Timothy Sauer v. JPMorgan Chase Bank, N.A.

United States District Court for the Eastern District of California

Timothy Sauer v. JPMorgan Chase Bank, N.A.

Trial Court Opinion

1 MArOjuRnG PA. RNa, oL, EBWarI SN o&. 2B6O53C4K7I US LLP 2 Marcos Sasso, Bar No. 228905 2049 Century Park East, Suite 700 3 Los Angeles, CA 90067-3109 Tel: +1.310.907.1000 4 Fax: +1.310.907.1001 [email protected] 5 [email protected]

6 MORGAN, LEWIS & BOCKIUS LLP Christina Chen, Bar No. 294921 7 One Market, Spear Street Tower San Francisco, CA 94105-1596 8 Tel: +1.415.442.1000 Fax: +1.415.442.1001 9 [email protected] 10 Attorneys for Defendant JPMORGAN CHASE BANK, N.A. 11

12 13 UNITED STATES DISTRICT COURT 14 EASTERN DISTRICT OF CALIFORNIA 15 TIMOTHY SAUER, an individual, CASE NO.: 2:25-cv-0673-DAD-JDP 16 Plaintiff, [PROPOSED] STIPULATED 17 PROTECTIVE ORDER v. 18 JPMORGAN CHASE BANK, 19 NATIONAL ASSOCIATION, and DOES 1 to 100, inclusive, 20 Defendants. 21

22 23 24 25 26 27 28 1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than pursuing this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve discovery and disclosure of confidential, 13 private, and/or proprietary information for which special protection from public 14 disclosure and from use for any purpose other than prosecution of this action is 15 warranted pursuant to Federal Rule of Civil Procedure 26, subdivision (c). Such 16 information includes, but is not limited to, private financial information, 17 confidential or proprietary business or commercial information, , personal 18 identifying information, sensitive personal data, employment and personnel files, 19 security-related information, third-party privacy protected information, information 20 the disclosure of which could result in annoyance or embarrassment, information 21 otherwise generally unavailable to the public, and/or information which may be 22 privileged or otherwise protected from disclosure under state or federal statutes, 23 court rules, case decisions, or common law. Accordingly, to expedite the flow of 24 information, to facilitate the prompt resolution of disputes over confidentiality of 25 discovery materials, to adequately protect information the parties are entitled to 26 keep confidential, to ensure that the parties are permitted reasonable necessary uses 27 of such material in preparation for and in the conduct of trial, to address their 28 1 handling at the end of the litigation, and serve the ends of justice, the parties agree 2 that a protective order for such information is justified in this matter. It is the intent 3 of the parties that information will not be designated as confidential for tactical 4 reasons and that nothing be so designated without a good faith belief that it has 5 been maintained in a confidential, non-public manner, and there is good cause why 6 it should not be part of the public record of this case. 7 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 8 The parties further acknowledge, as set forth in Section 14.3, below, that this 9 Stipulated Protective Order does not entitle them to file confidential information 10 under seal; Local Rules 140 and 141 set forth the procedures that must be followed 11 and the standards that will be applied when a party seeks permission from the court 12 to file material under seal or redaction. There is a strong presumption that the public 13 has a right of access to judicial proceedings and records in civil cases. In connection 14 with non-dispositive motions, good cause must be shown to support a filing under 15 seal. See Kamakana v. City & Cnty. of Honolulu,

447 F.3d 1172

, 1176 (9th Cir. 16 2006), Phillips v. Gen. Motors Corp.,

307 F.3d 1206

, 1210–11 (9th Cir. 2002), 17 Makar-Welbon v. Sony Elecs., Inc.,

187 F.R.D. 576, 577

(E.D. Wis. 1999) (even 18 stipulated protective orders require good cause showing), and a specific showing of 19 good cause or compelling reasons with proper evidentiary support and legal 20 justification, must be made with respect to Protected Material that a party seeks to 21 file under seal. The parties’ mere designation of Disclosure or Discovery Material 22 as CONFIDENTIAL does not—without the submission of competent evidence by 23 declaration, establishing that the material sought to be filed under seal qualifies as 24 confidential, privileged, or otherwise protectable—constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, 26 then compelling reasons, not only good cause, for the sealing must be shown, and 27 the relief sought shall be narrowly tailored to serve the specific interest to be 28 1 protected. See Pintos v. Pacific Creditors Ass’n,

605 F.3d 665

, 677–79 (9th Cir. 2 2010). For each item or type of information, document, or thing sought to be filed 3 or introduced under seal, the party seeking protection must articulate compelling 4 reasons, supported by specific facts and legal justification, for the requested sealing 5 order. Again, competent evidence supporting the application to file documents 6 under seal must be provided by declaration. 7 Any document that is not confidential, privileged, or otherwise protectable in 8 its entirety will not be filed under seal if the confidential portions can be redacted. 9 If documents can be redacted, then a redacted version for public viewing, omitting 10 only the confidential, privileged, or otherwise protectable portions of the document, 11 shall be filed. Any application that seeks to file documents under seal in their 12 entirety should include an explanation of why redaction is not feasible. 13 4. DEFINITIONS 14 4.1 Action: Timothy Sauer v. JPMorgan Chase Bank, N.A., Case No. 15 2:25-CV-00673-DAD-JDP. 16 4.2 Challenging Party: a Party or Non-Party that challenges the 17 designation of information or items under this Order. 18 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 19 how it is generated, stored or maintained) or tangible things that qualify for 20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 21 the Good Cause Statement. 22 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 23 their support staff). 24 4.5 Designating Party: a Party or Non-Party that designates information or 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 28 1 4.6 Disclosure or Discovery Material: all items or information, regardless 2 of the medium or manner in which it is generated, stored, or maintained (including, 3 among other things, testimony, transcripts, and tangible things), that are produced 4 or generated in disclosures or responses to discovery. 5 4.7 Expert: a person with specialized knowledge or experience in a matter 6 pertinent to the litigation who has been retained by a Party or its counsel to serve as 7 an expert witness or as a consultant in this Action. 8 4.8 House Counsel: attorneys who are employees of a party to this Action. 9 House Counsel does not include Outside Counsel of Record or any other outside 10 counsel. 11 4.9 Non-Party: any natural person, partnership, corporation, association or 12 other legal entity not named as a Party to this action. 13 4.10 Outside Counsel of Record: attorneys who are not employees of a 14 party to this Action but are retained to represent a party to this Action and have 15 appeared in this Action on behalf of that party or are affiliated with a law firm that 16 has appeared on behalf of that party, and includes support staff. 17 4.11 Party: any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, and Outside Counsel of Record (and their 19 support staffs). 20 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 21 Discovery Material in this Action. 22 4.13 Professional Vendors: persons or entities that provide litigation 23 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) 25 and their employees and subcontractors. 26 4.14 Protected Material: any Disclosure or Discovery Material that is 27 28 1 designated as “CONFIDENTIAL.” 2 4.15 Receiving Party: a Party that receives Disclosure or Discovery 3 Material from a Producing Party. 4 5. SCOPE 5 The protections conferred by this Stipulation and Order cover not only 6 Protected Material (as defined above), but also (1) any information copied or 7 extracted from Protected Material; (2) all copies, excerpts, summaries, or 8 compilations of Protected Material; and (3) any testimony, conversations, or 9 presentations by Parties or their Counsel that might reveal Protected Material. 10 Any use of Protected Material at trial shall be governed by the orders of the 11 trial judge and other applicable authorities. This Order does not govern the use of 12 Protected Material at trial. In other words, this Order shall govern pretrial 13 proceedings only, and nothing set forth herein prohibits the use at trial of any 14 Confidential Information or affects the admissibility of any evidence. The 15 procedures to govern the use and disclosure of Confidential Information and the 16 redaction of any “Confidential” or “Confidential Information” designation may be 17 the subject of further agreement of the Parties or order of the Court. Nothing herein 18 shall be construed as limiting a Party’s use of its own Confidential Information and 19 such use shall not constitute a waiver of the terms of this Order or the status of such 20 information as Confidential Information. Any of the Parties can remove their 21 designation of Confidential Information from any information it has previously so 22 designated. 23 6. DURATION 24 Even after final disposition of this litigation, the confidentiality obligations 25 imposed by this Order shall remain in effect until a Designating Party agrees 26 otherwise in writing or a court order otherwise directs. Final disposition shall be 27 deemed to be the later of (1) dismissal of all claims and defenses in this action, with 28 1 or without prejudice; and (2) final judgment herein after the completion and 2 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 3 including the time limits for filing any motions or applications for extension of time 4 pursuant to applicable law. 5 7. DESIGNATING PROTECTED MATERIAL 6 7.1 Exercise of Restraint and Care in Designating Material for 7 Protection. Each Party or Non-Party that designates information or 8 items for protection under this Order must take care to limit any such designation to 9 specific material that qualifies under the appropriate standards. The Designating 10 Party must designate for protection only those parts of material, documents, items 11 or oral or written communications that qualify so that other portions of the material, 12 documents, items or communications for which protection is not warranted are not 13 swept unjustifiably within the ambit of this Order. 14 Mass, indiscriminate, or routinized designations are prohibited. Designations 15 that are shown to be clearly unjustified or that have been made for an improper 16 purpose (e.g., to unnecessarily encumber the case development process or to 17 impose unnecessary expenses and burdens on other parties) may expose the 18 Designating Party to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 designated for protection do not qualify for protection, that Designating Party must 21 promptly notify all other Parties that it is withdrawing the inapplicable designation. 22 7.2 Manner and Timing of Designations. Except as otherwise provided in 23 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 24 that qualifies for protection under this Order must be clearly so designated before 25 the material is disclosed or produced. 26 Designation in conformity with this Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 28 1 documents, but excluding transcripts of depositions or other pretrial or trial 2 proceedings), that the Producing Party affix at a minimum, the legend 3 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 4 contains protected material. If only a portion of the material on a page qualifies for 5 protection, the Producing Party also must clearly identify the protected portion(s) 6 (e.g., by making appropriate markings in the margins). 7 A Party or Non-Party that makes original documents available for inspection 8 need not designate them for protection until after the inspecting Party has indicated 9 which documents it would like copied and produced. During the inspection and 10 before the designation, all of the material made available for inspection shall be 11 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 12 documents it wants copied and produced, the Producing Party must determine 13 which documents, or portions thereof, qualify for protection under this Order. 14 Then, before producing the specified documents, the Producing Party must affix the 15 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 16 portion of the material on a page qualifies for protection, the Producing Party also 17 must clearly identify the protected portion(s) (e.g., by making appropriate markings 18 in the margins). 19 (b) deposition testimony will be deemed confidential only if 20 designated as such at any time before the close of the deposition by either: (1) 21 identifying the specific testimony to be treated as “CONFIDENTIAL”; or (2) 22 requesting that the entire transcript and all exhibits thereto be treated as 23 “CONFIDENTIAL” until thirty (30) days after receipt by the Designating Party of 24 the deposition transcript from the court reporter. Any designation of deposition 25 testimony must be specific as to the portions of the transcript and/or any exhibits to 26 be protected, except that any exhibit that has previously been marked as 27 “CONFIDENTIAL” at the time of production, and which still bears that mark at the 28 1 time of its use in a deposition, shall be presumed to be confidential under this Order 2 without further designation. For testimony or documents to continue to be treated 3 as Protected Material after the expiration of the 30-day period, the Designating 4 Party must identify, in writing to all parties and within the 30-day period unless 5 otherwise agreed to by all parties, the specific portions of the transcript and exhibits 6 attached thereto it designates as “CONFIDENTIAL.” In circumstances where 7 portions of the transcript are designated as “CONFIDENTIAL,” the transcript pages 8 containing Protected Information may be separately bound by the court reporter, 9 who must affix to the top of each page the legend “Confidential,” as instructed by 10 the Designating Party. 11 (c) for information produced in some form other than documentary and 12 for any other tangible items, that the Producing Party affix in a prominent place on 13 the exterior of the container or containers in which the information is stored the 14 legend “CONFIDENTIAL.” If only a portion or portions of the information 15 warrants protection, the Producing Party, to the extent practicable, shall identify the 16 protected portion(s). 17 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 18 failure to designate qualified information or items does not, standing alone, waive 19 the Designating Party’s right to secure protection under this Order for such 20 material. Upon timely correction of a designation, the Receiving Party must make 21 reasonable efforts to assure that the material is treated in accordance with the 22 provisions of this Order. 23 24 25 26 27 28 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 and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 251. 7 8.3 The burden of persuasion in any such challenge proceeding shall be on 8 the Designating Party. Frivolous challenges, and those made for an improper 9 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 10 parties) may expose the Challenging Party to sanctions. Unless the Designating 11 Party has waived or withdrawn the confidentiality designation, all parties shall 12 continue to afford the material in question the level of protection to which it is 13 entitled under the Producing Party’s designation until the Court rules on the 14 challenge. 15 9. ACCESS TO AND USE OF PROTECTED MATERIAL 16 9.1 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 21 Receiving Party must comply with the provisions of Section 15 below (FINAL 22 DISPOSITION). 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 Order. 26 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 27 28 1 otherwise ordered by the court or permitted in writing by the Designating Party, a 2 Receiving Party may disclose any information or item designated 3 “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 5 well as employees of said Outside Counsel of Record to whom it is reasonably 6 necessary to disclose the information for this Action; 7 (b) the officers, directors, and employees (including House Counsel) of 8 the Receiving Party to whom disclosure is reasonably necessary for this Action; 9 (c) Experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (d) the Court and its personnel; 13 (e) court reporters and their staff; 14 (f) professional jury or trial consultants, mock jurors, and Professional 15 Vendors to whom disclosure is reasonably necessary for this Action and who have 16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (g) the author or recipient of a document containing the information or 18 a custodian or other person who otherwise possessed or knew the information; 19 (h) during their depositions, witnesses, and attorneys for witnesses, in 20 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 21 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 22 they will not be permitted to keep any confidential information unless they sign the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 24 agreed by the Designating Party or ordered by the court. 25 (i) any mediators or settlement officers and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 28 PRODUCED IN OTHER LITIGATION 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,” 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 7 order 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. If the 12 Designating Party timely seeks a protective order, the Party served with the 13 subpoena or court order shall not produce any information designated in this action 14 as “CONFIDENTIAL” before a determination by the court from which the 15 subpoena or order issued, unless the Party has obtained the Designating Party’s 16 permission. The Designating Party shall bear the burden and expense of seeking 17 protection in that court of its confidential material and nothing in these provisions 18 should be construed as authorizing or encouraging a Receiving Party in this Action 19 to disobey a lawful directive from another court. 20 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 21 BE PRODUCED IN THIS LITIGATION (a) The terms of this Order are applicable to information produced by a 22 23 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 24 produced by Non-Parties in connection with this litigation is protected by the 25 remedies and relief provided by this Order. Nothing in these provisions should be 26 construed as prohibiting a Non-Party from seeking additional protections. 27 (b) In the event that a Party is required, by a valid discovery request, to 28 produce a Non-Party’s confidential information in its possession, and the Party is 1 subject to an agreement with the Non-Party not to produce the Non-Party’s 2 confidential information, then the Party shall: 3 (1) promptly notify in writing the Requesting Party and the Non-Party 4 that some or all of the information requested is subject to a confidentiality 5 agreement with a Non-Party; 6 (2) promptly provide the Non-Party with a copy of the Stipulated 7 Protective Order in this Action, the relevant discovery request(s), and a reasonably 8 specific description of the information requested; and 9 (3) make the information requested available for inspection by the 10 Non-Party, if requested. 11 (c) If the Non-Party fails to seek a protective order from this court within 12 fourteen (14) days of receiving the notice and accompanying information, the 13 Receiving Party may produce the Non-Party’s confidential information responsive 14 to the discovery request. If the Non-Party timely seeks a protective order, the 15 Receiving Party shall not produce any information in its possession or control that 16 is subject to the confidentiality agreement with the Non-Party before a 17 determination by the court. Absent a court order to the contrary, the Non-Party 18 shall bear the burden and expense of seeking protection in this court of its Protected 19 Material. 20 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 21 MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 22 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 26 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 27 person or persons to whom unauthorized disclosures were made of all the terms of 28 1 this Order, and (d) request such person or persons to execute the “Acknowledgment 2 an Agreement to Be Bound” attached hereto as Exhibit A. 3 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 4 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other 7 protection, the obligations of the Receiving Parties are those set forth in Federal 8 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 9 whatever procedure may be established in an e-discovery order that provides for 10 production without prior privilege review. Pursuant to Federal Rule of Evidence 11 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 12 of a communication or information covered by the attorney-client privilege or work 13 product protection, the parties may incorporate their agreement in the stipulated 14 protective order submitted to the court. 15

16 14. MISCELLANEOUS 17 14.1 Right to Further Relief. Nothing in this Stipulated Protective Order 18 shall be construed as prohibiting any Party or Non-Party from seeking additional or 19 different protections or other relief. Nothing in this Order abridges the right of any 20 person to seek its modification by the Court in the future. 21 14.2 Right to Assert Other Objections. By stipulating to the entry of this 22 Protective Order, no Party waives any right it otherwise would have to object to 23 disclosing or producing any information or item on any ground not addressed in 24 this Stipulated Protective Order. Similarly, no Party waives any right to object on 25 any ground to use in evidence of any of the material covered by this Protective 26 Order. 27 14.3 Filing Protected Material. A Party that seeks to file under seal any 28 1 Protected Material must comply with Local Civil Rule 141. Protected Material 2 may only be filed under seal pursuant to a court order authorizing the sealing of the 3 specific Protected Material. If a Party’s request to file Protected Material under 4 seal is denied by the Court, then the Receiving Party may file the information in the 5 public record unless otherwise instructed by the Court. 6 15. FINAL DISPOSITION 7 After the final disposition of this Action, as defined in Paragraph 6, within 8 sixty (60) days of a written request by the Designating Party, each Receiving Party 9 must return all Protected Material to the Producing Party or destroy such material. 10 As used in this subdivision, “all Protected Material” includes all copies, abstracts, 11 compilations, summaries, and any other format reproducing or capturing any of the 12 Protected Material. Whether the Protected Material is returned or destroyed, the 13 Receiving Party must submit a written certification to the Producing Party (and, if 14 not the same person or entity, to the Designating Party) by the 60-day deadline that 15 (1) identifies (by category, where appropriate) all the Protected Material that was 16 returned or destroyed and (2) affirms that the Receiving Party has not retained any 17 copies, abstracts, compilations, summaries or any other format reproducing or 18 capturing any of the Protected Material. Notwithstanding this provision, Counsel 19 are entitled to retain an archival copy of all pleadings, motion papers, trial, 20 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 21 and trial exhibits, expert reports, attorney work product, and consultant and expert 22 work product, even if such materials contain Protected Material. Any such archival 23 copies that contain or constitute Protected Material remain subject to this Protective 24 Order as set forth in Section 6 (DURATION). 25 16. VIOLATION 26 Any violation of this Order may be punished by appropriate measures 27 including, without limitation, contempt proceedings and/or monetary sanctions. 28 ! || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 4 DATED: September 16, 2025 /s/ Meghan Baker Attorneys for Plaintiff Timothy Sauer 5 6 DATED: September 16, 2025 /s/ Arjun Rao 7 Attorneys for Defendant JPMorgan

Chase 8

Bank, N.A. 9 | FOR GOOD CAUSE SHOWN, 10 11 || IT IS SO ORDERED. 12 / 13 || Dated: _ September 18, 2025 ¢_—— JEREMY D. PETERSON 14 UNITED STATES MAGISTRATE JUDGE 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LEWIS & 16 LLP

1 2 EXHIBIT A 3 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4 I, ____________________________ [print or type full name], of 5 _______________________ [print or type full address], declare under penalty of 6 perjury that I have read in its entirety and understand the Stipulated Protective 7 Order that was issued by the United States District Court for the Central District of 8 California on ____________________ [date] in the case of Timothy Sauer v. 9 JPMorgan Chase Bank, N.A., Case No. 2:25-CV-00673-DAD-JDP. I agree to 10 comply with and to be bound by all the terms of this Stipulated Protective Order 11 and I understand and acknowledge that failure to so comply could expose me to 12 sanctions and punishment in the nature of contempt. I solemnly promise that I will 13 not disclose in any manner any information or item that is subject to this Stipulated 14 Protective Order to any person or entity except in strict compliance with the 15 provisions of this Order. I further agree to submit to the jurisdiction of the United 16 States District Court for the Eastern District of California for the purpose of 17 enforcing the terms of this Stipulated Protective Order, even if such enforcement 18 proceedings occur after termination of this action. 19 I hereby appoint _____________________________ [print or type full 20 name] of ____________________________________ [print or type full address 21 and telephone number] as my California agent for service of process in connection 22 with this action or any proceedings related to enforcement of this Stipulated 23 Protective Order. 24

25 Date: ____________________________ 26 City and State where sworn and signed: __________________________________ 27 Printed Name: _____________________ 28

Reference

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