Stacey Wade-James v. Genzyme Corporation

1 LAAngWel OJ.F HFoICraEcSek O (FS BANN 2G4E5L6 8J0. )H ORACEK, PC 2 angel@horaceklaw.com Iryll Robbins-Umel (SBN 249562) 3 iryll@horaceklaw.com 5701 West Slauson Avenue, Suite 210 4 Culver City, CA 90230 310-774-0323 310-774-3945 fax [5] Attorneys for Plaintiff [6] STACEY WADE-JAMES 7 SEYFARTH SHAW LLP Dana L. Peterson (SBN 178499) 8 dpeterson@seyfarth.com John Ayers-Mann (SBN 348249) 9 jayers-mann@seyfarth.com 2029 Century Park East, Suite 3500 10 Los Angeles, CA 90067-3021 Telephone: (310) 277-7200 11 Facsimile: (310) 201-5219 12 Attorneys for Defendant GENZYME CORPORATION dba SANOFI [14] UNITED STATES DISTRICT COURT [15] CENTRAL DISTRICT OF CALIFORNIA [16] 17 STACEY WADE-JAMES, an individual, Case No. 2:24-cv-01364 ODW-SSC 18 Plaintiff, STIPULATED PROTECTIVE ORDER 19 v. Assigned to Hon. Otis D. Wright, II 20 GENZYME CORPORATION, dba Complaint Filed: January 16, 2024 State Court Case No.: 24STCV01147 21 SANOFI, a corporation, and DOES 1 to 20, inclusive, Removal Date: February 20, 2024 [22] Defendants. Trial Date: June 10, 2025 [28] 1 1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 production of confidential or private information for which special protection from 4 public disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter 6 the following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that the 8 protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable legal 10 principles. 11 1.2 Good Cause Statement. 12 This action may involve medical information about Plaintiff, private information 13 about other employees, and sensitive commercial information for which special 14 protection from public disclosure and from use for any purpose other than prosecution of 15 this action is warranted. Such confidential materials and information consist of, among 16 other things, information pertaining to medical care, private details about other Sanofi 17 employees, and sensitive commercial information otherwise generally unavailable to the 18 public, or which may be privileged or otherwise protected from disclosure under state or 19 federal statutes, court rules, case decisions, or common law. Accordingly, to expedite 20 the flow of information, to facilitate the prompt resolution of disputes over 21 confidentiality of discovery materials, to adequately protect information the parties are 22 entitled to keep confidential, to ensure that the parties are permitted reasonable necessary 23 uses of such material in preparation for and in the conduct of trial, to address their 24 handling at the end of the litigation, and serve the ends of justice, a protective order for 25 such information is justified in this matter. It is the intent of the parties that information 26 will not be designated as confidential for tactical reasons and that nothing be so 27 designated without a good faith belief that it has been maintained in a confidential, non28 1 public manner, and there is good cause why it should not be part of the public record of 2 this case. 3 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties further 4 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 5 does not entitle them to file confidential information under seal; Local Rule 79-5 sets 6 forth the procedures that must be followed and the standards that will be applied when a 7 party seeks permission from the court to file material under seal. 8 There is a strong presumption that the public has a right of access to judicial 9 proceedings and records in civil cases. In connection with non-dispositive motions, 10 good cause must be shown to support a filing under seal. See Kamakana v. City and 11 Cnty. of Honolulu, 447 F.3d 1172 , 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. 12 Gen. Motors Corp., 307 F.3d 1206 , 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 13 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 14 require good cause showing), and a specific showing of good cause or compelling 15 reasons with proper evidentiary support and legal justification, must be made with 16 respect to Protected Material that a party seeks to file under seal. The parties’ mere 17 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 18 without the submission of competent evidence by declaration, establishing that the 19 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 20 protectable—constitute good cause. 21 Further, if a party requests sealing related to a dispositive motion or trial, then 22 compelling reasons, not only good cause, for the sealing must be shown, and the relief 23 sought shall be narrowly tailored to serve the specific interest to be protected. See 24 Pintos v. Pac. Creditors Ass’n, 605 F.3d 665 , 677–79 (9th Cir. 2010). For each item or 25 type of information, document, or thing sought to be filed or introduced under seal in 26 connection with a dispositive motion or trial, the party seeking protection must 27 articulate compelling reasons, supported by specific facts and legal justification, for the [28] 1 requested sealing order. Again, competent evidence supporting the application to file 2 documents under seal must be provided by declaration. 3 Any document that is not confidential, privileged, or otherwise protectable in its 4 entirety will not be filed under seal if the confidential portions can be redacted. If 5 documents can be redacted, then a redacted version for public viewing, omitting only 6 the confidential, privileged, or otherwise protectable portions of the document, shall be 7 filed. Any application that seeks to file documents under seal in their entirety should 8 include an explanation of why redaction is not feasible. 9 2. DEFINITIONS 10 2.1 Action: Stacey Wade-James v. Genzyme Corporation dba Sanofi. . 11 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 12 information or items under this Order. 13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 14 is generated, stored or maintained) or tangible things that qualify for protection under 15 Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in the Good 16 Cause Statement. 17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 18 support staff). 19 2.5 Designating Party: a Party or Non-Party that designates information or 20 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 21 2.6 Disclosure or Discovery Material: all items or information, regardless of the 22 medium or manner in which it is generated, stored, or maintained (including, among 23 other things, testimony, transcripts, and tangible things), that are produced or generated 24 in disclosures or responses to discovery in this matter. 25 2.7 Expert: a person with specialized knowledge or experience in a matter 26 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 27 expert witness or as a consultant in this Action. [28] 1 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 2 this Action, with or without prejudice; and (2) final judgment herein after the completion 3 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 4 including the time limits for filing any motions or applications for extension of time 5 pursuant to applicable law. 6 2.9 In-House Counsel: attorneys who are employees of a party to this Action. 7 In-House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 2.10 Non-Party: any natural person, partnership, corporation, association, or 10 other legal entity not named as a Party to this action. 11 2.11 Outside Counsel of Record: attorneys who are not employees of a party to 12 this Action but are retained to represent or advise a party to this Action and have 13 appeared in this Action on behalf of that party or are affiliated with a law firm which has 14 appeared on behalf of that party, and includes support staff. 15 2.12 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.14 Professional Vendors: persons or entities that provide litigation- support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 23 their employees and subcontractors. 24 2.15 Protected Material: any Disclosure or Discovery Material that is designated 25 as “CONFIDENTIAL.” 26 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 27 from a Producing Party. [28] 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only Protected 3 Material (as defined above), but also (1) any information copied or extracted from 4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 5 Material; and (3) any testimony, conversations, or presentations by Parties or their 6 Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the trial 8 judge. This Stipulated Protective Order does not govern the use of Protected Material 9 at trial. 10 4. TRIAL AND DURATION 11 The terms of this Stipulated Protective Order apply through Final Disposition of 12 the Action. 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and used 15 or introduced as an exhibit at trial becomes public and will be presumptively available 16 to all members of the public, including the press, unless compelling reasons supported 17 by specific factual findings to proceed otherwise are made to the trial judge in advance 18 of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing 19 for sealing documents produced in discovery from “compelling reasons” standard when 20 merits-related documents are part of court record). Accordingly, for such materials, the 21 terms of this Stipulated Protective Order do not extend beyond the commencement of 22 the trial. 23 Even after Final Disposition of this litigation, the confidentiality obligations 24 imposed by this Stipulated Protective Order shall remain in effect until a Designating 25 Party agrees otherwise in writing or a court order otherwise directs. 26 5. DESIGNATING PROTECTED MATERIAL 27 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each [28] 1 Party or Non-Party that designates information or items for protection under this Order 2 must take care to limit any such designation to specific material that qualifies under the 3 appropriate standards. The Designating Party must designate for protection only those 4 parts of material, documents, items, or oral or written communications that qualify so 5 that other portions of the material, documents, items, or communications for which 6 protection is not warranted are not swept unjustifiably within the ambit of this Order. 7 Mass, indiscriminate, or routinized designations are prohibited. Designations that 8 are shown to be clearly unjustified or that have been made for an improper purpose 9 (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating Party 11 to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in this 16 Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), or as 17 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 18 protection under this Stipulated Protective Order must be clearly so designated before 19 the material is disclosed or produced. 20 Designation in conformity with this Stipulated Protective Order requires: 21 (a) for information in documentary form (e.g., paper or electronic documents, 22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” to each page that 24 contains protected material. If only a portion or portions of the material on a page 25 qualifies for protection, the Producing Party also must clearly identify the protected 26 portion(s) (e.g., by making appropriate markings in the margins). 27 A Party or Non-Party that makes original documents available for inspection [28] 1 need not designate them for protection until after the inspecting Party has indicated 2 which documents it would like copied and produced. During the inspection and before 3 the designation, all of the material made available for inspection shall be deemed 4 CONFIDENTIAL. After the inspecting Party has identified the documents it wants 5 copied and produced, the Producing Party must determine which documents, or 6 portions thereof, qualify for protection under this Stipulated Protective Order. Then, 7 before producing the specified documents, the Producing Party must affix the 8 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 9 portion or portions of the material on a page qualifies for protection, the Producing 10 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 11 markings in the margins). 12 (b) for testimony given in depositions that the Designating Party identify the 13 Disclosure or Discovery Material on the record, before the close of the deposition all 14 protected testimony. 15 (c) for information produced in some form other than documentary and for 16 any other tangible items, that the Producing Party affix in a prominent place on the 17 exterior of the container or containers in which the information is stored the 18 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants 19 protection, the Producing Party, to the extent practicable, shall identify the protected 20 portion(s). 21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 22 failure to designate qualified information or items does not, standing alone, waive the 23 Designating Party’s right to secure protection under this Order for such material. Upon 24 timely correction of a designation, the Receiving Party must make reasonable efforts to 25 assure that the material is treated in accordance with the provisions of this Stipulated 26 Protective Order. [28] 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 Scheduling 4 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.”1 8 6.3 The burden of persuasion in any such challenge proceeding shall be on the 9 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 10 to harass or impose unnecessary expenses and burdens on other parties) may expose the 11 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 12 the confidentiality designation, all parties shall continue to afford the material in 13 question the level of protection to which it is entitled under the Producing Party’s 14 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 reaches a Final Disposition, a 21 Receiving Party must comply with the provisions of section 13 below. 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 Stipulated Protective Order. 25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise [26] 27 1 Judge Christensen’s Procedures are available at https://www.cacd.uscourts.gov/honorable-stephanie-s-christensen. [28] 1 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 2 may disclose any information or item designated “CONFIDENTIAL” only: 3 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as well 4 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 5 disclose the information for this Action; 6 (b) to the officers, directors, and employees (including House Counsel) of the 7 Receiving Party to whom disclosure is reasonably necessary for this Action; 8 (c) to Experts (as defined in this Order) of the Receiving Party to whom 9 disclosure is reasonably necessary for this Action and who have signed the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (d) to the court and its personnel; 12 (e) to court reporters and their staff; 13 (f) to professional jury or trial consultants, mock jurors, and Professional 14 Vendors to whom disclosure is reasonably necessary for this Action and who have 15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (g) to the author or recipient of a document containing the information or a 17 custodian or other person who otherwise possessed or knew the information; 18 (h) during their depositions, to witnesses, and attorneys for witnesses, in the 19 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party 20 requests that the witness sign the “Acknowledgment and Agreement to Be Bound” 21 (Exhibit A); and (2) the witness will not be permitted to keep any confidential 22 information unless they sign the “Acknowledgment and Agreement to Be Bound” 23 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. 24 Pages of transcribed deposition testimony or exhibits to depositions that reveal 25 Protected Material may be separately bound by the court reporter and may not be 26 disclosed to anyone except as permitted under this Stipulated Protective Order; and 27 (i) to any mediator or settlement officer, and their supporting personnel, [28] 1 mutually agreed upon by any of the parties engaged in settlement discussions. [2] 3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 4 IN OTHER LITIGATION 5 If a Party is served with a subpoena or a court order issued in other litigation that 6 compels disclosure of any information or items designated in this Action as 7 “CONFIDENTIAL,” that Party must: 8 (a) promptly notify in writing the Designating Party. Such notification shall 9 include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or order to 11 issue in the other litigation that some or all of the material covered by the subpoena or 12 order is subject to this Protective Order. Such notification shall include a copy of this 13 Stipulated Protective Order; and 14 (c) cooperate with respect to all reasonable procedures sought to be pursued by 15 the Designating Party whose Protected Material may be affected. 16 If the Designating Party timely seeks a protective order, the Party served with 17 the subpoena or court order shall not produce any information designated in this action 18 as “CONFIDENTIAL” before a determination by the court from which the subpoena or 19 order issued, unless the Party has obtained the Designating Party’s permission. The 20 Designating Party shall bear the burden and expense of seeking protection in that court 21 of its confidential material and nothing in these provisions should be construed as 22 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 23 directive from another court. 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25 PRODUCED IN THIS LITIGATION 26 9.1 Application. The terms of this Stipulated Protective Order are applicable to 27 information produced by a Non-Party in this Action and designated as [28] 1 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this 2 litigation is protected by the remedies and relief provided by this Order. Nothing in 3 these provisions should be construed as prohibiting a Non-Party from seeking additional 4 protections. 5 9.2 Notification. In the event that a Party is required, by a valid discovery 6 request, to produce a Non-Party’s confidential information in its possession, and the 7 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 8 confidential information, then the Party shall: 9 (a) promptly notify in writing the Requesting Party and the Non-Party that 10 some or all of the information requested is subject to a confidentiality agreement with a 11 Non-Party; 12 (b) make the information requested available for inspection by the Non-Party, 13 if requested. 14 9.3 Conditions of Production. If the Non-Party fails to seek a protective order 15 from this court within 14 days of receiving the notice and accompanying information, 16 the Receiving Party may produce the Non-Party’s confidential information responsive to 17 the discovery request. If the Non-Party timely seeks a protective order, the Receiving 18 Party shall not produce any information in its possession or control that is subject to the 19 confidentiality agreement with the Non-Party before a determination by the court. 20 Absent a court order to the contrary, the Non-Party shall bear the burden and expense of 21 seeking protection in this court of its Protected Material. 22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 Protected Material to any person or in any circumstance not authorized under this 25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 26 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 27 all unauthorized copies of the Protected Material, (c) inform the person or persons to [28] 1 whom unauthorized disclosures were made of all the terms of this Order, and (d) 2 request such person or persons to execute the “Acknowledgment and Agreement to Be 3 Bound” (Exhibit A). [4] 5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 PROTECTED MATERIAL 7 When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other protection, the 9 obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 10 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 11 procedure may be established in an e-discovery order that provides for production 12 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules of 13 Evidence, insofar as the parties reach an agreement on the effect of disclosure of a 14 communication or information covered by the attorney-client privilege or work product 15 protection, the parties may incorporate their agreement in the stipulated protective order 16 submitted to the court. 17 12. MISCELLANEOUS 18 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 19 abridges the right of any person to seek its modification by the court in the future. 20 12.2 Right to Assert Other Objections. By stipulating to the entry of this 21 Stipulated Protective Order no Party waives any right it otherwise would have to object 22 to disclosing or producing any information or item on any ground not addressed in this 23 Stipulated Protective Order. Similarly, no Party waives any right to object on any 24 ground to use in evidence of any of the material covered by this Stipulated Protective 25 Order. 26 12.3 Filing Protected Material. A Party that seeks to file under seal any 27 Protected Material must comply with Local Rule 79-5. Protected Material may only be [28] 1 filed under seal pursuant to a court order authorizing the sealing of the specific 2 Protected Material at issue. If a Party's request to file Protected Material under seal is 3 denied by the court, then the Receiving Party may file the information in the public 4 record unless otherwise instructed by the court. [5] 6 13. FINAL DISPOSITION 7 After the Final Disposition of this Action, as defined in paragraph 4, within 60 8 days of a written request by the Designating Party, each Receiving Party must return all 9 Protected Material to the Producing Party or destroy such material. As used in this 10 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 11 summaries, and any other format reproducing or capturing any of the Protected 12 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 13 must submit a written certification to the Producing Party (and, if not the same person 14 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 15 category, where appropriate) all the Protected Material that was returned or destroyed 16 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 17 compilations, summaries or any other format reproducing or capturing any of the 18 Protected Material. Notwithstanding this provision, Counsel is entitled to retain an 19 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 20 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 21 work product, and consultant and expert work product, even if such materials contain 22 Protected Material. Any such archival copies that contain or constitute Protected 23 Material remain subject to this Protective Order as set forth in Section 4. [28] 1 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished by any and all 3 appropriate measures including, without limitation, contempt proceedings and/or 4 monetary sanctions. [5] 6 SIGNATURE ATTESTATION 7 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, John Ayers-Mann, attest that all 8 signatories listed, and on whose behalf this filing is submitted, concur in the filing’s 9 content and have authorized the filing. [10] 11 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. [12] 13 Dated: February 6, 2025 LAW OFFICES OF ANGEL J. HORACEK, PC [14] 15 /s/ Angel J. Horacek Angel J. Horacek 16 Iryll Robbins-Umel 17 Attorneys for Plaintiff Stacey Wade-James [18] 19 Dated: February 6, 2025 SEYFARTH SHAW LLP [20] /s/ John Ayers-Mann 21 Dana L. Peterson John Ayers-Mann [22] Attorneys for Defendant 23 GENZYME CORPORATION, dba SANOFI [28] 1 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. [2] : Z— 4 || DATED: February 7, 2025 5 STEPHANIE 8. CHRISTENSEN 6 United States Magistrate Judge [27] 28 16 sieuieiiet STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND [3] 4 I, ________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury that 6 I have read in its entirety and understand the Stipulated Protective Order that was issued 7 by the United States District Court for the Central District of California on [date] in the 8 case of __________ [insert formal name of the case and the number and initials 9 assigned to it by the court]. I agree to comply with and to be bound by all the terms of 10 this Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that is 13 subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court 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. I hereby appoint ________________________ [print or type 19 full name] of _________ [print or type full address and telephone number] as my 20 California agent for service of process in connection with this action or any proceedings 21 related to enforcement of this Stipulated Protective Order. [22] 23 Date: ___________________________ 24 City and State where sworn and 25 signed: ___________________________ 26 Printed name: ___________________________ 27 Signature: ___________________________