Randall Roskelly v. County of Riverside

GRECH, PACKER, & HANKS 1 Trenton C. Packer (SBN 241057) tpacker@grechpackerlaw.com 2 7095 Indiana Ave Ste 200 Riverside, CA 92506 3 Phone: (951) 682-9311 Attorneys for Plaintiff RANDALL ROSKELLY [4] Christopher P. Wesierski [Bar No. 086736] 5 cwesierski@wzllp.com Michelle R. Prescott [Bar No. 262638] 6 mprescott@wzllp.com WESIERSKI & ZUREK LLP 7 29 Orchard Road Lake Forest, California 92630 8 Telephone: (949) 975-1000 Facsimile: (949) 756-0517 [9] Attorneys for Defendants [10] COUNTY OF RIVERSIDE and MICHAEL HEUER [13] UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA [16] RANDALL ROSKELLY, 17 Case No.: 5:25-cv-00888-JGB-DTB Plaintiff, [18] v. [Honorable District Judge, Jesus G. 19 Bernal, Magistrate Judge, David T. Bristow] 20 COUNTY OF RIVERSIDE; MICHAEL HEUER; and DOES 1-10, 21 inclusive, JOINT STIPULATION FOR A 22 Defendants. PROTECTIVE ORDER 23 DISCOVERY MATTER [27] 1 TO THE HONORABLE COURT: 2 Plaintiff RANDALL ROSKELLY, along with Defendants COUNTY OF 3 RIVERSIDE and MICHAEL HEUER, hereby submit the following stipulation for a 4 protective order. 5 Plaintiff and Defendants submit this stipulation and proposed stipulated 6 protective order so that the parties may carry out their obligations pursuant to Rule 7 26. [8] 9 Respectfully Submitted, 10 DATED: July 15, 2025 GRECH, PACKER, & HANKS [11] By: /s/ Trenton C. Packer 12 Trenton C. Packer, Esq. Attorneys for Plaintiff RANDALL [13] ROSKELLY [14] DATED: July 14, 2025 WESIERSKI & ZUREK LLP [17] By: /s/ Michelle R. Prescott [18] MICHELLE R. PRESCOTT 19 Attorneys for Defendants COUNTY OF RIVERSIDE and MICHAEL HEUER [3] UNITED STATES DISTRICT COURT [4] CENTRAL DISTRICT OF CALIFORNIA [6] 7 RANDALL ROSKELLY, C a s e N o .: 5:25-cv-00888-JGB-DTB 8 Plaintiff, 9 v. [Honorable District Judge, Jesus G. Bernal, Magistrate Judge, David T. 10 COUNTY OF RIVERSIDE; Bristow] MICHAEL HEUER; and DOES 1-10, 11 inclusive, 12 Defendants. JOINT STIPULATION FOR A PROTECTIVE ORDER [13] DISCOVERY MATTER [15] 16 1. PURPOSES AND LIMITATIONS 17 Disclosure and discovery activity in this action are likely to involve production 18 of confidential, proprietary, or private information for which special protection from 19 public disclosure and from use for any purpose other than prosecuting this litigation 20 may be warranted. Accordingly, the parties hereby stipulate to and petition the court 21 to enter the following Stipulated Protective Order. The parties acknowledge that this 22 Order does not confer blanket protections on all disclosures or responses to discovery 23 and that the protection it affords from public disclosure and use extends only to the 24 limited information or items that are entitled to confidential treatment under the 25 applicable legal principles. The parties further acknowledge, as set forth in Section 26 13.3, below, that this Stipulated Protective Order does not entitle them to file 27 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 1 that must be followed and the standards that will be applied when a party seeks 2 permission from the court to file material under seal. 3 2. GOOD CAUSE STATEMENT 4 Pursuant to Federal Rule of Civil Procedure 26(c), the Court recognizes that 5 pre-trial discovery in this case is likely to include the production of information 6 and/or documents that are confidential and/or privileged including the production of 7 information and/or documents which the Court agrees includes: (1) Personal data, 8 including but not limited to social security numbers and similar sensitive identifying 9 information, marital status, family members, educational and employment history, 10 home addresses, or similar information; (2) Medical and/or mental health history; 11 and (3) Medical Reports and Photographs. See Sanchez v. City of Santa Ana, 936 12 F.2d 1027 , 1033 (9th Cir. 1990); see also Kerr v. United States Dist. Ct. for N.D. 13 Cal., 511 F.2d 192, 198 (9th Cir. 1975), aff’d, 426 U.S. 394 (1976). Further, the 14 Court recognizes that discovery may require the production of certain law 15 enforcement records, policies, and procedures not available to the public and the 16 public disclosure of which could comprise officer safety, raise security issues, 17 and/or impede investigations. 18 Public disclosure of such material may pose a substantial risk of 19 embarrassment, oppression and/or physical harm to the individuals whose 20 Confidential Information is disclosed. Accordingly, good cause exists for entry of this 21 Protective Order to facilitate pre-trial disclosure while assuring the safety of these 22 sensitive disclosures. See Fed. R. Civ. Proc. 26(c). [23] 3. DEFINITIONS [24] 3.1 Action: this pending federal lawsuit. [25] 3.2 Challenging Party: a Party that challenges the designation of [26] information or items under this Order. [27] 3.3 “CONFIDENTIAL” Information or Items: information (regardless of 1 how it is generated, stored or maintained) or tangible things that qualify for protection 2 under Federal Rule of Civil Procedure 26(c). 3 3.4 Counsel (without qualifier): Outside Counsel of Record and House 4 Counsel (as well as their support staff). 5 3.5 Designating Party: a Party or Non-Party that designates information or 6 items that it produces in disclosures or in responses to discovery as 7 “CONFIDENTIAL.” 8 3.6 Disclosure or Discovery Material: all items or information, regardless of 9 the medium or manner in which it is generated, stored, or maintained (including, 10 among other things, testimony, transcripts, and tangible things), that are produced or 11 generated in disclosures or responses to discovery in this matter. 12 3.7 Expert: a person with specialized knowledge or experience in a matter 13 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 14 expert witness or as a consultant in this action. 15 3.8 House Counsel: attorneys who are employees of a party to this action. 16 House Counsel does not include Outside Counsel of Record or any other outside 17 counsel. 18 3.9 Non-Party: any natural person, partnership, corporation, association, or 19 other legal entity not named as a Party to this action. 20 3.10 Outside Counsel of Record: attorneys who are not employees of a party 21 to this action but are retained to represent or advise a party to this action and have 22 appeared in this action on behalf of that party or are affiliated with a law firm which 23 has appeared on behalf of that party. 24 3.11 Party: any party to this action, including all of its officers, directors, 25 employees, consultants, retained experts, and Outside Counsel of Record (and their 26 support staffs). 27 3.12 Producing Party: a Party or Non-Party that produces Disclosure or 1 3.13 Professional Vendors: persons or entities that provide litigation support 2 services (e.g., photocopying, videotaping, translating, preparing exhibits or 3 demonstrations, and organizing, storing, or retrieving data in any form or medium) 4 and their employees and subcontractors. 5 3.14 Protected Material: any Disclosure or Discovery Material that is 6 designated as “CONFIDENTIAL.” 7 3.15 Receiving Party: a Party that receives Disclosure or Discovery Material 8 from a Producing Party. 9 4. SCOPE 10 The protections conferred by this Stipulation and Order cover not only 11 Protected Material (as defined above), but also (1) any information copied or extracted 12 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 13 Protected Material; and (3) any testimony, conversations, or presentations by Parties 14 or their Counsel that might reveal Protected Material. However, the protections 15 conferred by this Stipulation and Order do not cover the following information: (a) 16 any information that is in the public domain at the time of disclosure to a Receiving 17 Party or becomes part of the public domain after its disclosure to a Receiving Party as 18 a result of publication not involving a violation of this Order, including becoming part 19 of the public record through trial or otherwise; and (b) any information known to the 20 Receiving Party prior to the disclosure or obtained by the Receiving Party after the 21 disclosure from a source who obtained the information lawfully and under no 22 obligation of confidentiality to the Designating Party. Any use of Protected Material at 23 trial shall be governed by a separate agreement or order. [24] 5. DURATION [25] Once a case proceeds to trial, all the information and documents used during [26] trial that was designated as confidential or maintained under this Order becomes [27] public and will be presumptively available to all members of the public, including the 1 press, unless the trial judge finds compelling reasons to proceed otherwise. See 2 Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172 , 1180-81 (9th Cir. 2006) 3 (distinguishing “good cause” showing for sealing documents produced in discovery 4 from “compelling reasons” needed for merits-related documents). Accordingly, the 5 terms of this Order do not extend beyond the beginning of trial. 6 Even after final disposition of this litigation, the confidentiality obligations 7 imposed by this Order shall remain in effect until a Designating Party agrees 8 otherwise in writing or a court order otherwise directs. Final disposition shall be 9 deemed to be the later of (1) dismissal of all claims and defenses in this action, with or 10 without prejudice; and (2) final judgment herein after the completion and exhaustion 11 of all appeals, rehearings, remands, trials, or reviews of this action, including the time 12 limits for filing any motions or applications for extension of time pursuant to 13 applicable law. 14 6. DESIGNATING PROTECTED MATERIAL 15 6.1 Exercise of Restraint and Care in Designating Material for Protection. 16 Each Party or Non-Party that designates information or items for protection 17 under this Order must take care to limit any such designation to specific material that 18 qualifies under the appropriate standards. The Designating Party must designate for 19 protection only those parts of material, documents, items, or oral or written 20 communications that qualify – so that other portions of the material, documents, 21 items, or communications for which protection is not warranted are not swept 22 unjustifiably within the ambit of this Order. 23 Mass, indiscriminate, or routinized designations are prohibited. Designations 24 that are shown to be clearly unjustified or that have been made for an improper 25 purpose (e.g., to unnecessarily encumber or retard the case development process or to 26 impose unnecessary expenses and burdens on other parties) expose the Designating 27 Party to sanctions. 1 designated for protection do not qualify for protection, that Designating Party must 2 promptly notify all other Parties that it is withdrawing the mistaken designation. 3 6.2 Manner and Timing of Designations. Except as otherwise provided in 4 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 5 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 6 under this Order must be clearly so designated before the material is disclosed or 7 produced. 8 Designation in conformity with this Order requires: 9 (a) For information in documentary form (e.g., paper or electronic 10 documents, but excluding transcripts of depositions or other pretrial or trial 11 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each 12 page that contains protected material. If only a portion or portions of the material on a 13 page qualifies for protection, the Producing Party also must clearly identify the 14 protected portion(s) (e.g., by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents or materials available for 16 inspection need not designate them for protection until after the inspecting Party has 17 indicated which material it would like copied and produced. During the inspection and 18 before the designation, all of the material made available for inspection shall be 19 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 20 it wants copied and produced, the Producing Party must determine which documents, 21 or portions thereof, qualify for protection under this Order. Then, before producing the 22 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend 23 to each page that contains Protected Material. If only a portion or portions of the 24 material on a page qualifies for protection, the Producing Party also must clearly 25 identify the protected portion(s) (e.g., by making appropriate markings in the 26 margins). 27 (b) for testimony given in deposition or in other pretrial or trial 1 deposition, hearing, or other proceeding, all protected testimony. 2 (c) for information produced in some form other than documentary 3 and for any other tangible items, that the Producing Party affix in a prominent place 4 on the exterior of the container or containers in which the information or item is stored 5 the legend “CONFIDENTIAL.” If only a portion or portions of the information or 6 item warrant protection, the Producing Party, to the extent practicable, shall identify 7 the protected portion(s). For electronically stored and transmitted files, the 8 Designating Party must include in the file name the “Confidential” designation. Any 9 party reproducing electronically stored and transmitted materials (e.g., printing copies) 10 not already designated “Confidential” shall label the material “Confidential” before 11 using or transmitting the material. 12 6.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 13 failure to designate qualified information or items does not, standing alone, waive the 14 Designating Party’s right to secure protection under this Order for such material. 15 Upon timely correction of a designation, the Receiving Party must make reasonable 16 efforts to assure that the material is treated in accordance with the provisions of this 17 Order. 18 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 19 7.1 Timing of Challenges. Any Party may challenge a designation of 20 confidentiality at any time. Unless a prompt challenge to a Designating Party’s 21 confidentiality designation is necessary to avoid foreseeable, substantial unfairness, 22 unnecessary economic burdens, or a significant disruption or delay of the litigation, a 23 Party does not waive its right to challenge a confidentiality designation by electing not 24 to mount a challenge promptly after the original designation is disclosed. 25 7.2 Meet and Confer. The Challenging Party shall initiate the dispute 26 resolution process by providing written notice of each designation it is challenging 27 and describing the basis for each challenge. To avoid ambiguity as to whether a 1 confidentiality is being made in accordance with this specific paragraph of the 2 Protective Order. The parties shall attempt to resolve each challenge in good faith and 3 must begin the process by conferring directly (in voice to voice dialogue; other forms 4 of communication are not sufficient) within 14 days of the date of service of notice. In 5 conferring, the Challenging Party must explain the basis for its belief that the 6 confidentiality designation was not proper and must give the Designating Party an 7 opportunity to review the designated material, to reconsider the circumstances, and, if 8 no change in designation is offered, to explain the basis for the chosen designation. A 9 Challenging Party may proceed to the next stage of the challenge process only if it has 10 engaged in this meet and confer process first or establishes that the Designating Party 11 is unwilling to participate in the meet and confer process in a timely manner. 12 8. ACCESS TO AND USE OF PROTECTED MATERIAL 13 8.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this case 15 only for prosecuting, defending, or attempting to settle this litigation. Such Protected 16 Material may be disclosed only to the categories of persons and under the conditions 17 described in this Order. When the litigation has been terminated, a Receiving Party 18 must comply with the provisions of section 14 below (FINAL DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 8.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 25 only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this action, as well 27 as employees of said Outside Counsel of Record to whom it is reasonably necessary 1 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 2 A; 3 (b) the officers, directors, and employees (including House Counsel) of the 4 Receiving Party to whom disclosure is reasonably necessary for this litigation and 5 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (c) Experts (as defined in this Order) of the Receiving Party to whom 7 disclosure is reasonably necessary for this litigation and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (d) the court and its personnel; 10 (e) court reporters and their staff, professional jury or trial consultants, 11 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary 12 for this litigation and who have signed the “Acknowledgment and Agreement to Be 13 Bound” (Exhibit A); 14 (f) during their depositions, witnesses in the action to whom disclosure is 15 reasonably necessary and who have signed the “Acknowledgment and Agreement to 16 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered 17 by the court. Pages of transcribed deposition testimony or exhibits to depositions 18 that reveal Protected Material must be separately bound by the court reporter and 19 may not be disclosed to anyone except as permitted under this Stipulated Protective 20 Order. 21 (g) the author or recipient of a document containing the information or a 22 custodian or other person who otherwise possessed or knew the information. 23 (h) any mediator or settlement officer, and their supporting personnel, 24 mutually agreed upon by any of the parties engaged in settlement discussions. 25 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 26 OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation 1 “CONFIDENTIAL,” that Party must: 2 (a) promptly notify in writing the Designating Party. Such notification 3 shall include a copy of the subpoena or court order; 4 (b) promptly notify in writing the party who caused the subpoena or order 5 to issue in the other litigation that some or all of the material covered by the 6 subpoena or order is subject to this Protective Order. Such notification shall include 7 a copy of this Stipulated Protective Order; and 8 (c) cooperate with respect to all reasonable procedures sought to be 9 pursued by the Designating Party whose Protected Material may be affected. 10 If the Designating Party timely seeks a protective order, the Party served with 11 the subpoena or court order shall not produce any information designated in this 12 action as “CONFIDENTIAL” before a determination by the court from which the 13 subpoena or order issued, unless the Party has obtained the Designating Party’s 14 permission. The Designating Party shall bear the burden and expense of seeking 15 protection in that court of its confidential material – and nothing in these provisions 16 should be construed as authorizing or encouraging a Receiving Party in this action 17 to disobey a lawful directive from another court. 18 10. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 19 IN THIS LITIGATION 20 (a) The terms of this Order are applicable to information produced by a 21 Non-Party in this action and designated as “CONFIDENTIAL.” Such information 22 produced by Non-Parties in connection with this litigation is protected by the 23 remedies and relief provided by this Order. Nothing in these provisions should be 24 construed as prohibiting a Non-Party from seeking additional protections. 25 (b) In the event that a Party is required, by a valid discovery request, to 26 produce a Non-Party’s confidential information in its possession, and the Party is 27 subject to an agreement with the Non-Party not to produce the Non-Party’s 1 (1) promptly notify in writing the Requesting Party and the Non2 Party that some or all of the information requested is subject to a confidentiality 3 agreement with a Non-Party; 4 (2) promptly provide the Non-Party with a copy of the Stipulated 5 Protective Order in this litigation, the relevant discovery request(s), and a 6 reasonably specific description of the information requested; and 7 (3) make the information requested available for inspection by the 8 Non-Party. 9 (c) If the Non-Party fails to object or seek a protective order from this 10 court within 14 days of receiving the notice and accompanying information, the 11 Receiving Party may produce the Non-Party’s confidential information responsive 12 to the discovery request. If the Non-Party timely seeks a protective order, the 13 Receiving Party shall not produce any information in its possession or control that is 14 subject to the confidentiality agreement with the Non-Party before a determination 15 by the court. Absent a court order to the contrary, the Non-Party shall bear the 16 burden and expense of seeking protection in this court of its Protected Material. 17 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 18 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 19 Protected Material to any person or in any circumstance not authorized under this 20 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 21 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 22 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 23 persons to whom unauthorized disclosures were made of all the terms of this Order, 24 and (d) request such person or persons to execute the “Acknowledgment and 25 Agreement to Be Bound” that is attached hereto as Exhibit A. [27] 1 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 7 may be established in an e-discovery order that provides for production without 8 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 9 as the parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 parties may incorporate their agreement in the stipulated protective order submitted 12 to the court. 13 13. MISCELLANEOUS 14 13.1 Right to Further Relief. Nothing in this Order abridges the right of any 15 person to seek its modification by the court in the future. 16 13.2 Right to Assert Other Objections. By stipulating to the entry of this 17 Protective Order no Party waives any right it otherwise would have to object to 18 disclosing or producing any information or item on any ground not addressed in this 19 Stipulated Protective Order. Similarly, no Party waives any right to object on any 20 ground to use in evidence of any of the material covered by this Protective Order. 21 13.3 Filing Protected Material. Without written permission from the 22 Designating Party or a court order secured after appropriate notice to all interested 23 persons, a Party may not file in the public record in this action any Protected Material. 24 A Party that seeks to file under seal any Protected Material must comply with Civil 25 Local Rule 79-5. Protected Material may only be filed under seal pursuant to a court 26 order authorizing the sealing of the specific Protected Material at issue. Pursuant to 27 Civil Local Rule 79.5, a sealing order will issue only upon a request establishing that 1 entitled to protection under the law. If a Receiving Party's request to file Protected 2 Material under seal pursuant to Civil Local Rule 79.5 is denied by the court, then the 3 Receiving Party may file the information in the public record unless otherwise 4 instructed by the court. 5 14. FINAL DISPOSITION 6 Within 90 days after the final disposition of this action, as defined in 7 paragraph 5, upon written notification served by Producing or Designating Party, 8 each Receiving Party must return all Protected Material to the Producing Party or 9 destroy such material. As used in this subdivision, “all Protected Material” includes 10 all copies, abstracts, compilations, summaries, and any other format reproducing or 11 capturing any of the Protected Material. Whether the Protected Material is returned 12 or destroyed, the Receiving Party must submit a written certification to the 13 Producing Party (and, if not the same person or entity, to the Designating Party) by 14 the 90 day deadline that (1) identifies (by category, where appropriate) all the 15 Protected Material that was returned or destroyed and (2) affirms that the Receiving 16 Party has not retained any copies, abstracts, compilations, summaries or any other 17 format reproducing or capturing any of the Protected Material. Notwithstanding this 18 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 19 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 20 deposition and trial exhibits, expert reports, attorney work product, and consultant 21 and expert work product, even if such materials contain Protected Material. Any 22 such archival copies that contain or constitute Protected Material remain subject to 23 this Protective Order as set forth in Section 5 (DURATION). [27] 1 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. [2] 3 || DATED: July 15, 2025 GRECH, PACKER, & HANKS [4] By: /s/ Trenton C. Packer 5 Trenton C. Packer, Esq. 6 Attorneys for Plaintiff RANDALL ROSKELLY [8] 9 || DATED: July 14, 2025 WESIERSKI & ZUREK LLP [11] 12 By: /s/ Michelle R. Prescott MICHELLE R. PRESCOTT 13 Attorneys for Defendants COUNTY OF 14 RIVERSIDE and MICHAEL HEUER [15] 16 || PURSUANT TO STIPULATION, IT IS SO ORDERED. [18] DATED: July 15, 2025 : 19 HONO E DXVID T. BRISTOW 50 United States District Magistrate Judge [28] 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 __________________________ [print or type full address], declare under penalty of 5 perjury that I have read in its entirety and understand the Stipulated Protective Order 6 that was issued by the United States District Court for the Central District of 7 California on ____________________[date] in the case of Randall Roskelly v. 8 County of Riverside et al., Case No. Case No.: 5:25-cv-00888-JGB-DTB. I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order and 10 I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Central District of California for the purpose of enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. 19 I hereby appoint __________________________ [print or type full name] of 20 _______________________________________ [print or type full address and 21 telephone number] as my California agent for service of process in connection with 22 this action or any proceedings related to enforcement of this Stipulated Protective 23 Order. 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________