Pacific Dental Services LLC v. Homeland Insurance Company of New York et al, No. 8:2013cv00749 - Document 40 (C.D. Cal. 2016)
Court Description: ORDER GRANTING STIPULATED PROTECTIVE ORDER by Magistrate Judge Jean P. Rosenbluth re Stipulation for Protective Order 39 . IT IS ORDERED that the Stipulated Protective Order, in its entirety, is hereby GRANTED and ordered into full force and effect. (See Order for details) [ Note Changes Made By The Court]. (bem)
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Pacific Dental Services LLC v. Homeland Insurance Company of New York et al 1 2 3 4 5 Doc. 40 MARC J. SHRAKE (Bar No. 219331) mjs@amclaw.com DAVID J. BILLINGS (Bar No. 175383) NOTE: CHANGES MADE BY THE COURT djb@amclaw.com ANDERSON, McPHARLIN & CONNERS LLP 707 Wilshire Boulevard Suite 4000 Los Angeles, California 90017-3623 TELEPHONE: (213) 688-0080 FACSIMILE: (213) 622-7594 6 Attorneys for Defendant and Counterclaim Plaintiff HOMELAND INSURANCE COMPANY OF NEW YORK 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 11 PACIFIC DENTAL SERVICES, LLC, a Delaware Limited Liability Company, 12 Plaintiff, 13 vs. 14 HOMELAND INSURANCE 15 COMPANY OF NEW YORK; and DOES 1 through 25, 16 Defendants. 17 Case No. SACV13-749-JLS (JPRx) ORDER GRANTING STIPULATED PROTECTIVE ORDER Trial Date: None 18 HOMELAND INSURANCE COMPANY OF NEW YORK, 19 Counterclaimant, 20 vs. 21 PACIFIC DENTAL SERVICES, LLC, 22 a Delaware Limited Liability Company, 23 Counterdefendant. 24 25 The Court, having considered the Stipulated Protective Order and finding that 26 good cause exists, orders the following: 27 IT IS ORDERED that the Stipulated Protective Order, in its entirety, is 28 hereby GRANTED and ordered into full force and effect. The pertinent elements 1496784.1 05608-025 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER Dockets.Justia.com 1 requested in the stipulation are as follows: 2 2. DEFINITIONS 3 2.1 Challenging Party: a Party or Non-Party that challenges the 4 designation of information or items under this Order. 5 2.2 “CONFIDENTIAL” Information or Items: information (regardless 6 of how it is generated, stored or maintained) or tangible things that qualify for 7 protection under Federal Rule of Civil Procedure 26(c). 8 2.3 Counsel (without qualifier): Outside Counsel of Record and House 9 Counsel (as well as their support staff). 2.4 Designating Party: a Party or Non-Party that designates information or LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 items that it produces in disclosures or in responses to discovery as 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 12 “CONFIDENTIAL.” 13 2.5 Disclosure or Discovery Material: all items or information, regardless 14 of 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 2.6 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 19 an expert witness or as a consultant in this action. 20 2.7 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 2.8 Non-Party: any natural person, partnership, corporation, association, or 24 other legal entity not named as a Party to this action. 25 2.9 Outside Counsel of Record: attorneys who are not employees of a 26 party to this action but are retained to represent or advise a party to this action and 27 have appeared in this action on behalf of that party or are affiliated with a law firm 28 which has appeared on behalf of that party. 1496784.1 05608-025 2 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 2.10 Party: any party to this action, including all of its officers, directors, 2 employees, consultants, retained experts, and Outside Counsel of Record (and their 3 support staffs). 4 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 5 Discovery Material in this action. 6 2.12 Professional Vendors: persons or entities that provide litigation 7 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 8 demonstrations, and organizing, storing, or retrieving data in any form or medium) 9 and their employees and subcontractors. 2.13 Protected Material: any Disclosure or Discovery Material that is LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 designated as “CONFIDENTIAL.” 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 12 2.14 Receiving Party: a Party that receives Disclosure or Discovery 13 Material from a Producing Party. 14 3. SCOPE 15 The protections conferred by this Stipulation and Order cover not only 16 Protected Material (as defined above), but also (1) any information copied or 17 extracted from Protected Material; (2) all copies, excerpts, summaries, or 18 compilations of Protected Material; and (3) any testimony, conversations, or 19 presentations by Parties or their Counsel that might reveal Protected Material. 20 However, the protections conferred by this Stipulation and Order do not cover the 21 following information: (a) any information that is in the public domain at the time of 22 disclosure to a Receiving Party or becomes part of the public domain after its 23 disclosure to a Receiving Party as a result of publication not involving a violation of 24 this Order, including becoming part of the public record through trial or otherwise; 25 and (b) any information that has come or shall come into the Receiving Party’s 26 legitimate possession independently of the Designating Party. Any use of Protected 27 Material at trial shall be governed by a separate agreement or order. 28 / / / 1496784.1 05608-025 3 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 4. DURATION 2 Even after final disposition of this litigation, the confidentiality obligations 3 imposed by this Order shall remain in effect until a Designating Party agrees 4 otherwise in writing or a court order otherwise directs. Final disposition shall be 5 deemed to be the later of (1) dismissal of all claims and defenses in this action, with 6 or without prejudice; and (2) final judgment herein after the completion and 7 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 8 including the time limits for filing any motions or applications for extension of time 9 pursuant to applicable law. LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS DESIGNATING PROTECTED MATERIAL 11 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 5. 5.1 Exercise of Restraint and Care in Designating Material for 12 Protection. Each Party or Non-Party that designates information or items for 13 protection under this Order must take care to limit any such designation to specific 14 material that it believes in good faith will, if disclosed to the public, have the effect 15 of causing harm to its competitive position. The Designating Party must designate 16 for protection only those parts of material, documents, items, or oral or written 17 communications that qualify – so that other portions of the material, documents, 18 items, or communications for which protection is not warranted are not swept 19 unjustifiably within the ambit of this Order. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the mistaken designation. 23 5.2 Manner and Timing of Designations. Except as otherwise provided 24 in this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. 28 / / / 1496784.1 05608-025 4 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic documents, 3 but excluding transcripts of depositions or other pretrial or trial proceedings), that 4 the Producing Party affix the legend “CONFIDENTIAL” to each page that contains 5 protected material. If only a portion or portions of the material on a page qualifies 6 for protection, the Producing Party also must clearly identify the protected portion(s) 7 (e.g., by making appropriate markings in the margins). A Party or Non-Party that 8 makes original documents or materials available for inspection need not designate 9 them for protection until after the inspecting Party has indicated which material it LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 all of the material made available for inspection shall be deemed 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 would like copied and produced. During the inspection and before the designation, 12 “CONFIDENTIAL.” After the inspecting Party has identified the documents it 13 wants copied and produced, the Producing Party must determine which documents, 14 or portions thereof, qualify for protection under this Order. Then, before producing 15 the specified documents, the Producing Party must affix the “CONFIDENTIAL” 16 legend to each page that contains Protected Material. If only a portion or portions of 17 the material on a page qualifies for protection, the Producing Party also must clearly 18 identify the protected portion(s) (e.g., by making appropriate markings in the 19 margins). 20 (b) for testimony given in deposition and other discovery-related proceedings 21 that the Designating Party identify on the record, before the close of the deposition, 22 hearing, or other proceeding, all protected testimony. 23 (c) for information produced in some form other than documentary and for 24 any other tangible items, that the Producing Party affix in a prominent place on the 25 exterior of the container or containers in which the information or item is stored the 26 legend “CONFIDENTIAL.” If only a portion or portions of the information or item 27 warrant protection, the Producing Party, to the extent practicable, shall identify the 28 protected portion(s). 1496784.1 05608-025 5 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive 3 the Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 9 designation of confidentiality at any time. Unless a prompt challenge to a LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 substantial unfairness, unnecessary economic burdens, or a significant disruption or 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 Designating Party’s confidentiality designation is necessary to avoid foreseeable, 12 delay of the litigation, a Party does not waive its right to challenge a confidentiality 13 designation by electing not to mount a challenge promptly after the original 14 designation is disclosed. 15 6.2 Dispute Resolution under Local Rules 37-1, 37-2, 37-3, and 37-4. 16 The Challenging Party shall initiate the dispute resolution process by the procedures 17 set forth in Local Rule 37-1 and providing written notice of each designation it is 18 challenging and describing the basis for each challenge. Thereafter, the Parties shall 19 engage in a good-faith attempt to resolve any differences. To avoid ambiguity as to 20 whether a challenge has been made, the written notice must recite that the challenge 21 to confidentiality is being made in accordance with this specific paragraph of the 22 Protective Order. In conferring, the Challenging Party must explain the basis for its 23 belief that the confidentiality designation was not proper and must give the 24 Designating Party an opportunity to review the designated material, to reconsider 25 the circumstances, and, if no change in designation is offered, to explain the basis 26 for the chosen designation. A Challenging Party may proceed to the next stage of 27 the challenge process, pursuant to Local Rules 37-2, 37-3, and 37-4, only if it has 28 engaged in this meet and confer process first or establishes that the Designating 1496784.1 05608-025 6 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 Party is unwilling to participate in the meet and confer process in a timely manner. 2 Under Local Rules 37-2, 37-3, and 37-4, the moving party is the Challenging Party 3 and the opposing party is the Designating Party. The burden of persuasion in any 4 such challenge proceeding shall be on the Designating Party. All parties shall 5 continue to afford the material in question the level of protection to which it is 6 entitled under the Producing Party’s designation until the court rules on the 7 challenge. 8 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 7.1 Basic Principles. A Receiving Party may use Protected Material that LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 case only for prosecuting, defending, or attempting to settle this litigation. Such 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 is disclosed or produced by another Party or by a Non-Party in connection with this 12 Protected Material may be disclosed only to the categories of persons and under the 13 conditions described in this Order. When the litigation has been terminated, a 14 Receiving Party must comply with the provisions of Section 13 below (FINAL 15 DISPOSITION). 16 Protected Material must be stored and maintained by a Receiving Party at a 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 otherwise ordered by the court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 24 employees of said Outside Counsel of Record to whom it is reasonably necessary to 25 disclose the information for this litigation; 26 (b) the officers, directors, and employees (including House Counsel) of the 27 Receiving Party to whom disclosure is reasonably necessary for this litigation and 28 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1496784.1 05608-025 7 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is reasonably necessary for this litigation and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) the court and its personnel; 5 (e) court reporters and their staff, professional jury or trial consultants, mock 6 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this 7 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” 8 (Exhibit A); 9 (f) during their depositions, witnesses in the action to whom disclosure is LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 reasonably necessary and who have signed the “Acknowledgment and Agreement to 12 by the court. Pages of transcribed deposition testimony or exhibits to depositions 13 that reveal Protected Material must be separately bound by the court reporter and 14 may not be disclosed to anyone except as permitted under this Order. 15 (g) the author or recipient of a document containing the information or a 16 custodian or other person who otherwise possessed or knew the information. 17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 18 PRODUCED IN OTHER LITIGATION 19 If a Party is served with a subpoena or a court order issued in other litigation 20 that compels disclosure of any information or items designated in this action as 21 “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such notification shall 23 include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena or order to 25 issue in the other litigation that some or all of the material covered by the subpoena 26 or order is subject to this Protective Order. Such notification shall include a copy of 27 this Stipulated Protective Order; and 28 / / / 1496784.1 05608-025 8 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 (c) cooperate with respect to all reasonable procedures sought to be pursued 2 by the Designating Party whose Protected Material may be affected. If the 3 Designating Party timely seeks a protective order, the Party served with the 4 subpoena or court order shall not produce any information designated in this action 5 as “CONFIDENTIAL” before a determination by the court from which the 6 subpoena or order issued, unless the Party has obtained the Designating Party’s 7 permission. The Designating Party shall bear the burden and expense of seeking 8 protection in that court of its Protected Material – and nothing in these provisions 9 should be construed as authorizing or encouraging a Receiving Party in this action LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 9. 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 to disobey a lawful directive from another court. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 12 PRODUCED IN THIS LITIGATION 13 The terms of this Order are applicable to information produced by a Non- 14 Party in this action and designated as “CONFIDENTIAL.” Such information 15 produced by Non-Parties in connection with this litigation is protected by the 16 remedies and relief provided by this Order. Nothing in these provisions should be 17 construed as prohibiting a Non-Party from seeking additional protections. 18 In the event that a Party is required, by a valid discovery request, to 19 produce a Non-Party’s Protected Material in its possession, and the Party is subject 20 to an agreement with the Non-Party not to produce the Non-Party’s Protected 21 Material, then the Party shall: 22 (a) promptly notify in writing the Requesting Party and the Non-Party that 23 some or all of the information requested is subject to a confidentiality agreement 24 with a Non-Party; 25 (b) promptly provide the Non-Party with a copy of the Stipulated Protective 26 Order in this litigation, the relevant discovery request(s), and a reasonably specific 27 description of the information requested; and 28 / / / 1496784.1 05608-025 9 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 (c) make the information requested available for inspection by the Non-Party. 2 If the Non-Party fails to object or seek a protective order from this court 3 within 14 days of receiving the notice and accompanying information, the Receiving 4 Party may produce the Non-Party’s Protected Material responsive to the discovery 5 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 6 not produce any information in its possession or control that is subject to the 7 confidentiality agreement with the Non-Party before a determination by the court. 8 Absent a court order to the contrary, the Non-Party shall bear the burden and 9 expense of seeking protection in this court of its Protected Material. LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 10. If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Order, the Receiving Party must immediately (a) notify in writing the Designating 14 Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 15 unauthorized copies of the Protected Material, (c) inform the person or persons to 16 whom unauthorized disclosures were made of all the terms of this Order, and (d) 17 request such person or persons to execute the “Acknowledgment and Agreement to 18 Be Bound” that is attached hereto as Exhibit A. Any unauthorized disclosure of 19 Protected Material may constitute contempt of Court. 20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 21 PROTECTED MATERIAL 22 When a Producing Party gives notice to Receiving Parties that certain 23 inadvertently produced material is subject to a claim of privilege or other protection, 24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 26 procedure may be established in an e-discovery order that provides for production 27 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 28 (e), insofar as the parties reach an agreement on the effect of disclosure of a 1496784.1 05608-025 10 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 communication or information covered by the attorney-client privilege or work 2 product protection, the parties may incorporate their agreement in the stipulated 3 protective order submitted to the court subject to the Court’s approval. Nothing in 4 this Order shall be construed to require the production of documents protected from 5 disclosure by the attorney-client privilege and/or the work product doctrine. 6 12. MISCELLANEOUS 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of 8 any person to seek its modification by the court in the future. Nothing in this Order 9 shall be construed as precluding a person from seeking additional protection from LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 including an order that such information not be disclosed or that it be disclosed only 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 the court against the disclosure or production of other commercial information, 12 in a designated way. 13 12.2 Right to Assert Other Objections. By stipulating to the entry of this 14 Order, no Party waives any right it otherwise would have to object to disclosing or 15 producing any information or item on any ground not addressed in Order. Similarly, 16 no Party waives any right to object on any ground to use in evidence of any of the 17 material covered by this Order. 18 12.3 Filing Protected Material. Without written permission from the 19 Designating Party or a court order secured after appropriate notice to all interested 20 persons, a Party may not file in the public record in this action any Protected 21 Material. A Party that seeks to file under seal any Protected Material must comply 22 with Local Rule 79-5. Protected Material may only be filed under seal pursuant to a 23 court order authorizing the sealing of the specific Protected Material at issue. 24 Pursuant to Local Rule 79-5, a sealing order will issue only upon a request 25 establishing that the Protected Material at issue is privileged, protectable as a trade 26 secret, or otherwise entitled to protection under the law. If a Receiving Party's 27 request to file Protected Material under seal pursuant to Local Rule 79-5.2.2(b) is 28 denied by the court, then the Receiving Party may file the information in the public 1496784.1 05608-025 11 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 record pursuant to Local Rule 79-5.2.2(b)(ii) unless otherwise instructed by the 2 court. 3 13. FINAL DISPOSITION 4 Within 60 days after the final disposition of this action, as defined in 5 Section 4, each Receiving Party must return all Protected Material to the Producing 6 Party or destroy such material. As used in this subdivision, “all Protected Material” 7 includes all copies, abstracts, compilations, summaries, and any other format 8 reproducing or capturing any of the Protected Material. Whether the Protected 9 Material is returned or destroyed, the Receiving Party must submit a written LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 Designating Party) by the 60 day deadline that (1) identifies (by category, where 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 certification to the Producing Party (and, if not the same person or entity, to the 12 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 13 that the Receiving Party has not retained any copies, abstracts, compilations, 14 summaries or any other format reproducing or capturing any of the Protected 15 Material. Notwithstanding this provision, Counsel are entitled to retain an archival 16 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 17 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 18 work product, and consultant and expert work product, even if such materials 19 contain Protected Material. Any such archival copies that contain or constitute 20 Protected Material remain subject to this Order as set forth in Section 4, 21 “DURATION.” 22 IT IS SO ORDERED 23 24 DATED: October 21, 2016 25 26 27 United States Magistrate Judge 28 1496784.1 05608-025 12 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AGREEMENT TO BE BOUND 3 I, ______________________, declare as follows: My address is 4 ___________________________, my present occupation is ___________________ 5 and I am currently employed by _______________________. I have been retained 6 by _____________________ with respect to this litigation. I have read in its entirety 7 and understand the Stipulated Protective Order that was issued by the United States 8 District Court for the Central District of California on ______ in the case entitled 9 ___________________________________, case no. ______________. I agree to LOS ANGELES, CALIFORNIA 90017-3623 LAWYERS 11 I understand and acknowledge that failure to so comply could expose me to 707 WILSHIRE BOULEVARD, SUITE 4000 ANDERSON, MCPHARLIN & CONNERS LLP 10 comply with and to be bound by all the terms of this Stipulated Protective Order and 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 Central 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. I hereby appoint 19 __________________ of ___________________ as my California agent for service 20 of process in connection with this action or any proceedings related to enforcement 21 of this Stipulated Protective Order. 22 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 1496784.1 05608-025 13 [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER
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