Golnaz Kamali v. Walgreen Co.

Filing 14

STIPULATED PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg re Stipulation for Protective Order 13 . ***** SEE ORDER FOR DETAILS. ***** (mp)

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1 BRYAN CAVE LLP 2 3 4 5 6 Leslie H. Helmer (SBN 150296) Nicole N. King (SBN 290204) 120 Broadway, Suite 300 Santa Monica, CA 90401 Telephone: (310) 576-2100 Facsimile: (310) 576-2200 Email: lhhelmer@bryancave.com nicole.king@bryancave.com 7 Attorneys for Defendant 8 WALGREEN CO., a Corporation 9 Santa Monica, CA 90301 Bryan Cave LLP UNITED STATES DISTRICT COURT 11 120 Broadway, Suite 300 10 CENTRAL DISTRICT OF CALIFORNIA 12 13 GOLNAZ KAMALI, 14 Case No. 2:16-cv-08662-PA-AGR Plaintiff, 15 (Los Angeles County Superior Court Case No. BC633041) vs. 16 WALGREEN CO., a Corporation and 17 DOES 1-10, INCLUSIVE, 18 STIPULATED PROTECTIVE ORDER Defendants. 19 20 21 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 A. 1 PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 2 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 in Santa Monica, CA 90301 Bryan Cave LLP 120 Broadway, Suite 300 11 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. B. 15 GOOD CAUSE STATEMENT This action may involve the production of confidential information, including 16 17 complaints customers have made regarding their experience at Walgreens’ 18 pharmacies (“Walgreens”) for which special protection from public disclosure and 19 from use for any purpose other than litigation of this action is warranted because the 20 information implicates privacy rights of third parties.1 In addition, this action may 21 involve the production of employee personnel information for which special 22 protection from public disclosure and from use for any purpose other than litigation of 23 this action is warranted because the information implicates privacy rights of third 24 1 Note: This Protective Order does not contemplate the production of customer information, including customer names and contact information. Therefore, such 26 issues are not included in this Protective Order and the parties have agreed to further 27 meet and confer regarding such issues, possibly with the help of a Magistrate Judge, in the future. 25 28 1 PROOF OF SERVICE SM01DOCS\1178934 1 parties. Further, this action may involve production of private medical information 2 concerning Plaintiff, including information related to emotional distress. The action 3 may also involve other confidential and/or proprietary business information, including 4 the production of internal policies of Walgreens and Walgreens’ store procedures that 5 are otherwise generally unavailable to the public, or which may be privileged or 6 otherwise protected from disclosure under state or federal statutes, court rules, case 7 decisions, or common law. Accordingly, to expedite the flow of information, to 8 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 9 to adequately protect information the parties are entitled to keep confidential, to 10 ensure that the parties are permitted reasonable necessary uses of such material in 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 preparation for and in the conduct of trial, to address their handling at the end of the 12 litigation, and serve the ends of justice, a protective order for such information is 13 justified in this matter. It is the intent of the parties that information will not be 14 designated as confidential for tactical reasons and that nothing be so designated 15 without a good faith belief that it has been maintained in a confidential, non-public 16 manner, and there is good cause why it should not be part of the public record of this 17 case. 18 1. DEFINITIONS 19 1.1 Action: This pending federal law suit. 20 1.2 Challenging Party: a Party or Non-Party that challenges the designation 21 of information or items under this Order. 22 1.3 “CONFIDENTIAL” Information or Items: information (regardless of 23 how it is generated, stored or maintained) or tangible things that qualify for 24 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 25 the Good Cause Statement. 26 1.4 Counsel: Outside Counsel of Record and In-House Counsel (as well as 27 their support staff). 28 1.5 Designating Party: a Party or Non-Party that designates information or 2 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 items that it produces in disclosures or in responses to discovery as 2 “CONFIDENTIAL.” 3 1.6 Disclosure or Discovery Material: all items or information, regardless 4 of the medium or manner in which it is generated, stored, or maintained (including, 5 among other things, testimony, transcripts, and tangible things), that are produced or 6 generated in disclosures or responses to discovery in this matter. 7 1.7 Expert: a person with specialized knowledge or experience in a matter 8 pertinent to the litigation who has been retained by a Party or its counsel to serve as 9 an expert witness or as a consultant in this Action. 10 1.8 In-House Counsel: Attorneys who are employees of a Party to this 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 Action. In-House Counsel does not include Outside Counsel of Record or any other 12 outside counsel. 13 1.9 Non-Party: any natural person, partnership, corporation, association, or 14 other legal entity not named as a Party to this action. 15 1.10 Outside Counsel of Record: Attorneys who are not employees of a 16 Party to this Action but are retained to represent or advise a Party to this Action and 17 have appeared in this Action on behalf of that Party or are affiliated with a law firm 18 which has appeared on behalf of that Party, and includes support staff. 19 1.11 Party: any Party to this Action, including all of its officers, directors, 20 employees, consultants, retained experts, and Outside Counsel of Record (and their 21 support staffs). 22 1.12 Producing Party: a Party or Non-Party that produces Disclosure or 23 Discovery Material in this Action. 24 1.13 Professional Vendors: persons or entities that provide litigation support 25 services (e.g., photocopying, videotaping, translating, preparing exhibits or 26 demonstrations, and organizing, storing, or retrieving data in any form or medium) 27 and their employees and subcontractors. 28 1.14 Protected Material: any Disclosure or Discovery Material that is 3 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 designated as “CONFIDENTIAL.” 1.15 Receiving Party: a Party that receives Disclosure or Discovery Material 2 3 from a Producing Party. 4 2. SCOPE 5 The protections conferred by this Stipulation and Order cover not only 6 Protected Material (as defined above), but also (1) any information copied or 7 extracted from Protected Material; (2) all copies, excerpts, summaries, or 8 compilations of Protected Material; and (3) any testimony, conversations, or 9 presentations by Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the 10 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 trial judge. This Order does not govern the use of Protected Material at trial. 12 3. DURATION 13 Even after final disposition of this litigation, the confidentiality obligations 14 imposed by this Order shall remain in effect until a Designating Party agrees 15 otherwise in writing or a court order otherwise directs. Final disposition shall be 16 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 17 or without prejudice; and (2) final judgment herein after the completion and 18 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 19 including the time limits for filing any motions or applications for extension of time 20 pursuant to applicable law. 21 4. DESIGNATING PROTECTED MATERIAL 22 4.1 23 Each Party or Non-Party that designates information or items for protection Exercise of Restraint and Care in Designating Material for Protection. 24 under this Order must take care to limit any such designation to specific material 25 that qualifies under the appropriate standards. The Designating Party must designate 26 for protection only those parts of material, documents, items, or oral or written 27 communications that qualify so that other portions of the material, documents, 28 items, or communications for which protection is not warranted are not swept 4 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 unjustifiably within the ambit of this Order. 2 Mass, indiscriminate, or routinized designations are prohibited. Designations 3 that are shown to be clearly unjustified or that have been made for an improper 4 purpose (e.g., to unnecessarily encumber the case development process or to impose 5 unnecessary expenses and burdens on other parties) may expose the Designating 6 Party to sanctions. 7 If it comes to a Designating Party’s attention that information or items that it 8 designated for protection do not qualify for protection, that Designating Party must 9 promptly notify all other Parties that it is withdrawing the inapplicable designation. 10 4.2 Manner and Timing of Designations. Except as otherwise provided in 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 12 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 13 under this Order must be clearly so designated before the material is disclosed or 14 produced. 15 Designation in conformity with this Order requires: (a) 16 for information in documentary form (e.g., paper or electronic 17 documents, but excluding transcripts of depositions or other pretrial or trial 18 proceedings), that the Producing Party affix at a minimum, the legend 19 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 20 contains protected material. If only a portion or portions of the material on a page 21 qualifies for protection, the Producing Party also must clearly identify the protected 22 portion(s) (e.g., by making appropriate markings in the margins). 23 A Party or Non-Party that makes original documents available for inspection 24 need not designate them for protection until after the inspecting Party has indicated 25 which documents it would like copied and produced. During the inspection and 26 before the designation, all of the material made available for inspection shall be 27 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 28 documents it wants copied and produced, the Producing Party must determine which 5 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 documents, or portions thereof, qualify for protection under this Order. Then, before 2 producing the specified documents, the Producing Party must affix the 3 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 4 portion or portions of the material on a page qualifies for protection, the Producing 5 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 6 markings in the margins). (b) 7 for testimony given in depositions that the Designating Party 8 identify the Disclosure or Discovery Material on the record, before the close of the 9 deposition all protected testimony. (c) 10 for information produced in some form other than documentary 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 and for any other tangible items, that the Producing Party affix in a prominent place 12 on the exterior of the container or containers in which the information is stored the 13 legend “CONFIDENTIAL.” If only a portion or portions of the information 14 warrants protection, the Producing Party, to the extent practicable, shall identify the 15 protected portion(s). 4.3 16 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive 18 the Designating Party’s right to secure protection under this Order for such material. 19 Upon timely correction of a designation, the Receiving Party must make reasonable 20 efforts to assure that the material is treated in accordance with the provisions of this 21 Order. 22 5. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 5.1 Timing of Challenges. Any Party or Non-Party may challenge a 24 designation of confidentiality at any time that is consistent with the Court’s 25 Scheduling Order. 26 5.2 Meet and Confer. The Challenging Party shall initiate the 27 dispute resolution process under Local Rule 37.1 et seq. 28 5.3 The burden of persuasion in any such challenge proceeding shall be on 6 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 the Designating Party. Frivolous challenges, and those made for an improper 2 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 3 parties) may expose the Challenging Party to sanctions. Unless the Designating 4 Party has waived or withdrawn the confidentiality designation, all parties shall 5 continue to afford the material in question the level of protection to which it is 6 entitled under the Producing Party’s designation until the Court rules on the 7 challenge. 8 6. ACCESS TO AND USE OF PROTECTED MATERIAL 9 6.1 Basic Principles. A Receiving Party may use Protected Material that is 10 disclosed or produced by another Party or by a Non-Party in connection with this 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 Action only for prosecuting, defending, or attempting to settle this Action. Such 12 Protected Material may be disclosed only to the categories of persons and under the 13 conditions described in this Order. When the Action has been terminated, a 14 Receiving Party must comply with the provisions of section 13 below (FINAL 15 DISPOSITION). 16 Protected Material must be stored and maintained by a Receiving Party at a 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Order. 19 6.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 otherwise ordered by the court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only to: (a) 23 the Receiving Party’s Outside Counsel of Record in this Action, 24 as well as employees of said Outside Counsel of Record to whom it is reasonably 25 necessary to disclose the information for this Action; (b) 26 the officers, directors, and employees (including House Counsel) 27 of the Receiving Party to whom disclosure is reasonably necessary for this Action; (c) 28 Experts (as defined in this Order) of the Receiving Party to 7 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 whom disclosure is reasonably necessary for this Action and who have signed the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (d) the court and its personnel; 4 (e) court reporters and their staff; 5 (f) professional jury or trial consultants, mock jurors, and 6 Professional Vendors to whom disclosure is reasonably necessary for this Action 7 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 8 A); (g) 9 the author or recipient of a document containing the information 10 or a custodian or other person who otherwise possessed or knew the information; (h) 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 during their depositions, witnesses, and attorneys for witnesses, 12 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 13 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 14 they will not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 16 agreed by the Designating Party or ordered by the court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may 18 be separately bound by the court reporter and may not be disclosed to anyone except 19 as permitted under this Stipulated Protective Order; and (i) 20 any mediator or settlement officer, and their supporting 21 personnel, mutually agreed upon by any of the parties engaged in settlement 22 discussions. 23 7. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 24 IN OTHER LITIGATION 25 If a Party is served with a subpoena or a court order issued in other litigation 26 that compels disclosure of any information or items designated in this Action as 27 “CONFIDENTIAL,” that Party must: (a) 28 promptly notify in writing the Designating Party. Such 8 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 notification shall include a copy of the subpoena or court order; (b) 2 promptly notify in writing the party who caused the subpoena or 3 order to issue in the other litigation that some or all of the material covered by the 4 subpoena or order is subject to this Protective Order. Such notification shall include 5 a copy of this Stipulated Protective Order; and (c) 6 cooperate with respect to all reasonable procedures sought to be 7 pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with 8 9 the subpoena or court order shall not produce any information designated in this 10 action as “CONFIDENTIAL” before a determination by the court from which the 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 subpoena or order issued, unless the Party has obtained the Designating Party’s 12 permission. The Designating Party shall bear the burden and expense of seeking 13 protection in that court of its confidential material and nothing in these provisions 14 should be construed as authorizing or encouraging a Receiving Party in this Action 15 to disobey a lawful directive from another court. 16 8. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 17 PRODUCED IN THIS LITIGATION (a) 18 The terms of this Order are applicable to information produced 19 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 20 information produced by Non-Parties in connection with this litigation is protected 21 by the remedies and relief provided by this Order. Nothing in these provisions 22 should be construed as prohibiting a Non-Party from seeking additional protections. (b) 23 In the event that a Party is required, by a valid discovery request, 24 to produce a Non-Party’s confidential information in its possession, and the Party is 25 subject to an agreement with the Non-Party not to produce the Non-Party’s 26 confidential information, then the Party shall: (1) 27 promptly notify in writing the Requesting Party and the 28 Non-Party that some or all of the information requested is subject to a 9 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 confidentiality agreement with a Non-Party; (2) 2 promptly provide the Non-Party with a copy of the 3 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 4 reasonably specific description of the information requested; and (3) 5 make the information requested available for inspection by 6 the Non-Party, if requested. (c) 7 If the Non-Party fails to seek a protective order from this court 8 within 14 days of receiving the notice and accompanying information, the Receiving 9 Party may produce the Non-Party’s confidential information responsive to the 10 discovery request. If the Non-Party timely seeks a protective order, the Receiving 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 Party shall not produce any information in its possession or control that is subject to 12 the confidentiality agreement with the Non-Party before a determination by the 13 court. Absent a court order to the contrary, the Non-Party shall bear the burden and 14 expense of seeking protection in this court of its Protected Material. 15 9. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 19 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 20 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 21 persons to whom unauthorized disclosures were made of all the terms of this Order, 22 and (d) request such person or persons to execute the “Acknowledgment and 23 Agreement to Be Bound” that is attached hereto as Exhibit A. 24 10. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 25 PROTECTED MATERIAL 26 When a Producing Party gives notice to Receiving Parties that certain 27 inadvertently produced material is subject to a claim of privilege or other protection, 28 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 10 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 2 may be established in an e-discovery order that provides for production without 3 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 4 as the parties reach an agreement on the effect of disclosure of a communication or 5 information covered by the attorney-client privilege or work product protection, the 6 parties may incorporate their agreement in the stipulated protective order submitted 7 to the court. 8 11. MISCELLANEOUS 9 11.1 Right to Further Relief. Nothing in this Order abridges the right of any 10 person to seek its modification by the Court in the future. 11.2 Right to Assert Other Objections. By stipulating to the entry of this 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 12 Protective Order no Party waives any right it otherwise would have to object to 13 disclosing or producing any information or item on any ground not addressed in this 14 Stipulated Protective Order. Similarly, no Party waives any right to object on any 15 ground to use in evidence of any of the material covered by this Protective Order. 11.3 Filing Protected Material. A Party that seeks to file under seal any 16 17 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 18 only be filed under seal pursuant to a court order authorizing the sealing of the 19 specific Protected Material at issue. If a Party’s request to file Protected Material 20 under seal is denied by the court, then the Receiving Party may file the information 21 in the public record unless otherwise instructed by the court. 22 12. FINAL DISPOSITION 23 After the final disposition of this Action, as defined in paragraph 4, within 60 24 days of a written request by the Designating Party, each Receiving Party must return 25 all Protected Material to the Producing Party or destroy such material. As used in 26 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 27 summaries, and any other format reproducing or capturing any of the Protected 28 Material. Whether the Protected Material is returned or destroyed, the Receiving 11 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 Party must submit a written certification to the Producing Party (and, if not the same 2 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 3 (by category, where appropriate) all the Protected Material that was returned or 4 destroyed and (2) affirms that the Receiving Party has not retained any copies, 5 abstracts, compilations, summaries or any other format reproducing or capturing any 6 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 7 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 8 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 9 reports, attorney work product, and consultant and expert work product, even if such 10 materials contain Protected Material. Any such archival copies that contain or 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 constitute Protected Material remain subject to this Protective Order as set forth in 12 Section 3 (DURATION). 13 /// 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 22 23 24 25 26 27 28 12 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 13. Any violation of this Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 DATED: February 15, 2017 7 /s/ Tyler F. Clark Tyler F. Clark, Esq. 9 Yi-Hsuan Rachel Lin, Esq. Attorneys for Plaintiff GOLNAZ KAMALI 10 tyler@clarkemploymentlaw.com Rachel@clarkemploymentlaw.com 8 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 12 DATED: February 15, 2017 13 /s/ Nicole N. King Leslie H. Helmer 15 Nicole N. King Attorneys for Defendant WALGREEN CO. 16 lhhelmer@bryancave.com nicole.king@bryancave.com 14 17 18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 20 DATED: February 23, 2017 21 22 __________________________________ 23 Alicia G. Rosenberg 24 United States Magistrate Judge 25 26 27 28 13 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ________________ [print or type full name], of ________________ [print 4 or type full address], declare under penalty of perjury that I have read in its entirety 5 and understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on [date] in the case of Golnaz 7 Kamali vs. Walgreen Co., et al., Case No. 2:16-cv-08662-BRO-AGRx. I agree to 8 comply with and to be bound by all the terms of this Stipulated Protective Order and 9 I understand and acknowledge that failure to so comply could expose me to sanctions 10 and punishment in the nature of contempt. I solemnly promise that I will not disclose 120 Broadway, Suite 300 Santa Monica, CA 90301 Bryan Cave LLP 11 in any manner any information or item that is subject to this Stipulated Protective 12 Order to any person or entity except in strict compliance with the provisions of this 13 Order. I further agree to submit to the jurisdiction of the United States District 14 Court for the Central District of California for the purpose of enforcing the 15 terms of this Stipulated Protective Order, even if such enforcement proceedings 16 occur after termination of this action. I hereby appoint _______________ [print 17 or type full name] of ____________________ [print or type full address and 18 telephone number] as my California agent for service of process in connection with 19 this action or any proceedings related to enforcement of this Stipulated Protective 20 Order. 21 Date:________________________________ 22 City and State where sworn and signed:___________________________ 23 Printed Name:_________________________ 24 Signature:___________________________ 25 26 27 28 14 STIPULATED PROTECTIVE ORDER SM01DOCS\1178934

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