Mkrtchyan v. Sacramento County

Opinion

] 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 FOR THE EASTERN DISTRICT OF CALIFORNIA 8 ARAM MKRTCHYAN, Case No. 2:25-cv-01405-DJC-CSK 10 Plaintiff, 11 ORDER GRANTING STIPULATED V. PROTECTIVE ORDER

13 || SACRAMENTO COUNTY, et al., (ECF No. 12) 14 Defendants. 15 16 The Court has reviewed the parties’ stipulated protective order below (ECF No. 12), and 17 || finds it comports with the relevant authorities and the Court’s Local Rule. See L.R. 141.1. The 18 || Court APPROVES the protective order, subject to the following clarification. 19 The Court’s Local Rules indicate that once an action is closed, it “will not retain 20 || jurisdiction over enforcement of the terms of any protective order filed in that action.” L.R. 21 || 141.1(f); see Bylin Heating Sys., Inc. v. Thermal Techs., Inc., 2012 WL 13237584, at *2 (E.D. 22 || Cal. Oct. 29, 2012) (noting that courts in the district generally do not retain jurisdiction for 23 || disputes concerning protective orders after closure of the case). Thus, the Court will not retain 24 ||jurisdiction over this protective order once the case is closed. 25 26 || Dated: July 24, 2025 C (yi S$ 27 CHI SOO KIM 38 || 5. mert405.25 UNITED STATES MAGISTRATE JUDGE

STIPULATED PROTECTIVE ORDER

2 Patrick H. Dwyer, SBN 137743 LAW OFFICE OF PATRICK H. DWYER 3 P.O. Box 1705 Penn Valley, CA 95946 4 TEL: 530.432.5407 5 FAX: 530.432.9122 pdwyer@pdwyerlaw.com 6 Attorney for Plaintiff Aram Mkrtchyan

7 Matthew W. Gross, SBN 324007 8 mgross@porterscott.com Jeffery M. Isaacs, SBN 338853 9 jisaacs@porterscott.com 2100 Harvard Street, Suite 500 10 Sacramento, California 95815 11 TEL: 916.929.1481 FAX: 916.927.3706 12 Attorneys for Defendants SACRAMENTO COUNTY, Officer Dugdale and Does 1-10 13

15 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 16

17 ARAM MKRTCHYAN, an individual, CASE NO. 2:25-cv-01405-DJC-CSK

18 Plaintiff [PROPOSED] PROTECTIVE ORDER 19 20 v. Complaint Filed: 05/19/2025

21 SACRAMENTO COUNTY, CALIFORNIA, a county government and the operator of 22 the Sacramento County Sheriff’s 23 Department; SCSD Officer Max Dugdale, and 24 Does 1-10, in their individual capacity,

25 Defendants. 26 ___________________________________/

28 1 A. PURPOSES AND LIMITATIONS 2 Disclosure and discovery activity in this action are likely to involve production of confidential, 3 proprietary, or private information for which protection from public disclosure and from use for any 4 purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate 5 to, and petition the court to enter, the following Stipulated Protective Order. The parties acknowledge that 6 this Order does not confer blanket protections on all disclosures or responses to discovery and that the 7 protection it affords extends only to the limited extent such information or items are entitled to confidential 8 treatment under the applicable federal law, including the Health Insurance Portability and Accountability 9 Act (“HIPAA”) and the Federal Rules of Civil Procedure. The parties further acknowledge that this 10 Stipulated Protective Order does not entitle them to file confidential information under seal. Civil Local 11 Rule 141 sets forth the procedures that must be followed and the standards that will be applied when a 12 party seeks permission from the court to file material under seal. 13 B. STIPULATION 14 The parties hereby stipulate and agree as follows: 15 1. DOCUMENTS. The following documents are “Protected Materials” and shall not be used 16 for any purpose other than this litigation: 17 (a) all video covering Plaintiff at the Sacramento County Rio Consumnes Correctional 18 Facility (“RCCC”) from the time Plaintiff was brought to RCCC prior to November 1, 2024, until date of 19 filing of the Complaint; 20 (b) any incident report or investigation concerning the allegations in the Complaint.; 21 (c) all medical records, including x-rays, for Plaintiff while at the Sacramento County 22 jail; 23 (d) plaintiff’s past and current medical records; 24 (e) medical billings, insurance information and evidence of payments made; 25 (f) personnel files of any peace officer or medical personnel involved in this case; 26 (g) any Internal Affairs Investigation materials from the Sacramento County Sheriff’s 27 Dept.; 28 (h) Sacramento County Correctional Health policies; 1 (i) Sacramento County Sheriff Dept. Policies; and 2 (j) if a party wants to designate a document other than what is identified above as 3 confidential under this Protective Order, the procedure set forth in Sections D and E shall be followed. 4 2. SCOPE 5 The protections conferred by this Stipulation and Order cover not only Protected Material, but 6 also: (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, 7 or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties 8 or their Counsel of Record that might reveal Protected Material. However, the protections conferred by 9 this Stipulation and Order do not cover the following information: (a) any information that is in the public 10 domain at the time of disclosure to a Receiving Party or becomes part of the public domain after its 11 disclosure to a Receiving Party as a result of publication not involving a violation of this Order, including 12 becoming part of the public record through court order, trial, or otherwise; and (b) any information known 13 to the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from 14 a source who obtained the information lawfully and under no obligation of confidentiality to the 15 Designating Party. Any use of Protected Material at trial shall be governed by a separate agreement or 16 order. 17 3. DURATION 18 Even after final disposition of this litigation, the confidentiality obligations imposed by this Order 19 shall remain in effect until: (1) a Designating Party agrees otherwise in writing; (2) a court order otherwise 20 directs; or (3) there is a complete return or destruction of all Protected Material pursuant to Section 8. 21 Final disposition shall be deemed to be the later of: (1) dismissal of all claims and defenses in this action, 22 with or without prejudice; and (2) final judgment herein after the completion and exhaustion of all appeals, 23 rehearings, remands, trials, or reviews of this action, including the time limits for filing any motions or 24 applications for extension of time pursuant to applicable law. 25 4. ACCESS TO AND USE OF PROTECTED MATERIAL 26 4.1 Basic Principles 27 A Receiving Party may use Protected Material that is disclosed or produced by another Party or 28 1 by a Non-Party in connection with this case only for prosecuting, defending, or attempting to settle this 2 litigation. Such Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the litigation has been terminated, a Receiving Party must 4 comply with the provisions of section 8 below (FINAL DISPOSITION). Protected Material must be stored 5 and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited 6 to the persons authorized under this Order. 7 4.2 Disclosure of “CONFIDENTIAL” Information or Items 8 Unless otherwise ordered by the court or permitted in writing by the Designating Party, a Receiving 9 Party may disclose any information or item designated “CONFIDENTIAL” (a “confidential” designation 10 means that it is Protected Material) only to: 11 (a) the Receiving Party’s Counsel of Record in this action, as well as employees of said 12 Counsel of Record to whom it is reasonably necessary to disclose the information for this litigation; 13 (b) the officers, directors, and employees of the Receiving Party to whom disclosure is 14 reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be 15 Bound” (Exhibit A); 16 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is reasonably 17 necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” 18 (Exhibit A); 19 (d) the court and its personnel; 20 (e) court reporters and their staff, professional jury or trial consultants, and Professional 21 Vendors to whom disclosure is reasonably necessary for this litigation and who have signed the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary 24 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 25 agreed by the Designating Party or ordered by the court. Pages of transcribed deposition testimony or 26 exhibits to depositions that reveal Protected Material must be separately bound by the court reporter and 27 may not be disclosed to anyone except as permitted under this Stipulated Protective Order. 28 (g) the author or recipient of a document containing the information or a custodian or other 1 person who otherwise possessed or knew the information. 2 5. PROTECTED MATERIAL SUBPOENAED OR ORDERED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation that compels 4 disclosure of any information or items designated in this action as Protected Material, that Party must: 5 (a) promptly notify in writing the Designating Party. Such notification shall include a 6 copy of the subpoena or court order; 7 (b) promptly notify in writing the party who caused the subpoena or order to issue in 8 the other litigation that some or all of the material covered by the subpoena or order is subject to this 9 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 10 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 11 Designating Party whose Protected Material may be affected. 12 If the Designating Party timely seeks a protective order, the Party served with the subpoena or 13 court order shall not produce any information designated in this action as “CONFIDENTIAL” (i.e., 14 Protected Material) before a determination by the court from which the subpoena or order issued, unless 15 the Party has obtained the Designating Party’s permission. The Designating Party shall bear the burden 16 and expense of seeking protection in that court of its purported Protected Material – and nothing in these 17 provisions should be construed as authorizing or encouraging a Receiving Party in this action to disobey 18 a lawful directive from another court. 19 20 6. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material 21 to any person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving 22 Party must immediately: 23 (a) notify in writing the Designating Party of the unauthorized disclosures; 24 (b) use its best efforts to retrieve all unauthorized copies of the Protected Material; 25 (c) inform the person or persons to whom unauthorized disclosures were made of all 26 the terms of this Order; and 27 (d) request such person or persons to execute the “Acknowledgment and Agreement to 28 1 Be Bound” that is attached hereto as Exhibit A.

2 7. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 3 PROTECTED MATERIAL 4 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced 5 material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties are 6 those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 7 whatever procedure may be established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an 9 agreement on the effect of disclosure of a communication or information covered by the attorney-client 10 privilege or work product protection, the parties may incorporate their agreement in the stipulated 11 protective order submitted to the court. 12 8. FINAL DISPOSITION 13 Within 60 days after the final disposition of this action, as defined in paragraph 3, each Receiving 14 Party must return all Protected Material to the Producing Party or destroy such material. As used in this 15 subdivision, “all Protected Material” includes all copies, abstracts, compilations, summaries, and any other 16 format reproducing or capturing any of the Protected Material. Whether the Protected Material is returned 17 or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if not 18 the same person or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by category, 19 where appropriate) all the Protected Material that was returned or destroyed and (2) affirms that the 20 Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format 21 reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel of Record 22 are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 23 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work 24 product, and consultant and expert work product, even if such materials contain Protected Material. Any 25 such archival copies that contain or constitute Protected Material remain subject to this Protective Order 26 as set forth in Section 3 (DURATION). 27 28 1 9. MISCELLANEOUS 2 9.1 Right to Further Relief 3 Nothing in this Order abridges the right of any person to seek its modification or a change in 4 designation of particular material as “CONFIDENTIAL” (i.e., Protected Material) by the court in the 5 future. 6 9.2 Right to Assert Other Objections 7 By stipulating to the entry of this Protective Order no Party waives any right it otherwise would have to 8 object to disclosing or producing any information or item on any ground not addressed in this Stipulated 9 Protective Order. Similarly, no Party waives any right to object on any ground to use in evidence of any 10 of the material covered by this Protective Order. 11 9.3 Filing Protected Material 12 Without written permission from the Designating Party or a court order secured after appropriate 13 notice to all interested persons, a Party may not file in the public record in this action any Protected 14 Material. A Party that seeks to file under seal any Protected Material must comply with Civil Local Rule 15 141. Protected Material may only be filed under seal pursuant to a court order authorizing the sealing of 16 the specific Protected Material at issue. Pursuant to Civil Local Rule 141, a sealing order will issue only 17 upon a request establishing that the Protected Material at issue is privileged, protectable as a trade secret, 18 or otherwise entitled to protection under the law. 19 C. DEFINITIONS 20 1. “Challenging Party” means a Party or Non-Party that challenges the designation of 21 information or items under this Order. 22 2. “CONFIDENTIAL” means information (regardless of how it is generated, stored or 23 maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c). 24 3. “Designating Party” means a Party or Non-Party that designates information or items that 25 it produces in disclosures or in responses to discovery as “CONFIDENTIAL”. 26 4. “Disclosure or Discovery Material” means all items or information, regardless of the 27 medium or manner in which it is generated, stored, or maintained (including, among other things, 28 testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to 1 discovery in this matter. 2 5. “Expert” means a person with specialized knowledge or experience in a matter pertinent to 3 this litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a 4 consultant in this action, (2) is not a past or current employee of a Party and (3) at the time of retention, is 5 not anticipated to become an employee of a Party. 6 6. “Non-Party” means any natural person, partnership, corporation, association, or other 7 legal entity not named as a Party to this action. 8 7. “Counsel of Record” means attorneys who have appeared in this action on behalf of that 9 party or are affiliated with a law firm or governmental entity which has appeared on behalf of that party. 10 8. “Party” means any party to this action, including all of its officers, directors, employees, 11 consultants, retained experts, and Counsel of Record (and their support staffs). 12 9. “Producing Party” means a Party or Non-Party that produces Disclosure or Discovery 13 Material in this action. 14 10. “Professional Vendors” means persons or entities that provide litigation support services 15 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 16 storing, or retrieving data in any form or medium) and their employees and subcontractors. 17 11. “Protected Material” means any Disclosure or Discovery Material that is designated as 18 “CONFIDENTIAL” or as “Protected Material”. 19 12. “Receiving Party” means a Party that receives Disclosure or Discovery Material from a 20 Producing Party. 21 D. DESIGNATING PROTECTED MATERIAL 22 1. Exercise of Restraint and Care in Designating Material for Protection 23 A party may designate material other than identified Section B.1 as confidential. Each Party or 24 Non-Party that designates information or items for protection under this Order must take care to limit any 25 such designation to specific material that qualifies under the appropriate standards. To the extent it is 26 practical to do so, the Designating Party must designate for protection only those parts of material, 27 documents, items, or oral or written communications that qualify – so that other portions of the material, 28 documents, items, or communications for which protection is not warranted are not swept unjustifiably 1 within the ambit of this Order. 2 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be 3 clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber or 4 retard the case development process or to impose unnecessary expenses and burdens on other parties) 5 expose the Designating Party to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it designated for 7 protection do not qualify for protection at all or do not qualify for the level of protection initially asserted, 8 that Designating Party must promptly notify all other parties that it is withdrawing the mistaken 9 designation. 10 2. Manner and Timing of Designations 11 Except as otherwise provided in this Order or as otherwise stipulated or ordered, Disclosure or 12 Discovery Material that qualifies for protection under this Order must be clearly so designated before the 13 material is disclosed or produced. Designation in conformity with this Order requires: 14 (a) for information in documentary form (e.g., paper or electronic documents, but 15 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix 16 the legend “CONFIDENTIAL” or “Protected Material” to each page that contains protected material. If 17 only a portion or portions of the material on a page qualifies for protection, the Producing Party also must 18 clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins) and must 19 specify, for each portion, the level of protection being asserted. Alternatively, the Producing Party may 20 designate an entire production or storage device (such as CD or flash drive) as confidential by including 21 notice of such designation or including “CONFIDENTIAL” or “Protected Material” in the title of each 22 designated file. 23 A Party or Non-Party that makes original documents or materials available for inspection 24 need not designate them for protection until after the inspecting Party has indicated which material it 25 would like copied and produced. During the inspection and before the designation, all of the material made 26 available for inspection shall be deemed “CONFIDENTIAL”. After the inspecting Party has identified the 27 documents it wants copied and produced, the Producing Party must determine which documents, or 28 portions thereof, qualify for protection under this Order. Then, before producing the specified documents, 1 the Producing Party must affix the appropriate legend (i.e., “CONFIDENTIAL” or “Protected Material”) 2 to each page that contains Protected Material. If only a portion or portions of the material on a page 3 qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by 4 making appropriate markings in the margins) and must specify, for each portion, the level of protection 5 being asserted. 6 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 7 Designating Party identify on the record, before the close of the deposition, hearing, or other proceeding, 8 or in a writing to all parties within 30 business days of receipt of the deposition or hearing transcript, all 9 protected testimony and specify the level of protection being asserted. A Designating Party may specify, 10 at the deposition or up to 30 days afterwards that the entire transcript shall be treated as 11 “CONFIDENTIAL”, Protected Material. 12 Parties shall give the other parties notice if they reasonably expect a deposition, hearing or 13 other proceeding to include Protected Material so that the other parties can ensure that only authorized 14 individuals who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A) are present 15 at those proceedings. The use of a document as an exhibit at a deposition shall not in any way affect its 16 designation as “CONFIDENTIAL” or “Protected Material”. 17 Transcripts containing Protected Material shall have an obvious legend on the title page 18 that the transcript contains Protected Material, and the title page shall be followed by a list of all pages 19 (including line numbers as appropriate) that have been designated as Protected Material and the level of 20 protection being asserted by the Designating Party. The Designating Party shall inform the court reporter 21 of these requirements. Any transcript that is prepared before the expiration of a 30-day period for 22 designation shall be treated during that period as if it had been designated CONFIDENTIAL or Protected 23 Material in its entirety unless otherwise agreed. After the expiration of that period, the transcript shall be 24 treated only as actually designated. 25 (c) for information produced in some form other than documentary and for any other 26 tangible items, that the Producing Party affix in a prominent place on the exterior of the container or 27 containers in which the information or item is stored the legend “CONFIDENTIAL” or “Protected 28 Material”. If only a portion or portions of the information or item warrant protection, the Producing Party, 1 to the extent practicable, shall identify the protected portion(s). 2 3. Inadvertent Failures to Designate 3 If timely corrected, an inadvertent failure to designate qualified information or items does not, 4 standing alone, waive the Designating Party’s right to secure protection under this Order for such material. 5 Upon timely correction of a designation, the Receiving Party must make reasonable efforts to assure that 6 the material is treated in accordance with the provisions of this Order. 7 E. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 1. Timing of Challenges 9 Any Party or Non-Party may challenge a designation of confidentiality at any time. Unless a 10 prompt challenge to a Designating Party’s confidentiality designation is necessary to avoid foreseeable, 11 substantial unfairness, unnecessary economic burdens, or a significant disruption or delay of the litigation, 12 a Party does not waive its right to challenge a confidentiality designation by electing not to mount a 13 challenge promptly after the original designation is disclosed. 14 2. Meet and Confer 15 The Challenging Party shall initiate the dispute resolution process by providing written notice of 16 each designation it is challenging and describing the basis for each challenge. To avoid ambiguity as to 17 whether a challenge has been made, the written notice must recite that the challenge to confidentiality is 18 being made in accordance with this specific paragraph of the Protective Order. The parties shall attempt 19 to resolve each challenge in good faith and must begin the process by conferring directly (in voice to voice 20 dialogue; other forms of communication are not sufficient) within 14 days of the date of service of notice. 21 In conferring, the Challenging Party must explain the basis for its belief that the confidentiality designation 22 was not proper and must give the Designating Party an opportunity to review the designated material, to 23 reconsider the circumstances, and, if no change in designation is offered, to explain the basis for the chosen 24 designation. A Challenging Party may proceed to the next stage of the challenge process only if it has 25 engaged in this meet and confer process first or establishes that the Designating Party is unwilling to 26 participate in the meet and confer process in a timely manner. 27 3. Judicial Intervention 28 If the Parties cannot resolve a challenge without court intervention, the Designating Party shall file 1 and serve a motion to retain confidentiality within 21 days of the initial notice of challenge or within 14 2 days of the parties agreeing that the meet and confer process will not resolve their dispute, whichever is 3 earlier. Each such motion must be accompanied by a competent declaration affirming that the movant has 4 complied with the meet and confer requirements imposed in the preceding paragraph. Failure by the 5 Designating Party to make such a motion including the required declaration within 21 days (or 14 days, if 6 applicable) shall automatically waive the confidentiality designation for each challenged designation. 7 In addition, the Challenging Party may file a motion challenging a confidentiality designation at 8 any time if there is good cause under FRCP 26(c), including a challenge to the designation of a deposition 9 transcript or any portions thereof. Any motion brought pursuant to this provision must be accompanied 10 by a competent declaration affirming that the movant has complied with the meet and confer requirements 11 imposed by the preceding paragraph. 12 The burden of persuasion in any such challenge proceeding shall be on the Moving Party. Frivolous 13 challenges and those made for an improper purpose (e.g., to harass or impose unnecessary expenses and 14 burdens on other parties) may expose the Challenging Party to sanctions. Unless the Designating Party 15 has waived the confidentiality designation by failing to file a motion to retain confidentiality as described 16 above, all parties shall continue to afford the material in question the protection to which it is entitled 17 under the Producing Party’s designation until the court rules on the challenge. 18 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 19 Dated: July 18, 2025 PORTER SCOTT A PROFESSIONAL CORPORATION 20

21 By: _s/_Matthew W. Gross______________ Matthew W. Gross, SBN 324007 22 Jeffery M. Isaacs, SBN 338853 Attorneys for Defendants Sacramento County, 23 Sacramento SHERIFF’S DEPARTMENT, Officer 24 Dugdale, and Does 1-10

25 Dated: July 18, 2025 LAW OFFICE OF PATRICK H. DWYER 26

27 By: _s/ Patrick H. Dwyer_______________ Patrick H. Dwyer 28 Attorney for Plaintiff Aram Mkrtchyan 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of _________________ [print or 4 type full address], declare under penalty of perjury that I have read in its entirety and understand the 5 Stipulated Protective Order that was issued by the United States District Court for the Eastern District of 6 California on _______ in the case of Aram Mkrtchyan v. Sacramento County, et al., Case No. 2:25-CV- 7 01405-DJC-CSK. I agree to comply with and to be bound by all the terms of this Stipulated Protective 8 Order and I understand and acknowledge that failure to so comply could expose me to sanctions and 9 punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any 10 information or item that is subject to this Stipulated Protective Order to any person or entity except in 11 strict compliance with the provisions of this Order. 12 I further agree to submit to the jurisdiction of the United States District Court for the Eastern 13 District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if 14 such enforcement proceedings occur after termination of this action. 15 I hereby appoint ____________________________________ [print or type full name] of 16 ________________________________________ [print or type full address and telephone number] as my 17 California agent for service of process in connection with this action or any proceedings related to 18 enforcement of this Stipulated Protective Order. 19 20 Date: 21 City and State where sworn and signed: ________________________, California 22 Printed name: ____________________ 23 Signature:_______________________ 24 25 26 27 28