Jeremy Gene Foy v. Town of Apple Valley

Opinion

JOHN M. FUJII, SBN 172718 2 MAHAHDI CORZANO, SBN 254905 2 Park Plaza, Suite 450 Irvine, California 92614 Phone: (52 392-5501 4] Fax: (949) 392-5501 Email: JFujii@FujiiLawGroup.com 5] Email: MCorzano@FujiiLawGroup.com Attorneys for Defendants COUNTY OF SAN BERNARDINO, ALEXANDER PANGBUM, DET. KEVIN 8] RIBERICH, DET. MAURICIO RIVAS, DET. DAVID FRATT, DET. EVAN TODD, 9] DEP. DANIEL VALLEJO, DEP. LEVI KERR, DEP. ANDREW SANDERS, DEP. 10] RYAN GRISSOM, AND DEP. JAMES LEE 1] 14 15] JEREMY GENE FOY, an individual, CASE NO.: 5:24-cv-02619-KK-SHK 16 Plaintiff, Judge: Kenly Kiya Kato. Magistrate Judge: Shashi H. Kewalramani 17 V. 18 TOWN OF APPLE VALLEY, a public STIPULATION AND PROPOSED entity. COUNTY OF SAN. PROTECTIVE ORDER 19] BERNARDINO, a public entity, SERGEANT JONATHAN ANDERSEN, 20] CORPORAL ALEXANDER PANGBUM, DETECTIVE KEVIN RIBERICH, 21] DETECTIVE MAURICIO RIVAS, DETECTIVE DAVID FRATT, DANIEL VALLEJO, DEPUTY LEVI DEPUTY RYAN GRISSOM, and 24] DEPUTY JAMES LEE, individuals; and DOES 1 through 50, inclusive, 25 26 Defendants. 27 28

PURPOSES AND LIMITATIONS 2 Defendants COUNTY OF SAN BERNARDINO, SGT. JONATHAN 3 ANDERSEN, CPL. ALEXANDER PANGBUM, DET. KEVIN RIBERICH, DET. 4 MAURICIO RIVAS, DET. DAVID FRATT, DET. EVAN TODD, DEP. DANIEL 5] VALLEJO, DEP. LEVI KERR, DEP. ANDREW SANDERS, DEP. RYAN GRISSOM, AND DEP. JAMES LEE (collectively, “Defendants”) contend that discovery in this 7 action (the “Action”) is likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, Defendants Plaintiff JEREMY GENE FOY (‘Plaintiff’), with Plaintiff and Defendants 11}collectively referred to herein as the “Parties” or individually as the “Party,” hereby 12 stipulate to and petition the Court to enter the following Stipulated Protective Order (the 13 “Protective Order”). The Parties acknowledge that this Protective Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it 15]affords from public disclosure and use extends only to the limited information or items 16 that are entitled to confidential treatment under the applicable legal principles. GOOD CAUSE STATEMENT 18 This Action involves records of detention, arrest, search warrant, and investigations 19] performed by the San Bernardino County Sheriff's Department and its personnel, agents, employees, and/or other third parties contracted with the County. Defendants assert the underlying incident, and evidence thereof, may involve the identity of personnel, 22 third-party witnesses, and others, that is private or confidential in nature. Further, Defendants anticipate that Plaintiff will seek confidential documents in this matter which 24\|may include, but are not limited to, personnel records of law enforcement officers, 25]}employment records, and confidential information from the San Bernardino County Sheriff's Department (including potential information implicating privacy of third 27 parties) not generally available to the public, or which may be privileged or otherwise 28 protected from disclosure under state or federal statutes, court rules, case decisions, or _1 of 13 _

1}common law. Should this information (photos, videos, personnel records, private 2information of witnesses, etc.) be disclosed without the protection of this Protective 3]}Order, and open access to the information be allowed, the privacy and safety of those involved in this Action, and other law enforcement matters, could be placed at risk. 5 Accordingly, to expedite the flow of information, facilitate the prompt resolution 6] of disputes over confidentiality of discovery materials, adequately protect information the 7 Parties are entitled to keep confidential, ensure the Parties are permitted reasonable and necessary uses of such material in preparation for trial and address their handling at the of the litigation, and serve the ends of justice, a protective order for such information justified in this matter. It is the intent of the Parties that information will not be 11] designated as “confidential” for tactical reasons and that nothing be so designated without good faith belief that it has been maintained in a confidential, non-public manner, and 13 there is good cause why it should not be part of the public record in this Action. ACKNOWLEDGEMENT OF UNDER SEAL FILING PROCEDURE 15 The Parties further acknowledge, as set forth in Section 14.3, below, that this Stipulated Protective Order does not entitle them to file confidential information under 17 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to file material 19]/under seal. There is a strong presumption that the public has a right of access to judicial 20 proceedings and records in civil cases. In connection with non-dispositive motions, good 21 cause must be shown to support a filing under seal. See Kamakana v. City and County o Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 23/1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 2411577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and specific showing of good cause or compelling reasons with proper evidentiary support legal justification, must be made with respect to Protected Material that a party seeks 27 \to file under seal. The Parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL does not— without the submission of competent evidence by _% of 13 _

1'declaration, establishing that the material sought to be filed under seal qualifies as 2 confidential, privileged, or otherwise protectable—constitute good cause. Further, if a 3 party requests sealing related to a dispositive motion or trial, then compelling reasons, not 4lonly good cause, for the sealing must be shown, and the relief sought shall be narrowly 5 tailored to serve the specific interest to be protected. See Pintos v. Pacific Creditors 6] ’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of information, 7 \document, or thing sought to be filed or introduced under seal, the party seeking protection must articulate compelling reasons, supported by specific facts and legal justification, for the requested sealing order. Again, competent evidence supporting the 10] application to file documents under seal must be provided by declaration. Any document is not confidential, privileged, or otherwise protectable in its entirety will not be filed 12]under seal if the confidential portions can be redacted. If documents can be redacted, then redacted version for public viewing, omitting only the confidential, privileged, or 14] otherwise protectable portions of the document, shall be filed. Any application that seeks 15 to file documents under seal in their entirety should include an explanation of why redaction is not feasible. 17}/4. DEFINITIONS 18 4.1 Action. This pending federal lawsuit entitled JEREMY GENE FOY v. TOWN OF APPLE VALLEY, et al. case number 5:24-cv-02619-KK-SHK. 20 4.2 Challenging Party. A Party or Non-Party that challenges the designation of 21]/information or items under this Protective Order. 22 4.3 “CONFIDENTIAL” Information or Items. Information (regardless of how was or is generated, stored, or maintained) or tangible things that qualify for protection under Fed. R. Civ. P. 26(c), and as specified above in the Good Cause Statement above. 25 4.4 Counsel. Outside Counsel of Record and House Counsel, as these terms are 26 defined below (as well as their support staff). 27 4.5 Designating Party. A Party or Non-Party that designates information or 28 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 2 of 13 _

1 4.6 Disclosure or Discovery Material. All items or information, regardless of medium or manner in which they are generated, stored, or maintained (including, 3]among other things, testimony, transcripts, and tangible things) that are produced or 4] generated in disclosures or responses to discovery in this matter. 5 4.7 Expert. A person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as 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 counsel. 10 4.9 Non-Party. Any natural person, partnership, corporation, association, or other legal entity not named as a Party to this Action. 12 4.10 Qutside Counsel of Record. Attorneys who are not employees of a Party to Action but are retained to represent or advise a Party to this Action and have appeared this Action on behalf of that Party or are affiliated with a law firm which has appeared behalf of that Party, and include support staff. 16 4.11 Party. Any Party to this Action, including all of its officers, directors, 17 }employees, consultants, retained experts, and Outside Counsel of Record (and their 18 support staff). 19 4.12 Producing Party. A Party or Non-Party that produces Disclosure or Discovery Material in this Action. 21 4.13 Professional Vendors. Persons or entities that produce litigation support 22\\services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 24 their employees and subcontractors. 25 4.14 Protected Material. Any Disclosure or Discovery Material that is designated “CONFIDENTIAL.” 27 4.15 Receiving Party. A Party that receives Disclosure or Discovery Material 28] from a Producing Party. _Aof13_

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. Any use of Protected Material at trial shall 7 be governed by the orders of the trial judge and other applicable authorities. This Order does not govern the use of Protected Material at trial. 916. DURATION 10 Once a case proceeds to trial, information that was designated as 11] CONFIDENTIAL or maintained pursuant to this protective order used or introduced as exhibit at trial becomes public and will be presumptively available to all members of 13 the public, including the press, unless compelling reasons supported by specific factual 14] findings to proceed otherwise are made to the trial judge in advance of the trial. See 15 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 16 }documents produced in discovery from “compelling reasons” standard when merits- 17 related documents are part of court record). Accordingly, the terms of this protective 18] order do not extend beyond the commencement of the trial. DESIGNATING PROTECTED MATERIAL 20 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each 21 /Party or Non-Party that designates information or items for protection under this 22 Protective Order must take care to limit any such designation to specific material that 23 qualifies under the appropriate standards. The Designating Party must designate for 24 protection only those parts of material, documents, items, or oral or written 25 communications that qualify so that other portions of the material, documents, items, or 26 communications for which protection is not warranted are not swept unjustifiably within ambit of this Protective Order. 28 Mass, indiscriminate, or routinized designations are prohibited. Designations that

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shown to be clearly unjustified or that have been made for an improper purpose (e.g., unnecessarily encumber the case development process or to impose unnecessary 3 expenses and burdens on other parties) may expose the Designating Party to sanctions. 4 If it comes to a Designating Party’s attention that information or items that it 5 \designated for protection do not qualify for protection, that Designating Party must 6] promptly notify all other Parties that it is withdrawing the inapplicable designation. 7 7.2. Manner and Timing of Designations. Except as otherwise provided in this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that 9] qualifies for protection under this Order must be clearly so designated before the material disclosed or produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 14] that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 15] “CONFIDENTIAL legend”), to each page that contains protected material. If only a portion of the material on a page qualifies for protection, the Producing Party also must 17 clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection need designate them for protection until after the inspecting Party has indicated which 21;documents it would like copied and produced. During the inspection and before the 22 designation, all of the material made available for inspection shall be deemed 23 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied and produced, the Producing Party must determine which documents, or portions 25 thereof, qualify for protection under this Order. Then, before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 27 that contains Protected Material. If only a portion of the material on a page qualifies for 28] protection, the Producing Party also must clearly identify the protected portion(s) (e.g., _ bof 13 _

making appropriate markings in the margins). 2 (b) for testimony given in depositions that the Designating Party identifies Disclosure or Discovery Material on the record, before the close of the deposition all protected testimony. 5 (c) for information produced in some form other than documentary and for other tangible items, that the Producing Party affix in a prominent place on the 7 exterior of the container or containers in which the information is stored the legend “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, Producing Party, to the extent practicable, shall identify the protected portion(s). 10 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure designate qualified information or items does not, standing alone, waive the Designating Party’s right to secure protection under this Protective Order for such 13])material. Upon timely correction of a designation, the Receiving Party must make 14 reasonable efforts to assure that the material is treated in accordance with the provisions this Protective Order. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 8.1 Timing of Challenges. Any Party or Non-Party may challenge a designation confidentiality at any time that is consistent with the Court’s orders. 19 8.2 Meetand Confer. The Challenging Party shall initiate the dispute resolution 20 process under Local Rule 37.1 et seq. 21 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint stipulation pursuant to Local Rule 37-2. 23 8.4 Burden. The burden of persuasion in any such challenge proceeding shall on the Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 26 may expose the Challenging Party to sanctions. Unless the Designating Party has waived withdrawn the confidentiality designation, all parties shall continue to afford the material in question the level of protection to which it is entitled under the Producing _Fof 13 _

1 Party’s designation until the Court rules on the challenge. 21/9. ACCESS TO AND USE OF PROTECTED MATERIAL 3 9.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Non-Party in connection with this Action Sjonly for prosecuting, defending, or attempting to settle this Action. Such Protected 6 Material may be disclosed only to the categories of persons and under the conditions 7 described in this Protective Order. When the Action has been terminated, a Receiving Party must comply with the provisions of Section 13 below (FINAL DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a location in a secure manner that ensures that access is limited only to the persons authorized 11]under this Protective Order. 129.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered the Court or permitted in writing by the Designating Party, a Receiving Party may 14] disclose any information or item designated “CONFIDENTIAL” only to: 15 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 16]/}employees of the Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this Action. 18 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; 20 (c) Experts (as defined in this Protective Order) of the Receiving Party to whom 21 \disclosure is reasonably necessary for this Action and who have signed the 22 ‘“Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (d) the Court and its personnel; 24 (e) court reporters and their staff; 25 (f) professional jury or trial consultants, mock jurors, and Professional Vendors whom disclosure is reasonably necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 28 (g) the author or recipient of a document containing the information or a

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1}/custodian or other person who otherwise possessed or knew the information; 2 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 3 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted keep any confidential information unless they sign the “Acknowledgment and 6 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party ordered by the court. Pages of transcribed deposition testimony or exhibits to 8] depositions that reveal Protected Material may be separately bound by the court reporter may not be disclosed to anyone except as permitted under this Stipulated Protective 10] Order; and 11 (i) any mediator or settlement officer, and their supporting personnel, mutually 12 }agreed upon by any of the Parties engaged in settlement discussions. 13/10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 15 If a Party is served with a subpoena or a court order issued in other litigation that 16];compels disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification shall 19]}include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order to 21}/issue in the other litigation that some or all of the material covered by the subpoena or 22 \order is subject to this Protective Order. Such notification shall include a copy of this 23 Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued by 25 the Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served with the 27 subpoena or court order shall not produce any information designated in this Action as ““CONFIDENTIAL” before a determination by the court from which the subpoena or _9of 13 _

1]}order issued, unless the Party has obtained the Designating Party’s written permission. Designating Party shall bear the burden and expense of seeking protection in that 3}court of its CONFIDENTIAL Information or Items, and nothing in these provisions 4!'should be construed as authorizing or encouraging a Receiving Party in this Action to 5} disobey a lawful directive from another court. 6}11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 8 (a) The terms of this Order are applicable to information produced by a Non- 9 Party in this Action and designated as “CONFIDENTIAL.” Such information produced Non-Parties in connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a 12]}Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to produce Non-Party’s confidential information in its possession, and the Party is subject to an 15]agreement with the Non-Party not to produce the Non-Party’s confidential information, 16 then the Party shall: 17 (1) promptly notify in writing the Requesting Party and the NonParty that 18]/some or all of the information requested is subject to a confidentiality agreement with a Non-Party; 20 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 21]}Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and 23 (3) make the information requested available for inspection by the Non- Party, if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 14 26 days of receiving the notice and accompanying information, the Receiving Party may 27 produce the Non-Party’s confidential information responsive to the discovery request. If Non-Party timely seeks a protective order, the Receiving Party shall not produce any _10 of 13 —

l'information in its possession or control that is subject to the confidentiality agreement 2 }with the Non-Party before a determination by the court. Absent a court order to the 3 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 4 court of its Protected Material. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 Protected Material to any person or in any circumstances not authorized under this Protective Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the person or persons to whom 11]unauthorized disclosures were made of all the terms of this Protective Order, and (d) 12 request such person or persons to execute the “Acknowledgment and Agreement to Be 13 }Bound” that is attached hereto as Exhibit A. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 When a Producing Party gives notice to the Receiving Parties that certain 17 }inadvertently produced material is subject to a claim of privilege or other protections, the 18] obligations of the Receiving Parties are those set forth in Fed. R. Civ. P. 26(b)(5)(B). This 19]provision is not intended to modify whatever procedure may be established in an e- 20 discovery order that provides for production without prior privilege review. Pursuant to 21 Federal Rule of Evidence 502(d) and (ce), insofar as the Parties reach an agreement on the 22\effect of disclosure of a communication or information covered by the attorney-client 23 privilege or work product protection, the Parties may may incorporate their agreement in stipulated protective order submitted to the court. 2514. MISCELLANEOUS 26 14.1 Right to Further Relief. Nothing in this Protective Order abridges the right 27 of any person to seek its modification by the Court in the future. 28 14.2 Right to Assert Other Objections. By stipulating to the entry of this _11 of 13 —

1] Protective Order, no Party waives any right it otherwise would have to object to disclosing producing any information or item on any ground not addressed in this Protective Order. Similarly, no Party waives any right to object on any ground to the use in evidence any of the material covered by this Protective Order. 5 15.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 7]\under seal pursuant to a court order authorizing the sealing of the specific Protected 8] Material at issue. If a Party’s request to file Protected Material under seal is denied by Court, then the Receiving Party may file the information in the public record unless 10] otherwise instructed by the Court. FINAL DISPOSITION 12 After the final disposition of this Action, as defined in paragraph 6, within 60 days a written request by the Designating Party, each Receiving Party must return all 14 Protected Material to the Producing Party or destroy such material. As used in this 15]/subdivision, “all Protected Material” includes all copies, abstracts, compilations, 16 /summaries, and any other format reproducing or capturing any of the Protected Material. 17] Whether the Protected Material is returned or destroyed, the Receiving Party must submit written certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by category, where 20] appropriate) all the Protected Material that was returned or destroyed and (2) affirms that Receiving Party has not retained any copies, abstracts, compilations, summaries or other format reproducing or capturing any of the Protected Material. Notwithstanding 23 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 24 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 25 deposition and trial exhibits, expert reports, attorney work product, and consultant and 26 expert work product, even if such materials contain Protected Material. Any such archival copies that contain or constitute Protected Material remain subject to this Protective Order set forth in Section 6 (DURATION). _ 19 of 13 —

MVIOLATIONS 2 Any violation of this Protective Order may be punished by any and all appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 Pursuant to Local Rule 5-4.3.4, by my signature below I, Mahadhi Corzano, attest 6 that all other signatories concur in this filing’s content and have authorized this filing. 7 Dated: July 14, 2025 FUJH LAW GROUP LLP 9 10 By: __/s/Mahadhi Corzano JOHN M. FUJII 11 MAHADHI CORZANO Attorneys for Defendants 12 County of San Bernardino, Jonathan Andersen, Alexander Pangburn, Kevin 13 Riberich, Mauricio Rivas, David Fratt, Evan Todd, Daniel Vallejo, Levi Kerr, 14 Andrew Sanders, Ryan Grissom, and James Lee 15 16 Dated: July 14, 2025 ADAMSON AHDOOT LLP 17 18 By: __/s/Daniel M. Stefanic 19 Alan A. Ahdoot Christopher B. Adamson 20 Daniel M. Stefanic Attorneys for Plaintiff 21 Jeremy Gene Foy 22 24 95 Dated: 07/15/2025 26) SM ape ep 27 HON. SHASHI H. KEWALRAMANI 3g United States Magistrate Judge

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3 All, , [print or type full 5 /name], declare under penalty of perjury that I have read in its entirety and understand 6 the Protective Order that was issued by the United States District Court for the Central District of California on date [date] in the Action of JEREMY GENE 8 FORY v. TOWN OF APPLE VALLEY, et al. case number 5:24-cv-02619-KK-SHK. agree to comply with and to be bound by all the terms of this Protective Order, and understand and acknowledge that failure to so comply could expose me to sanctions punishment in the nature of contempt. I solemnly promise that I will not disclose in manner any information or item that is subject to this Protective Order to any person entity except in strict compliance with the provisions of this Protective Order. I further 14]agree to submit to the jurisdiction of the United States District Court for the Central 15] District of California for the purpose of enforcing the terms of this Protective Order, even such enforcement proceedings occur after termination of this Action. 17 I hereby appoint as my California 18]agent for service of process in connection with this Action or any proceedings related to 19] enforcement of this Protective Order. 20 21} Date: 22 City and State where sworn and signed: 23} Printed name: Signature: 25 26 27 28 _EXUIBIT A _