Fabiola Acevedo v. eXp World Holdings, Inc. ( 2023 )

1 2 3 4 5 6 7 8 9 10 11 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA 14 FABIOLA ACEVEDO, JANE DOE 1, Case No. 2:23-CV-01304-AB-AGR 15 JANE DOE 2, JANE DOE 3, and JOHN 16 DOE 1, Hon. Andre Birotte, Jr. Plaintiffs, 17 v. JOINT PROTECTIVE ORDER 18 EXP REALTY, LLC, EXP WORLD 19 HOLDINGS, INC., MICHAEL L. 20 BJORKMAN; DAVIS S. GOLDEN; GLENN SANFORD; BRENT GOVE; and 21 DOES 1-10, 22 Defendants. 23 24 25 26 27 28 132669765.1 1 The parties agree as follows: 2 1. A. Purpose 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 and 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 following 7 Stipulated Protective Order. The parties acknowledge that this Order does not confer 8 blanket protections on all disclosures or responses to discovery and that the protection 9 it affords from public disclosure and use extends only to the limited information or 10 items that are entitled to confidential treatment under the applicable legal principles. 11 The parties further acknowledge, as set forth in Section 12.3, below, that unless 12 specifically set forth in this Stipulated Protective Order, it does not entitle them to file 13 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that 14 must be followed and the standards that will be applied when a party seeks permission 15 from the Court to file material under seal. 16 B. Good Cause Statement 17 This action is likely to involve medical records, mental health records, photos 18 and videos of third parties, and/or financial information for which special protection 19 from public disclosure and from use for any purpose other than prosecution and defense 20 of this action is warranted. Such confidential and proprietary materials and information 21 consist of, among other things, confidential business or financial information, 22 information regarding confidential business practices, or other confidential research, 23 development, or commercial information (including information implicating privacy 24 rights of third parties), information otherwise generally unavailable to the public, or 25 which may be privileged or otherwise protected from disclosure under state or federal 26 statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow 27 of information, to facilitate the prompt resolution of disputes over confidentiality of 28 132669765.1 2 1 discovery materials, to adequately protect information the parties are entitled to keep 2 confidential, to ensure that the parties are permitted reasonable necessary uses of such 3 material in preparation for and in the conduct of trial, to address their handling of such 4 material at the end of the litigation, and serve the ends of justice, a protective order 5 covering such information is justified in this matter. It is the intent of the parties that 6 information will not be designated as confidential for tactical reasons and that nothing 7 be so designated without a good faith belief that it has been maintained in a 8 confidential, non-public manner, and there is good cause why it should not be part of 9 the public record of this case. 10 2. DEFINITIONS 11 2.1 Action: this pending federal lawsuit. 12 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 13 information or items under this Order. 14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 15 it is generated, stored or maintained) or tangible things that qualify for protection under 16 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 17 Statement.1 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 19 support staff). 20 2.5 Designating Party: a Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 2.6 Disclosure or Discovery Material: all items or information, regardless of 24 the medium or manner in which generated, stored, or maintained (including, among 25 26 27 1 Notwithstanding the lack of “Highly Confidential” or “Attorneys Eyes Only” designation, nothing in this 28 Protective Order prohibits a party or non-party from making a motion requesting such a designation. 1 other things, testimony, transcripts, and tangible things), that are produced or generated 2 in disclosures or responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its Counsel to serve as an 5 expert witness or as a consultant in this Action. 6 2.8 House Counsel: attorneys who are employees of a Party to this Action. 7 House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 2.9 Non-Party: any natural person, partnership, corporation, association or 10 other legal entity not named as a Party to this action. 11 2.10 Outside Counsel of Record: attorneys who are not employees of a Party to 12 this Action but are retained to represent or advise a Party to this Action and have 13 appeared in this Action on behalf of that Party or are affiliated with a law firm that has 14 appeared on behalf of that Party, and includes support staff. 15 2.11 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staff). 18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.13 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 23 their employees and subcontractors. 24 2.14 Protected Material: any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL”. 26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 27 from a Producing Party. 28 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only Protected 3 Material (as defined above), but also (1) any information copied or extracted from 4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 5 Material; and (3) any testimony, conversations, or presentations by Parties or their 6 Counsel that might reveal Protected Material. However, the protections conferred by 7 this Stipulation and Order do not cover the following information: (a) any information 8 that is in the public domain at the time of disclosure to a Receiving Party or becomes 9 part of the public domain after its disclosure to a Receiving Party as a result of 10 publication not involving a violation of this Order, including becoming part of the 11 public record through trial or otherwise; and (b) any information known to the 12 Receiving Party prior to the disclosure or obtained by the Receiving Party after the 13 disclosure from a source who obtained the information lawfully and under no 14 obligation of confidentiality to the Designating Party. 15 Any use of Protected Material at trial shall be governed by the orders of the trial 16 judge. This Order does not govern the use of Protected Material at trial. 17 4. DURATION 18 Even after final disposition of this litigation, the confidentiality obligations 19 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 20 in writing or a court order otherwise directs. Final disposition shall be deemed to be the 21 later of (1) dismissal of all claims and defenses in this Action, with or without 22 prejudice; and (2) final judgment herein after the completion and exhaustion of all 23 appeals, rehearings, remands, trials, or reviews of this Action, including the time limits 24 for filing any motions or applications for extension of time pursuant to applicable law. 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for Protection. 27 Each Party or Non-Party that designates information or items for protection under this 28 Order must take care to limit any such designation to specific material that qualifies 1 under the appropriate standards. The Designating Party must designate for protection 2 only those parts of materials, documents, items or oral or written communications that 3 qualify so that other portions of the materials, documents, items or communications for 4 which protection is not warranted are not swept unjustifiably within the ambit of this 5 Order. 6 Mass, indiscriminate or routinized designations are prohibited. Designations that 7 are shown to be clearly unjustified or that have been made for an improper purpose 8 (e.g., to unnecessarily encumber the case development process or to impose 9 unnecessary expenses and burdens on other parties) may expose the Designating Party 10 to sanctions. 11 If it comes to a Designating Party’s attention that information or items that it 12 designated for protection do not qualify for protection, that Designating Party must 13 promptly notify all other Parties that it is withdrawing the inapplicable designation. 14 5.2 Manner and Timing of Designations. Except as otherwise provided in this 15 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 16 or ordered, Disclosure or Discovery Material that qualifies for protection under this 17 Order must be clearly so designated before the material is disclosed or produced. 18 Designation in conformity with this Order requires: 19 (a) for information in documentary form (e.g., paper or electronic documents, but 20 excluding transcripts of depositions or other pretrial or trial proceedings), that the 21 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 22 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 23 portion of the material on a page qualifies for protection, the Producing Party also must 24 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 25 margins). 26 A Party or Non-Party that makes original documents available for inspection 27 need not designate them for protection until after the inspecting Party has indicated 28 which documents it would like copied and produced. During the inspection and before 1 the designation, all of the documents made available for inspection shall be deemed 2 CONFIDENTIAL. After the inspecting Party has identified the documents it wants 3 copied and produced, the Producing Party must determine which documents, or 4 portions thereof, qualify for protection under this Order. Then, before producing the 5 specified documents, the Producing Party must affix the CONFIDENTIAL legend to 6 each page that contains Protected Material. If only a portion of the material on a page 7 qualifies for protection, the Producing Party also must clearly identify the protected 8 portion(s) (e.g., by making appropriate markings in the margins). 9 A party has fourteen (14) days from the production of non-party discovery to 10 designate any documents as CONFIDENTIAL. The production of a non-party shall 11 remain CONFIDENTIAL for the entirety of the fourteen (14) days irrespective of the 12 designation of the non-party. 13 (b) for testimony given in depositions, that the Designating Party identifies the 14 Disclosure or Discovery Material on the record, before the close of the deposition, all 15 protected testimony. 16 (c) for information produced in some form other than documentary and for any 17 other tangible items, that the Producing Party affix in a prominent place on the exterior 18 of the container or containers in which the information is stored the legend 19 “CONFIDENTIAL.” If only a portion or portions of the information warrants 20 protection, the Producing Party, to the extent practicable, shall identify the protected 21 portion(s). 22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive the 24 Designating Party’s right to secure protection under this Order for such material. Upon 25 timely correction of a designation, the Receiving Party must make reasonable efforts to 26 assure that the material is treated in accordance with the provisions of this Order. 27 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 28 1 Any CONFIDENTIAL designation is subject to challenge by any party or 2 non¬party (hereafter “party”). The following procedure shall apply to any such 3 challenge. 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time that is consistent with the Court’s Scheduling 6 Order. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 resolution process under Local Rule 37-1, et seq. 9 6.3 Obligation to File Motion. If the parties cannot reach agreement as to any 10 documents designated CONFIDENTIAL, for the purpose of discovery, the designating 11 party shall file with the court, within forty-five (45) days of the conclusion of the meet 12 and confer,2 a motion to retain the CONFIDENTIAL designation. The designating 13 party has the burden to show good cause for the CONFIDENTIAL designation. 14 Frivolous challenges, and those made for an improper purpose (e.g., to harass or 15 impose unnecessary expenses and burdens on other parties) may expose the 16 Challenging Party to sanctions. The failure to file the motion within forty-five (45) days 17 of the conclusion of the meet and confer by the designating party waives the 18 CONFIDENTIAL designation of documents to which an objection was made. All 19 Parties shall continue to afford the material its CONFIDENTIAL designation until the 20 Court rules on the motion. 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a Non-Party in connection with this 24 25 26 2 A meet and confer is concluded by either party indicating in writing that the meet and confer efforts have 27 concluded. Conclusion of the meet and confer process does not require both parties to agree that the meet and confer 28 efforts have resulted in an impasse. a 1 Action only for prosecuting, defending or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the Action has been terminated, a Receiving 4 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 5 Protected Material must be stored and maintained by a Receiving Party at a location 6 and in a secure manner that ensures that access is limited to the persons authorized 7 under this Order. 8 7.2 Disclosure of CONFIDENTIAL Information or Items. Unless otherwise 9 ordered by the Court or permitted by the Designating Party, a Receiving Party may 10 disclose any information or item designated CONFIDENTIAL only to: 11 (a) the Parties to this Action; 12 (b) the Receiving Party’s Outside Counsel of Record in this Action; 13 (c) the partners and employees (including House Counsel) of the Receiving Party 14 to whom disclosure is reasonably necessary for this Action, as well as employees of 15 said Outside Counsel of Record to whom it is reasonably necessary to disclose the 16 information for this Action; 17 (d) Experts (as defined in this Order) of the Receiving Party to whom disclosure 18 is reasonably necessary for purposes of this Action and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (e) the Court and its personnel; 21 (f) court reporters, videographers and their staff; 22 (g) professional jury or trial consultants, mock jurors, and Professional Vendors 23 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (h) the author or recipient of a document containing the information or a 25 custodian or other person who the Parties agree in writing otherwise already possessed 26 or knew the information; 27 (i) during their depositions, witnesses, and attorneys for witnesses, in the Action 28 to whom disclosure is reasonably necessary provided: (1) the parties request that the 1 witness signs the “Acknowledgement and Agreement to Be Bound” (Exhibit A); and 2 (2) they will not be permitted to keep any confidential information, unless otherwise 3 agreed by the Designating Party or ordered by the Court. If the witness does not sign 4 Exhibit A, the witness will not be permitted to receive the Confidential Exhibits or the 5 Confidential portion of the deposition transcript, unless otherwise ordered by the 6 Court. In the event that the witness does not sign Exhibit A, the witness will be 7 provided an opportunity to read the transcript at the Court Reporter office for purposes 8 of reviewing and signing, but will not be permitted to maintain any copies. Pages of 9 transcribed deposition testimony or exhibits to depositions that reveal Protected 10 Material may be separately bound by the court reporter and may not be disclosed to 11 anyone except as permitted under this Stipulated Protective Order; 12 (j) any mediator or settlement officer, and their supporting personnel, mutually 13 agreed upon by the Parties engaged in settlement discussions; and (j) any other person 14 to whom the Designating Party agrees in writing or on the record. 15 16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 17 PRODUCED IN OTHER LITIGATION 18 If a Party is served with a subpoena or a court order issued in other litigation that 19 compels disclosure of any information or items designated in this Action as 20 “CONFIDENTIAL”, that Party must: 21 (a) promptly notify the Designating Party in writing. Such notification shall 22 include a copy of the subpoena or court order; 23 (b) promptly notify in writing the entity who caused the subpoena or order to 24 issue in the other litigation that some or all of the material covered by the subpoena or 25 order is subject to this Stipulated Protective Order. Such notification shall include a 26 copy of this Stipulated Protective Order; and 27 (c) cooperate with respect to all reasonable procedures sought to be pursued by 28 the Designating Party whose Protected Material may be affected. If the Designating 1 Party timely seeks a protective order, the Party served with the subpoena or court order 2 shall not produce any CONFIDENTIAL information before a determination by the 3 court from which the subpoena or order issued, unless the Party has obtained the 4 Designating Party’s permission. The Designating Party shall bear the burden and 5 expense of seeking protection in that court of its confidential material and nothing in 6 these provisions should be construed as authorizing or encouraging a Receiving Party 7 in this Action to disobey a lawful directive from another court. 8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 9 PRODUCED IN THIS LITIGATION 10 (a) The terms of this Stipulated Protective Order are applicable to information 11 produced by a Non-Party in this Action and designated CONFIDENTIAL. Such 12 information produced by Non-Parties in connection with this Action is protected by the 13 remedies and relief provided by this Stipulated Protective Order. Nothing in these 14 provisions should be construed as prohibiting a Non-Party from seeking additional 15 protections. 16 (b) In the event that a Party is required, by a valid discovery request, to produce a 17 Non-Party’s confidential information in its possession, and the Party is subject to an 18 agreement with the Non-Party not to produce the Non-Party’s confidential information, 19 then the Party shall: 20 (1) promptly notify the Requesting Party and the Non-Party in writing that some 21 or all of the information requested is subject to a confidentiality agreement with a 22 Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 24 Order in this Action, the relevant discovery request(s), and a reasonably specific 25 description of the information requested; and 26 (3) make the information requested available for inspection by the Non-Party, if 27 requested. 28 1 (c) If the Non-Party fails to seek a protective order from this Court within 14 2 days of receiving the notice and accompanying information, the Receiving Party may 3 produce the Non-Party’s confidential information responsive to the discovery request. 4 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 5 any information in its possession or control that is subject to the confidentiality 6 agreement with the Non-Party before a determination by the Court. 7 Absent a court order to the contrary, the Non-Party shall bear the burden and 8 expense of seeking protection in this Court of its Protected Material. 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 12 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 13 the Designating Party of the unauthorized disclosure(s), (b) use its best efforts to 14 retrieve all unauthorized copies of the Protected Material, (c) inform the person or 15 persons to whom unauthorized disclosures were made of all the terms of this Stipulated 16 Protective Order, and (d) request such person or persons to execute the 17 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A. 18 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 Inadvertent Disclosures. In the event that any party makes an inadvertent 21 disclosure of attorney-client and/or work product information or other documents 22 which are confidential, such disclosures shall be clawed back pursuant to the Federal 23 Rules of Evidence Rule 502(b) and Federal Rules of Civil Procedure Rule 26(b)(5)(B). 24 Upon a party’s notice of a claim of confidentiality for any such disclosure, the date of 25 such notice shall constitute the designation date which triggers the non-designating 26 party’s obligation to challenge the designation pursuant to paragraph 6. 27 12. MISCELLANEOUS 28 1 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 2 person to seek its modification by the Court in the future. 3 12.2 Right to Assert Other Objections. By stipulating to the entry of this 4 Stipulated Protective Order, no Party waives any right it otherwise would have to object 5 to disclosing or producing any information or item on any ground not addressed in this 6 Stipulated Protective Order. Similarly, no Party waives any right to object on any 7 ground to the use in evidence of any of the material covered by this Stipulated 8 Protective Order. 9 12.3 Filing Protected Material. A Party that seeks to file under seal any 10 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 11 only be filed under seal pursuant to a court order authorizing the sealing of the specific 12 Protected Material at issue. If a Party’s request to file Protected Material under seal is 13 denied by the Court, then the Receiving Party may file the Protected Material in the 14 public record unless otherwise instructed by the Court. 15 13. FINAL DISPOSITION 16 After the final disposition of this Action, as defined in paragraph 4, within 60 17 days of a written request by the Designating Party, each Receiving Party must return all 18 Protected Material to the Producing Party or destroy such material. As used in this 19 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 20 summaries, and any other format reproducing or capturing any of the Protected 21 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 22 must submit a written certification to the Producing Party (and, if not the same person 23 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 24 category, where appropriate) all the Protected Material that was returned or destroyed 25 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 26 compilations, summaries or any other format reproducing or capturing any of the 27 Protected Material. In the event that a law firm’s shared file drive is periodically 28 backed-up for cybersecurity, disaster recovery, and insurance compliance purposes (a 1 process commonly known as “snapshotting”), the Receiving Party need not destroy 2 these back-up snapshots if the Receiving Party certifies to the Designating Party that 3 (1) the snapshots are only accessible by the law firm’s litigation technology and 4 information technology teams through a third-party data security vendor and (2) that no 5 persons at the law firm have access to the back-ups or the files contained therein. 6 Notwithstanding this provision, counsel are entitled to retain an archival copy of 7 all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 8 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 9 work product, and consultant and expert work product, even if such materials contain 10 Protected Material. Any such archival copies that contain or constitute Protected 11 Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 12 13 VIOLATION 14 Any violation of this Stipulated Protective Order may be punished by appropriate 15 measures including, without limitation, contempt proceedings and/or monetary 16 sanctions and/or equitable relief. 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 19 By: /s/ Jennifer A. Lenze 20 Jennifer A. Lenze, Esq. 21 LENZE LAWYERS, PLC 999 Corporate Drive, Suite 100 22 Ladera Ranch, CA 92694 23 Brooke F. Cohen, Esq. 24 Andrea S. Hirsch, Esq. 25 COHEN HIRSCH LP 5256 Peachtree Road, Suite 195 E 26 Atlanta, GA 30341 27 Attorneys for Plaintiffs 28 1 > By: /s/ William Pallares William Pallares, Esq. 3 Kyle R. Maland, Esq. 4 LEWIS BRISBOIS BISGAARD AND SMITH LLP 550 West C Street Suite 1700 5 San Diego, CA 92101 6 Attorneys for Defendants eXp World Holdings, Inc, eXp Realty, LLC and Glenn Sanford 7 8 By: /s/ Katherine T. Van Dusen Alexander William Preve, Esq. 9 Katharine T. Van Dusen, Esq. 10 Rees Ferriter Morgan, Esq. Sean P.J. Coyle, Esq. COBLENTZ PATCH DUFFY AND BASS LLP 12 One Montgomery Street Suite 3000 San Francisco, CA 94101 13 Attorneys for Defendant Brent Gove 14 By: /s/ Peter Levine Is Peter Levine, Esq. 16 PETER K. LEVINE, APLC 5455 Wilshire Blvd., Suite 1250 17 Los Angeles, CA 90036 18 Attorney for Defendant David Golden 19 By: /s/ Richard A. Schonfeld 20 Richard A. Schonfeld, Esq. CHESNOFF AND SCHONFELD 71 520 South 4" Street 2 Las Vegas, NV 89101 33 Attorney for Defendant Michael Bjorkman 24 SO ORDERED: 25 4 ee 26 Ubi December 5, 2023 27 ALICIA G. ROSENBERG Date 3g UNITED STATES MAGISTRATE JUDGE 132669763.1 15 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [full name], of ____________________ 4 [full address], declare under penalty of perjury that I have read in its entirety and 5 understand the Stipulated Protective Order that was issued by the United States District 6 Court for the Central District of California on [date] in the case of Acevedo et al. v. eXp 7 Realty, et al., 2:23-cv-01304-AB-AGR. I agree to comply with and to be bound by all 8 the terms of this Stipulated Protective Order and I understand and acknowledge that 9 failure to so comply could expose me to sanctions and punishment in the nature of 10 contempt. I solemnly promise that I will not disclose in any manner any information or 11 item that is subject to this Stipulated Protective Order to any person or entity except in 12 strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for 14 the Central District of California for the purpose of enforcing the terms of this 15 Stipulated Protective Order, even if such enforcement proceedings occur after 16 termination of this action. I hereby appoint __________________________ [full name] 17 of _______________________________________ [full address and telephone 18 number] as my California agent for service of process in connection with this action or 19 any proceedings related to enforcement of this Stipulated Protective Order. 20 Date: ______________________________________ 21 City and State where signed: _________________________________ 22 Printed name: _______________________________ 23 Signature: __________________________________ 24 25 26 27 28