Samantha Arredondo v. County of San Bernardino

• Court: District Court, C.D. California
• Decided: May 22, 2024
• Docket: 5:24-cv-00163
• Status: Unknown

Opinion

1 || Eugene P. Ramirez (State Bar No. 134865) eugene. □□ So 2 || Lynn Carpenter (State Bar No. 310011) gin carpenter@manningkass.com 3 ayleig! Andersen (State Bar No. 306442) Kasei .andersen@manningkass.com 4|| MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 5||801 S. Figueroa St, 15th Floor, Los Angeles, California 90017-3012 6 || Telephone: GB) 624-6900 Facsimile: (213) 624-6999 7 Attorneys for Defendant, COUNTY OF 8 || SAN BERNARDINO 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11

SAMANTHA ARREDONDO, Case No. 5:24-cv-00163-KK-DTB 13 individually and as Successor in Interest to Samuel Arredondo, deceased, 14 STIPULATED PROTECTIVE Plaintiff, ORDER; [PROPOSED] ORDER 15 V. Z| 616 COUNTY OF SAN BERNARDINO, a FQ! municipal entity, and DOES 1-10, Action Filed: 01/23/24 Inclusive, 18 Defendants. 19 20 21 || TO THE HONORABLE COURT: 22 By and through their counsel of record in this action, SAMANTHA 23 || ARREDONDO ("Plaintiff"), and COUNTY OF SAN BERNARDINO ("Defendant") 24 ||— the parties — hereby stipulate for the purpose of jointly requesting that the honorable 25 || Court enter a protective order re confidential documents in this matter [and pursuant 26 || to Fed. R. Civ. P. 5.2, 7, and 26, as well as U.S. Dist. Ct., S.D. Cal., Local Rules 7-1 27 ||and 52-4.1; and any applicable Orders of the Court] — as follows: 28 || ///

Li} 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 || proprietary, or private information for which special protection from public disclosure 4 || and from use for any purpose other than prosecuting this litigation may be warranted. 5 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 || 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 8 || the 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 10 || legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 11||that this Stipulated Protective Order does not entitle them to file confidential

12 || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 13 || followed and the standards that will be applied when a party seeks permission from 14 || the court to file material under seal. 15 B. GOOD CAUSE STATEMENT 16 Defendant contends that peace officers have a federal privilege of privacy in 3 —17||their personnel file records: a reasonable expectation of privacy therein that is 18 || underscored, specified, and arguably heightened by the Pitchess protective procedure 19 || of California law. See Sanchez v. Santa Ana Police Dept., 936 F.2d 1027, 1033-1034 20 || (9th Cir. 1990); Hallon v. City of Stockton, 2012 U.S. Dist. LEXIS 14665, *2-3, 12- 21 || 13 (E.D. Cal. 2012) (concluding that “while “[f]ederal law applies to privilege based 22 ||discovery disputes involving federal claims,” the “state privilege law which is 23 consistent with its federal equivalent significantly assists in applying [federal] 24 || privilege law to discovery disputes’’); Soto v. City of Concord, 162 F.R.D. 603, 613 25 ||n. 4, 616 (N.D. Cal. 1995) (peace officers have constitutionally-based “privacy rights 26 || [that] are not inconsequential” in their police personnel records); cf: Cal. Penal Code 27||§§ 832.7, 832.8; Cal. Evid. Code §§ 1040-1047. Defendant further contends that 28 || uncontrolled disclosure of such personnel file information can threaten the safety of

1 || non-party witnesses, officers, and their families/associates. 2 Second, Defendant contends that municipalities and law enforcement agencie 3 ||have federal deliberative-executive process privilege, federal official informatio 4|| privilege, federal law enforcement privilege, and attorney-client privilege (and/c 5 ||attorney work product protection). Defendant further contends that personnel fil 6||records are restricted from disclosure by the public entity’s custodian of record 7 || pursuant to applicable California law and that uncontrolled release is likely to result i 8 ||needless intrusion of officer privacy; impairment in the collection of third-part 9||witness information and statements and related legitimate law enforcemer 10 || investigations/interests; and a chilling of open and honest discussion regarding and/c 11 || investigation into alleged misconduct that can erode a public entity’s ability to identif 12 || and/or implement any remedial measures that may be required. 13 In light of the nature of the claims and allegations in this case and the parties 14 || representations that discovery in this case will involve the production of □□□□□□□□□□□ 15 records, and in order to expedite the flow of information, to facilitate the promr 16 || resolution of disputes over confidentiality of discovery materials, to adequately protec 5 17 information the parties are entitled to keep confidential, to ensure that the parties ar 18 || permitted reasonable necessary uses of such material in connection with this action, t 19 || address their handling of such material at the end of the litigation, and to serve the end 20 || of justice, a protective order for such information is justified in this matter. The partie 21 ||shall not designate any information/documents as confidential without a good fait 22 || belief that such information/documents have been maintained in a confidential, nor 23 || public manner, and that there is good cause or a compelling reason why it should nc 24 || be part of the public record of this case. 25 |} 2. DEFINITIONS. 26 2.1 Action: The above-captioned federal lawsuit. 27 2.2 Challenging Party: a Party or Non-Party that challenges the designatio 28 || of information or items under this Order.

1 2.3. “CONFIDENTIAL” Information or Items: information (regardless c 2 || how it is generated, stored or maintained) or tangible things that qualify for protectio 3 || under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Caus 4 || Statement. 5 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as the: 6 || support staff). 7 2.5 Designating Party: a Party or Non-Party that designates information 8|litems that it produces in disclosures or in responses to discovery a 9 || “CONFIDENTIAL.” 10 2.6 Disclosure or Discovery Material: all items or information, regardless 11 || the medium or manner in which it is generated, stored, or maintained (including, amon

12 || other things, testimony, transcripts, and tangible things), that are produced or generate 13 |}in disclosures, responses to discovery, deposition testimony, document production: 14 || and exchange of electronically stored information (“ESI”) in the Action. 15 2.7 Expert: a person with specialized knowledge or experience in a matte 16 || pertinent to the litigation who has been retained by a Party or its counsel to serve as a 3 expert witness or as a consultant in this Action. 18 2.8 House Counsel: attorneys who are employees of a party to this Actiot || House Counsel does not include Outside Counsel of Record or any other outsid 20 || counsel. 21 2.9 Non-Party: any natural person, partnership, corporation, association, ¢ 22 || other legal entity not named as a Party to this action. 23 2.10 Qutside Counsel of Record: attorneys who are not employees of a part 24 || to this Action but are retained to represent or advise a Party to this Action and hav 25 || appeared in this Action on behalf of that Party or are affiliated with a law firm whic 26 || has appeared on behalf of that Party, including support staff. 27 2.11 Party: any party to this Action, including all of its officers, director: 28 ||employees, consultants, retained experts, and Outside Counsel of Record (and the:

1 || support staffs). 2 2.12 Producing Party: a Party or Non-Party that produces Disclosure c 3 || Discovery Material in this Action. 4 2.13 Professional Vendors: persons or entities that provide litigation suppo: 5||services (e.g., photocopying, videotaping, translating, preparing □□□□□□□□ 6 || demonstrations, and organizing, storing, or retrieving data in any form or medium) an 7 || their employees and subcontractors. 8 2.14 Protected Material: any Disclosure or Discovery Material that | 9 || designated as “CONFIDENTIAL.” 10 2.15 Receiving Party: a Party that receives Disclosure or Discovery □□□□□□ «| 11 || from a Producing Party. 12||3. SCOPE The protections conferred by this Stipulation and Order cover not only Protecte Material (as defined above), but also (1) any information copied or extracted fror | 15||Protected Material; (2) all copies, excerpts, summaries, or compilations of Protecte | || Material; and (3) any testimony, conversations, or presentations by Parties or the: 3 Counsel that might reveal Protected Material. 18 Any use of Protected Material during a court hearing or at trial shall be governe 19 || by the orders of the presiding judge. This Order does not govern the use of Protecte 20 || Material during a court hearing or at trial. 4. DURATION 22 Even after final disposition of this litigation, the confidentiality obligation 23 || imposed by this Order shall remain in effect until a Designating Party agrees otherwis 24 || in writing or a court order otherwise directs. Final disposition shall be deemed to b 25 || the later of (1) dismissal of all claims and defenses in this Action, with or □□□□□□ 26 || prejudice; and (2) final judgment herein after the completion and exhaustion of a 27 || appeals, rehearings, remands, trials, or reviews of this Action, including the tim 28 ||limits for filing any motions or applications for extension of time pursuant t

1 || applicable law. 21/5. DESIGNATING PROTECTED MATERIAL 3 5.1 Exercise of Restraint and Care in Designating Material for □□□□□□□□□□ 4||Each Party or Non-Party that designates information or items for protection unde 5 ||this Order must take care to limit any such designation to specific material th: 6 || qualifies under the appropriate standards. The Designating Party must designate fc 7||protection only those parts of material, documents, items, or oral or writte 8 || communications that qualify so that other portions of the material, documents, item: 9 || or communications for which protection is not warranted are not swept unjustifiabl 10 || within the ambit of this Order. ay dl Mass, indiscriminate, or routinized designations are prohibited. Designation | 12 ||that are shown to be clearly unjustified or that have been made for an imprope 13 || purpose (e.g., to unnecessarily encumber the case development process or to impos unnecessary expenses and burdens on other parties) may expose the Designatin 15 Party to sanctions. 16 If it comes to a Designating Party’s attention that information or items that □ 3 FI —17|| designated for protection do not qualify for protection, that Designating Party mus 18 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 19 5.2 Manner and Timing of Designations. Except as otherwise provided 1 20 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwis 21 stipulated or ordered, Disclosure or Discovery Material that qualifies for protectio 22 ||under this Order must be clearly so designated before the material is disclosed c 23 || produced. 24 Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic document: 26 || but excluding transcripts of depositions), that the Producing Party affix at a minimun □□ the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) to each pag 28 || that contains protected material. If only a portion or portions of the material on a pag

1 || qualifies for protection, the Producing Party also must clearly identify the protecte 2 || portion(s) (e.g., by making appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for inspectio need not designate them for protection until after the inspecting Party has indicate 5 || which documents it would like copied and produced. During the inspection and befor 6|| the designation, all of the material made available for inspection shall be deeme 7|| “CONFIDENTIAL.” After the inspecting Party has identified the documents it want 8 || copied and produced, the Producing Party must determine which documents, c || portions thereof, qualify for protection under this Order. Then, before producing th specified documents, the Producing Party must affix the “CONFIDENTIAL” legen 11 || to each page that contains Protected Material. If only a portion or portions of th

| || material on a page qualifies for protection, the Producing Party also must clearl || identify the protected portion(s) (e.g., by making appropriate markings in th margins). 15 (b) for testimony given in depositions that the Designating Party identifies o 16]| the record, before the close of the deposition as protected testimony. 3 17 (c) for information produced in some form other than documentary and for an other tangible items, that the Producing Party affix in a prominent place on the exteric 19|| of the container or containers in which the information is stored the legen 20|| “CONFIDENTIAL.” If only a portion or portions of the information warrant protection, the Producing Party, to the extent practicable, shall identify the protecte 22 || portion(s). 23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadverter 24 || failure to designate qualified information or items does not, standing alone, waiv 25 || the Designating Party’s right to secure protection under this Order for such materia 26 || Upon timely correction of a designation, the Receiving Party must make reasonabl 27 || efforts to assure that the material 1s treated in accordance with the provisions of thi 28 || Order.

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge 3 || designation of confidentiality at any time that is consistent with the Court’s Schedulin 4 || Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the disput 6 || resolution process under Local Rule 37.1 et seq. 7 6.3. The burden of persuasion in any such challenge proceeding shall be o 8 || the Designating Party. Frivolous challenges, and those made for an improper purpos 9 ||(e.g., to harass or impose unnecessary expenses and burdens on other parties) ma 10||expose the Challenging Party to sanctions. Unless the Designating Party ha 11 || waived or withdrawn the confidentiality designation, all parties shall continue to affor

| ||the material in question the level of protection to which it is entitled under th 13 || Producing Party’s designation until the Court rules on the challenge. 14|| 7. ACCESS TO AND USE OF PROTECTED MATERIAL 15 7.1 Basic Principles. A Receiving Party may use Protected Material that 1 | disclosed or produced by another Party or by a Non-Party in connection with thi 3 Fl —17||Action only for prosecuting, defending, or attempting to settle this Action. Suc 18 || Protected Material may be disclosed only to the categories of persons and under th 19 || conditions described in this Order. When the Action has been terminated, a Receivin 20 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 21 Protected Material must be stored and maintained by a Receiving Party at 22 ||location and in a secure manner that ensures that access is limited to the person 23 || authorized under this Order. 24 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unles 25 || otherwise ordered by the court or permitted in writing by the Designating Party, 26 || Receiving Party may disclose any information or item designated “CONFIDENTIAL 27 || only to: 28 (a) the Receiving Party’s Outside Counsel of Record in this Action, a

1 |} well as employees of said Outside Counsel of Record to whom it is reasonabl 2 ||necessary to disclose the information for this Action; 3 (b) the officers, directors, and employees (including House Counsel) of th 4 || Receiving Party to whom disclosure is reasonably necessary for this Action; 5 (c) Experts (as defined in this Order) of the Receiving Party to whor 6 ||disclosure is reasonably necessary for this Action and who have signed th 7 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) the court and its personnel; 9 (ec) court reporters and deposition videographers and their staff; 10 (f) professional jury or trial consultants, mock jurors, and □□□□□□□□□□□ 11 || Vendors to whom disclosure is reasonably necessary for this Action and who hav

12 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (g) the author or recipient of a document containing the information or 14 || custodian or other person who otherwise possessed or knew the information; 15 (h) during their depositions, witnesses, and attorneys for witnesses, in th 16 || Action to whom disclosure is reasonably necessary provided: 3 17 (1) the deposing party requests that the witness sign the form attached a 18 || Exhibit 1 hereto; and 19 (2) they will not be permitted to keep any confidential information unles 20 || they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unles 21 ||otherwise agreed by the Designating Party or ordered by the court. Pages c 22 transcribed deposition testimony or exhibits to depositions that reveal Protecte 23 || Material may be separately bound by the court reporter and may not be disclosed t 24 || anyone except as permitted under this Stipulated Protective Order; and 25 (1) any mediator or settlement officer, and their supporting personne 26 || mutually agreed upon by any of the parties engaged in settlement discussions. 27 || /// 28 || ///

1/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED I 2 || OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation thé 4\|compels disclosure of any information or items designated in this Action a 5 ||“CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notificatio 7 || shall include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order t 9 || issue in the other litigation that some or all of the material covered by the subpoena c 10 || order is subject to this Protective Order, including a copy of this Stipulated Protectiv 11 || Order; and

12 (c) cooperate with respect to all reasonable procedures sought to be pursue 13 || by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served wit | 15||the subpoena or court order shall not produce any information designated in this actio 16 “CONFIDENTIAL” before a determination by the court from which the subpoen 3 4! —17|lor order issued, unless the Party has obtained the Designating Party’s permission, ¢ 18 || unless otherwise required by the law or court order. The Designating Party shall bee 19 || the burden and expense of seeking protection in that court of its confidential materia 20 || Nothing in these provisions should be construed as entitling a Receiving Party in thi 21 || Action to disobey a lawful directive from another court. 22119. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCEI 23 || IN THIS LITIGATION 24 (a) The terms of this Order are applicable to information produced by a Nor ||Party in this Action and designated as “CONFIDENTIAL.” Such informatio 26 || produced by Non-Parties in connection with this litigation is protected by the remedie 27 ||and relief provided by this Order. Nothing in these provisions should be construe 28 ||as prohibiting a Non-Party from seeking additional protections.

1 (b) In the event that a Party is required, by a valid discovery request, t 2 || produce a Non-Party’s confidential information in its possession, and the Party 1 3 || subject to an agreement with the Non-Party not to produce the Non-Party’s □□□□□□□□□□□ 4 || information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non-Party □□□ 6 ||some or all of the information requested is subject to a confidentiality agreement wit 7 \|a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated Protectiv 9||Order in this Action, the relevant discovery request(s), and a reasonably specifi 10 || description of the information requested; and 11 (3) make the information requested available for inspection by the Non-Party 12 requested. 13 (c) Ifthe Non-Party fails to seek a protective order from this court □□□□□□□ 14 || days of receiving the notice and accompanying information, the Receiving Party ma 15 produce the Non-Party’s confidential information responsive to the discovery reques 16 || If the Non-Party timely seeks a protective order, the Receiving Party shall not produc

—17||any information in its possession or control that is subject to the confidentialit 18 || agreement with the Non-Party before a determination by the court. Absent a court ord¢ 19 || to the contrary, the Non-Party shall bear the burden and expense of seeking protectio 20 || in this court of its Protected Material. 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclose 23 || Protected Material to any person or in any circumstance not authorized under thi 24 || Stipulated Protective Order, the Receiving Party must immediately (a) notify 1 25 || writing the Designating Party of the unauthorized disclosures, (b) use its best effort 26 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person c 27 || persons to whom unauthorized disclosures were made of all the terms of this Orde: 28 ||and (d) request such person or persons to execute the “Acknowledgment an

1 || Agreement to Be Bound” that is attached hereto as Exhibit A. 2\)}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWIS: 3 || PROTECTED MATERIAL 4 When a Producing Party gives notice to Receiving Parties that certai 5 || inadvertently produced material is subject to a claim of privilege or other protectiot 6 ||the obligations of the Receiving Parties are those set forth in Federal Rule of Civ 7 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedur 8 || may be established in an e-discovery order that provides for production without pric 9 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as th 10|| parties reach an agreement on the effect of disclosure of a communication c 11 ||information covered by the attorney-client privilege or work product protection, th

12 || parties may incorporate their agreement in the stipulated protective order submitted t 13 || the court. 14|| 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the nght of an 16 || person to seek its modification by the Court in the future. 3 17 12.2 Right to Assert Other Objections. By stipulating to the entry of thi 18 || Protective Order no Party waives any right it otherwise would have to object t 19 || disclosing or producing any information or item on any ground not addressed in thi 20 || Stipulated Protective Order. Similarly, no Party waives any right to object on an 21 || ground to use in evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal an 23 || Protected Material must comply with Civil Local Rule 79-5. Protected Material ma 24 || only be filed under seal pursuant to a court order authorizing the sealing of the specifi 25 || Protected Material at issue. If a Party's request to file Protected Material under seal 1 26 || denied by the court, then the Receiving Party may file the information in the publi 27 ||record unless otherwise instructed by the court. 28 |} ///

13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 6 3 || days of a written request by the Designating Party, each Receiving Party must retur 4 ||all Protected Material to the Producing Party or destroy such material. As used 1 5 || this subdivision, “all Protected Material” includes all copies, abstracts, compilation: 6 ||summaries, and any other format reproducing or capturing any of the Protecte 7||Material. Whether the Protected Material is returned or destroyed, the Receivin 8 || Party must submit a written certification to the Producing Party (and, if not the sam 9 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifie 10||(by category, where appropriate) all the Protected Material that was returned c 11 ||destroyed and (2) affirms that the Receiving Party has not retained any copie: 12 || abstracts, compilations, summaries or any other format reproducing or capturing an 13 ||}of the Protected Material. Notwithstanding this provision, Counsel are entitled t retain an archival copy of all pleadings, motion papers, trial, deposition, and hearin 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, exper 16 || reports, attorney work product, and consultant and expert work product, even if suc 3 —17||materials contain Protected Material. Any such archival copies that contain c 18 || constitute Protected Material remain subject to this Protective Order as set forth 1 19 || Section 4 (DURATION). 20||14. Any violation of this Order may be punished by any and all appropriate measure 21 || including, without limitation, contempt proceedings and/or monetary sanctions. 22 | /// 23 |} /// 24 /// 25 |} /// 26 |} /// 27 || /// 28 |} ///

1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 || DATED: May 22, 2024 MANNING & KASS 4 ELLROD, RAMIREZ, TRESTER LLP 5 6 By: /s/ Kayleigh A. Andersen 7 Eugene P. Ramirez g Lynn L. Carpenter Kayleigh Andersen 9 Attorneys for Defendant, COUNTY OF 10 SAN BERNARDINO 11

})/DATED: May 22, 2024 THE COCHRAN FIRM

14 By: Briaw T. Dunw ee 15 Brian T. Dunn, Esq. 16 Attorney for Plaintiff, SAMANTHA ARREDONDO

18 19 20 21 22 23 24 25 26 27 28

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2

4|| DATED: May 22, 2024 ° 5 Honorable David T. Bristow 6 United States Magistrate Judge 7 9 10 11

13 614

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, [print or type full name], c 5 [print or type full address], declare unde 6||penalty of perjury that I have read in its entirety and understand the Stipulate 7 ||Protective Order that was issued by the United States District Court for the □□□□□□ 8 || District of California on in the case of ARREDONDO v. COUNT’ 9 || OF SAN BERNARDINO, et al., Case No. 5:24-cv-00163-KK-DTB. I agree to compl 10 || with and to be bound by all the terms of this Stipulated Protective Order and «| |funderstand and acknowledge that failure to so comply could expose me to sanction

12 punishment in the nature of contempt. I solemnly promise that I will not disclos 13 ||in any manner any information or item that is subject to this Stipulated Protectiv Order to any person or entity except in strict compliance with the provisions of thi | Order. 16 I further agree to submit to the jurisdiction of the United States District Cow 3 for the Central District of California for the purpose of enforcing the terms of thi || Stipulated Protective Order, even if such enforcement proceedings occur afte 19 || termination of this action. I hereby appoint [print c 20 || type full name] of [print or type fu ||address and telephone number] as my California agent for service of process 1 22 || connection with this action or any proceedings related to enforcement of this Stipulate 23 || Protective Order. 24 Date: 25 City and State where sworn and signed: 26 27 Printed name: 28 Signature: