Adam Trotter v. ExxonMobil Corp. et al

Filing 99

MODIFIED STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIALITY OF DISCOVERY MATERIAL [MODIFICATIONS MADE TO PARAGRAPHS III, VIII, IX] by Magistrate Judge Jacqueline Chooljian. 97 (sbou)

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M. RANDALL OPPENHEIMER (S.B. #77649)
[e-mail]
DAWN SESTITO (S.B. #214011)
[e-mail]
O’MELVENY & MYERS LLP
400 South Hope Street
Los Angeles, California 90071-2899
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
EXXON MOBIL CORPORATION,
EXXONMOBIL OIL CORPORATION,
EXXONMOBIL REFINING AND SUPPLY
COMPANY

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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ADAM TROTTER,

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Plaintiff,
v.
EXXON MOBIL CORP., et al.,
Defendants.

Case No. 2:17-cv-02279-PSG (JCx)
MODIFIED STIPULATED
PROTECTIVE ORDER
REGARDING
CONFIDENTIALITY OF
DISCOVERY MATERIAL
[MODIFICATIONS MADE TO
PARAGRAPHS III, VIII, IX]
[DISCOVERY DOCUMENT:
REFERRED TO MAGISTRATE
JUDGE JACQUELINE
CHOOLJIAN]

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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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WHEREAS, pursuant to Federal Rules of Civil Procedure 26(c) and 29,

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Local Rule 79-5, it is appropriate for the Court to limit the disclosure of certain

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confidential information produced in the course of discovery;
WHEREAS, there is a good cause for entry of this Stipulated Protective

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Order;
NOW THEREFORE Plaintiff Adam Trotter (“Plaintiff”), and Defendants

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Exxon Mobil Corporation, ExxonMobil Oil Corporation, and ExxonMobil Refining

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and Supply Company (“Defendants”) (collectively, the “Parties”), hereby stipulate,

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subject to the Court’s approval, as follows:

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I.

INTRODUCTION

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A.

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

PURPOSES AND LIMITATIONS

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proprietary, or private information for which special protection from public

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disclosure and from use for any purpose other than prosecuting this litigation may

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be warranted. Accordingly, the Parties hereby stipulate to and petition the Court to

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enter the following Protective Order. The Parties acknowledge that this Order does

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

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

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

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legal principles. The Parties further acknowledge, as set forth in Section XII.C,

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infra, that this Order does not entitle them to file confidential information under

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seal; 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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materials under seal.

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B.

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Plaintiff has brought this lawsuit claiming, inter alia, that he suffered

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personal injuries as a result of the operation of the refinery in Torrance, California

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(the “Torrance Refinery”).

GOOD CAUSE STATEMENT

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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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i.

Confidential Designations

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Plaintiff anticipates that discovery in this matter may involve disclosure of

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personally identifiable information protected by the Health Insurance Portability

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and Accountability Act (“HIPAA”) or other similar laws, statutes, and

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regulations that protect privacy, that would cause harm if made part of the public

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record. To protect from the irreparable harm resulting from the disclosure of such

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material, this type of information may be properly designated confidential.

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Defendants anticipate that discovery in this matter may involve disclosure of

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commercially sensitive documents unavailable to the public. Such documents may

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include confidential, proprietary, or private information regarding operations,

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systems, processes, and technology utilized at the Torrance Refinery, as well as

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trade secrets, financial information, proprietary research, and commercial

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information that may implicate the privacy rights or competitive interests of third

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parties. To protect from the irreparable harm resulting from the disclosure of such

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material, these types of commercial records may be properly designated

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confidential.

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ii.

Intent of the Parties

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

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resolution of disputes over confidentiality of discovery materials, to adequately

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protect information the Parties are entitled to keep confidential, to ensure that the

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Parties are permitted reasonable use of such material in preparation for trial, to

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address the handling of such materials at the end of this litigation, and to serve the

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ends of justice, a protective order is justified in this matter. It is the intent of the

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Parties that information will not be designated as confidential for tactical reasons.

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The Parties also intend that no materials will be designated confidential without a

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good faith belief that such material has been maintained in a confidential, non-

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public manner, and that there is good cause why it should not be part of the public

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record of this case.
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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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II.

“Action” means Trotter v. ExxonMobil Corp., No. 2:17-cv-02279-PSG

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DEFINITIONS

(JCx).
“Challenging Party” means a Party or Non-Party that challenges the
designation applied to any Disclosure or Discovery Material under this Order.
“CONFIDENTIAL” is a designation that may be applied to any Disclosure

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or Discovery Material to denote that it is Confidential Information. Information

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designated as “CONFIDENTIAL” may be used and communicated only as

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provided in this Protective Order.

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“Confidential Information” is any Disclosure or Discovery Material that

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qualifies for protection under Federal Rule of Civil Procedure 26(c), and as

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specified above in the Good Cause Statement. Confidential Information must be

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marked with the “CONFIDENTIAL” designation according to the terms of this

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Order.

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“Counsel” means Outside Counsel of Record and In-House Counsel as well
as the support staff of each.

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“Designating Party” means any Party or any Non-Party from whom

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discovery is sought in this action and who invokes the protections of this Order.

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“Disclosure or Discovery Material” means all items or information,

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regardless of the medium or manner in which it is 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 by any Designating Party in disclosures or responses to

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discovery or subpoenas in this matter.

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“Expert” means a person with specialized knowledge or experience in a

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

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serve as an expert witness or as a non-testifying consultant in this Action.

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“In-House Counsel” means an attorney who is an employee of a Party and
whose responsibilities consist of performing legal services for such Party.
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STIPULATED PROTECTIVE ORDER
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“Non-Party” means any natural person, partnership, corporation, association,
or other legal entity not named as a Party to this Action.
“Outside Counsel” means outside counsel of record for each Party who are

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not employees of a Party to this Action but are retained to represent or advise a

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Party to this Action and have appeared in this Action on behalf of that Party or are

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affiliated with a law firm which has appeared on behalf of that Party, including all

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attorneys, staff, and clerical and support personnel.
“Party” means any Party to this Action, including all directors, officers,

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managers, managing entities, consultants, partners, members, or employees (or the
functional equivalent).
“Producing Party” means any Party or Non-Party that produces Disclosure or

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Discovery Material in this Action.

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“Professional Vendors” means persons or entities that provide litigation

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support 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.
“Privilege” or “Privileged” refers to the attorney-client privilege, attorney

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work-product doctrine, or any other claim of privilege to justify withholding

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otherwise discoverable information.
“Protected Material” means any Disclosure or Discovery Material that is

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designated as “CONFIDENTIAL.”
“Receiving Party” means a Party that receives Disclosure or Discovery

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Material from a Producing Party.

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III.

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SCOPE
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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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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presentations by Parties or their Counsel that might reveal Protected Material, other

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than during a court hearing or at trial.

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Any use of Protected Material during a court hearing or at trial shall be

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governed by the orders of the presiding judge. This Order does not govern the use

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of Protected Material during a court hearing or at trial.

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IV.

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DURATION
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

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deemed to be the later of: (1) dismissal of all claims and defenses in this Action

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with prejudice, or (2) final judgment after the completion and exhaustion of all

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appeals, rehearings, remands, trials, or reviews of this Action, including the time

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limits for filing any motions or applications for extension of time pursuant to

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applicable law.

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V.

DESIGNATING PROTECTED MATERIAL

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A.

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

EXERCISE OF RESTRAINT AND CARE

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

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that qualifies under the appropriate standards. The Designating Party must

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

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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 (with the

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exception of third-party designations, as noted below). Designations that are shown

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to be clearly unjustified or that have been made for an improper purpose (e.g., to

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unnecessarily encumber the case development process or to impose unnecessary

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STIPULATED PROTECTIVE ORDER
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expenses and burdens on other Parties) may expose the Designating Party to

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sanctions.

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

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were designated for protection do not qualify for protection, such Designating Party

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must promptly notify all other Parties of the withdrawal of the inapplicable

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designation.

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B.

MANNER AND TIMING

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Except as otherwise provided in this Order, or as otherwise stipulated or

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

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

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Designation in conformity with this Order requires:
i.

For Information in Documentary Form

Information in documentary form such as paper or electronic documents, but

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excluding transcripts of depositions or other pretrial or trial proceedings, the

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Producing Party must affix at a minimum, the legend “CONFIDENTIAL”

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(hereinafter “CONFIDENTIAL legend”) to each page that contains protected

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material. If only a portion or portions of the material on a page qualifies for

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protection, the Producing Party also must clearly identify the protected portion(s)

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

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ii.

For Testimony Given in Depositions

The Designating Party must identify the Disclosure or Discovery Material

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and all protected testimony on the record as Confidential before the close of the

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deposition. Alternatively, counsel for any Party or Non-Party, or the deponent may

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elect to take twenty (20) days to designate the portions of the deponent’s transcript

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that qualify as Confidential by transcript page and line number. Until the expiration

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of this twenty-day period the transcript shall be treated as Confidential. Such

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designation shall be communicated in writing to all Parties.

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STIPULATED PROTECTIVE ORDER
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iii.

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For information produced in some form other than documentary (such as a

Other Information

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DVD containing documents) and for other tangible items, the Producing Party must

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affix in a prominent place on the exterior of the container or containers in which the

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information is stored the legend “CONFIDENTIAL.” If only a portion or portions

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of the information warrants protection, the Producing Party, to the extent

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practicable, shall identify the protected portion(s).

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C.

DESIGNATING NON-PARTY DOCUMENTS

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Notwithstanding Section V.A, in order to avoid undue burdens on Non-

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Parties producing materials in this litigation, a third party’s Disclosures or

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Discovery Materials may be designated as Confidential Information in bulk.

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However, such materials will remain subject to challenge under the procedures

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specified in Section VI, infra.

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Additionally, within thirty (30) days of a Non-Party’s production of any

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Disclosure or Discovery Material, any Party may designate such Disclosure or

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Discovery Material as Confidential if, in the good faith opinion of that Party, the

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Disclosure or Discovery Material contains that Party’s Confidential Information.

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The designation must be in writing, and provided to all Parties as well as to the

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Non-Party that produced the Disclosure or Discovery Material. All Disclosure or

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Discovery Material produced by a Non-Party shall be treated as Confidential

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Information for a period of thirty (30) days following the date of production.

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D.

INADVERTENT FAILURE TO DESIGNATE

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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 make reasonable efforts to assure that the material is treated in

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accordance with the provisions of this Order. If feasible, the Designating Party

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shall promptly provide a copy of any Disclosure or Discovery Material with the
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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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proper designation to counsel for the Receiving Party, upon receipt of which the

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Receiving Party shall promptly return or destroy all copies with the incorrect

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designation.

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VI.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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A.

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Any Party or Non-Party may challenge a designation of confidentiality at any

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TIMING OF CHALLENGES

time that is consistent with the Court’s Scheduling Order.

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B.

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The Challenging Party shall initiate the dispute resolution process (and, if

MEET AND CONFER

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necessary, file a discovery motion seeking to change the confidentiality

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designations) under Local Rule 37-1, et seq. The burden of persuasion in any such

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challenge proceeding shall be on the Designating Party. Frivolous challenges, and

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those made for an improper purpose (e.g., to harass or impose unnecessary

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expenses and burdens on other parties) may expose the Challenging Party to

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sanctions. Unless the Designating Party has waived or withdrawn the

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confidentiality designation, all Parties shall continue to afford the material in

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question the level of protection to which it is entitled under the Designating Party’s

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designation until the Court rules on the challenge.

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VII. ACCESS TO AND USE OF PROTECTED MATERIALS

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A.

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A Receiving Party may use Protected Material that is disclosed or produced

BASIC PRINCIPLES

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by another Party or by a Non-Party in connection with this Action only for

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prosecuting, defending, or attempting to settle this Action. Such Protected Material

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

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

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must comply with the provisions of Section XIII below.

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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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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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B.

DISCLOSURE OF CONFIDENTIAL INFORMATION

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Unless otherwise ordered by the Court or permitted in writing by the

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Designating Party, a Receiving Party may disclose any Confidential Information

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only to:

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(1) the Receiving Party’s Outside Counsel in this Action, as well as

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employees of said Outside Counsel to whom it is reasonably necessary to

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disclose the information for this Action;

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

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the Receiving Party to whom disclosure is reasonably necessary for this

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Action;

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(3) Experts of the Receiving Party to whom disclosure is reasonably

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necessary for this Action and who have signed Exhibit A;

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(4) the Court and its personnel;

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(5) court reporters and their staff;

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(6) professional jury or trial consultants, mock jurors, and Professional

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Vendors to whom disclosure is reasonably necessary for this Action and who

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have signed Exhibit A;

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(7) the author or recipient of a document containing the information or a

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custodian or other person who otherwise possessed or knew the information;

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(8) during their depositions, witnesses, and attorneys for witnesses, in the

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Action to whom disclosure is reasonably necessary provided:

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(a) they have signed Exhibit A; and

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(b) they will not be permitted to keep any confidential information,

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unless otherwise agreed by the Designating Party or ordered by the

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Court. Pages of transcribed deposition testimony or exhibits to
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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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depositions that reveal Protected Material may be separately bound by

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the court reporter and may not be disclosed to anyone except as

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permitted under this Stipulated Protective Order;

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(9) any mediator or settlement officer, and their supporting personnel,

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mutually agreed upon by any of the Parties engaged in settlement

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discussions.

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C.

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If any Party or Counsel desires to disclose Protected Material to any person

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REQUESTS FOR ADDITIONAL DISCLOSURE

other than those otherwise permitted access to such information under the terms of

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this Protective Order, such Party or Counsel must obtain written consent of the

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Designating Party or the Court authorizing such disclosure. Except as expressly

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agreed in writing by the Designating Party or ordered by the Court, each person to

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whom the Protected Material is to be disclosed under this provision must execute

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Exhibit A.

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D.

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A Designating Party’s designation of information as Protected Material shall

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NO EFFECT ON PARTY’S OWN USE

not affect that Party’s own right to use any information so designated.

18 VIII. 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 Protected Materials in this Action, that Party must:

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(1) promptly notify in writing the Designating Party and provide a copy of

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the subpoena or court order unless prohibited by law;

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(2) 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

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subpoena or order is subject to this Protective Order and provide a copy of

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this Order; and

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STIPULATED PROTECTIVE ORDER
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(3) cooperate with respect to all reasonable procedures sought to be pursued

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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 Protected Material before a

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

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Party has obtained the Designating Party’s permission or unless otherwise required

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by the law or court order. The Designating Party shall bear the burden and expense

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of seeking protection in that court of that Party’s confidential material and nothing

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in these provisions should be construed as authorizing or encouraging a Receiving

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

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IX.

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NON-PARTY’S PROTECTED MATERIAL
The terms of this Order are applicable to Protected Materials produced by a

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Non-Party in this Action. Such information produced by Non-Parties in connection

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with this litigation is protected by the remedies and relief provided by this Order.

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Nothing in these provisions should be construed as prohibiting a Non-Party from

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seeking additional protections.

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

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a Non-Party’s confidential information in the Party’s 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:

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(1) promptly notify in writing the Requesting Party and the Non-Party that

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

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agreement with a Non-Party;

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(2) promptly provide the Non-Party with a copy of this Order, the relevant

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

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requested; and

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(3) make the information requested available for inspection by the Non-

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Party, if requested.
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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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If a Non-Party represented by counsel fails to commence the process called

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for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving the notice and

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accompanying information or fails contemporaneously to notify the Receiving

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Party that it has done so, the Receiving Party may produce the Non-Party’s

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confidential information responsive to the discovery request. If an unrepresented

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Non-Party fails to seek a protective order from this Court within fourteen (14) days

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of receiving the notice and accompanying information, the Receiving Party may

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

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request. If the Non-Party timely seeks a protective order, the Receiving Party shall

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not produce any information that is subject to the confidentiality agreement with the

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Non-Party before a determination by the Court unless otherwise required by the law

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or court order. 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 the Non-Party’s Protected

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Material.

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X.

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UNAUTHORIZED DISCLOSURE
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:

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(1) notify in writing the Designating Party of the unauthorized disclosures;

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(2) use best efforts to retrieve all unauthorized copies of the Protected

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Material;

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(3) inform the person or persons to whom unauthorized disclosures were

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made of all the terms of this Order; and

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(4) request such person or persons to execute Exhibit A.

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XI.

INADVERTENT PRODUCTION
In the event that any Disclosure or Discovery Material containing or

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constituting privileged attorney-client communications or protected by the attorney

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work product or other applicable doctrine is inadvertently produced, the producing
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STIPULATED PROTECTIVE ORDER
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Party and/or Non-Party shall notify the Receiving Party promptly after it is

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discovered that such material was inadvertently produced for inspection or

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provided. Upon receipt of such notification the Receiving Party shall promptly

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return to counsel for the disclosing Party any and all copies of such Disclosure or

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Discovery Material and thereafter refrain from any use whatsoever, in this case or

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otherwise. Nothing herein shall prevent the Receiving Party from contending that

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any such Disclosure or Discovery Material was not inadvertently produced or that

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privilege was waived for reasons other than the mere inadvertent production

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thereof.

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XII. MISCELLANEOUS

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A.

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Nothing in this Order abridges the right of any person to seek its

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RIGHT TO FURTHER RELIEF

modification by the Court in the future.

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B.

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By stipulating to the entry of this Order, no Party waives any right to object

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to disclosing or producing any information or item on any ground not addressed in

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this Order. Similarly, no Party waives any right to object on any ground to use in

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evidence any of the material covered by this Order.

RIGHT TO ASSERT OTHER OBJECTIONS

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C.

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A Party that seeks to file under seal any Protected Material must comply with

FILING PROTECTED MATERIAL

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Local Rule 79-5. Protected Material may only be filed under seal pursuant to a

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court order authorizing the sealing of the specific Protected Material at issue. If a

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Party’s request to file Protected Material under seal is denied by the Court, then the

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Receiving Party may file the information in the public record unless otherwise

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instructed by the Court.

26 XIII. FINAL DISPOSITION
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Within sixty (60) days after the termination of this litigation (as defined in
Section IV, supra) and the expiration of the time for appeal, each Receiving Party
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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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must return all Protected Material to the Producing Party or destroy such material.

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As used in this subdivision, “all Protected Material” includes all copies, abstracts,

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compilations, summaries, and any other format reproducing or capturing any of the

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Protected Material. Whether the Protected Material is returned or destroyed, the

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Receiving Party must submit a written certification to the Producing Party (and, if

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not the same person or entity, to the Designating Party) by the sixty-day deadline

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that confirms compliance with the terms of this Section. Notwithstanding this

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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 IV.

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XIV. PENALTIES

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Any willful violation of this Order may be punished by contempt

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proceedings, financial or evidentiary sanctions, reference to disciplinary authorities,

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or other appropriate action at the discretion of the Court.

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IT IS SO STIPULATED.

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Dated: May 21, 2018

M. RANDALL OPPENHEIMER
DAWN SESTITO
O’MELVENY & MYERS LLP

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By: /s/ Dawn Sestito
Dawn Sestito
Attorneys for Defendant
EXXON MOBIL CORPORATION,
EXXONMOBIL OIL CORPORATION,
EXXONMOBIL REFINING AND
SUPPLY COMPANY

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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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Dated: May 21, 2018

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By: /s/ Adam Trotter
Adam Trotter

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Plaintiff, Pro Se

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ADAM TROTTER

ATTESTATION
I hereby attest that the other signatories listed, on whose behalf this filing is
submitted, concur in the filing’s content and have authorized the filing.

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Dated: May 21, 2018

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DAWN SESTITO
O’MELVENY & MYERS LLP
By: /s/ Dawn Sestito
Dawn Sestito

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED AS MODIFIED.

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Dated: May 23, 2018

_____________/s/_____________________
Honorable Jacqueline Chooljian
United States Magistrate Judge

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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)

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EXHIBIT A

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ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND

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I, ____________________________, declare under penalty of perjury under

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the laws of the United States and California that I have read in its entirety and

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understand the Stipulated Protective Order Regarding the Confidentiality Discovery

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Material (the “Order”) that was issued by the United States District Court for the

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Central District of California in the matter Trotter v. Exxon Mobil Corp., No. 2:17-

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cv-02279-PSG (JCx).

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I agree to comply with and to be bound by all the terms of the Order and I

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

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

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disclose in any manner any information or item that is subject to the Order to any

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person or entity except in strict compliance with the provisions of the Order. I

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

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Central District of California for the purpose of enforcing the terms of the Order,

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even if such enforcement proceedings occur after termination of this action. I

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hereby appoint ____________________ [print full name] of __________________

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_________________________________ [print full address and telephone number]

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as my California agent for service of process in connection with this action or any

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proceedings related to enforcement of the Order.

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Dated: ___________________

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City and State where sworn and signed: ___________________

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Printed name: ______________________________

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Signature: _________________________________
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STIPULATED PROTECTIVE ORDER
CASE NO. 2:17-CV-02279-PSG (JCx)