1 2 3 4 5 6 7 8 10 CENTRAL DISTRICT OF CALIFORNIA — WESTERN DIVISION 11 $12 VLADIMIR ROYTER, Case No. 2:24-cv-06484-FLA-PVCx Plaintiff, STIPULATED PROTECTIVE ORDER CORPORATION and DOES 1 t0 50, 16 Defendant(s). 17 18 19 1. INTRODUCTION 20 1.1 PURPOSES AND LIMITATIONS 71 Discovery in this action may involve production of confidential, proprietary, or 22 private information for which special protection from public disclosure and from use □□ 23 any purpose other than prosecuting this litigation may be warranted. 24 Accordingly, the Parties hereby stipulate to and petition the Court to enter the 2 following Stipulated Protective Order. The Parties acknowledge that this Order does nx 26 ! confer blanket protections on all disclosures or responses to discovery and that the 27 protection it affords from public disclosure and use extends only to the limited 28
1 information or items that are entitled to confidential treatment under the applicable leg 2 principles. The Parties further acknowledge, as set forth in Section 12.3 below, that thi 3 Order does not entitle them to file Confidential Information under seal; Civil Local Ru 79-5 sets forth the procedures that must be followed and the standards that will be 5 applied when a Party seeks permission from the Court to file material under seal. 6 1.2 GOOD CAUSE STATEMENT 7 This action arises from alleged injuries sustained by Plaintiff VLADIMIR g || ROYTER (“Vladimir”) due to an incident in a Costco retail store. Vladimir was g || attempting to move a box containing a mattress when he tore his biceps tendon. 190 Vladimir alleges negligence and premises liability causes of action. ll Evidence or potential evidence that will be disclosed in discovery is expected to 8 12 || include confidential and proprietary information and documents regarding business 13 practices pertaining to safety, products sold in Costco, and other matters which are 14 generally unavailable to the public and could be exploited by actors (e.g. criminals and 3 15 || Scammers) who have no interest in or need for evidence produced in this case for their 16 Own unlawful purposes. Likewise, evidence shall include surveillance footage which 1 17 also generally unavailable to the public. This footage invokes the same concerns as th 1g || other information discussed above, and potentially implicates third party privacy 19 ] concerns as well. 20 Accordingly, to expedite the flow of information, to facilitate the prompt 91 resolution of disputes over confidentiality of discovery materials, to adequately protect 92 information the parties are entitled to keep confidential, to ensure that the parties are 93 permitted reasonable necessary uses of such material in preparation for and in the 94 conduct of trial, to address their handling at the end of the litigation, and serve the ends 25 of justice, a protective order for such information is justified in this matter. It is the 26 intent of the parties that information will not be designated as confidential for tactical 97 reasons and that nothing be so designated without a good faith belief that it has been 28 -2-
maintained in a confidential, non-public manner, and there is good cause why it should 7 not be part of the public record of this case. 3 2. DEFINITIONS 4 2.1 Action: This pending federal lawsuit, which originated in the Superior Court 5 of the State of California and was removed to Federal Court by Defendant COSTCO 6 WHOLESALE CORPORATION (“Defendant” or “Costco”) on diversity jurisdiction 7 grounds. g 2.2 Challenging Party: a Party or Nonparty that challenges the designation of g || information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 11 generated, stored, or maintained) or tangible things that qualify for protection under 8 12 || Federal Rule of Civil Procedure 26(c) and as specified above in the Good Cause 13 Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 3 15 || Support staff). 16 2.5 Designating Party: a Party or Nonparty that designates information or ttems 17 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 18 2.6 Disclosure or Discovery Material: all items or information, regardless of the 19 medium or manner in which it is generated, stored, or maintained (including, among 29 other things, testimony, transcripts, and tangible things), that are produced or generatec 21 in disclosures or responses to discovery in this matter. 2.7 Expert: a person with specialized knowledge or experience in a matter 23 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 94 expert witness or as a consultant in this action. 25 2.8 House Counsel: attorneys who are employees of a Party to this Action. Hous 26 Counsel does not include Outside Counsel of Record or any other outside counsel. 7 2.9 Nonparty: any natural person, partnership, corporation, association, or other 2g || legal entity not named as a Party to this action. -3-
1 2.10 Outside Counsel of Record: attorneys who are not employees of a Party to 7 this Action but are retained to represent or advise a Party and have appeared in this 3 Action on behalf of that Party or are affiliated with a law firm that has appeared on behalf of that Party, including support staff. 5 2.11 Party: any Party to this Action, including all of its officers, directors, 6 employees, consultants, retained experts, and Outside Counsel of Record (and their 7 support staffs). 8 2.12 Producing Party: a Party or Nonparty that produces Disclosure or Discover g || Material in this Action. 10 2.13 Professional Vendors: persons or entities that provide litigation support 11 services (for example, photocopying, videotaping, translating, preparing exhibits or 8 12 || demonstrations, and organizing, storing, or retrieving data in any form or medium) □□□□ 13 their employees and subcontractors. 14 2.14 Protected Material: any Disclosure or Discovery Material that is designated 15 as “CONFIDENTIAL.” 16 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material fro: 17 a Producing Party. 18 3. SCOPE 19 The protections conferred by this Stipulation and Order cover not only Protected 29 Material (as defined above) but also any information copied or extracted from Protecte 91 Material; all copies, excerpts, summaries, or compilations of Protected Material; and a 97 testimony, conversations, or presentations by Parties or their Counsel that might reveal 93 Protected Material. 24 Any use of Protected Material at trial will be governed by the orders of the trial 25 Judge. This Order does not govern the use of Protected Material at trial. 4. DURATION 7 Once a case proceeds to trial, all the information that was designated as ag || confidential or maintained under this Order becomes public and will be presumptively 4.
Free access — add to your briefcase to read the full text and ask questions with AI
1 2 3 4 5 6 7 8 10 CENTRAL DISTRICT OF CALIFORNIA — WESTERN DIVISION 11 $12 VLADIMIR ROYTER, Case No. 2:24-cv-06484-FLA-PVCx Plaintiff, STIPULATED PROTECTIVE ORDER CORPORATION and DOES 1 t0 50, 16 Defendant(s). 17 18 19 1. INTRODUCTION 20 1.1 PURPOSES AND LIMITATIONS 71 Discovery in this action may involve production of confidential, proprietary, or 22 private information for which special protection from public disclosure and from use □□ 23 any purpose other than prosecuting this litigation may be warranted. 24 Accordingly, the Parties hereby stipulate to and petition the Court to enter the 2 following Stipulated Protective Order. The Parties acknowledge that this Order does nx 26 ! confer blanket protections on all disclosures or responses to discovery and that the 27 protection it affords from public disclosure and use extends only to the limited 28
1 information or items that are entitled to confidential treatment under the applicable leg 2 principles. The Parties further acknowledge, as set forth in Section 12.3 below, that thi 3 Order does not entitle them to file Confidential Information under seal; Civil Local Ru 79-5 sets forth the procedures that must be followed and the standards that will be 5 applied when a Party seeks permission from the Court to file material under seal. 6 1.2 GOOD CAUSE STATEMENT 7 This action arises from alleged injuries sustained by Plaintiff VLADIMIR g || ROYTER (“Vladimir”) due to an incident in a Costco retail store. Vladimir was g || attempting to move a box containing a mattress when he tore his biceps tendon. 190 Vladimir alleges negligence and premises liability causes of action. ll Evidence or potential evidence that will be disclosed in discovery is expected to 8 12 || include confidential and proprietary information and documents regarding business 13 practices pertaining to safety, products sold in Costco, and other matters which are 14 generally unavailable to the public and could be exploited by actors (e.g. criminals and 3 15 || Scammers) who have no interest in or need for evidence produced in this case for their 16 Own unlawful purposes. Likewise, evidence shall include surveillance footage which 1 17 also generally unavailable to the public. This footage invokes the same concerns as th 1g || other information discussed above, and potentially implicates third party privacy 19 ] concerns as well. 20 Accordingly, to expedite the flow of information, to facilitate the prompt 91 resolution of disputes over confidentiality of discovery materials, to adequately protect 92 information the parties are entitled to keep confidential, to ensure that the parties are 93 permitted reasonable necessary uses of such material in preparation for and in the 94 conduct of trial, to address their handling at the end of the litigation, and serve the ends 25 of justice, a protective order for such information is justified in this matter. It is the 26 intent of the parties that information will not be designated as confidential for tactical 97 reasons and that nothing be so designated without a good faith belief that it has been 28 -2-
maintained in a confidential, non-public manner, and there is good cause why it should 7 not be part of the public record of this case. 3 2. DEFINITIONS 4 2.1 Action: This pending federal lawsuit, which originated in the Superior Court 5 of the State of California and was removed to Federal Court by Defendant COSTCO 6 WHOLESALE CORPORATION (“Defendant” or “Costco”) on diversity jurisdiction 7 grounds. g 2.2 Challenging Party: a Party or Nonparty that challenges the designation of g || information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 11 generated, stored, or maintained) or tangible things that qualify for protection under 8 12 || Federal Rule of Civil Procedure 26(c) and as specified above in the Good Cause 13 Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 3 15 || Support staff). 16 2.5 Designating Party: a Party or Nonparty that designates information or ttems 17 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 18 2.6 Disclosure or Discovery Material: all items or information, regardless of the 19 medium or manner in which it is generated, stored, or maintained (including, among 29 other things, testimony, transcripts, and tangible things), that are produced or generatec 21 in disclosures or responses to discovery in this matter. 2.7 Expert: a person with specialized knowledge or experience in a matter 23 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 94 expert witness or as a consultant in this action. 25 2.8 House Counsel: attorneys who are employees of a Party to this Action. Hous 26 Counsel does not include Outside Counsel of Record or any other outside counsel. 7 2.9 Nonparty: any natural person, partnership, corporation, association, or other 2g || legal entity not named as a Party to this action. -3-
1 2.10 Outside Counsel of Record: attorneys who are not employees of a Party to 7 this Action but are retained to represent or advise a Party and have appeared in this 3 Action on behalf of that Party or are affiliated with a law firm that has appeared on behalf of that Party, including support staff. 5 2.11 Party: any Party to this Action, including all of its officers, directors, 6 employees, consultants, retained experts, and Outside Counsel of Record (and their 7 support staffs). 8 2.12 Producing Party: a Party or Nonparty that produces Disclosure or Discover g || Material in this Action. 10 2.13 Professional Vendors: persons or entities that provide litigation support 11 services (for example, photocopying, videotaping, translating, preparing exhibits or 8 12 || demonstrations, and organizing, storing, or retrieving data in any form or medium) □□□□ 13 their employees and subcontractors. 14 2.14 Protected Material: any Disclosure or Discovery Material that is designated 15 as “CONFIDENTIAL.” 16 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material fro: 17 a Producing Party. 18 3. SCOPE 19 The protections conferred by this Stipulation and Order cover not only Protected 29 Material (as defined above) but also any information copied or extracted from Protecte 91 Material; all copies, excerpts, summaries, or compilations of Protected Material; and a 97 testimony, conversations, or presentations by Parties or their Counsel that might reveal 93 Protected Material. 24 Any use of Protected Material at trial will be governed by the orders of the trial 25 Judge. This Order does not govern the use of Protected Material at trial. 4. DURATION 7 Once a case proceeds to trial, all the information that was designated as ag || confidential or maintained under this Order becomes public and will be presumptively 4.
1 available to all members of the public, including the press, unless the trial judge finds 2 compelling reasons to proceed otherwise. See Kamakana v. City & Cnty. of Honolulu, 3 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for 4 sealing documents produced in discovery from “compelling reasons” needed for merit: 5 related documents). Accordingly, the terms of this Order do not extend beyond the 6 beginning of trial unless the trial judge Orders otherwise. 7 Even after final disposition of this litigation, the confidentiality obligations g || imposed by this Order will remain in effect until a Designating Party agrees otherwise g || writing or a court order otherwise directs. Final disposition is the later of (1) dismissal 19 all claims and defenses in this Action, with or without prejudice, or (2) final judgment 11 after the completion and exhaustion of all appeals, rehearings, remands, trials, or □□□□□□ 8 12 || of this Action, including the time limits for filing any motions or applications for 13 extension of time under applicable law. 14 5. DESIGNATING PROTECTED MATERIAL 3 15 5.1 Each Party or Nonparty that designates information or ttems for protection 16 under this Order must take care to limit any such designation to specific material that 17 qualifies under the appropriate standards. To the extent practicable, the Designating 1g || Party must designate for protection only those parts of material, documents, items, or 19 Oral or written communications that qualify so that other portions of the material, 29 documents, items, or communications for which protection is not warranted are not 91 Swept unjustifiably within the ambit of this Order. Indiscriminate or routinized designations are prohibited. Designations that are 93 shown to be clearly unjustified or that have been made for an improper purpose (for 94 example, to unnecessarily encumber the case-development process or to impose 25 unnecessary expenses and burdens on other parties) may expose the Designating Party 26 sanctions. 7 If it comes to a Designating Party’s attention that information or items it 2g || designated for protection do not qualify for that level of protection, that Designating -5-
Party must promptly notify all other Parties that it is withdrawing the inapplicable 9 designation. 3 5.2 Except as otherwise provided in this Order, Disclosure or Discovery Materia 4 that qualifies for protection under this Order must be clearly so designated before the 5 material is disclosed or produced. 6 Designation in conformity with this Order requires the following: 7 (a) for information in documentary form (for example, paper or electronic g || documents but excluding transcripts of depositions or other pretrial or trial proceeding: g || the Producing Party must affix at a minimum the legend “CONFIDENTIAL” to each 10 page that contains Protected Material. If only a portion or portions of the material on a 11 page qualify for protection, the Producing Party should to the extent practicable clearly 8 12 || identify the protected portion(s) (for example, by making appropriate markings in the 13 Margins). 14 A Party or Nonparty that makes original documents available for inspection nee 3 15 || not designate them for protection until after the inspecting Party has indicated which 16 documents it would like copied and produced. During the inspection and before the 17 designation, all material made available for inspection must be treated as 1g || “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 19 copied and produced, the Producing Party must determine which documents, or portiot 99 thereof, qualify for protection under this Order. Then, before producing the specified 91 documents, the Producing Party must affix the “CONFIDENTIAL” legend to each pag 97 that contains Protected Material. If only a portion or portions of the material on a page 93 qualify for protection, the Producing Party should to the extent practical clearly identif 94 the protected portion(s) (for example, by making appropriate markings in the margins). 25 (b) for testimony given in depositions, the Designating Party must identify the 26 Disclosure or Discovery Material that is protected on the record, before the close of the 97 deposition. 28 -6-
1 (c) for information produced in some form other than documentary and for any 7 other tangible items, the Producing Party must affix in a prominent place on the exteric 3 of the container or containers in which the information is stored the legend “CONFIDENTIAL.” [f only a portion or portions of the information warrant □□□□□□□□□□ 5 the Producing Party, to the extent practicable, must identify the protected portion(s). 6 5.3 If timely corrected, an inadvertent failure to designate qualified information| 7 items does not, standing alone, waive the Designating Party’s right to secure protectior g || under this Order for that material. On timely correction of a designation, the Receiving g || Party must make reasonable efforts to assure that the material is treated in accordance 19 with the provisions of this Order. ll 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS B12 6.1 Any Party or Nonparty may challenge a designation of confidentiality at any 13 time consistent with the Court’s scheduling order. 14 6.2 The Challenging Party must initiate the dispute-resolution process (and, if 3 15 || necessary, file a discovery motion) under Local Rule 37. 16 6.3 The burden of persuasion in any such proceeding is on the Designating Party 17 Frivolous challenges, and those made for an improper purpose (for example, to □□□□□□□ 1g || impose unnecessary expenses and burdens on other parties), may expose the Challengi 19 Party to sanctions. Unless the Designating Party has waived or withdrawn the 29 confidentiality designation, all parties must continue to afford the material in question 91 the level of protection to which it is entitled under the Producing Party’s designation 92 until the Court rules on the challenge. 23 24 7. ACCESS TO AND USE OF PROTECTED MATERIAL 25 7.1 A Receiving Party may use Protected Material that is disclosed or produced 26 another Party or by a Nonparty in connection with this Action only for prosecuting, 27 defending, or attempting to settle this Action. Such Protected Material may be disclose 2g || only to the categories of people and under the conditions described in this Order. Wher -7-
1 the Action has been terminated, a Receiving Party must comply with the provisions of 7 Section 13 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a manner sufficiently secure to ensure that access is limited to the peop 5 authorized under this Order. 6 7.2 Unless otherwise ordered by the Court or permitted in writing by the 7 Designating Party, a Receiving Party may disclose any information or item designated g || “CONFIDENTIAL” only to the following people: 9 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 190 employees of that Outside Counsel of Record to whom it is reasonably necessary to 11 disclose the information for this Action; 8 12 (b) the officers, directors, and employees (including House Counsel) of the 13 Receiving Party to whom disclosure is reasonably necessary for this Action; 14 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 3 15 || reasonably necessary for this Action and who have signed the “Acknowledgment and 16 Agreement to Be Bound” (Exhibit A); 17 (d) the Court and its personnel; 18 (ec) court reporters and their staff; 19 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 1 29 whom disclosure is reasonably necessary for this Action and who have signed the 91 “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) the author or recipient of a document containing the information or a custodi 93 or other person who otherwise possessed or knew the information; 24 (h) during their depositions, witnesses and attorneys for witnesses to whom 95 disclosure is reasonably necessary, provided that the deposing party requests that the 26 Witness sign the form attached as Exhibit A hereto and the witnesses will not be 97 permitted to keep any confidential information unless they sign the form, unless 9g || otherwise agreed by the Designating Party or ordered by the Court. Pages of transcribe -8-
1 deposition testimony or exhibits to depositions that reveal Protected Material may be 2 separately bound by the court reporter and may not be disclosed to anyone except as 3 permitted under this Order; and 4 (i) any mediator or settlement officer, and their supporting personnel, mutually 5 agreed on by any of the Parties engaged in settlement discussions or appointed by the 6 Court. 7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED □ g OTHER LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation tha 190 compels disclosure of any information or items designated in this Action as 11 “CONFIDENTIAL,” that Party must B12 (a) promptly notify in writing the Designating Party. Such notification must 13 mclude a copy of the subpoena or court order unless prohibited by law; 14 (b) promptly notify in writing the party who caused the subpoena or order to isst 3 15 || in the other litigation that some or all of the material covered by the subpoena or order 16 Subject to this Protective Order. Such notification must include a copy of this Order; ar 17 (c) cooperate with respect to all reasonable procedures sought to be pursued by t 1g || Designating Party whose Protected Material may be affected. If the Designating Party 19 timely seeks a protective order, the Party served with the subpoena or court order shou 29 not produce any information designated in this action as “CONFIDENTIAL” before a 91 determination on the protective-order request by the relevant court unless the Party has 92 obtained the Designating Party’s permission. The Designating Party bears the burden 93 and expense of seeking protection of its Confidential Material, and nothing in these 94 provisions should be construed as authorizing or encouraging a Receiving Party in this 25 Action to disobey a lawful directive from another court. 26 27 28 -9-
1 9. ANONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 3 (a) The terms of this Order are applicable to information produced by a Nonpart 4 in this Action and designated as “CONFIDENTIAL.” Such information is protected by 5 the remedies and relief provided by this Order. Nothing in these provisions should be 6 construed as prohibiting a Nonparty from seeking additional protections. 7 (b) In the event that a Party is required by a valid discovery request to produce a g || Nonparty’s Confidential Information in its possession and the Party is subject to an g || agreement with the Nonparty not to produce the Nonparty’s Confidential Information, 19 then the Party must (1) promptly notify in writing the Requesting Party and the Nonparty B12 that some or all of the information requested is subject to a confidentiality 13 agreement with a Nonparty; 14 (2) promptly provide the Nonparty with a copy of this Order, the 3 15 relevant discovery request(s), and a reasonably specific description of the 16 information requested; and 17 (3) make the information requested available for inspection by the 18 Nonparty, if requested. 19 (c) If the Nonparty fails to seek a protective order within 21 days of receiving th 29 notice and accompanying information, the Receiving Party may produce the Nonparty’ 91 Confidential Information responsive to the discovery request. If the Nonparty timely 92 seeks a protective order, the Receiving Party must not produce any information in its 93 possession or control that is subject to the confidentiality agreement with the Nonparty 94 before a ruling on the protective-order request. Absent a court order to the contrary, the 25 Nonparty must bear the burden and expense of seeking protection of its Protected 26 Material. 27 28 -10-
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this Ord« the Receiving Party must immediately notify the Designating Party in writing of the 5 unauthorized disclosures, use its best efforts to retrieve all unauthorized copies of the 6 Protected Material, inform the person or people to whom unauthorized disclosures wer 7 made of the terms of this Order, and ask that person or people to execute the g || “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A. 9 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE When a Producing Party gives notice to Receiving Parties that certain 8 12 || inadvertently produced material is subject to a claim of privilege or other protection, tk 13 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 14 Procedure 26(b)(5)(B). 12. MISCELLANEOUS 16 12.1 Nothing in this Order abridges the right of any person to seek its 17 modification by the Court. 18 12.2 By stipulating to the entry of this Order, no Party waives any right it 19 otherwise would have to object to disclosing or producing any information or item on 29 any ground not addressed in this Order. Similarly, no Party waives any right to object « 91 any ground to use in evidence of any of the material covered by this Order. 2 12.3 A Party that seeks to file under seal any Protected Material must comply wi 93 Civil Local Rule 79-5. Protected Material may be filed under seal only pursuant to a 94 court order authorizing the sealing of the specific Protected Material at issue. If a Party 25 request to file Protected Material under seal is denied, then the Receiving Party may fil 26 the information in the public record unless otherwise instructed by the Court. 27 28 -]1-
1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 da 3 of a written request by the Designating Party, cach Receiving Party must return all 4 Protected Material to the Producing Party or destroy such material. As used in this 5 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected Materi 7 Whether the Protected Material is returned or destroyed, the Receiving Party must g || submit a written certification to the Producing Party (and, if not the same person or g || entity, to the Designating Party) by the 60-day deadline that identifies (by category, 190 when appropriate) all the Protected Material that was returned or destroyed and affirms 11 that the Receiving Party has not retained any copies, abstracts, compilations, □□□□□□□□ 8 or any other format reproducing or capturing any of the Protected Material. 13 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 14 pleadings; motion papers; trial, deposition, and hearing transcripts; legal memoranda; 3 15 || correspondence; deposition and trial exhibits; expert reports; attorney work product; ar 16 consultant and expert work product even if such materials contain Protected Material. 17 Any such archival copies that contain or constitute Protected Material remain subject t 1g || this Order as set forth in Section 4 (DURATION). 19 a0 || /// ay □□□ 92 } /// 93 /// 94 /// /// 26 /// /// ag || /// -]2-
1 14. SANCTIONS 2 Any willful violation of this Order may be punished by civil or criminal contemy 3 financial or evidentiary sanctions, reference to disciplinary authorities, or other 4 appropriate action at the discretion of the Court. 5 6 FOR GOOD CAUSE SHOWN BY THE PARTIES’ STIPULATION, IT IS SO , ORDERED.
Mt ? || DATED: September 19, 2024 fuk 10 HON. PEDRO V. CASTILLO 4 United States Magistrate Judge
: 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -]3-
1 4 I, [full name], of [ful 5 address], declare under penalty of perjury that I have read in its entirety and understan 6 the Stipulated Protective Order that was issued by the U.S. District Court for the Centr 7 District of California on [date] in the case of Vladimir Royter and g || Larisa Royter v. Costco Wholesale Corporation, Case No.: 2:24-cv-06484-FLA-PVC g || agree to comply with and to be bound by all terms of this Stipulated Protective Order 19 and I understand and acknowledge that failure to so comply could expose me to 11 Sanctions and punishment, including contempt. I solemnly promise that I will not 8 12 || disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the provisions 14 of this Order. 3 15 I further agree to submit to the jurisdiction of the U.S. District Court for the 16 Central District of California for the purpose of enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 1g || action. I hereby appoint [full name] of 19 [full address and telephone □□□□□□ 29 as my California agent for service of process in connection with this action or any 91 proceedings related to enforcement of this Stipulated Protective Order. 22 3 Date: City and State where signed: 25 Printed name: 26 Signature: 27 28 -14-