United States v. US GC Investment LLC

• Court: District Court, C.D. California
• Decided: February 5, 2024
• Docket: 2:22-cv-02182
• Status: Unknown

Opinion

2 3 4 5

6 UNITED STATES DISTRICT COURT 7 CENTRAL DISTRICT OF CALIFORNIA 8

9 UNITED STATES OF AMERICA ex rel. AZIZA GEORGIAN, Case No. 2:22-cv-2182 AB-PDx 10

Plaintiffs, 11 STIPULATED PROTECTIVE v. ORDER1 12

13 US GC INVESTMENT LP et al.,

Defendants. 14

15 16 1. A. PURPOSES AND LIMITATIONS 17 Discovery in this action is likely to involve production of confidential, 18 proprietary, or private information for which special protection from public 19 disclosure and from use for any purpose other than prosecuting this litigation may be 20 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 21 the following Stipulated Protective Order. The parties acknowledge that this Order 22 does not confer blanket protections on all disclosures or responses to discovery and 23 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. 26

27 1 This Stipulated Protective Order is substantially based on the model protective 1 B. GOOD CAUSE STATEMENT 2 This action is likely to involve commercial, financial, and/or proprietary 3 information for which special protection from public disclosure and from use for any 4 purpose other than prosecution of this action is warranted. Such confidential and 5 proprietary materials and information consist of, among other things, confidential 6 business or financial information, information regarding confidential business 7 practices, or other commercial information (including information implicating 8 privacy rights of third parties), information otherwise generally unavailable to the 9 public, or which may be privileged or otherwise protected from disclosure under 10 state or federal statutes, court rules, case decisions, or common law. Accordingly, to 11 expedite the flow of information, to facilitate the prompt resolution of disputes over 12 confidentiality of discovery materials, to adequately protect information the parties 13 are entitled to keep confidential, to ensure that the parties are permitted reasonable 14 necessary uses of such material in preparation for and in the conduct of trial, to 15 address their handling at the end of the litigation, and serve the ends of justice, a 16 protective order for such information is justified in this matter. It is the intent of the 17 parties that information will not be designated as confidential for tactical reasons 18 and that nothing be so designated without a good faith belief that it has been 19 maintained in a confidential, non-public manner, and there is good cause why it 20 should not be part of the public record of this case. 21 22 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 23 The parties further acknowledge, as set forth in Section 12.3, below, that this 24 Stipulated Protective Order does not entitle them to file confidential information 25 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 26 the standards that will be applied when a party seeks permission from the court to 27 file material under seal. 1 proceedings and records in civil cases. In connection with non-dispositive motions, 2 good cause must be shown to support a filing under seal. See Kamakana v. City and 3 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 4 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 5 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 6 good cause showing), and a specific showing of good cause or compelling reasons 7 with proper evidentiary support and legal justification, must be made with respect to 8 Protected Material that a party seeks to file under seal. The parties’ mere designation 9 of Disclosure or Discovery Material as CONFIDENTIAL or CONFIDENTIAL- 10 COUNSELS’ EYES ONLY does not—without the submission of competent 11 evidence by declaration, establishing that the material sought to be filed under seal 12 qualifies as confidential, privileged, or otherwise protectable—constitute good 13 cause. 14 Further, if a party requests sealing related to a dispositive motion or trial, then 15 compelling reasons, not only good cause, for the sealing must be shown, and the 16 relief sought shall be narrowly tailored to serve the specific interest to be protected. 17 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each 18 item or type of information, document, or thing sought to be filed or introduced under 19 seal in connection with a dispositive motion or trial, the party seeking protection 20 must articulate compelling reasons, supported by specific facts and legal 21 justification, for the requested sealing order. Again, competent evidence supporting 22 the application to file documents under seal must be provided by declaration. 23 Any document that is not confidential, privileged, or otherwise protectable in 24 its entirety will not be filed under seal if the confidential portions can be redacted. If 25 documents can be redacted, then a redacted version for public viewing, omitting only 26 the confidential, privileged, or otherwise protectable portions of the document, shall 27 be filed. Any application that seeks to file documents under seal in their entirety 1 2 2. DEFINITIONS 3 2.1 Action: this pending federal lawsuit 4 2.2 Challenging Party: a Party or Non-Party that challenges the designation 5 of information or items under this Order. 6 2.3 “CONFIDENTIAL” or “CONFIDENTIAL-COUNSELS’ EYES 7 ONLY” Information or Items: information (regardless of how it is generated, stored 8 or maintained) or tangible things that qualify for protection under Federal Rule of 9 Civil Procedure 26(c), and as specified above in the Good Cause Statement. 10 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 11 their support staff). 12 2.5 Designating Party: a Party or Non-Party that designates information or 13 items that it produces in disclosures or in responses to discovery as 14 “CONFIDENTIAL.” 15 2.6 Disclosure or Discovery Material: all items or information, regardless 16 of the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced or 18 generated in disclosures or responses to discovery in this matter. 19 2.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as 21 an expert witness or as a consultant in this Action. 22 2.8 House Counsel: attorneys who are employees of a party to this Action. 23 House Counsel does not include Outside Counsel of Record or any other outside 24 counsel. 25 2.9 Non-Party: any natural person, partnership, corporation, association, or 26 other legal entity not named as a Party to this action. 27 2.10 Outside Counsel of Record: attorneys who are not employees of a party 1 appeared in this Action on behalf of that party or are affiliated with a law firm which 2 has appeared on behalf of that party, and includes support staff. 3 2.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 2.13 Professional Vendors: persons or entities that provide litigation support 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 and their employees and subcontractors. 12 2.14 Protected Material: any Disclosure or Discovery Material that is 13 designated as “CONFIDENTIAL.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 15 from a Producing Party. 16 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 compilations of Protected Material; and (3) any testimony, conversations, or 22 presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the 24 trial judge. This Order does not govern the use of Protected Material at trial. 25 26 4. DURATION 27 FINAL DISPOSITION of the action is defined as the conclusion of any 1 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 2 has run. Except as set forth below, the terms of this protective order apply through 3 FINAL DISPOSITION of the action. The parties may stipulate that they will be 4 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 5 but will have to file a separate action for enforcement of the agreement once all 6 proceedings in this case are complete. 7 Once a case proceeds to trial, information that was designated as 8 CONFIDENTIAL or CONFIDENTIAL-COUNSELS’ EYES ONLY or maintained 9 pursuant to this protective order used or introduced as an exhibit at trial becomes 10 public and will be presumptively available to all members of the public, including 11 the press, unless compelling reasons supported by specific factual findings to proceed 12 otherwise are made to the trial judge in advance of the trial. See Kamakana, 447 F.3d 13 at 1180-81 (distinguishing “good cause” showing for sealing documents produced in 14 discovery from “compelling reasons” standard when merits-related documents are 15 part of court record). Accordingly, for such materials, the terms of this protective 16 order do not extend beyond the commencement of the trial. 17 18 5. DESIGNATING PROTECTED MATERIAL 19 5.1 Exercise of Restraint and Care in Designating Material for Protection. 20 Each Party or Non-Party that designates information or items for protection under 21 this Order must take care to limit any such designation to specific material that 22 qualifies under the appropriate standards. The Designating Party must designate for 23 protection only those parts of material, documents, items, or oral or written 24 communications that qualify so that other portions of the material, documents, items, 25 or communications for which protection is not warranted are not swept unjustifiably 26 within the ambit of this Order. 27 Mass, indiscriminate, or routinized designations are prohibited. Designations 1 that are shown to be clearly unjustified or that have been made for an improper 2 purpose (e.g., to unnecessarily encumber the case development process or to impose 3 unnecessary expenses and burdens on other parties) may expose the Designating 4 Party to sanctions. 5 If it comes to a Designating Party’s attention that information or items that it 6 designated for protection do not qualify for protection, that Designating Party must 7 promptly notify all other Parties that it is withdrawing the inapplicable designation. 8 5.2 Manner and Timing of Designations. Except as otherwise provided in 9 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 10 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 11 under this Order must be clearly so designated before the material is disclosed or 12 produced. 13 Designation in conformity with this Order requires: 14 (a) for information in documentary form (e.g., paper or electronic 15 documents, but excluding transcripts of depositions or other pretrial or trial 16 proceedings), that the Producing Party affix at a minimum, the legend 17 “CONFIDENTIAL” or “CONFIDENTIAL-COUNSELS’ EYES ONLY” 18 (collectively hereinafter, a “CONFIDENTIAL legend”), to each page that contains 19 protected material. If only a portion or portions of the material on a page qualifies 20 for protection, the Producing Party also must clearly identify the protected portion(s) 21 (e.g., by making appropriate markings in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and 25 before the designation, all of the material made available for inspection shall be 26 deemed “CONFIDENTIAL-COUNSELS’ EYES ONLY.” After the inspecting 27 Party has identified the documents it wants copied and produced, the Producing Party 1 this Order. Then, before producing the specified documents, the Producing Party 2 must affix the appropriate “CONFIDENTIAL legend” to each page that contains 3 Protected Material. If only a portion or portions of the material on a page qualifies 4 for protection, the Producing Party also must clearly identify the protected portion(s) 5 (e.g., by making appropriate markings in the margins). 6 (b) for testimony given in depositions that the Designating Party identify 7 the Disclosure or Discovery Material on the record, before the close of the deposition 8 all protected testimony. 9 (c) for information produced in some form other than documentary and for 10 any other tangible items, that the Producing Party affix in a prominent place on the 11 exterior of the container or containers in which the information is stored the 12 appropriate “CONFIDENTIAL legend.” If only a portion or portions of the 13 information warrants protection, the Producing Party, to the extent practicable, shall 14 identify the protected portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not, standing alone, waive 17 the Designating Party’s right to secure protection under this Order for such material. 18 Upon timely correction of a designation, the Receiving Party must make reasonable 19 efforts to assure that the material is treated in accordance with the provisions of this 20 Order. 21 22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 24 designation of confidentiality at any time that is consistent with the Court’s 25 Scheduling Order. 26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 27 resolution process under Local Rule 37.1 et seq. 1 the Designating Party. Frivolous challenges, and those made for an improper purpose 2 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 3 expose the Challenging Party to sanctions. Unless the Designating Party has waived 4 or withdrawn the confidentiality designation, all parties shall continue to afford the 5 material in question the level of protection to which it is entitled under the Producing 6 Party’s designation until the Court rules on the challenge. 7 8 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 7.1 Basic Principles. A Receiving Party may use Protected Material that is 10 disclosed or produced by another Party or by a Non-Party in connection with this 11 Action only for prosecuting, defending, or attempting to settle this Action. Such 12 Protected Material may be disclosed only to the categories of persons and under the 13 conditions described in this Order. When the Action has been terminated, a 14 Receiving Party must comply with the provisions of section 13 below (FINAL 15 DISPOSITION). 16 Protected Material must be stored and maintained by a Receiving Party at a 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 otherwise ordered by the court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 24 as employees of said Outside Counsel of Record to whom it is reasonably necessary 25 to disclose the information for this Action; 26 (b) the officers, directors, and employees (including House Counsel) of the 27 Receiving Party to whom disclosure is reasonably necessary for this Action; 1 disclosure is reasonably necessary for this Action and who have signed the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (d) the court and its personnel; 4 (e) court reporters and their staff; 5 (f) professional jury or trial consultants, mock jurors, and Professional 6 Vendors to whom disclosure is reasonably necessary for this Action and who have 7 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (g) the author or recipient of a document containing the information or a 9 custodian or other person who otherwise possessed or knew the information; 10 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 11 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 12 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 13 not be permitted to keep any confidential information unless they sign the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 15 agreed by the Designating Party or ordered by the court. Pages of transcribed 16 deposition testimony or exhibits to depositions that reveal Protected Material may 17 be separately bound by the court reporter and may not be disclosed to anyone except 18 as permitted under this Stipulated Protective Order; and 19 (i) any mediator or settlement officer, and their supporting personnel, 20 mutually agreed upon by any of the parties engaged in settlement discussions. 21 7.3 Disclosure of “CONFIDENTIAL-COUNSELS’ EYES ONLY” 22 Information or Items. Unless otherwise ordered by the court or permitted in writing 23 by the Designating Party, a Receiving Party may disclose any information or item 24 designated “CONFIDENTIAL-COUNSELS’ EYES ONLY” only to: 25 (a) the Receiving Party’s Counsel of Record in this Action, whether 26 Outside or House, as well as employees of said Counsel of Record to whom it is 27 reasonably necessary to disclose the information for this Action; 1 disclosure is reasonably necessary for this Action and who have signed the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (d) the court and its personnel; 4 (e) court reporters and their staff; 5 (f) professional jury or trial consultants, mock jurors, and Professional 6 Vendors to whom disclosure is reasonably necessary for this Action and who have 7 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (g) the author or recipient of a document containing the information or a 9 custodian or other person who otherwise possessed or knew the information; 10 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 11 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 12 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 13 not be permitted to keep any confidential information unless they sign the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A) and specifically agreed 15 by the Designating Party, or ordered by the court. Pages of transcribed deposition 16 testimony or exhibits to depositions that reveal Protected Material may be separately 17 bound by the court reporter and may not be disclosed to anyone except as permitted 18 under this Stipulated Protective Order; and 19 (i) any mediator or settlement officer, and their supporting personnel, 20 mutually agreed upon by any of the parties engaged in settlement discussions. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 22 IN OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL” or “CONFIDENTIAL-COUNSELS’ EYES ONLY,” that Party 26 must: 27 (a) promptly notify in writing the Designating Party. Such notification shall 1 include a copy of the subpoena or court order; 2 (b) promptly notify in writing the party who caused the subpoena or order 3 to issue in the other litigation that some or all of the material covered by the subpoena 4 or order is subject to this Protective Order. Such notification shall include a copy of 5 this Stipulated Protective Order; and 6 (c) cooperate with respect to all reasonable procedures sought to be pursued 7 by the Designating Party whose Protected Material may be affected. 8 If the Designating Party timely seeks a protective order, the Party served 9 with the subpoena or court order shall not produce any information designated in this 10 action as “CONFIDENTIAL” or “CONFIDENTIAL-COUNSELS’ EYES ONLY” 11 before a determination by the court from which the subpoena or order issued, unless 12 the Party has obtained the Designating Party’s written permission. The Designating 13 Party shall bear the burden and expense of seeking protection in that court of its 14 confidential material and nothing in these provisions should be construed as 15 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 16 directive from another court. 17 18 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 19 PRODUCED 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” or “CONFIDENTIAL- 22 COUNSELS’ EYES ONLY.” Such information produced by Non-Parties in connection 23 with this litigation is protected by the remedies and relief provided by this Order. 24 Nothing in these provisions should be construed as prohibiting a Non-Party from 25 seeking additional protections. 26 (b) In the event that a Party is required, by a valid discovery request, to 27 produce a Non-Party’s confidential information in its possession, and the Party is 1 confidential information, then the Party shall: 2 (1) promptly notify in writing the Requesting Party and the Non-Party 3 that some or all of the information requested is subject to a confidentiality agreement 4 with a Non-Party; 5 (2) promptly provide the Non-Party with a copy of the Stipulated 6 Protective Order in this Action, the relevant discovery request(s), and a reasonably 7 specific description of the information requested; and 8 (3) make the information requested available for inspection by the 9 Non-Party, if requested. 10 (c) If the Non-Party fails to seek a protective order from this court within 11 14 days of receiving the notice and accompanying information, the Receiving Party 12 may produce the Non-Party’s confidential information responsive to the discovery 13 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 14 not produce any information in its possession or control that is subject to the 15 confidentiality agreement with the Non-Party before a determination by the court. 16 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 17 of seeking protection in this court of its Protected Material. 18 19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 20 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 21 Protected Material to any person or in any circumstance not authorized under this 22 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 23 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 24 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 25 persons to whom unauthorized disclosures were made of all the terms of this Order, 26 and (d) request such person or persons to execute the “Acknowledgment and 27 Agreement to Be Bound” that is attached hereto as Exhibit A. 1 11. 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 prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 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 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 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 any 23 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 24 only be filed under seal pursuant to a court order authorizing the sealing of the 25 specific Protected Material at issue. If a Party's request to file Protected Material 26 under seal is denied by the court, then the Receiving Party may file the information 27 in the public record unless otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in 5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving 8 Party must submit a written certification to the Producing Party (and, if not the same 9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 10 (by category, where appropriate) all the Protected Material that was returned or 11 destroyed and (2)affirms that the Receiving Party has not retained any copies, 12 abstracts, compilations, summaries or any other format reproducing or capturing any 13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 16 reports, attorney work product, and consultant and expert work product, even if such 17 materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Protective Order as set forth in 19 Section 4 (DURATION). 20 21 22 23 24 25 26 27 1 || 14. Any violation of this Order may be punished by any and all appropriate 2 || measures including, without limitation, contempt proceedings and/or monetary 3 || sanctions. 4 5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 || DATED: Feb. 2, 2024 8 9 || /s/ Patrick S. Almonrode 10 Attorneys for Plaintiff Aziza Georgian 11 D DATED: Feb. 2, 2024 13 14 /s Diana Spielberger Attorneys for Defendants 15 16 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 18 19 DATED: February 05, 2024 20 | Febiucas Dana kue_ 22 || Patricia Donahue 74 United States Magistrate Judge 24 25 26 27 28

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, ________________________ [print or type full name], of 4 ___________________________________________ [print or type full address], 5 declare under penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States District Court for 7 the Central District of California on [date] in the case of United States ex rel. 8 Aziza Georgian v. US GC Investment LP et al., 2:22-cv-2182-AB-PDx. I agree to 9 comply with and to be bound by all the terms of this Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and 11 punishment in the nature of contempt. I solemnly promise that I will not disclose 12 in any manner any information or item that is subject to this Order to any person or 13 entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint ____________________________ 18 [print or type full name] of ____________________________________________ 19 [print or type full address and telephone number] as my California agent for service 20 of process in connection with this action or any proceedings related to enforcement 21 of this Stipulated Protective Order. 22

23 Date: __________________________ 24 City and State where sworn and signed: _____________________________ 25

26 Printed name: ____________________________________ 27