Laurie B LLC v. Wells Fargo Bank, N.A. et al

Filing 31

STIPULATED PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal. (See Order for Further Details) (kl)

Steven Glaser (State Bar No. 120557)
Law Offices Of Steven Glaser
2 315 S. Beverly Drive, Suite 410
Beverly Hills, CA90212
3 Telephone: [phone]
Facsimile: [phone]
4 E-Mail:
[e-mail]
1

5

Attorney For Plaintiff LAURIE B LLC

Robert Louis Fisher, A Prof. Corp.
(State Bar No. 053524)
7 Barton, Klugman & Oetting LLP
350 South Grand Avenue, Suite 2200
8 Los Angeles, CA 90071-3454
6

Telephone: [phone]
Facsimile: [phone]
10 E-mail:
[e-mail]
11
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9

Attorneys for Defendant WELLS FARGO BANK,
NATIONAL ASSOCIATION

12

UNITED STATES DISTRICT COURT

13

CENTRAL DISTRICT OF CALIFORNIA

14
15

Case No. CV14-3942-DMG-SSx

Laurie B LLC, a California limited
liability company,
16
17
18

Discovery Document: Refer to
Magistrate Judge Suzanne H. Segal

Plaintiff,
vs.

Date Action Filed: April 24, 2014
(Los Angeles Superior Court Case No.
BC 062 442)

19 Wells Fargo Bank, N.A., and Does 1

through 10,

20

STIPULATED PROTECTIVE
ORDER

Defendants.

21
22

[Federal Rules of Civil Procedure,
Rule 26(c)(1)]

23

Trial Date: July 28, 2015

24
25

1.

26

Discovery in this action is likely to involve production of confidential,

A.

PURPOSES AND LIMITATIONS

27

proprietary, or private information for which special protection from public

28

disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter

2

the following Stipulated Protective Order. The parties acknowledge that this Order does

3

not confer blanket protections on all disclosures or responses to discovery and that the

4

protection it affords from public disclosure and use extends only to the limited

5

information or items that are entitled to confidential treatment under the applicable legal

6

principles. The parties further acknowledge, as set forth in Section 12.3, below, that this

7

Stipulated Protective Order does not entitle them to file confidential information under

8

seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the

9

standards that will be applied when a party seeks permission from the Court to file
material under seal.

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10

12

B.

GOOD CAUSE STATEMENT

The documents exchanged in this case include checks and checking account

13 statements and bank records. The checks in issue and account statements bear account
14 numbers and addresses of Melvyn and Laurie Bernie, 1928 Jewelry, Laurie B, LLC,
15

Emily A LLC, Jewelm LLC, 1928 Watch Company, the Bernie Family Trust, Kids

16

Castle, and Nat-Sim Corporation. They also include bank policies and procedures which

17

are proprietary policies and procedures of WELLS FARGO BANK, NATIONAL

18

ASSOCIATION (“WELLS FARGO BANK”) designed to detect and prevent fraud and

19

proprietary bank policies and procedures for processing checks deposited over the

20

counter and through automated teller machines. Public disclosure of the information on

21

the checks would compromise account numbers and other information which should be

22

kept confidential in compliance with the policy of the Judicial Council of the United

23

States and the E-Government Act of 2002 and Article 1, Section 1 of the California

24

Constitution.

25

Disclosure of the Bank policies and procedures designed to detect and prevent

26

fraud and systems for processing checks deposited over the counter and through

27

automated teller machines could provide those who wish to perpetrate fraud information

28

regarding WELLS FARGO BANK’S policies and procedures which would lead to
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increased fraudulent activities and losses to WELLS FARGO BANK and its customers.

2

Accordingly, to expedite the flow of information, to facilitate the prompt resolution of

3

disputes over confidentiality of discovery materials, to adequately protect information the

4

parties are entitled to keep confidential, to ensure that the parties are permitted reasonable

5

necessary uses of such material in preparation for and in the conduct of trial, to address

6

their handling at the end of the litigation, and serve the ends of justice, a protective order

7

for such information is justified in this matter. It is the intent of the parties that

8

information will not be designated as confidential for tactical reasons and that nothing be

9

so designated without a good faith belief that it has been maintained in a confidential,
non-public manner, and there is good cause why it should not be part of the public record

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10

of this case.

12

2.

13
14

DEFINITIONS
2.1

Action: Laurie B LLC, a California limited liability company,

Plaintiff, vs. Wells Fargo Bank, N.A., and Does 1 through 10, Defendants, being

15 United States District Court, Central District of California Case No. CV14-394216 DMG-SSx.
17
18

2.2

Challenging Party: a Party or Non-Party that challenges the

designation of information or items under this Order.

19

2.3

"CONFIDENTIAL" Information or Items: information (regardless

20

of how it is generated, stored or maintained) or tangible things that qualify for protection

21

under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

22

Statement.

23
24

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as

their support staff).

25

2.5

Designating Party: a Party or Non-Party that designates information

26

or items that it produces in disclosures or in responses to discovery as

27

“CONFIDENTIAL."

28

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2.6

Disclosure or Discovery Material: all items or information,

2

regardless of the medium or manner in which it is generated, stored, or maintained

3

(including, among other things, testimony, transcripts, and tangible things), that are

4

produced or generated in disclosures or responses to discovery in this matter.

5

2.7

Expert: a person with specialized knowledge or experience in a

6

matter pertinent to the litigation who has been retained by a Party or its counsel to serve

7

as an expert witness or as a consultant in this Action.

8
9

12

counsel.
2.9

Non-Party: any natural person, partnership, corporation, association,

or other legal entity not named as a Party to this action.

13
14

House Counsel: attorneys who are employees of a party to this

Action. House Counsel does not include Outside Counsel of Record or any other outside

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2.8

2.10

Outside Counsel of Record: attorneys who are not employees of a

party to this Action but are retained to represent or advise a party to this Action and have

15 appeared in this Action on behalf of that party or are affiliated with a law firm which has
16 appeared on behalf of that party, and includes support staff.
17

2.11

Party: any party to this Action, including all of its officers, directors,

18

employees, consultants, retained experts, and Outside Counsel of Record (and their

19

support staffs).

20
21

2.12

Producing Party: a Party or Non-Party that produces Disclosure or

Discovery Material in this Action.

22

2.13

Professional Vendors: persons or entities that provide litigation

23

support services (e.g., photocopying, videotaping, translating, preparing exhibits or

24

demonstrations, and organizing, storing, or retrieving data in any form or medium) and

25

their employees and subcontractors.

26

2.14

Protected Material: any Disclosure or Discovery Material that is

27

designated as "CONFIDENTIAL."

28

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2.15

2

Material from a Producing Party.

Receiving Party: a Party that receives Disclosure or Discovery

3

3.

4

The protections conferred by this Stipulation and Order cover not only Protected

SCOPE

5 Material (as defined above), but also (1) any information copied or extracted from
6 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
7 Material; and (3) any testimony, conversations, or presentations by Parties or their
8 Counsel that might reveal Protected Material.
9

Any use of Protected Material at trial shall be governed by the orders of the trial

11
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10 judge. This Order does not govern the use of Protected Material at trial.

Nothing in this Stipulation and Order shall require any party to file or attempt to

12 file any document containing protected material under seal. Any party demanding that
13 protected material be filed under seal shall make the demand separately, in writing, to the
14 other party and the parties shall meet and confer concerning the demand.
15

4.

16

Even after final disposition of this litigation, the confidentiality obligations

17

imposed by this Order shall remain in effect until a Designating Party agrees otherwise in

18

writing or a court order otherwise directs. Final disposition shall be deemed to be the

19

later of (1) dismissal of all claims and defenses in this Action, with or without prejudice;

20

and (2) final judgment herein after the completion and exhaustion of all appeals,

21

rehearings, remands, trials, or reviews of this Action, including the time limits for filing

22

any motions or applications for extension of time pursuant to applicable law.

23
24

5.

DURATION

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for

25

Protection. Each Party or Non-Party that designates information or items for protection

26

under this Order must take care to limit any such designation to specific material that

27 qualifies under the appropriate standards. The Designating Party must designate for
28 protection only those parts of material, documents, items, or oral or written
5
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communications that qualify so that other portions of the material, documents, items, or

2

communications for which protection is not warranted are not swept unjustifiably within

3

the ambit of this Order.

4

Mass, indiscriminate, or routinized designations are prohibited.

5

Designations that are shown to be clearly unjustified or that have been made for an

6

improper purpose (e.g., to unnecessarily encumber the case development process or to

7

impose unnecessary expenses and burdens on other parties) may expose the Designating

8

Party to sanctions.

9

If it comes to a Designating Party's attention that information or items that
it designated for protection do not qualify for protection, that Designating Party must

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10

promptly notify all other Parties that it is withdrawing the inapplicable designation.

12

5.2

Manner and Timing of Designations. Except as otherwise provided

13

in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

14

stipulated or ordered, Disclosure or Discovery Material that qualifies for protection under

15

this Order must be clearly so designated before the material is disclosed or produced.

16
17

Designation in conformity with this Order requires:
(a)

for information in documentary form (e.g., paper or electronic

18

documents, but excluding transcripts of depositions or other pretrial or trial proceedings),

19

that the Producing Party affix at a minimum, the legend "CONFIDENTIAL" (hereinafter

20

"CONFIDENTIAL legend"), to each page that contains protected material. If only a

21

portion or portions of the material on a page qualifies for protection, the Producing Party

22

also must clearly identify the protected portion(s) (e.g., by making appropriate markings

23

in the margins).

24

A Party or Non-Party that makes original documents available for inspection need

25

not designate them for protection until after the inspecting Party has indicated which

26

documents it would like copied and produced. During the inspection and before the

27

designation, all of the material made available for inspection shall be deemed

28

"CONFIDENTIAL." After the inspecting Party has identified the documents it wants
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copied and produced, the Producing Party must determine which documents, or portions

2

thereof, qualify for protection under this Order. Then, before producing the specified

3

documents, the Producing Party must affix the "CONFIDENTIAL legend" to each page

4

that contains Protected Material. If only a portion or portions of the material on a page

5

qualifies for protection, the Producing Party also must clearly identify the protected

6

portion(s) (e.g., by making appropriate markings in the margins).

7

(b)

for testimony given in depositions that the Designating Party identify

8

the Disclosure or Discovery Material on the record, before the close of the deposition all

9

protected testimony.
(c)

for information produced in some form other than documentary and

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10

for any other tangible items, that the Producing Party affix in a prominent place on the

12

exterior of the container or containers in which the information is stored the legend

13

"CONFIDENTIAL." If only a portion or portions of the information warrants protection,

14

the Producing Party, to the extent practicable, shall 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 the

17

Designating Party's right to secure protection under this Order for such material. Upon

18

timely correction of a designation, the Receiving Party must make reasonable efforts to

19

assure that the material is treated in accordance with the provisions of this Order.

20

6.

21

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges. Any Party or Non-Party may challenge a

22

designation of confidentiality at any time that is consistent with the Court's Scheduling

23

Order.

24
25
26

6.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.
6.3

The burden of persuasion in any such challenge proceeding shall be

27

on the Designating Party. Frivolous challenges, and those made for an improper purpose

28

(e.g., to harass or impose unnecessary expenses and burdens on other parties) may expose
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the Challenging Party to sanctions. Unless the Designating Party has waived or

2

withdrawn the confidentiality designation, all parties shall continue to afford the material

3

in question the level of protection to which it is entitled under the Producing Party's

4

designation until the Court rules on the challenge.

5

7.

6

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that

7

is disclosed or produced by another Party or by a Non-Party in connection with this

8

Action only for prosecuting, defending, or attempting to settle this Action. Such

9

Protected Material may be disclosed only to the categories of persons and under the
conditions described in this Order. When the Action has been terminated, a Receiving

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Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

12

Protected Material must be stored and maintained by a Receiving Party at a

13

location and in a secure manner that ensures that access is limited to the persons

14

authorized under this Order.

15

7.2

Disclosure of "CONFIDENTIAL" Information or Items. Unless

16

otherwise ordered by the court or permitted in writing by the Designating Party, a

17

Receiving Party may disclose any information or item designated "CONFIDENTIAL"

18

only to:

19

(a)

the Receiving Party's Outside Counsel of Record in this Action, as

20

well as employees of said Outside Counsel of Record to whom it is reasonably necessary

21

to disclose the information for this Action;

22
23
24

(b)

the officers, directors, and employees (including House Counsel) of

the Receiving Party to whom disclosure is reasonably necessary for this Action;
(c)

Experts (as defined in this Order) of the Receiving Party to whom

25

disclosure is reasonably necessary for this Action and who have signed the

26

"Acknowledgment and Agreement to Be Bound" (Exhibit A);

27

(d)

the court and its personnel;

28

(e)

court reporters and their staff;
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(f)

professional jury or trial consultants, mock jurors, and Professional

2 Vendors to whom disclosure is reasonably necessary for this Action and who have signed
3 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

(h)

during their depositions, witnesses ,and attorneys for witnesses, in

7 the Action to whom disclosure is reasonably necessary provided: (1) the deposing party
8 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not
9 be permitted to keep any confidential information unless they sign the "Acknowledgment

11 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to
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10 and Agreement to Be Bound" (Exhibit A), unless otherwise agreed by the Designating

12 depositions that reveal Protected Material may be separately bound by the court reporter
13 and may not be disclosed to anyone except as permitted under this Stipulated Protective
14 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 OTHER LITIGATION

19

If a Party is served with a subpoena or a court order issued in other litigation that

20 compels disclosure of any information or items designated in this Action as
21 "CONFIDENTIAL," that Party must:
22

(a)

promptly notify in writing the Designating Party. Such notification

23 shall include a copy of the subpoena or court order;
24

(b)

promptly notify in writing the party who caused the subpoena or

25

order to issue in the other litigation that some or all of the material covered by the

26

subpoena or order is subject to this Protective Order. Such notification shall include a

27

copy of this Stipulated Protective Order; and

28

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(c)

cooperate with respect to all reasonable procedures sought to be

2 pursued by the Designating Party whose Protected Material may be affected.
3

If the Designating Party timely seeks a protective order, the Party served with the

4 subpoena or court order shall not produce any information designated in this action as
5 "CONFIDENTIAL" before a determination by the court from which the subpoena or
6 order issued, unless the Party has obtained the Designating Party's permission. The
7 Designating Party shall bear the burden and expense of seeking protection in that court of
8 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 directive

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10 from another court.

12

9.

A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

13

(a)

The terms of this Order are applicable to information produced by a

14 Non-Party in this Action and designated as "CONFIDENTIAL." Such information
15 produced by Non-Parties in connection with this litigation is protected by the remedies
16

and relief provided by this Order. Nothing in these provisions should be construed as

17

prohibiting a Non-Party from seeking additional protections.

18

(b)

In the event that a Party is required, by a valid discovery request, to

19

produce a Non-Party's confidential information in its possession, and the Party is subject

20

to an agreement with the Non-Party not to produce the Non-Party's confidential

21

information, then the Party shall:

22

(1)

promptly notify in writing the Requesting Party and the Non-

23

Party that some or all of the information requested is subject to a confidentiality

24

agreement with a Non-Party;

25

(2)

promptly provide the Non-Party with a copy of the Stipulated

26

Protective Order in this Action, the relevant discovery request(s), and a reasonably

27

specific description of the information requested; and

28

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1
2

(3)

make the information requested available for inspection by

the Non-Party, if requested.

3

(c)

If the Non-Party fails to seek a protective order from this court

4

within 14 days of receiving the notice and accompanying information, the Receiving

5

Party may produce the Non-Party's confidential information responsive to the discovery

6

request. If the Non-Party timely seeks a protective order, the Receiving Party shall not

7

produce 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 order

9

to the contrary, the Non-Party shall bear the burden and expense of seeking protection in
this court of its Protected Material.

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10.

12

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

13

Protected Material to any person or in any circumstance not authorized under this

14

Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

15

the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

16

all unauthorized copies of the Protected Material, (c) inform the person or persons to

17 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
18 such person or persons to execute the "Acknowledgment and Agreement to Be Bound"
19 that is attached hereto as Exhibit A.
20
21
22

11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain

23 inadvertently produced material is subject to a claim of privilege or other protection, the
24 obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure
25

26(b)(5)(B). This provision is not intended to modify whatever procedure may be

26

established in an e-discovery order that provides for production without prior privilege

27

review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach

28

an agreement on the effect of disclosure of a communication or information covered by
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the attorney-client privilege or work product protection, the parties may incorporate their

2

agreement in the stipulated protective order submitted to the court.

3

12.

4
5

MISCELLANEOUS
12.1

Right to Further Relief. Nothing in this Order abridges the right of

any person to seek its modification by the Court in the future.

6

12.2

Right to Assert Other Objections. By stipulating to the entry of this

7

Protective Order no Party waives any right it otherwise would have to object to disclosing

8

or producing any information or item on any ground not addressed in this Stipulated

9

Protective Order. Similarly, no Party waives any right to object on any ground to use in
evidence of any of the material covered by this Protective Order.

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12.3

Filing Protected Material. A Party that seeks to file under seal any

12 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
13 only be filed under seal pursuant to a court order authorizing the sealing of the specific
14 Protected Material at issue. If a Party's request to file Protected Material under seal is
15 denied by the court, then the Receiving Party may file the information in the public
16 record unless otherwise instructed by the court.
17

13.

18

After the final disposition of this Action, as defined in paragraph 4, within 60 days

FINAL DISPOSITION

19 of a written request by the Designating Party, each Receiving Party must return all
20

Protected Material to the Producing Party or destroy such material. As used in this

21

subdivision, "all Protected Material" includes all copies, abstracts, compilations,

22

summaries, and any other format reproducing or capturing any of the Protected Material.

23

Whether the Protected Material is returned or destroyed, the Receiving Party must submit

24

a written certification to the Producing Party (and, if not the same person or entity, to the

25

Designating Party) by the 60 day deadline that (1) identifies (by category, where

26

appropriate) all the Protected Material that was returned or destroyed and (2)affirms that

27

the Receiving Party has not retained any copies, abstracts, compilations, summaries or

28

any other format reproducing or capturing any of the Protected Material. Notwithstanding
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this provision, Counsel are entitled to retain an archival copy of all pleadings, motion

2

papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,

3

deposition and trial exhibits, expert reports, attorney work product, and consultant and

4 expert work product, even if such materials contain Protected Material. Any such archival
5 copies that contain or constitute Protected Material remain subject to this Protective
6 Order as set forth in Section 4 (DURATION).
7

14.

8

All parties to this Stipulation shall redact any bank record disclosed during

REDACTION OF PERSONAL IDENTIFIERS

third party or before presenting the document to the Clerk to exclude personal

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the course of discovery in this action before making the record available to any

10
BARTON, KLUGMAN & OETTING LLP

9

identifiers in compliance with the policy of the Judicial Council of the United

12

States and the E-Government Act of 2002 and Article 1, Section 1 of the

13

California Constitution and shall redact the following personal data identifiers

14

from all documents, exhibits and attachments disclosed to third parties or filed with

15

the Court:

16
17

(a)

number must be included in a document, all of the number shall be redacted;

18
19

Social Security numbers: If an individual’s Social Security

(b)

Names of minor children: If the involvement of a minor child

must be mentioned, only the initials of that child should be used;

20

(c)

Dates of birth: If an individual’s date of birth must be included

21 in a document, all of the date except the year shall be redacted;
22

(d)

Financial account numbers: If financial account numbers are

23 relevant, identify the name or type of account and the financial institution where
24 maintained, and redact all except the last four digits of the account number;
25

(e)

Home address: If a home address must be included, all of the

26 address except the city and state shall be redacted.
27

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28

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W:\Working\Fisher\WFB\Laurie B\Pldgs\Stipulated Protective Order.doc

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Any violation of this Order may be punished by any and all

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appropriate measures including, without limitation, contempt proceedings and/or

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monetary sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: ____________________________

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LAW OFFICES OF STEVEN GLASER

By _________________________________
Steven Glaser
Attorneys for Plaintiff LAURIE B LLC
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350 SOUTH GRAND AVENUE, SUITE 2200
LOS ANGELES, CALIFORNIA 90071-3454
TELEPHONE [phone]

BARTON, KLUGMAN & OETTING LLP

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Dated: ____________________________
BARTON, KLUGMAN & OETTING LLP

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By: ________________________________
Robert Louis Fisher,
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A Professional Corporation
Attorneys for Defendant WELLS FARGO
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BANK, NATIONAL ASSOCIATION
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
Dated: October 6, 2014 ___________________________

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___________/s/____________________
Suzanne H. Segal
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United States Magistrate Judge
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W:\Working\Fisher\WFB\Laurie B\Pldgs\Stipulated Protective Order.doc

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, ________________________________ [print or type full name], of

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__________________________________ [print or type full address], declare

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under penalty of perjury that I have read in its entirety and understand the

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Stipulated Protective Order that was issued by the United States District Court for

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the Central District of California on ______________ [date] in the case of Laurie

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B LLC, a California limited liability company, Plaintiff, vs. Wells Fargo Bank,

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N.A., and Does 1 through 10, Defendants, United States District Court, Central
District of California Case No. CV14-3942-DMG-SSx. I agree to comply with and

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350 SOUTH GRAND AVENUE, SUITE 2200
LOS ANGELES, CALIFORNIA 90071-3454
TELEPHONE [phone]

BARTON, KLUGMAN & OETTING LLP

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to be bound by all the terms of this Stipulated Protective Order and I understand

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and acknowledge that failure to so comply could expose me to sanctions and

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punishment in the nature of contempt. I solemnly promise that I will not disclose

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in any manner any information or item that is subject to this Stipulated Protective

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Order to any person or entity except in strict compliance with the provisions of this

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Order. I further agree to submit to the jurisdiction of the United States District

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Court for the Central District of California for the purpose of enforcing the terms

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of this Stipulated Protective Order, even if such enforcement proceedings occur

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after termination of this action. I hereby appoint ______________________[print

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or type full name] of ___________________________________[print or type full

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address and telephone number] as my California agent for service of process in

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connection with this action or any proceedings related to enforcement of this

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Stipulated Protective Order.

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Date: _____________________

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City and State where sworn and signed: __________________________________

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Printed name: ______________________________________

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Signature: _________________________________________

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W:\Working\Fisher\WFB\Laurie B\Pldgs\Stipulated Protective Order.doc