Counsel is 23 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 24 and hearing transcripts, legal memoranda, correspondence, deposition and trial 25 exhibits, expert reports, attorney work product, and consultant and expert work 26 product, even if such materials contain Protected Material. Any such archival copies 27 that contain or constitute Protected Material remain subject to this Protective Order 1 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished by any and 3 all appropriate measures including, without limitation, contempt proceedings and/or 4 monetary sanctions. 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 DATED: 1/15/2025 /s/Sandra Smith Thayer______________________ Kirk Pasich, [email protected] 9 Sandra Smith Thayer, [email protected] 10 Caitlin Oswald, [email protected] Eliza J. Logan, [email protected] 11 Mcguire Woods LLP 12 1800 Century Park E., 8th Floor Los Angeles, California 90067 13 Telephone: (310) 315-8200 14 Facsimile: (310) 315-8210 Attorneys for Plaintiffs 15 DATED: 1/15/25 /s/Larry M. Golub__________________________ 16 Larry M. Golub, [email protected] 17 Thomas J. Placido, [email protected] 18 Sacro & Walker LLP 700 N. Brand Blvd., Suite 610 19 Glendale, California 91203 20 Telephone: (818) 721-9597 Facsimile: (818) 721-9870 21 22 Sabrina Haurin, [email protected] Jolene S. Griffith, [email protected] 23 Bailey Cavalieri LLC 24 10 West Broad Street, Suite 2100 Columbus, Ohio 43215-3422 25 Telephone: (614) 221-3155 26 Facsimile: (614) 221-0479 Attorneys for Defendant 27 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 Za 4 DATED: January 16, 2025 5 STEPHANIE S. CHRISTENSEN United States Magistrate Judge

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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 6 (“Protective Order”) that was issued by the United States District Court for the 7 Central District of California in the case of Sempra v. Associated Electric & Gas 8 Insurance Services Limited, Case No. 2:23-cv-10544-JLS-SSC. I agree to comply 9 with and to be bound by all the terms of this Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and 11 punishment in the nature of contempt. I solemnly promise that I will not disclose 12 in any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. 19 20 Date: ___________________________ 21 City and State where sworn and signed: ___________________________ 22 Printed name: ___________________________ 23 Signature: ___________________________ 24

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