Cassandra Wilson v. Edison International Inc et al

Filing 68

PROTECTIVE ORDER by Magistrate Judge Patrick J. Walsh 67 . SEE ORDER. (im)

Download PDF
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 CASSANDRA WILSON, and all 12 other individuals similarly situated, Plaintiff, 13 14 vs. 15 THEODORE F. CRAVER, JR., and ROBERT BOADA, 16 Defendants. 17 Case No. LACV15-09139 JAK (PJWx) STIPULATED PROTECTIVE ORDER DISCOVERY MATTER 18 19 20 21 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. The parties further acknowledge, as set forth 11 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 12 file confidential information under seal; Civil Local Rule 79-5 sets forth the 13 procedures that must be followed and the standards that will be applied when a party 14 seeks permission from the court to file material under seal. 15 B. 16 This action is likely to involve valuable commercial, financial, regulatory, GOOD CAUSE STATEMENT 17 research, development, technical and/or proprietary information for which special 18 protection from public disclosure and from use for any purpose other than 19 prosecution of this action is warranted. Such confidential and proprietary materials 20 and information consist of, among other things, confidential business or financial 21 information, information regarding confidential business practices, or other 22 confidential research, development, or commercial information (including 23 information implicating privacy rights of third parties), information otherwise 24 generally unavailable to the public, or which may be privileged or otherwise 25 protected from disclosure under state or federal statutes, court rules, case decisions, 26 or common law. Accordingly, to expedite the flow of information, to facilitate the 27 prompt resolution of disputes over confidentiality of discovery materials, to 28 adequately protect information the parties are entitled to keep confidential, to ensure STIPULATED PROTECTIVE ORDER 1 that the parties are permitted reasonable necessary uses of such material in 2 preparation for and in the conduct of trial, to address their handling at the end of the 3 litigation, and serve the ends of justice, a protective order for such information is 4 justified in this matter. It is the intent of the parties that information will not be 5 designated as confidential for tactical reasons and that nothing be so designated 6 without a good faith belief that it has been maintained in a confidential, non-public 7 manner, and there is good cause why it should not be part of the public record of this 8 case. 9 2. 10 DEFINITIONS 2.1 Action: Wilson v. Edison Int’l et al., No. LACV15-09139 JAK (PJWx) 11 (C.D. Cal.). 12 2.2 Challenging Party: a Party or Non-Party that challenges the designation 13 of information or items under this Order. 14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for 16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 17 the Good Cause Statement. 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 19 their 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 24 of the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced or 26 generated in disclosures or responses to discovery in this matter. 27 2.7 Expert: a person with specialized knowledge or experience in a matter 28 pertinent to the litigation who has been retained by a Party or its counsel to serve as STIPULATED PROTECTIVE ORDER 1 an expert witness or as a consultant in this Action. 2 2.8 House Counsel: attorneys who are employees of a current or former 3 party to this Action. House Counsel does not include Outside Counsel of Record or 4 any other outside counsel. 5 2.9 Non-Party: any natural person, partnership, corporation, association, or 6 other legal entity not named as a current or former Party to this action. 7 2.10 Outside Counsel of Record: attorneys who are not employees of a party 8 to this Action but are retained to represent or advise a party to this Action and have 9 appeared in this Action on behalf of that party or are affiliated with a law firm which 10 has appeared on behalf of that party, and includes support staff. 11 2.11 Party: any party to this Action, including all of its officers, directors, 12 employees, consultants, retained experts, and Outside Counsel of Record (and their 13 support staffs). 14 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 15 Discovery Material in this Action. 16 2.13 Professional Vendors: persons or entities that provide litigation support 17 services (e.g., photocopying, videotaping, translating, preparing exhibits or 18 demonstrations, and organizing, storing, or retrieving data in any form or medium) 19 and their employees and subcontractors. 20 2.14 Protected Material: any Disclosure or Discovery Material that is 21 designated as “CONFIDENTIAL.” 22 2.15 Receiving Party: a Party that receives Disclosure or Discovery 23 Material from a Producing Party. 24 3. SCOPE 25 The protections conferred by this Stipulation and Order cover not only 26 Protected Material (as defined above), but also (1) any information copied or 27 extracted from Protected Material; (2) all copies, excerpts, summaries, or 28 compilations of Protected Material; and (3) any testimony, conversations, or STIPULATED PROTECTIVE ORDER 1 presentations by Parties or their Counsel that might reveal Protected Material. 2 Any use of Protected Material at trial shall be governed by the orders of the 3 trial judge. This Order does not govern the use of Protected Material at trial. 4 4. DURATION 5 Even after final disposition of this litigation, the confidentiality obligations 6 imposed by this Order shall remain in effect until a Designating Party agrees 7 otherwise in writing or a court order otherwise directs. Final disposition shall be 8 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 9 or without prejudice; and (2) final judgment herein after the completion and 10 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 11 including the time limits for filing any motions or applications for extension of time 12 pursuant to applicable law. 13 5. DESIGNATING PROTECTED MATERIAL 14 5.1 Exercise of Restraint and Care in Designating Material for Protection. 15 Each Party or Non-Party that designates information or items for protection under 16 this Order must take care to limit any such designation to specific material that 17 qualifies under the appropriate standards. The Designating Party must designate for 18 protection only those parts of material, documents, items, or oral or written 19 communications that qualify so that other portions of the material, documents, 20 items, or communications for which protection is not warranted are not swept 21 unjustifiably within the ambit of this Order. 22 Mass, indiscriminate, or routinized designations are prohibited. Designations 23 that are shown to be clearly unjustified or that have been made for an improper 24 purpose (e.g., to unnecessarily encumber the case development process or to impose 25 unnecessary expenses and burdens on other parties) may expose the Designating 26 Party to sanctions. 27 If it comes to a Designating Party’s attention that information or items that it 28 designated for protection do not qualify for protection, that Designating Party must STIPULATED PROTECTIVE ORDER 1 promptly notify all other Parties that it is withdrawing the inapplicable designation. 2 5.2 Manner and Timing of Designations. Except as otherwise provided in 3 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 4 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 5 under this Order must be clearly so designated before the material is disclosed or 6 produced. 7 8 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 9 documents, but excluding transcripts of depositions or other pretrial or trial 10 proceedings), that the Producing Party affix at a minimum, the legend 11 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 12 contains protected material. If only a portion or portions of the material on a page 13 qualifies for protection, the Producing Party also must clearly identify the protected 14 portion(s) (e.g., by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents available for inspection 16 need not designate them for protection until after the inspecting Party has indicated 17 which documents it would like copied and produced. During the inspection and 18 before the designation, all of the material made available for inspection shall be 19 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 20 documents it wants copied and produced, the Producing Party must determine which 21 documents, or portions thereof, qualify for protection under this Order. Then, before 22 producing the specified documents, the Producing Party must affix the 23 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 24 portion or portions of the material on a page qualifies for protection, the Producing 25 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 26 markings in the margins). 27 28 STIPULATED PROTECTIVE ORDER 1 (b) for testimony given in depositions that the Designating Party 2 identify the Disclosure or Discovery Material within 30 days after the close of the 3 deposition. 4 (c) for information produced in some form other than documentary 5 and for any other tangible items, that the Producing Party affix in a prominent place 6 on the exterior of the container or containers in which the information is stored the 7 legend “CONFIDENTIAL.” If only a portion or portions of the information 8 warrants protection, the Producing Party, to the extent practicable, shall identify the 9 protected portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive 12 the Designating Party’s right to secure protection under this Order for such material. 13 Upon timely correction of a designation, the Receiving Party must make reasonable 14 efforts to assure that the material is treated in accordance with the provisions of this 15 Order. 16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 18 designation of confidentiality at any time that is consistent with the Court’s 19 Scheduling Order. 20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 21 resolution process under Local Rule 37.1 et seq. 22 6.3 The burden of persuasion in any such challenge proceeding shall be on 23 the Designating Party. Frivolous challenges, and those made for an improper 24 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 25 parties) may expose the Challenging Party to sanctions. Unless the Designating 26 Party has waived or withdrawn the confidentiality designation, all parties shall 27 continue to afford the material in question the level of protection to which it is 28 entitled under the Producing Party’s designation until the Court rules on the STIPULATED PROTECTIVE ORDER 1 challenge. 2 7. ACCESS TO AND USE OF PROTECTED MATERIAL 3 7.1 Basic Principles. A Receiving Party may use Protected Material that is 4 disclosed or produced by another Party or by a Non-Party in connection with this 5 Action only for prosecuting, defending, or attempting to settle this Action. Such 6 Protected Material may be disclosed only to the categories of persons and under the 7 conditions described in this Order. When the Action has been terminated, a 8 Receiving Party must comply with the provisions of section 13 below (FINAL 9 DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a 11 location and in a secure manner that ensures that access is limited to the persons 12 authorized under this Order. 13 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 14 otherwise ordered by the Court or permitted in writing by the Designating Party, a 15 Receiving Party may disclose any information or item designated 16 “CONFIDENTIAL” only to: 17 (a) the Receiving Party’s Outside Counsel of Record in this Action, 18 as well as employees of said Outside Counsel of Record to whom it is reasonably 19 necessary to disclose the information for this Action; 20 (b) the officers, directors, and employees of the Receiving Party, as 21 well as House Counsel, to whom disclosure is reasonably necessary for this Action; 22 (c) Experts (as defined in this Order) of the Receiving Party to 23 whom disclosure is reasonably necessary for this Action and who have signed the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (d) the Court and its personnel; 26 (e) court reporters and their staff; 27 (f) professional jury or trial consultants, mock jurors, and 28 Professional Vendors to whom disclosure is reasonably necessary for this Action STIPULATED PROTECTIVE ORDER 1 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 2 A); 3 (g) the author or recipient of a document containing the information 4 or a custodian or other person who otherwise possessed or knew the information; 5 (h) during their depositions, witnesses, and attorneys for witnesses, 6 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 7 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 8 they will not be permitted to keep any confidential information unless they sign the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 10 agreed by the Designating Party or ordered by the Court. Pages of transcribed 11 deposition testimony or exhibits to depositions that reveal Protected Material may 12 be separately bound by the court reporter and may not be disclosed to anyone except 13 as permitted under this Stipulated Protective Order; and 14 (i) any mediator or settlement officer, and their supporting 15 personnel, mutually agreed upon by any of the parties engaged in settlement 16 discussions. 17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 18 IN OTHER LITIGATION 19 If a Party is served with a subpoena or a court order issued in other litigation 20 that 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 23 notification 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 27 a copy of this Stipulated Protective Order; and 28 STIPULATED PROTECTIVE ORDER 1 (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 4 the subpoena or court order shall not produce any information designated in this 5 action as “CONFIDENTIAL” before a determination by the court from which the 6 subpoena or order issued, unless the Party has obtained the Designating Party’s 7 permission. The Designating Party shall bear the burden and expense of seeking 8 protection in that court of its confidential material and nothing in these provisions 9 should be construed as authorizing or encouraging a Receiving Party in this Action 10 to disobey a lawful directive from another court. 11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 12 PRODUCED IN THIS LITIGATION 13 (a) The terms of this Order are applicable to information produced 14 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 15 information produced by Non-Parties in connection with this litigation is protected 16 by the remedies and relief provided by this Order. Nothing in these provisions 17 should be construed as prohibiting a Non-Party from seeking additional protections. 18 (b) In the event that a Party is required, by a valid discovery request, 19 to produce a Non-Party’s confidential information in its possession, and the Party is 20 subject to an agreement with the Non-Party not to produce the Non-Party’s 21 confidential information, then the Party shall: 22 (1) promptly notify in writing the Requesting Party and the 23 Non-Party that some or all of the information requested is subject to a 24 confidentiality agreement with a Non-Party; 25 (2) promptly provide the Non-Party with a copy of the 26 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 27 reasonably specific description of the information requested; and 28 (3) make the information requested available for inspection by STIPULATED PROTECTIVE ORDER 1 the Non-Party, if requested. 2 (c) If the Non-Party fails to seek a protective order from this Court 3 within 14 days of receiving the notice and accompanying information, the Receiving 4 Party may produce the Non-Party’s confidential information responsive to the 5 discovery request. If the Non-Party timely seeks a protective order, the Receiving 6 Party shall not produce any information in its possession or control that is subject to 7 the confidentiality agreement with the Non-Party before a determination by the 8 Court. Absent a court order to the contrary, the Non-Party shall bear the burden and 9 expense of seeking protection in this court of its Protected Material. 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 16 persons to whom unauthorized disclosures were made of all the terms of this Order, 17 and (d) request such person or persons to execute the “Acknowledgment and 18 Agreement to Be Bound” that is attached hereto as Exhibit A. 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other protection, 23 the obligations of the Receiving Parties include those set forth in Federal Rule of 24 Civil Procedure 26(b)(5)(B). A Producing Party’s inadvertent production of such 25 material shall not constitute a waiver with respect to such material or generally of 26 such privilege or other protection. If a Receiving Party receives materials that 27 appear to be subject to an attorney-client privilege, the common interest privilege, or 28 otherwise protected by a discovery privilege or immunity, the Receiving Party must STIPULATED PROTECTIVE ORDER 1 refrain from further use or examination of the materials that may be privileged, and 2 shall immediately notify the Producing Party, in writing, that he or she possesses 3 material that appears to be privileged. In the event a Producing Party discovers it has 4 disclosed material that is subject to a claim of privilege or other protection, the 5 Producing Party may provide notice to the Receiving Parties advising of the 6 disclosure and requesting return or destruction of the material. Upon such notice, the 7 Receiving Parties shall make no further use or examination of the material and shall 8 immediately segregate them in a manner that will prevent further disclosure or 9 dissemination of their contents, and, within ten days of receiving such notice, shall 10 destroy or return all original documents identified by the Producing Party in such 11 notice (whether electronic or hard copy), shall destroy or delete any and all copies 12 (whether electronic or hard copy), and shall expunge from any other document 13 information or material derived from the produced material. The Producing Party 14 will provide the Receiving Parties with a privilege log that reasonably identifies the 15 basis for the assertion of privilege or protection. 16 If, based on (1) the privilege log entries provided by the Producing Party, or 17 (2) the Receiving Party’s review of documents that occurred prior to the assertion of 18 privilege and claw-back, there is a dispute over whether the clawed back documents 19 at issue are protected from disclosure by virtue of a privilege or immunity from 20 discovery, the original documents shall nevertheless be immediately destroyed or 21 returned to the Producing Party along with all copies (whether electronic or hard 22 copy) thereof. All counsel shall undertake reasonable efforts to resolve the issue of 23 whether the documents are privileged without court intervention. To the extent 24 counsel cannot resolve the issue, the Receiving Party may bring a motion to compel 25 production of the material, but may not assert as a ground for compelling production 26 the fact or circumstance that the material had already been produced. In conjunction 27 with such a motion, the Receiving Party may request the Court review in camera the 28 clawed back documents at issue, and, if the Court so orders, the Producing Party STIPULATED PROTECTIVE ORDER 1 shall provide the documents under seal to the Court for in-camera review. In the 2 event of a motion to compel production of the documents, the burden is on the 3 Producing Party to provide, in its opposition to the motion to compel, information 4 regarding the content and context of the documents sufficient to establish the 5 applicability of any asserted privilege or immunity from discovery. 6 This provision is not intended to modify whatever procedure may be 7 established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 parties may incorporate their agreement in the stipulated protective order submitted 12 to the court. 13 12. MISCELLANEOUS 14 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 15 person to seek its modification by the Court in the future. 16 12.2 Right to Assert Other Objections. By stipulating to the entry of this 17 Protective Order no Party waives any right it otherwise would have to object to 18 disclosing or producing any information or item on any ground not addressed in this 19 Stipulated Protective Order. Similarly, no Party waives any right to object on any 20 ground to use in evidence of any of the material covered by this Protective Order. 21 12.3 Filing Protected Material. A Party that seeks to file under seal any 22 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 23 only be filed under seal pursuant to a court order authorizing the sealing of the 24 specific Protected Material at issue. If a Party’s request to file Protected Material 25 under seal is denied by the court, then the Receiving Party may file the information 26 in the public record unless otherwise instructed by the court. 27 13. FINAL DISPOSITION 28 After the final disposition of this Action, as defined in paragraph 4, within 60 STIPULATED PROTECTIVE ORDER 1 days of a written request by the Designating Party, each Receiving Party must return 2 all Protected Material to the Producing Party or destroy such material. As used in 3 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 4 summaries, and any other format reproducing or capturing any of the Protected 5 Material. Whether the Protected Material is returned or destroyed, the Receiving 6 Party must submit a written certification to the Producing Party (and, if not the same 7 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 8 (by category, where appropriate) all the Protected Material that was returned or 9 destroyed and (2) affirms that the Receiving Party has not retained any copies, 10 abstracts, compilations, summaries or any other format reproducing or capturing any 11 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 12 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 13 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 14 reports, attorney work product, and consultant and expert work product, even if such 15 materials contain Protected Material. Any such archival copies that contain or 16 constitute Protected Material remain subject to this Protective Order as set forth in 17 Section 4 (DURATION). 18 14. Any violation of this Order may be punished by any and all appropriate 19 measures including, without limitation, contempt proceedings and/or monetary 20 sanctions. 21 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER 1 DATED: October 11, 2016 MUNGER, TOLLES & OLSON LLP HENRY WEISSMANN JOHN M. GILDERSLEEVE JORDAN X. NAVARRETTE 2 3 4 By: 5 s/ John M. Gildersleeve JOHN M. GILDERSLEEVE 6 Attorneys for Defendants THEODORE F. CRAVER, JR. and ROBERT BOADA 7 8 9 10 DATED: October 11, 2016 ZAMANSKY LLC JACOB H. ZAMANSKY SAMUEL E. BONDEROFF EDWARD H. GLENN JR. 11 12 13 14 KIRBY NOONAN LANCE & HOGE LLP MICHAEL L. KIRBY 15 By: 16 17 s/ Samuel E. Bonderoff SAMUEL E. BONDEROFF Attorneys for Plaintiff CASSANDRA WILSON 18 19 20 Pursuant to Local Rule 5-4.3.4, I, John M. Gildersleeve, attest that the above 21 signatory has authorized this filing and concurs in its content. 22 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 DATED October 12, 2016 25 26 Hon. Patrick J. Walsh 27 United States Magistrate Judge 28 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _______________________________________ [print or type full address], declare 5 under penalty of perjury that I have read in its entirety and understand the Stipulated 6 Protective Order that was issued by the United States District Court for the Central 7 District of California on _____________ in the case of Wilson v. Edison Int’l et al., 8 No. LACV15-09139 JAK (PJWx) (C.D. Cal.). I agree to comply with and to be 9 bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the 15 Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [print 18 or type full name] of _______________________________________ [print or type 19 full address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this 21 Stipulated Protective Order. 22 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28 STIPULATED PROTECTIVE ORDER

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?