Vincent Turrey v. City of Los Angeles

• Court: District Court, C.D. California
• Decided: April 19, 2023
• Docket: 2:22-cv-05492
• Status: Unknown

Opinion

1 || Yana G. Henriks, Esq. (SBN 250638) Email: Pent iks alan h.cont 2 ||McMURRAY HENRIKS, LL 811 Wilshire Blvd., Suite 1640 3 Los Angeles, CA 90017 Tel.: (323) 931-6200 4 || Fax: (323) 931-9521 5 || Attorney for Plaintiff, VINCENT TURREY 6 HYDEE FELDSTEIN SOTO, City Attorney (SBN RCO) 7 || SCOTT MARCUS, Chief Assistant City Attorney (SBN 184980) CORY M. BRENITTE, Senior Assistant ity Attorney (SEN 115453) 8 || IRVING R. ESTRADA, Deputy City Attorney (SBN 314785) 200 N. Main Street, 6th floor 9 || Los Angeles, California 90012 Tel: (213) 978-2247 Fax: (213) 978-8785 10 || Email: Irving. Estrada@lacity.org 11 Attorneys (or. Relendants, CITY OF LOS ANGELES, LOS ANGELES POLICE DEPARTMENT, CHIEF MICHEL MOORE (named in the Complaint as “POLICE 12 || CHIEF MICHAEL MOORE”), OFFICER JOEL DOMINGUEZ and OFFICER 13 RICARDO LEON

14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 7 VINCENT TURREY, an individual, CASE NO. CV22-05492 MCS (MRWx) Hon. Mark C. Searst; St CH - Ctrm. 7C 18 Plaintiff, Hon. Mag. Michael R. Wilner; Roybal — Ctrm. 550 19 vs. 0 STIPULATED PROTECTIVE ORDER CITY OF LOS ANGELES, a 91 || California municipal entity; LOS ANGELES POLICE Check if submitted without material 22 | DEPARTMENT, a public entity; modifications to MRW form POLICE CHIEF MICHAEL 23 MOORE, an individual; OFFICER. ||JOEL DOMINGUEZ, an individual; OFFICER RICARDO LEON, an 25 individual; and DOES 1-50, inclusive, 26 Defendants. 28 ]

144i. INTRODUCTION 2 1.1 PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 || proprietary, or private information for which special protection from public disclosure 5 from use for any purpose other than prosecuting this litigation may be warranted. 6 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 7 || following Stipulated Protective Order. The parties acknowledge that this Order does 8 |jnot confer blanket protections on all disclosures or responses to discovery and that the 9 || protection it affords from public disclosure and use extends only to the limited 10 || information or items that are entitled to confidential treatment under the applicable 11 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 12 || that this Stipulated Protective Order does not entitle them to file confidential 13 |\information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 14 || followed and the standards that will be applied when a party seeks permission from 15 court to file material under seal. 16 1.2 GOOD CAUSE STATEMENT 17 WHEREAS Plaintiff VINCENT TURREY (“Plaintiff’) is seeking materials 18 || and information that Defendant the City of Los Angeles (“City”) maintains as 19 || confidential, including but limited to, video recordings, audio recordings, other 20 confidential information and documents regarding this incident, and other 21 administrative materials and information currently in the possession of the City and 22 || which the City believes need special protection from public disclosure and from use 23 || for any purpose other than prosecuting this litigation. 24 The City asserts that the confidentiality of the materials and information sought 25 || by Plaintiffs is recognized by California and federal law, as evidenced inter alia by 26 |i California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., 27 ||511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City has not 28 || publicly released the materials and information referenced above except under

1 || protective order or pursuant to a court order, if at all. These materials and information 2 || are of the type that has been used to initiate disciplinary action against Los Angeles 3 | Police Department (“LAPD”) officers, and has been used as evidence in disciplinary 4 || proceedings, where the officers’ conduct was considered to be contrary to LAPD 5 || policy. 6 The City contends that absent a protective order delineating the responsibilities 7 of nondisclosure on the part of the parties hereto, there is a specific risk of 8 |j unnecessary and undue disclosure by one or more of the many attorneys, secretaries, 9 || law clerks, paralegals and expert witnesses involved in this case, as well as the 10 corollary risk of embarrassment, harassment and professional and legal harm on the 11 || part of the LAPD officers referenced in the materials and information. The unfettered 12 disclosure of the materials and information, absent a protective order, would allow the 13 || media to share this information with potential jurors in the area, impacting the rights 14 || of Defendant herein to receive a fair trial. 15 Accordingly, to expedite the flow of information, to facilitate the prompt 16 ||resolution of disputes over confidentiality of discovery materials, to adequately 17 || protect information the parties are entitled to keep confidential, to ensure that the 18 || parties are permitted reasonable necessary uses of such material in preparation for and 19 |lin the conduct of trial, to address their handling at the end of the litigation, and serve 20 || the ends of justice, a protective order for such information is justified in this matter. It 21 || is the intent of the parties that information will not be designated as confidential for 22 tactical reasons and that nothing be so designated without a good faith belief that it 23 been maintained in a confidential, non-public manner, and there is good cause 24 || why it should not be part of the public record of this case. 25 The parties therefore stipulate that there is Good Cause for, and hereby jointly 26 || request that the honorable Court issue a Protective Order regarding confidential 27 documents consistent with the terms and provisions of this Stipulation, However, the 28 entry of a Protective Order by the Court pursuant to this Stipulation shall not be

1 || construed as any ruling by the Court on the aforementioned legal statements or 2 |\privilege claims in this section, no shall this section be construed as part of any such 3 || Court Order, The City has not publicly released the documents, video or information 4 ||referenced above except under protective order or pursuant to court order, if at all. 5 642. DEFINITIONS 7 2.1 Action: Vincent Turrey vy. City of Los Angeles, et al. 22-cv-05492- 8 || MCS-MRWx. 9 2.2 Challenging Party: a Party or Non-Party that challenges the designation 10 || of information or items under this Order. 11 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 12 |i how it is generated, stored or maintained) or tangible things that qualify for protection 13 || under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 14 || Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 16 ||support staff). 17 2.5 Designating Party: a Party or Non-Party that designates information or 18 || items that it produces in disclosures or in responses to discovery as 19 || “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless of 21 ||the medium or manner in which it is generated, stored, or maintained (including, 22 ||among other things, testimony, transcripts, and tangible things), that are produced or 23 || generated in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an 26 expert witness or as a consultant in this Action. 27 28 |///

1 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 | House Counsel does not include Outside Counsel of Record or any other outside 3 || counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association, or 5 other legal entity not named as a Party to this action. 6 2.10 Outside Counsel of Record: attorneys who are not employees of a party 7 |\to this Action but are retained to represent or advise a party to this Action and have 8 ||appeared in this Action on behalf of that party or are affiliated with a law firm which 9 ||has appeared on behalf of that party, and includes support staff. 10 2.11 Party: any party to this Action, including all of its officers, directors, 11 |}employees, consultants, retained experts, and Outside Counsel of Record (and their 12 || support staffs). 13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 || Discovery Material in this Action. 15 2.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 ||demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 ||and their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is 20 || designated as “CONFIDENTIAL.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 22 from a Producing Party. 23 24 |13. SCOPE 25 The protections conferred by this Stipulation and Order cover not only 26 || Protected Material (as defined above), but also (1) any information copied or extracted 27 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 28 || Protected Material; and (3) any testimony, conversations, or presentations by Parties

1 |lor their Counsel that might reveal Protected Material. 2 Any use of Protected Material at trial will be governed by the orders of the trial 3 ||judge. This Order does not govern the use of Protected Material at trial. 4 §|t4. DURATION 6 Even after final disposition of this litigation, the confidentiality obligations 7 || imposed by this Order will remain in effect until a Designating Party agrees otherwise 8 || in writing or a court order otherwise directs. Final disposition will be deemed to be 9 the later of (1) dismissal of all claims and defenses in this Action, with or without 10 |j prejudice; and (2) final judgment herein after the completion and exhaustion of all 11 ||appeals, rehearings, remands, trials, or reviews of this Action, including the time 12 || limits for filing any motions or applications for extension of time pursuant to 13 || applicable law. 14 15 ||5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for Protection. 17 || Each Party or Non-Party that designates information or items for protection under this 18 || Order must take care to limit any such designation to specific material that qualifies 19 || under the appropriate standards. The Designating Party must designate for protection 20 || only those parts of material, documents, items, or oral or written communications that 21 || qualify so that other portions of the material, documents, items, or communications 22 || for which protection is not warranted are not swept unjustifiably within the ambit of 23 this Order. 24 Mass, indiscriminate, or routinized designations are prohibited. Designations 25 | that are shown to be clearly unjustified or that have been made for an improper 26 || purpose (e.g., to unnecessarily encumber the case development process or to impose 27 || unnecessary expenses and burdens on other parties) may expose the Designating Party 28 || to sanctions.

1 Lf it comes to a Designating Party’s attention that information or items that it 2 |\designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2. Manner and Timing of Designations. Except as otherwise provided in 5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 \lunder this Order must be clearly so designated before the material is disclosed or 8 || produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic documents, 11 || but excluding transcripts of depositions or other pretrial or trial proceedings), that the 12 || Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 13 | “CONFIDENTIAL legend”), to each page that contains protected material. If only a 14 || portion or portions of the material on a page qualifies for protection, the Producing 15 || Party also must clearly identify the protected portion(s) (e.g., by making appropriate 16 | markings in the margins). 17 A Party or Non-Party that makes original documents available for inspection 18 need not designate them for protection until after the inspecting Party has indicated 19 || which documents it would like copied and produced. During the inspection and before 20 the designation, all of the material made available for inspection will be deemed 21 1|“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 22 || copied and produced, the Producing Party must determine which documents, or 23 || portions thereof, qualify for protection under this Order. Then, before producing the 24 |i specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 25 to each page that contains Protected Material. If only a portion or portions of the 26 || material on a page qualifies for protection, the Producing Party also must clearly 27 |lidentify the protected portion(s) (e.g., by making appropriate markings in the 28 || margins).

1 (b) for testimony given in depositions that the Designating Party identify the 2 || Disclosure or Discovery Material on the record, before the close of the deposition all 3 || protected testimony. 4 (c) for information produced in some form other than documentary and for any 5 || other tangible items, that the Producing Party affix in a prominent place on the 6 || exterior of the container or containers in which the information is stored the legend 7 \|“CONFIDENTIAL.” If only a portion or portions of the information warrants 8 || protection, the Producing Party, to the extent practicable, will identify the protected 9 || portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive the 12 || Designating Party’s right to secure protection under this Order for such material. 13 || Upon timely correction of a designation, the Receiving Party must make reasonable 14 |lefforts to assure that the material is treated in accordance with the provisions of this 15 || Order. 16 17 16. CHALLENGING CONFIDENTIALITY DESIGNATIONS 18 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 19 || designation of confidentiality at any time that is consistent with the Court’s 20 || Scheduling Order. 21 6.2 Meet □□□ Confer. The Challenging Party will initiate the dispute 22 ||resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 23 ||et seq. 24 6.3. The burden of persuasion in any such challenge proceeding will be on the 25 || Designating Party. Frivolous challenges,.and those made for an improper purpose 26 || (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 27 |\expose the Challenging Party to sanctions. Unless the Designating Party has waived 28 || or withdrawn the confidentiality designation, all parties will continue to afford the 8g

1 | material in question the level of protection to which it is entitled under the Producing 2 || Party’s designation until the Court rules on the challenge. 3 4||7. ACCESS TO AND USE OF PROTECTED MATERIAL | 5 7.1 Basic Principles. A Receiving Party may use Protected Material that is 6 || disclosed or produced by another Party or by a Non-Party in connection with this 7 || Action only for prosecuting, defending, or attempting to settle this Action. Such 8 || Protected Material may be disclosed only to the categories of persons and under the 9 conditions described in this Order. When the Action has been terminated, a Receiving 10 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 11 Protected Material must be stored and maintained by a Receiving Party ata 12 || location and in a secure manner that ensures that access is limited to the persons 13 |jauthorized under this Order. 14 7.2 Disclosure of “CONFIDENTIAL” Information or items. Unless 15 || otherwise ordered by the court or permitted in writing by the Designating Party, a 16 || Receiving Party may disclose any information or item designated “CONFIDENTIAL” 17 || only to: 18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 19 ||as employees of said Outside Counsel of Record to whom it is reasonably necessary to 20 || disclose the information for this Action; 21 (b) the officers, directors, and employees (including House Counsel) of the 22 || Receiving Party to whom disclosure is reasonably necessary for this Action; 23 (c) Experts (as defined in this Order) of the Receiving Party to whom 24 || disclosure is reasonably necessary for this Action and who have signed the 25 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (d) the Court and its personnel; 27 (e) court reporters and their staff 28 |\// i 9g

1 (f) professional jury or trial consultants, mock jurors, and Professional 2 || Vendors to whom disclosure is reasonably necessary for this Action and who have 3 ||signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information or a 5 || custodian or other person who otherwise possessed or knew the information; 6 (hb) during their depositions, witnesses ,and attorneys for witnesses, in the 7 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 8 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 9 || not be permitted to keep any confidential information unless they sign the 10 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 11 || by the Designating Party or ordered by the court. Pages of transcribed deposition 12 || testimony or exhibits to depositions that reveal Protected Material may be separately 13 || bound by the court reporter and may not be disclosed to anyone except as permitted 14 || under this Stipulated Protective Order; and 15 (i) any mediator or settlement officer, and their supporting personnel, 16 \| mutually agreed upon by any of the parties engaged in settlement discussions, 17 18 ||8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 19 || OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation 21 |jthat compels disclosure of any information or items designated in this Action as 22. “CONFIDENTIAL,” that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification will 24 |linclude a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order 26 issue in the other litigation that some or all of the material covered by the subpoena 27 lor order is subject to this Protective Order. Such notification will include a copy of 28 this Stipulated Protective Order; and 1G

1 (c) cooperate with respect to all reasonable procedures sought to be pursued 2 by the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with A |\the subpoena or court order will not produce any information designated in this action 5 “CONFIDENTIAL” before a determination by the court from which the subpoena 6 || or order issued, unless the Party has obtained the Designating Party’s permission. The 7 || Designating Party will bear the burden and expense of seeking protection in that court 8 || of its confidential material and nothing in these provisions should be construed as 9 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful 10 || directive from another court. 11 1219. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 13 || PRODUCED IN THIS LITIGATION 14 (a) The terms of this Order are applicable to information produced by a 15 ||Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 16 || produced by Non-Parties in connection with this litigation is protected by the 17 ||vemedies and relief provided by this Order. Nothing in these provisions should be 18 || construed as prohibiting a Non-Party from seeking additional protections. 19 (b) In the event that a Party is required, by a valid discovery request, to 20 || produce a Non-Party’s confidential information in its possession, and the Party is 21 || subject to an agreement with the Non-Party not to produce the Non-Party’s 22 || confidential information, then the Party will: 23 (1) promptly notify in writing the Requesting Party and the Non-Party 24 ||that some or all of the information requested is subject to a confidentiality agreement 25 |j with a Non-Party; 26 (2) promptly provide the Non-Party with a copy of the Stipulated 27 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 28 || specific description of the information requested; and fi

1 (3) make the information requested available for inspection by the Non- 2 || Party, if requested. 3 (c) If the Non-Party fails to seck a protective order from this court within 14 4 | days of receiving the notice and accompanying information, the Receiving Party may 5 || produce the Non-Party’s confidential information responsive to the discovery request. 6 || If the Non-Party timely seeks a protective order, the Receiving Party will not produce 7 || any information in its possession or control that is subject to the confidentiality 8 || agreement with the Non-Party before a determination by the court. Absent a court 9 || order to the contrary, the Non-Party will bear the burden and expense of seeking 10 |) protection in this court of its Protected Material. 14 12 ||}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 || Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 16 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 17 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 18 persons to whom unauthorized disclosures were made of all the terms of this Order, 19 || and (d) request such person or persons to execute the “Acknowledgment and 20 || Agreement to Be Bound” that is attached hereto as Exhibit A. 21 2211. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, 26 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 |i Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 28 || may be established in an e-discovery order that provides for production without prior 12.

1 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 || parties reach an agreement on the effect of disclosure of a communication or 3 || information covered by the attorney-client privilege or work product protection, the 4 || parties may incorporate their agreement in the stipulated protective order submitted to 5 || the court. 6 7\|12. MISCELLANEOUS 8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 || person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 |) Protective Order no Party waives any right it otherwise would have to object to 12 || disclosing or producing any information or item on any ground not addressed in this 13 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 || ground to use in evidence of any of the material covered by this Protective Order. 15 12.3 Filing Protected Material. A Party that seeks to file under seal any 16 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 17 || only be filed under seal pursuant to a court order authorizing the sealing of the 18 || specific Protected Material at issue. Ifa Party's request to file Protected Material 19 || under seal is denied by the court, then the Receiving Party may file the information in 20 || the public record unless otherwise instructed by the court. 21 22 |;13. FINAL DISPOSITION 23 After the fina! disposition of this Action, as defined in paragraph 4, within 60 24 || days of a written request by the Designating Party, each Receiving Party must return 25 |{all Protected Material to the Producing Party or destroy such material. As used in this 26 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 27 |jsummaries, and any other format reproducing or capturing any of the Protected 28 Material. Whether the Protected Material is returned or destroyed, the Receiving 13

1 Party must submit a written certification to the Producing Party (and, if not the same 2 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 3 \|(by category, where appropriate) all the Protected Material that was returned or 4 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 5 ||abstracts, compilations, summaries or any other format reproducing or capturing any 6 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 7 ||retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 8 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 9 reports, attorney work product, and consultant and expert work product, even if such 10 || materials contain Protected Material. Any such archival copies that contain or L1 || constitute Protected Material remain subject to this Protective Order as set forth in 12 Section 4 (DURATION). 13 [j/// 14 ||/// 15 16 |i/// 17 ||/// 18 ||/// 19 ||/// 20 21 22 {|/// 23 fi 24 ii 25 |i/// 26 |j/// 27 |i 28 |I/// 14

1{/14. Any willful violation of this Order may be punished by civil or criminal 2 || contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 3 || authorities, or other appropriate action at the discretion of the Court. 4 5 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 . T\patep: YW/ 22 Ok» Ye 8 Attorneys for Plaintiff 9 10 JEL DATED: __ 4/18/2023 I] TO qi eam — 12 13 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERET. [ 4 14 1D |DATED: 4/1923 th MAA 16 United States Magistrate Judge 17 18 19 20 21 22 23 24 25 26 27 28 15

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, [full name], of 5 || [full address], declare under penalty of perjury that I have read in its entirety and 6 ||understand the Stipulated Protective Order that was issued by the United States 7 || District Court for the Central District of California on [date] in the case of 8 [insert case name and number]. I agree to comply with and to be 9 || bound by all the terms of this Stipulated Protective Order and I understand and 10 |}acknowledge that failure to so comply could expose me to sanctions and punishment 11 || in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 |jany information or item that is subject to this Stipulated Protective Order to any 13 || person or 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 15 || for 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 [full 18 name] of {full address and 19 | telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 || Order. 22 || Date: 23 City and State where signed: 24 25 || Printed name: 26 27 || Signature: 28 16