Amy Joseph v. Trader Joes Company

Filing 77

PROTECTIVE ORDER by Magistrate Judge Andrew J. Wistrich: GRANTED. (SEE DOCUMENT FOR FURTHER DETAILS) 76 (klg)

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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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In re Trader Joe’s Tuna Litigation

Case No. 2:16-cv-01371-ODW (AJW)
[PROPOSED] STIPULATED
PROTECTIVE ORDER

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[PROPOSED] STIPULATED PROTECTIVE ORDER

2:16-CV-01371-ODW-AJW

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1.

PURPOSES AND LIMITATIONS

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Disclosure and discovery activity in this action are likely to involve production

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of privileged, confidential, proprietary, trade secret, or private information for which

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special protection from public disclosure and from use for any purpose other than

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prosecuting and defending this litigation may be warranted. Accordingly, Plaintiff

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Atzimba Reyes and Defendants Trader Joe’s Company and Trader Joe’s East Inc.

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hereby stipulate to and petition the court to enter the following Stipulated Protective

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Order. The Parties acknowledge that this Order does not confer blanket protections

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on all disclosures or responses to discovery and that the protection it affords from

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public disclosure and use extends only to the limited information or items that are

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entitled to confidential treatment under the applicable legal principles. The Parties

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further acknowledge, as set forth in Section 12.3, below, that this Stipulated

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Protective Order does not entitle them to file confidential information under seal;

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

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standards that will be applied when a party seeks permission from the court to file

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material under seal.

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2.

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DEFINITIONS
2.1.

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

of information or items under this Order.
2.2.

“Confidential” Information or Items: information (regardless of how it

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is generated, stored, or maintained) or tangible things that qualify for protection under

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Federal Rule of Civil Procedure 26(c).

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2.3.

Counsel (without qualifier):

Outside Counsel of Record and House

Counsel (as well as their support staff).
2.4.

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

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

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.”

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2.5.

Disclosure or Discovery Material: all items and information, regardless

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of the medium or manner in which they are generated, stored, or maintained

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

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

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2.6.

Expert: a person with specialized knowledge or experience in a matter

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pertinent to the litigation who has been retained by a Party or its, his, or her counsel

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to serve as an expert witness or as a consultant in this action, and who is not currently

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employed by or acting as a business consultant or advisor to a competing retail

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grocer.

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2.7.

“HIGHLY CONFIDENTIAL” Information or Items:

information

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(regardless of how it is generated, stored or maintained) or tangible things that qualify

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for protection under Federal Rule of Procedure 26(c), the disclosure of which the

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Designating Party believes in good faith would create a substantial risk of serious

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financial or other injury that cannot be avoided by less restrictive means.

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2.8.

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

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

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counsel.

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2.9.

Non-Party: any natural person, partnership, corporation, limited liability

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

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2.10. Outside Counsel of Record: attorneys who are not employees of a Party

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to this action but are retained to represent or advise a Party to this action and have

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appeared in this action on behalf of that Party or are associated or affiliated with a

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law firm that has appeared on behalf of that Party, and their support staff.

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2.11. Party: any Party to this action, including all of its, his or her officers,

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directors, employees, consultants, retained experts, and Outside Counsel of Record

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(and their support staffs).

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2.12. Producing Party:

a Party or Non-Party that produces Disclosure or

Discovery Material in this action.
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2.13. Professional Vendors: persons or entities that provide litigation support

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

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

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and their employees and subcontractors.

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2.14. Protected Material:

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any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.”
2.15. Receiving Party: a Party that receives Disclosure or Discovery Material

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from a Producing Party.

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3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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Protected Material (as defined above), but also (1) any information copied or

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extracted from Protected Material; (2) all copies, excerpts, summaries, or

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compilations of Protected Material; and (3) any testimony, conversations, or

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presentations by Parties or their Counsel that might reveal Protected Material.

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However, the protections conferred by this Stipulation and Order do not cover the

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following information: (a) any information that is in the public domain at the time of

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disclosure to a Receiving Party or that becomes part of the public domain after its

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disclosure to a Receiving Party as a result of publication not involving a violation of

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this Order, including becoming part of the public record through trial or otherwise;

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and (b) any information known to the Receiving Party prior to the disclosure or

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obtained by the Receiving Party after the disclosure from a source who obtained the

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information lawfully and under no obligation of confidentiality to the Designating

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Party.

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agreement or order.

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4.

Any use of Protected Material at trial shall be governed by a separate

DURATION

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Even after final disposition of this litigation, the confidentiality obligations

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

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otherwise in writing or a court order otherwise directs. Final disposition shall be
[PROPOSED] STIP. PROTECTIVE ORDER

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deemed to be the later of (1) dismissal of all claims and defenses in this action, with

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or without prejudice; and (2) final judgment herein after the completion and

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exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,

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including the time limits for any motions or applications for extension of time

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pursuant to applicable law.

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5.

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DESIGNATING PROTECTED MATERIAL
5.1.

Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or Non-Party that designates information or items for protection under this

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

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under the appropriate standards. To the extent practicable, the Designating Party

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must designate for protection only those parts of material, documents, items, or oral

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or written communications that qualify – so that other portions of the material,

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documents, items, or communications for which protection is not warranted are not

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swept unjustifiably within the ambit of this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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

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

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

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Party to sanctions.

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If it comes to a Designating Party’s attention that information or items that it

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designated for protection do not qualify for protection, that Designating Party must

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

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5.2.

Manner and Timing of Designations. Expect as otherwise provided in

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

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

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

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produced.

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Designation in conformity with this Order requires:
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(a)

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

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

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proceedings), that the Producing Party affix the legend “CONFIDENTIAL” or

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“HIGHLY CONFIDENTIAL” to each page that contains protected material. If only

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

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clearly identify the protected portions (e.g., by making appropriate markings in the

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margins).

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A Party or Non-Party that makes original documents or materials available for

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inspection need not designate them for protection until after the inspecting Party has

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indicated which material it would like copied and produced. During the inspection

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and before the designation, all of the materials made available for inspection shall be

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deemed “HIGHLY CONFIDENTIAL.” After the inspecting Party has identified the

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documents it wants copied and produced, the Producing Party must determine which

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documents, or portions thereof, qualify for protection under this Order. Then, before

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producing the specified documents, the Producing Party must affix the

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” legend to each page that

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

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

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

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(b) for testimony given in depositions or in other pretrial proceedings,

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that the Designating Party identify on the record, before the close of the deposition,

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hearing, or other proceeding, all protected testimony. When it is impractical to

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identify separately each portion of testimony that is entitled to protection and it

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appears that substantial portions of the testimony may qualify for protection, the

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Designating Party may invoke on the record (before the deposition, hearing, or other

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proceeding is concluded) a right to have up to 14 days from receipt of the transcript to

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identify the specific portions of the testimony as to which protection is sought and to

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specify the level of protection being asserted. Only those portions of the testimony
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that are appropriately designated for protection within those 14 days shall be covered

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by the provisions of this Stipulated Protective Order. Alternatively, a Designating

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Party may specify, at the deposition or up to 14 days from receipt of the transcript, if

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that period is properly invoked, that the entire transcript shall be treated as “HIGHLY

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CONFIDENTIAL.”

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Transcripts containing Protected Material shall have an obvious legend on the

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title page that the transcript contains Protected Material, and the title page shall be

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followed by a list of all pages (including line numbers as appropriate) that have been

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designated as Protected Material and the level of protection being asserted by the

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Designating Party. The Designating Party shall inform the court reporter of these

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requirements. Any transcript that is prepared before the expiration of the 14-day

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period for designation shall be treated during that period as if it had been designated

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“HIGHLY CONFIDENTIAL.”

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(c) for information produced in some form other than documentary and

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

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

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the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” If only a portion

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or portions of the information or item warrant protection, the Producing Party, to the

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extent practicable, shall identify the protected portion(s).
5.3.

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Inadvertent Failure to Designate. If corrected within a reasonable period

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of time, an inadvertent failure to designate qualified information or items does not,

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standing alone, waive the Designating Party’s right to secure protection under this

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Order for such material. Upon timely correction of a designation, the Receiving

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Party must take reasonable efforts to assure that the material is treated in accordance

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with the provisions of this Order.

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6.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1.

Timing of Challenges. Any Party or Non-Party may make a good-faith

challenge to a designation of confidentiality at any time. Unless a prompt challenge
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to a Designating Party’s confidentiality designation is necessary to avoid foreseeable,

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substantial unfairness, unnecessary economic burdens, or a significant disruption or

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delay of the litigation, a Party does not waive its right to challenge a confidentiality

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designation by electing not to mount a challenge promptly after the original

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designation is disclosed.
6.2.

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resolution process under Local Rule 37-1 et seq.
6.3.

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Meet and Confer. The Challenging Party shall initiate the dispute

Joint Stipulation. Any challenge submitted to the court shall be via a

joint stipulation pursuant to Local Rule 37-2.
6.4.

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The burden of persuasion in any such challenge proceeding shall be on

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

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(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

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expose the Challenging Party to sanctions. Unless the Designating Party has waived

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or withdrawn the confidentiality designations, all parties shall continue to afford the

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material in question the level of protection to which it is entitled under the Producing

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Party’s designation until the court rules on the challenge.

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7.

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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1.

Basic Principles. A Receiving Party may use Protected Material that is

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

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

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Material may not be used for any other purpose, including any use relating to any

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other actual or potential litigation, whether or not related to this litigation. Protected

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Material may be disclosed only to the categories of persons and under the conditions

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described in this Order. When the litigation has been terminated, a Receiving Party

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

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

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

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authorized under this Order.
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7.2.

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Disclosure of “CONFIDENTIAL” Information or Items.

Unless

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

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Receiving

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“CONFIDENTIAL” only to:

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(a)

Party

may

disclose

any

information

or

item

designated

the Receiving Party’s Outside Counsel of Record in this action, as

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

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necessary to disclose the information for this litigation;
(b)

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other attorneys working on discrete projects related to this action

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at the request of Receiving Party’s Outside Counsel of Record in this action to whom

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it is reasonably necessary to disclose the information for completion of said projects

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and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

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A);
(c)

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

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of the Receiving Party to whom disclosure is reasonably necessary for this litigation

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and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

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A);

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(d)

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

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

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“Acknowledgment and Agreement to Be Bound” (Exhibit A);

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(e)

the court and its personnel;

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(f)

court reporters and their staff, professional jury or trial

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consultants, mock jurors, and Professional Vendors to whom disclosure is reasonably

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necessary for this litigation and who have signed the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A);

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(g)

during their depositions, witnesses in the action to whom

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disclosure is reasonably necessary and who have signed the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A), unless otherwise ordered by the court. Pages

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of transcribed deposition testimony or exhibits to depositions that reveal Protected
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Material must be separately bound by the court reporter and may not be disclosed to

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anyone except as permitted under this Stipulated Protective Order.
(h)

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the author or recipient of a document containing the information

or a custodian or other person who otherwise possessed or knew the information.
7.3.

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Disclosure of “HIGHLY CONFIDENTIAL” Information or Items.

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Unless otherwise ordered by the court or permitted in writing by the Designating

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Party, a Receiving Party may disclose any information or item designated “HIGHLY

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CONFIDENTIAL” only to:

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(a)

the Receiving Party’s Outside Counsel of Record in this action, as

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

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necessary to disclose the information for this litigation;
(b)

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one officer, director, or employee (including House Counsel) of

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the Receiving Party to whom disclosure is reasonably necessary for this litigation and

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who has signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(c)

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other attorneys working on discrete projects related to this action

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at the request of Receiving Party’s Outside Counsel of Record in this action to whom

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it is reasonably necessary to disclose the information for completion of said projects

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and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

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A);

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(d)

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

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

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“Acknowledgement and Agreement to Be Bound” (Exhibit A);

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(e)

the court and its personnel;

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(f)

court reporters and their staff, professional jury or trial

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consultants, and Professional Vendors to whom disclosure is reasonably necessary for

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this litigation and who have signed the “Acknowledgement and Agreement to Be

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Bound” (Exhibit A);

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(g)

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during their depositions, witnesses in the action to whom

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disclosure is reasonably necessary and who have signed the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A), unless otherwise ordered by the court. Pages

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of transcribed deposition testimony or exhibits to depositions that reveal Protected

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Material must be separately bound by the court reporter and may not be disclosed to

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anyone except as permitted under this Stipulated Protective Order.
(h)

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the author or recipient of a document containing the information

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or a custodian or other person who otherwise possessed or knew the information.

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8.

PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

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PRODUCED IN OTHER LITIGATION

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

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that compels disclosure of any information or items designated in this action as

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL,” that Party must:
(a)

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promptly notify in writing the Designating Party. Such notification shall

include a copy of the subpoena or court order;
(b)

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promptly notify in writing the party who caused the subpoena or order to

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

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order is subject to this Order. Such notification shall include a copy of this Order;

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and
(c)

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cooperate with respect to all reasonable procedures sought to be pursued

by the Designating Party whose Protected Material may be affected.

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

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the subpoena or court order shall not produce any information designated in this

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action

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determination by the court from which the subpoena or order issued, unless the Party

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has obtained the Designating Party’s permission. The Designating Party shall bear

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the burden and expense of seeking protection in that court of its confidential material

as

“CONFIDENTIAL”

or

“HIGHLY

CONFIDENTIAL”

before

a

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– and nothing in these provisions should be construed as authorizing or encouraging a

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Receiving Party in this action to disobey a lawful directive from another court.

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9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

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PRODUCED IN THIS LITIGATION

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(a)

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

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Non-Party in this action and designated as “CONFIDENTIAL.” Such information

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produced by Non-Parties in connection with this litigation is protected by the

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

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construed as prohibiting a Non-Party from seeking additional protections.

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(b)

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

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

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subject to an agreement with the Non-Party not to produce the Non-Party’s

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confidential information, then the Party shall:
(1)

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promptly notify in writing the Requesting Party and the Non-Party

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

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with a Non-Party;
(2)

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promptly provide the Non-Party with a copy of this Order, the

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relevant discovery request(s), and a reasonably specific description of the information

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required; and
(3)

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make the information requested available for inspection by the

Non-Party.
(c)

If the Non-Party does not seek a protective order from this court within

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

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

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request assuming the Receiving Party has complied with all duties and obligations

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owed to the Non-Party with respect to maintaining the confidentiality of the Non-

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Party information in its possession. If the Non-Party timely seeks a protective order,

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the Receiving Party shall not produce any information in its possession or control that
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is subject to the confidentiality agreement with the Non-Party before a determination

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by the court.1 Absent a court order to the contrary, the Non-Party shall bear the

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burden and expense of seeking protection in this court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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persons to whom unauthorized disclosures were made of all the terms of this Order,

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and (d) request such person or persons to execute the “Acknowledgment and

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Agreement to Be Bound” that is attached hereto as Exhibit A.

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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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inadvertently produced material is subject to a claim of privilege or other protection,

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the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

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

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

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

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Parties reach an agreement on the effect of disclosure of a communication or

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information covered by the attorney-client privilege or work product protection, the

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Parties may incorporate their agreement in the stipulated protective order submitted

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to the court.

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The purpose of this provision is to alert the interested parties to the existence of
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protect its confidentiality interests in this court.
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12.

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.

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

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

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producing any information or item on any ground not addressed in this Order.

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Similarly, no Party waives any right to object on any ground to use in evidence of any

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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

10

Protected Material must comply with Local Civil Rule 79-5. Protected Material may

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only be filed under seal pursuant to a court order authorizing the sealing of the

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specific Protected Material at issue. If a Party’s request to file Protected Material

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under seal is denied by the court, then the Receiving Party may file the information in

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the public record unless otherwise instructed by the court.

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12.4. Additional Parties or Attorneys.

If additional parties are joined or

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intervene in this action, the newly joined parties shall not have access to Protected

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Material until their counsel has executed and, at the request of any Party, filed with

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the court, its agreement to be bound by this Order.

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12.5. No Loss of Confidentiality by Use in Litigation or Appeal. If Protected

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Material is used in any court proceeding in this litigation or any appeal, it shall not

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lose its status as Protected Material through such use. Counsel shall comply with the

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terms of this Order and all applicable local rules and shall confer on the procedures

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necessary to protect the confidentiality of Protected Material used in the court of any

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court proceedings.

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12.6. Exclusion of Individuals from Depositions. Counsel for any Designating

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Party shall have the right to exclude from depositions any person who is not

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authorized by this Order to receive documents or information designated as Protected

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Material.
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13.

FINAL DISPOSITION

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Within 60 days after the final disposition of this action, as defined in paragraph

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4, each Receiving Party must return all Protected Material to the Producing Party or

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destroy such material. As used in this subdivision, “all Protected Material” includes

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all copies, abstracts, compilations, summaries, and any other format reproducing or

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capturing any of the Protected Material. Whether the Protected Material is returned

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or destroyed, the Receiving Party must submit a written certification to the Producing

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Party (and, if not the same person or entity, to the Designating Party) by the 60-day

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deadline that (1) identifies (by category, where appropriate) all the Protected Material

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that was returned or destroyed and (2) affirms that the Receiving Party has not

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retained any copies, abstracts, compilations, summaries, or any other format

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reproducing or capturing any of the Protected Material.

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provision, Counsel are entitled to retain an archival copy of all pleadings, motion

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

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

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and expert work product, even if such materials contain Protected Material. Any

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such archival copies that contain or constitute Protected Material remain subject to

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this Protective Order as set forth in Section 4 (DURATION).

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14.

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21

Notwithstanding this

VIOLATION
Any violation of this Order may be punished by appropriate measures

including, without limitation, contempt proceedings and/or monetary sanctions.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
PARKS & SOLAR, LLP
23 DATED: December 21, 2017
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By: _/s/ Robert J. Parks_________________
ROBERT J. PARKS
KEITH R. SOLAR
DOUGLAS W. GILLIE
Attorneys for Defendants
Trader Joe’s Company and
Trader Joe’s East Inc.
[PROPOSED] STIP. PROTECTIVE ORDER

14

2:16-cv-01371-ODW-AJW

1

DATED: December 21, 2017

2

BURSOR & FISHER, P.A.
By: /s/ L. Timothy Fisher
L. TIMOTHY FISHER

3
4

7

L. Timothy Fisher (State Bar No. 191626)
1990 North California Boulevard, Suite 940
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Interim Class Counsel

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6

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: December 21, 2017

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____________________________________
14 HON. ANDREW J. WISTRICH
15 United States Magistrate Judge
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[PROPOSED] STIP. PROTECTIVE ORDER

15

2:16-cv-01371-ODW-AJW

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

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

4

______________________________________________ [print or type full address],

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

6

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

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Central District of California in the case of Atzimba Reyes v. Trader Joe’s Company

8

et al., Case No. 2:16-cv-01371-ODW-AJW. I agree to comply with and to be bound

9

by all the terms of this Stipulated Protective Order and I understand and acknowledge

10

that failure to so comply could expose me to sanctions and punishment in the nature

11

of contempt. I solemnly promise that I will not disclose in any manner any

12

information or item that is subject to this Stipulated Protective Order to any person or

13

entity except in strict compliance with the provisions of this Order.

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I further agree to submit to the jurisdiction of the United States District Court

15

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

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Stipulated Protective Order, even if such enforcement proceedings occur after

17

termination of this action. I hereby appoint _______________________ [print or

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type full name] of ______________________________ [print or type full address

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

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with this action or any proceedings related to the enforcement of this Stipulated

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Protective Order.

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23

Date: ______________________________

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City and State where sworn and signed: __________________________

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Printed name: __________________________

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Signature: _____________________________
[PROPOSED] STIP. PROTECTIVE ORDER

16

2:16-cv-01371-ODW-AJW