Fabric Selection, Inc. v. Ms. Bubbles, Inc. et al

Filing 33

PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal, re: Stipulation for Protective Order, 32 . (mz)

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1 MICHAEL C. BAUM (SBN 65158) E-Mail: mbaum@rpblaw.com 2 ANDREW V. JABLON (SBN 199083) E-Mail: ajablon@rpblaw.com 3 STACEY N. KNOX (SBN 192966) E-Mail: sknox@rpblaw.com 4 RESCH POLSTER & BERGER LLP 1840 Century Park East, 17th Floor 5 Los Angeles, California 90067 Telephone: 310-277-8300 6 Facsimile: 310-552-3209 7 Attorneys for Plaintiff Fabric Selection, Inc. 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 10 11 FABRIC SELECTION, INC., a 12 California corporation, Plaintiff, 13 vs. 14 15 MS. BUBBLES, INC., a California corporation; ROSS STORES, INC., a 16 Delaware corporation; BEALL’S, INC., a Florida Corporation; BURLINGTON 17 STORES, INC., a Delaware corporation; and DOES 1 through 10, Inclusive, 18 Defendant. 19 Case No. 2:17-cv-02622-MWF-SS [PROPOSED] STIPULATED PROTECTIVE ORDER Trial Date: April 24, 2018 Magistrate Judge: Hon. Suzanne H. Segal 20 21 I. PURPOSES AND LIMITATIONS 22 Discovery in this action is likely to involve production of confidential, 23 proprietary, or private information for which special protection from public disclosure 24 and from use for any purpose other than prosecuting this litigation may be warranted. 25 Accordingly, the parties hereby stipulate to and petition the Court to enter the 26 following Stipulated Protective Order. The parties acknowledge that this Order does 27 not confer blanket protections on all disclosures or responses to discovery and that the 28 protection it affords from public disclosure and use extends only to the limited 570844.1 1 information or items that are entitled to confidential treatment under the applicable 2 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 3 that this Stipulated Protective Order does not entitle them to file confidential 4 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 5 followed and the standards that will be applied when a party seeks permission from the 6 court to file material under seal. 7 II. GOOD CAUSE STATEMENT 8 This action is likely to involve trade secrets, customer and pricing lists and other 9 valuable research, development, commercial, financial, technical and/or proprietary 10 information for which special protection from public disclosure and from use for any 11 purpose other than prosecution of this action is warranted. Such confidential and 12 proprietary materials and information consist of, among other things, confidential 13 business or financial information, information regarding confidential business 14 practices, or other confidential research, development, or commercial information, 15 information otherwise generally unavailable to the public, or which may be privileged 16 or otherwise protected from disclosure under state or federal statutes, court rules, case 17 decisions, or common law. Accordingly, to expedite the flow of information, to 18 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 19 to adequately protect information the parties are entitled to keep confidential, to ensure 20 that the parties are permitted reasonable necessary uses of such material in preparation 21 for and in the conduct of trial, to address their handling at the end of the litigation, and 22 serve the ends of justice, a protective order for such information is justified in this 23 matter. It is the intent of the parties that information will not be designated as 24 confidential for tactical reasons and that nothing be so designated without a good faith 25 belief that it has been maintained in a confidential, non-public manner, and there is 26 good cause why it should not be part of the public record of this case. 27 28 570844.1 1 III. DEFINITIONS 2 1. Action: Fabric Selection, Inc. v. Ms. Bubbles, Inc., et al. Case No. 3 2:17-cv-02622-MWF-SS. 4 2. Challenging Party: a Party or Non-Party that challenges the designation 5 of information or items under this Order. 6 3. “CONFIDENTIAL” Information or Items: information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for protection 8 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 9 Statement. 10 4. Counsel: Outside Counsel of Record and House Counsel (as well as their 11 support staff). 12 5. Designating Party: a Party or Non-Party that designates information or 13 items that it produces in disclosures or in responses to discovery as 14 “CONFIDENTIAL.” 15 6. Disclosure or Discovery Material: all items or information, regardless of 16 the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced or 18 generated in disclosures or responses to discovery in this matter. 19 7. Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 21 expert witness or as a consultant in this Action. 22 8. “HIGHLY CONFIDENTIAL” or “ATTORNEY EYES ONLY” 23 Information or Items: information (regardless of how it is generated, stored or 24 maintained) or tangible things that qualify for protection under Federal Rule of Civil 25 Procedure 26(c), and as specified above in the Good Cause Statement which are 26 particularly sensitive, for which the disclosure to another party in this action is likely 27 to significantly harm the disclosing party’s competitive position, or the disclosure of 28 which would contravene an obligation of confidentiality to a third person or to a Court. 570844.1 1 9. House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 10. Non-Party: any natural person, partnership, corporation, association, or 5 other legal entity not named as a Party to this action. 6 11. Outside Counsel of Record: attorneys who are not employees of a party 7 to this Action but are retained to represent or advise a party to this Action and have 8 appeared in this Action on behalf of that party or are affiliated with a law firm that has 9 appeared on behalf of that party, including support staff. 10 12. Party: any party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 13. Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 14. Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 18 their employees and subcontractors. 19 15. Protected Material: any Disclosure or Discovery Material that is 20 designated as “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY 21 EYES ONLY.” 22 16. Receiving Party: a Party that receives Disclosure or Discovery Material 23 from a Producing Party. 24 IV. SCOPE 25 The protections conferred by this Stipulation and Order cover not only 26 Protected Material (as defined above), but also (1) any information copied or extracted 27 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 28 570844.1 1 Protected Material; and (3) any testimony, conversations, or presentations by Parties 2 or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the trial 4 judge. This Order does not govern the use of Protected Material at trial. 5 V. DURATION 6 Once a case proceeds to trial, all of the court-filed information to be introduced 7 that was previously designated as confidential or maintained pursuant to this 8 protective order becomes public and will be presumptively available to all members of 9 the public, including the press, unless compelling reasons supported by specific factual 10 findings to proceed otherwise are made to the trial judge in advance of the trial. See 11 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) 12 (distinguishing “good cause” showing for sealing documents produced in discovery 13 from “compelling reasons” standard when merits-related documents are part of court 14 record). Accordingly, the terms of this protective order do not extend beyond the 15 commencement of the trial. 16 VI. DESIGNATING PROTECTED MATERIAL 17 A. 18 Exercise of Restraint and Care in Designating Material for Protection. 19 Each Party or Non-Party that designates information or items for protection 20 under this Order must take care to limit any such designation to specific material that 21 qualifies under the appropriate standards. The Designating Party must designate for 22 protection only those parts of material, documents, items, or oral or written 23 communications that qualify so that other portions of the material, documents, items, 24 or communications for which protection is not warranted are not swept unjustifiably 25 within the ambit of this Order. 26 Mass, indiscriminate, or routinized designations are prohibited. Designations 27 that are shown to be clearly unjustified or that have been made for an improper purpose 28 (e.g., to unnecessarily encumber the case development process or to impose 570844.1 1 unnecessary expenses and burdens on other parties) may expose the Designating Party 2 to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 designated for protection do not qualify for protection, that Designating Party must 5 promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 B. 7 Except as otherwise provided in this Order (see, e.g., second paragraph of Manner and Timing of Designations. 8 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery 9 Material that qualifies for protection under this Order must be clearly so designated 10 before the material is disclosed or produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial 14 proceedings), that the Producing Party affix, at a minimum, the legend 15 “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES 16 ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains protected 17 material. If only a portion or portions of the material on a page qualifies for protection, 18 the Producing Party may identify the protected portion(s) (e.g., by making appropriate 19 markings in the margins). 20 A Party or Non-Party that makes original documents available for inspection 21 need not designate them for protection until after the inspecting Party has indicated 22 which documents it would like copied and produced. During the inspection and before 23 the designation, all of the material made available for inspection shall be deemed 24 “HIGHLY CONFIDENTIAL.” After the inspecting Party has identified the 25 documents it wants copied and produced, the Producing Party must determine which 26 documents, or portions thereof, qualify for protection under this Order. Then, before 27 producing the specified documents, the Producing Party must affix the 28 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 570844.1 1 portion or portions of the material on a page qualifies for protection, the Producing 2 Party may clearly identify the protected portion(s) (e.g., by making appropriate 3 markings in the margins). 4 (b) for testimony given in depositions that the Designating Party identify the 5 Disclosure or Discovery Material on the record, before the close of the deposition. 6 (c) for information produced in some form other than documentary and for 7 any other tangible items, that the Producing Party affix in a prominent place on the 8 exterior of the container or containers in which the information is stored the legend 9 “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES 10 ONLY.” If only a portion or portions of the information warrants protection, the 11 Producing Party, to the extent practicable, shall identify the protected portion(s). 12 C. 13 If timely corrected, an inadvertent failure to designate qualified information or Inadvertent Failures to Designate. 14 items does not, standing alone, waive the Designating Party’s right to secure 15 protection under this Order for such material. Upon timely correction of a designation, 16 the Receiving Party must make reasonable efforts to assure that the material is treated 17 in accordance with the provisions of this Order. 18 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 19 A. 20 Any Party or Non-Party may challenge a designation of confidentiality at any Timing of Challenges. 21 time that is consistent with the Court’s Scheduling Order. 22 B. 23 The Challenging Party shall initiate the dispute resolution process under Local Meet and Confer. 24 Rule 37.1, et seq. Any discovery motion must strictly comply with the procedures set 25 forth in Local Rules 37-1, 37-2, and 37-3. 26 C. 27 The burden of persuasion in any such challenge proceeding shall be on the Burden. 28 Designating Party. Frivolous challenges, and those made for an improper purpose 570844.1 1 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 2 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 3 withdrawn the confidentiality designation, all parties shall continue to afford the 4 material in question the level of protection to which it is entitled under the Producing 5 Party’s designation until the Court rules on the challenge. 6 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL 7 A. 8 A Receiving Party may use Protected Material that is disclosed or produced by Basic Principles. 9 another Party or by a Non-Party in connection with this Action only for prosecuting, 10 defending, or attempting to settle this Action. Such Protected Material may be 11 disclosed only to the categories of persons and under the conditions described in this 12 Order. When the Action has been terminated, a Receiving Party must comply with the 13 provisions of section 13 below (FINAL DISPOSITION). 14 Protected Material must be stored and maintained by a Receiving Party at a 15 location and in a secure manner that ensures that access is limited to the persons 16 authorized under this Order. 17 B. 18 Unless otherwise ordered by the Court or permitted in writing by the Disclosure of “CONFIDENTIAL” Information or Items. 19 Designating Party, a Receiving Party may disclose any information or item designated 20 “CONFIDENTIAL” only to: 21 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 22 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 23 disclose the information for this Action; 24 (b) the officers, directors, and employees (including House Counsel) of the 25 Receiving Party to whom disclosure is reasonably necessary for this Action; 26 (c) Experts (as defined in this Order) of the Receiving Party to whom 27 disclosure is reasonably necessary for this Action and who have signed the 28 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 570844.1 1 (d) the Court and its personnel; 2 (e) court reporters and their staff; 3 (f) professional jury or trial consultants, mock jurors, and Professional 4 Vendors to whom disclosure is reasonably necessary for this Action and who have 5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (g) the author or recipient of a document containing the information or a 7 custodian or other person who otherwise possessed or knew the information; 8 (h) during their depositions, witnesses, and attorneys for witnesses, in the 9 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 10 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 11 not be permitted to keep any confidential information unless they sign the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 13 by the Designating Party or ordered by the Court. Pages of transcribed deposition 14 testimony or exhibits to depositions that reveal Protected Material may be separately 15 bound by the court reporter and may not be disclosed to anyone except as permitted 16 under this Stipulated Protective Order; and 17 (i) any mediator or settlement officer, and their supporting personnel, 18 mutually agreed upon by any of the parties engaged in settlement discussions. 19 C. 20 Disclosure of “HIGHLY CONFIDENTIAL” or “ATTORNEY EYES ONLY” Information or Items. 21 Unless otherwise ordered by the Court or permitted in writing by the 22 Designating Party, a Receiving Party may disclose any information or item designated 23 “HIGHLY CONFIDENTIAL” or “ATTORNEY EYES ONLY” only to: 24 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 25 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 26 disclose the information for this Action; 27 / / / 28 / / / 570844.1 1 (b) Experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (c) the Court and its personnel; 5 (d) court reporters and their staff; 6 (e) professional jury or trial consultants, mock jurors, and Professional 7 Vendors to whom disclosure is reasonably necessary for this Action and who have 8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (f) the author or recipient of a document containing the information or a 10 custodian or other person who otherwise possessed or knew the information; and 11 (g) any mediator or settlement officer, and their supporting personnel, 12 mutually agreed upon by any of the parties engaged in settlement discussions. 13 Notwithstanding the foregoing restrictions on the disclosure of information 14 designated as “Highly Confidential” or “Attorney’s Eyes Only,” counsel for Plaintiff 15 may disclose to representatives of Plaintiff the following information: (1) the number 16 of units purchased and sold (at wholesale and/or retail level); (2) claimed gross 17 revenue; (3) the per unit cost of goods (at wholesale and/or retail level); (4) claimed 18 gross profit or loss; and (5) claimed deductions beyond cost of goods attributable to the 19 sale of the challenged goods (at wholesale and/or retail level). 20 IX. PROTECTED 21 PRODUCED IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation that MATERIAL SUBPOENAED OR ORDERED 23 compels disclosure of any information or items designated in this Action as 24 “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES 25 ONLY,” that Party must: 26 (a) promptly notify in writing the Designating Party. Such notification shall 27 include a copy of the subpoena or court order; 28 570844.1 1 (b) promptly notify in writing the party who caused the subpoena or order to 2 issue in the other litigation that some or all of the material covered by the subpoena or 3 order is subject to this Protective Order. Such notification shall include a copy of this 4 Stipulated Protective Order; and 5 (c) cooperate with respect to all reasonable procedures sought to be pursued 6 by the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with 8 the subpoena or court order shall not produce any information designated in this action 9 as “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES 10 ONLY” before a determination by the court from which the subpoena or order issued, 11 unless the Party has obtained the Designating Party’s permission. The Designating 12 Party shall bear the burden and expense of seeking protection in that court of its 13 confidential material and nothing in these provisions should be construed as 14 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 15 directive from another court. 16 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 17 PRODUCED IN THIS LITIGATION 18 (a) The terms of this Order are applicable to information produced by a 19 Non-Party in this Action and designated as “CONFIDENTIAL,” “HIGHLY 20 CONFIDENTIAL,” or “ATTORNEY EYES ONLY.” Such information produced by 21 Non-Parties in connection with this litigation is protected by the remedies and relief 22 provided by this Order. Nothing in these provisions should be construed as prohibiting 23 a Non-Party from seeking additional protections. 24 (b) In the event that a Party is required, by a valid discovery request, to 25 produce a Non-Party’s confidential information in its possession, and the Party is 26 subject to an agreement with the Non-Party not to produce the Non-Party’s 27 confidential information, then the Party shall: 28 570844.1 1 (i) promptly notify in writing the Requesting Party and the Non-Party 2 that some or all of the information requested is subject to a confidentiality agreement 3 with a Non-Party; 4 (ii) promptly provide the Non-Party with a copy of the Stipulated 5 Protective Order in this Action, the relevant discovery request(s), and a reasonably 6 specific description of the information requested; and 7 (iii) make the information requested available for inspection by the 8 Non-Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this Court within 14 10 days of receiving the notice and accompanying information, the Receiving Party may 11 produce the Non-Party’s confidential information responsive to the discovery request. 12 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 13 any information in its possession or control that is subject to the confidentiality 14 agreement with the Non-Party before a determination by the Court. Absent a court 15 order to the contrary, the Non-Party shall bear the burden and expense of seeking 16 protection in this Court of its Protected Material. 17 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 18 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 19 Protected Material to any person or in any circumstance not authorized under this 20 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 21 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts to 22 retrieve all unauthorized copies of the Protected Material, (c) inform the person or 23 persons to whom unauthorized disclosures were made of all the terms of this Order, 24 and (d) request such person or persons to execute the “Acknowledgment and 25 Agreement to Be Bound” that is attached hereto as Exhibit A. 26 / / / 27 / / / 28 / / / 570844.1 1 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 7 may be established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 parties may incorporate their agreement in the stipulated protective order submitted to 12 the Court. 13 XIII. MISCELLANEOUS 14 2. Right to Further Relief. Nothing in this Order abridges the right of any 15 person to seek its modification by the Court in the future. 16 3. Right to Assert Other Objections. By stipulating to the entry of this 17 Protective Order, no Party waives any right it otherwise would have to object to 18 disclosing or producing any information or item on any ground not addressed in this 19 Stipulated Protective Order. Similarly, no Party waives any right to object on any 20 ground to use in evidence of any of the material covered by this Protective Order. 21 4. Filing Protected Material. A Party that seeks to file under seal any 22 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 23 only be filed under seal pursuant to a court order authorizing the sealing of the specific 24 Protected Material at issue; good cause must be shown in the request to file under seal. 25 If a Party’s request to file Protected Material under seal is denied by the Court, then 26 the Receiving Party may file the information in the public record unless otherwise 27 instructed by the Court. 28 570844.1 1 XIV. FINAL DISPOSITION 2 After the final disposition of this Action, within 60 days of a written request by 3 the Designating Party, each Receiving Party must return all Protected Material to the 4 Producing Party or destroy such material. As used in this subdivision, “all Protected 5 Material” includes all copies, abstracts, compilations, summaries, and any other 6 format reproducing or capturing any of the Protected Material. Whether the Protected 7 Material is returned or destroyed, the Receiving Party must submit a written 8 certification to the Producing Party (and, if not the same person or entity, to the 9 Designating Party) by the 60 day deadline that (1) identifies (by category, where 10 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 11 that the Receiving Party has not retained any copies, abstracts, compilations, 12 summaries or any other format reproducing or capturing any of the Protected Material. 13 Notwithstanding this provision, counsel are entitled to retain an archival copy of all 14 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 15 correspondence, deposition and trial exhibits, expert reports, attorney work product, 16 and consultant and expert work product, even if such materials contain Protected 17 Material. Any such archival copies that contain or constitute Protected Material remain 18 subject to this Protective Order as set forth in Section 4 (DURATION). 19 Any violation of this Order may be punished by any and all appropriate 20 measures including, without limitation, contempt proceedings and/or monetary 21 sanctions. 22 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. July 24 24 DATED: ____________, 2017 25 /S/ Suzanne H. Segal 26 Hon. Suzanne H. Segal 27 28 570844.1 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury that 5 I have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Central District of California on 7 [date] in the case of Fabric Selection, Inc. v. Ms. Bubbles, Inc., et al. Case No. Case 8 No. 2:17-cv-02622-MWF-SS. I agree to comply with and to be bound by all the terms 9 of this Stipulated Protective Order and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that is 12 subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 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 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. 18 _____________________________________ I [print or hereby type full appoint name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 570844.1

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