Angel Shaw v. Abbott Laboratories Inc et al

Filing 23

PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal re Stipulation for Protective Order 22 . (See document for details). (mr)

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JANET MARTIN LAW OFFICES
Janet G. Martin
601 Daily Drive No. 221
Camarillo, California 93010
Telephone: [phone]
[e-mail]
Attorney for Plaintiff ANGEL SHAW
ATKINSON, ANDELSON, LOYA, RUUD & ROMO PLC
Scott K. Dauscher (SBN 204105)
12800 Center Court Drive South, Suite 300
Cerritos, California 90703
Telephone: [phone]
Fax: [phone]
[e-mail]
GOLDBERG KOHN LTD.
Harleen Kaur (SBN 260229)
55 East Monroe Street, Suite 3300
Chicago, Illinois 60603
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendants Abbott Laboratories Inc.,
ABBOTT LABORATORIES INC. DBA
ABBOTT SALES, MARKETING & DISTRIBUTION CO., and
ABBOTT LABORATORIES

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IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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ANGEL SHAW
Plaintiff

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Case No. 2:17-cv-04783-SS

vs.

STIPULATED PROTECTIVE
ORDER

ABBOTT LABORATORIES INC.
DOING BUSINESS IN
LCALIFORNIA AS ABBOTT SALES
MARKETING & DISTRIBUTION
CO., ABBOTT LABORATORIES
INC., ABBOTT LABORATORIES
INC. DBA ABBOTT NUTRITION and
DOES 1 THROUGH 40, inclusive
Defendants.

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STIPULATED PROTECTIVE ORDER

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A.

PURPOSES AND LIMITATIONS

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

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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

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may be warranted. Accordingly, the parties hereby stipulate to and petition the

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Court to enter the following Stipulated Protective Order.

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acknowledge that this Order does not confer blanket protections on all

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

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

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The parties

entitled to confidential treatment under the applicable legal principles.
B.

GOOD CAUSE STATEMENT

This action is likely to involve trade secrets, including without limitation,
valuable research, development, commercial, financial, business, scientific,
economic, technical and other confidential and proprietary information for which
special protection from public disclosure and from use for any purpose other than
prosecution of this action is warranted.

Such confidential and proprietary

materials and information generally consist of secret information because it is
neither known to, nor readily ascertainable by, another person, and which a party
has taken reasonable measure to maintain such secrecy, from which independent
economic value is derived. Such confidential and proprietary materials and
information may also be privileged or otherwise protected from disclosure under
state or federal statutes, court rules, case decisions, or common law. In addition,
it is likely that the parties will exchange confidential personal information
relating to the parties to this action and non-parties, such as financial information,
medical or health-related information, personnel or other employment records of
non-parties, and personal identifiers such as home addresses, telephone numbers,
and Social Security numbers. Other confidential information may be exchanged,

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including but not limited to, records pertaining to internal investigations, business

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policies, procedures, and other records that contain non-public information, and

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agreements, contracts, and proposals which could harm a party's competitive

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interests and business. Accordingly, to expedite the flow of information, to

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facilitate the prompt resolution of disputes over confidentiality of discovery

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materials, to adequately protect information the parties are entitled to keep

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confidential, to ensure that the parties are permitted reasonable necessary uses of

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such material in preparation for and in the conduct of trial, to address their

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handling at the end of the litigation, and serve the ends of justice, a protective

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order for such information is justified in this matter. It is the intent of the parties

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that information will not be designated as confidential for tactical reasons and

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that nothing be so designated without a good faith belief that it has been

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maintained in a confidential manner, and there is good cause why it should not be

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part of the public record of this case.

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C.

ACKNOWLEDGMENT
PROCEDURE

OF

UNDER

SEAL

FILING

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The parties further acknowledge, as set forth in Section 12.3, below, that

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this Stipulated Protective Order does not entitle them to file confidential

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information under seal; Local Civil Rule 79-5 sets forth the procedures that must

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be followed and the standards that will be applied when a party seeks permission

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from the court to file material under seal.

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There is a strong presumption that the public has a right of access to

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judicial proceedings and records in civil cases.

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dispositive motions, good cause must be shown to support a filing under seal.

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See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir.

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2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002),

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Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999)

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(even stipulated protective orders require good cause showing), and a specific
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In connection with non-

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showing of good cause or compelling reasons with proper evidentiary support

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and legal justification, must be made with respect to Protected Material that a

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party seeks to file under seal. The parties' mere designation of Disclosure or

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Discovery Material as CONFIDENTIAL does not—without the submission of

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competent evidence by declaration, establishing that the material sought to be

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filed under seal qualifies as confidential, privileged, or otherwise protectable—

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constitute good cause.

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Further, if a party requests sealing related to a dispositive motion or trial,

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then compelling reasons, not only good cause, for the sealing must be shown, and

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the relief sought shall be narrowly tailored to serve the specific interest to be

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protected. See Pintos v. Pacific Creditors Ass'n., 605 F.3d 665, 677-79 (9th Cir.

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2010). For each item or type of information, document, or thing sought to be

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filed or introduced under seal in connection with a dispositive motion or trial, the

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party seeking protection must articulate compelling reasons, supported by

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specific facts and legal justification, for the requested sealing order. Again,

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competent evidence supporting the application to file documents under seal must

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be provided by declaration.

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Any document that is not confidential, privileged, or otherwise protectable

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in its entirety shall not be filed under seal if the confidential portions can be

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redacted. If documents can be redacted, then a redacted version for public

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viewing, omitting only the confidential, privileged, or otherwise protectable

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portions of the document, shall be filed. Any application that seeks to file

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documents under seal in their entirety should include an explanation of why

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redaction is not feasible.

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2.

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2.1.

Action: This pending federal lawsuit.

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2.2.

Challenging Party:

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designation of information or items under this Order.

DEFINITIONS

a Party or Non-Party that challenges the
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2.3.

"CONFIDENTIAL" Information or Items: information (regardless

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of how it is generated, stored or maintained), documents, or tangible things that

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qualify for protected under Federal Rule of Civil Procedure 26(c), and as

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specified above in the Good Cause Statement. For purposes of this Order, the

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term "document" or "documents" shall include, without limitation, all discovery

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materials, declarations or affidavits, or other documents produced or provided in

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the course of discovery.

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2.4.

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their support staff).

Counsel: Outside Counsel of Record and House Counsel (as well as

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2.5.

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

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

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"CONFIDENTIAL."

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2.6.

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regardless of the medium or manner in which it is generated, stored, or

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maintained (including, among other things, testimony, transcripts, and tangible

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things), that are produced or generated in disclosures or responses to discovery in

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this matter.

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2.7.

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

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to serve as an expert witness or as a consultant in this Action.

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2.8.

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Action. House Counsel does not include Outside Counsel of Record or any other

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outside counsel.

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2.9.

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

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2.10.

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party to this Action but are retained to represent or advise a party to this Action

Disclosure or Discovery Material:

all items or information,

Expert: a person with specialized knowledge or experience in a

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

Non-Party: any natural person, partnership, corporation, association

Outside Counsel of Record: attorneys who are not employees of a

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and have appeared in this Action on behalf of that party or are affiliated with a

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law firm that has appeared on behalf of that party, and includes support staff.

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2.11.

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

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Record (and their respective support staffs).

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2.12.

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Discovery Material in this Action.

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2.13.

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support services (e.g., court reporting, photocopying, videotaping, translating,

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preparing exhibits or demonstrations, and organizing, storing, or retrieving data

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in any form or medium) and their employees and subcontractors.

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2.14.

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designated as "CONFIDENTIAL."

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2.15.

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Material from a Producing Party.

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3.

Party:

any party to this Action, including all of its officers,

Producing Party: a Party or Non-Party that produces Disclosure or

Professional Vendors:

persons or entities that provide litigation

Protected Material: any Disclosure or Discovery Material that is

Receiving Party:

a Party that receives Disclosure or Discovery

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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

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

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

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

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Any use of Protected Material at trial shall be governed by the orders of

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the trial judge. This Order does not govern the use of Protected Material at trial.

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4.

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DURATION
Once a case proceeds to trial, information that was designated as

CONFIDENTIAL or maintained pursuant to this protective order used or
introduced as an exhibit at trial becomes public and will be presumptively

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available to all members of the public, including the press, unless compelling

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reasons supported by specific factual findings to proceed otherwise are made to

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the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81

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(distinguishing "good cause" showing for sealing documents produced in

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discovery from "compelling reasons" standard when merits-related documents

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are part of court record). Accordingly, the terms of this protective order do not

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extend beyond the commencement of the trial.

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5.

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DESIGNATING PROTECTED MATERIAL
5.1.

Exercise of Restraint and Care in Designating Material for

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Protection. Each Party or Non-Party that designates information or items for

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protection under this Order must take care to limit any such designation to

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specific material that qualifies under the appropriate standards. The Designating

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Party should designate for protection only those parts of material, documents,

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items or oral or written communications that qualify so that other portions of the

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material, documents, items or communications for which protection is not

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warranted are not swept unjustifiably within the ambit of this Order.

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Mass,

indiscriminate

or

routinized

designations

are

prohibited.

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

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an improper purpose (e.g., to unnecessarily encumber the case development

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process or to impose unnecessary expenses and burdens on other parties) may

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expose the Designating Party to sanctions.

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

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

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must promptly notify all other Parties that it is withdrawing the inapplicable

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designation.

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5.2.

Manner and Timing of Designations. Except as otherwise provided

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

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stipulated or ordered, Disclosure or Discovery Material that qualifies for
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protection under this Order must be clearly so designated before the material is

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disclosed or produced.

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Designation in conformity with this Order requires:
(a)

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

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

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proceedings), that the Producing Party affix at a minimum, the legend

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"CONFIDENTIAL" (hereinafter "CONFIDENTIAL legend"), to each page that

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contains protected material. If only a portion of the material on a page qualifies

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

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

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

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

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has indicated which documents it would like copied and produced. During the

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inspection and before the designation, all of the material made available for

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inspection shall be deemed "CONFIDENTIAL." After the inspecting Party has

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identified the documents it wants copied and produced, the Producing Party must

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determine which documents, or portions thereof, qualify for protection under this

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Order. Then, before producing the specified documents, the Producing Party

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must affix the "CONFIDENTIAL legend" to each page that contains Protected

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Material. If only a portion of the material on a page qualifies for protection, the

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Producing Party also must clearly identify the protected portion(s) (e.g., by

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making appropriate markings in the margins).

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(b)

for testimony given in depositions that the Designating Party

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identifies before the close of the deposition all Protected Material or testimony

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subject to this Order, or in writing within ten (10) business days after the receipt

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of the transcript of the deposition, and all testimony shall be treated as

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confidential until such deadline has passed.

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(c)

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for information produced in some form other than

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documentary and for any other tangible items, that the Producing Party affix in a

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

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information is stored the legend "CONFIDENTIAL."

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

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

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If only a portion or

Inadvertent Failures to Designate. If timely corrected, an inadvertent

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failure to designate qualified information or items does not, standing alone, waive

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the Designating Party's right to secure protection under this Order for such

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material. Upon timely correction of a designation, the Receiving Party must

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make reasonable efforts to assure that the material is treated in accordance with

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the provisions of this Order.

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6.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1.

Timing of Challenges. Any Party or Non-Party may challenge a

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designation of confidentiality at any time that is consistent with the Court's

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Scheduling Order.

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6.2.

Meet and Confer. The Challenging Party shall initiate the dispute

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

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

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

The burden of persuasion in any such challenge proceeding shall be

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

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purpose (e.g., to harass or impose unnecessary expenses and burdens on other

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parties) may expose the Challenging Party to sanctions. Unless the Designating

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Party has waived or withdrawn the confidentiality designation, all parties shall

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continue to afford the material in question the level of protection to which it is

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entitled under the Producing Party's designation until the Court rules on the

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challenge.
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7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1.

Basic Principles. A Receiving Party may use Protected Material that

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

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

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Such Protected Material may be disclosed only to the categories of persons and

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under the conditions described in this Order. When the Action has been

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terminated, a Receiving Party must comply with the provisions of Section 15

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below (FINAL DISPOSITION).

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

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

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authorized under this Order.

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7.2.

Disclosure of "CONFIDENTIAL" Information or Items. Unless

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

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Receiving

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"CONFIDENTIAL" only to:

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(a)

Party

may

disclose

any

information

or

item

designated

the Receiving Party's Outside Counsel of Record in this

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

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reasonably necessary to disclose the information for this Action;
(b)

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the officers, directors, and employees (including House

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Counsel) of the Receiving Party to whom disclosure is reasonably necessary for

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this Action;

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(c)

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

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whom disclosure is reasonably necessary for this Action and who have signed the

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"Acknowledgment and Agreement to Be Bound" (Exhibit A);

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(d)

the court and its personnel;

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(e)

court reporters and their staff;

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(f)

professional jury or trial consultants, mock jurors, and

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Professional Vendors to whom disclosure is reasonably necessary for this Action
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and who have signed the "Acknowledgment and Agreement to Be Bound"

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(Exhibit A);
(g)

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the author or recipient of a document containing the

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

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information;
(h)

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during their depositions, witnesses, and attorneys for

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witnesses, in the Action to whom disclosure is reasonably necessary provided:

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(1) the deposing party requests that the witness sign the form attached as Exhibit

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A hereto; and (2) they will not be permitted to keep any confidential information

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unless they sign the "Acknowledgment and Agreement to Be Bound" (Exhibit

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A), unless otherwise agreed by the Designating Party or ordered by the court.

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Pages of transcribed deposition testimony or exhibits to depositions that reveal

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Protected Material may be separately bound by the court reporter and may not be

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disclosed to anyone except as permitted under this Stipulated Protective Order;

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and
(i)

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any mediator or settlement officer, and their supporting

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personnel, mutually agreed upon by any of the parties engaged in settlement

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discussions.

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8.

PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

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PRODUCED IN OTHER LITIGATION

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

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litigation that compels disclosure of any information or items designated in this

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Action as "CONFIDENTIAL," that Party must:

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(a)

promptly notify in writing the Designating Party.

Such

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

promptly notify in writing the party who caused the subpoena

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

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the subpoena or order is subject to this Protective Order. Such notification shall

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include a copy of this Stipulated Protective Order; and
(c)

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cooperate with respect to all reasonable procedures sought to

be pursued by the Designating Party whose Protected Material may be affected.

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

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

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this action as "CONFIDENTIAL" before a determination by the court from

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which the subpoena or order issued, unless the Party has obtained the

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Designating Party's permission. The Designating Party shall bear the burden and

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

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

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

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9.

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A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a)

The terms of this Order are applicable to information

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produced by a Non-Party in this Action and designated as "CONFIDENTIAL."

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Such information produced by Non-Parties in connection with this litigation is

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protected by the remedies and relief provided by this Order. Nothing in these

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provisions should be construed as prohibiting a Non-Party from seeking

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additional protections.

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(b)

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

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request, to produce a Non-Party's confidential information in its possession, and

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the Party is subject to an agreement with the Non-Party not to produce the Non-

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Party's confidential information, then the Party shall:

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(1)

promptly notify in writing the Requesting Party and the

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Non-Party that some or all of the information requested is subject to a

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confidentiality agreement with a Non-Party;

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(2)

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promptly provide the Non-Party with a copy of the

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Stipulated Protective Order in this Action, the relevant discovery request(s), and

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a reasonably specific description of the information requested; and
(3)

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make the information requested available for inspection

by the Non-Party, if requested.
(c)

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If the Non-Party fails to seek a protective order from this

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court within 14 days of receiving the notice and accompanying information, the

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Receiving Party may produce the Non-Party's confidential information

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responsive to the discovery request. If the Non-Party timely seeks a protective

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order, the Receiving Party shall not produce any information in its possession or

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control that is subject to the confidentiality agreement with the Non-Party before

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a determination by the court. Absent a court order to the contrary, the Non-Party

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shall bear the burden and expense of seeking protection in this court of its

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Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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disclosed Protected Material to any person or in any circumstance not authorized

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under this Stipulated Protective Order, the Receiving Party must immediately (a)

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notify in writing the Designating Party of the unauthorized disclosures, (b) use its

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best efforts to retrieve all unauthorized copies of the Protected Material, (c)

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inform the person or persons to whom unauthorized disclosures were made of all

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the terms of this Order, and (d) request such person or persons to execute the

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"Acknowledgment an Agreement to Be Bound" attached hereto as Exhibit A.

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11.

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INADVERTENT OR UNINTENTIONAL PRODUCTION
PRIVILEGED OR OTHERWISE PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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

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protection, the obligations of the Receiving Parties are those set forth in Federal
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OF

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Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

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whatever procedure may be established in an e-discovery order that provides for

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production without prior privilege review. Pursuant to Federal Rule of Evidence

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502, any inadvertently disclosed or unintentionally produced material which is

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subject to a claim of privilege or other protection shall in no way prejudice or

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otherwise constitute a waiver of, or estoppel as to, any claim of attorney-client

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privilege, work production, or any other privilege to which the Producing Party

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would otherwise be entitled. If a claim of inadvertent disclosure or unintentional

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production is made pursuant to this paragraph by the Producing Party with

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respect to such material then in the custody of the Receiving Party, the Receiving

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Party shall promptly return to the Producing Party that material as to which the

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claim of inadvertent and/or unintentional disclosure or production has been made.

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The Receiving Party may then move the Court for an order compelling

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production of the material, but said motion shall not assert as a ground for

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entering such an order the fact or circumstances of the inadvertent and/or

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unintentional disclosure or production.

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12.

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MISCELLANEOUS
12.1. Right to Further Relief. Nothing in this Order abridges the right of

any person to seek its modification by the Court in the future.

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

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

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

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this Stipulated Protective Order. Similarly, no Party waives any right to object

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on any ground to use in evidence of any of the material covered by this Protective

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Order.

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12.3. Filing Protected Material. A Party that seeks to file under seal any

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

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may only be filed under seal pursuant to a court order authorizing the sealing of
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the specific Protected Material at issue. If a Party's request to file Protected

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

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information in the public record unless otherwise instructed by the court.

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13.

FINAL DISPOSITION

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After the final disposition of this Action, as defined in paragraph 4, within

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60 days of a written request by the Designating Party, each Receiving Party must

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

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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

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

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the Receiving Party must submit a written certification to the Producing Party

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

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

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Material that was returned or destroyed and (2) affirms that the Receiving Party

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has not retained any copies, abstracts, compilations, summaries or any other

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format reproducing or capturing any of the Protected Material. Notwithstanding

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

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

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correspondence, deposition and trial exhibits, expert reports, attorney work

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product, and consultant and expert work product, even if such materials contain

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Protected Material. Any such archival copies that contain or constitute Protected

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Material remain subject to this Protective Order as set forth in Section 4

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(DURATION).

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Further, with respect to Electronically Stored Information ("ESI"), the

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parties' counsel shall make reasonable efforts to remove such ESI from counsel's

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active systems, including active email servers, active document management

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systems, and active litigation support databases. The parties' counsel will not be

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required, however, to remove such ESI from any backup or disaster recovery
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systems, or from any other source which is not reasonably accessible because of

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undue burden or cost.

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Material remains subject to this Protective Order.

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14.

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Any such ESI that contains or constitutes Protected

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

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

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED: December 6, 2017

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/s/ Janet G. Martin
One of Her Attorneys
Janet Martin Law Offices
601 Daily Drive No. 221
Camarillo, California 93010
Telephone: [phone]

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DATED: December 6, 2017

/s/ Harleen Kaur
One of Their Attorneys

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GOLDBERG KOHN LTD.
Harleen Kaur (SBN 260229)
55 East Monroe Street, Suite 3300
Chicago, Illinois 60603
Telephone: [phone]
Fax: [phone]

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ATKINSON, ANDELSON, LOYA,
RUUD & ROMO PLC
Scott K. Dauscher (SBN 204105)
12800 Center Court Drive South,
Suite 300
Cerritos, California 90703
Telephone: [phone]
Fax: [phone]

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Attorneys for Defendant

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-16-

1

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: December 8, 2017

/S/
Honorable Suzanne H. Segal
United States Magistrate Judge

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-17-

1
EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

_____________________________

[print

or

type

full

name],

of

_________________ [print or type full address], declare under penalty of perjury
that I have read in its entirety and understand the Stipulated Protective Order that
was issued by the United States District Court for the Central District of
California on ___________________, 201____, in the case of Angel Shaw vs.
Abbott Laboratories Inc., et al. I agree to comply with and to be bound by all the
terms of this Stipulated Protective Order, and I understand and acknowledge that
failure to so comply could expose me to sanctions and punishment in the nature
of contempt. I solemnly promise that I will not disclose in any manner any
information or item that is subject to this Stipulated Protective Order to any
person or entity except in strict compliance with the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court for
the Central District of California for the purpose of enforcing the terms of this
Stipulated Protective Order, even if such enforcement proceedings occur after
termination of this action.
I hereby appoint __________________________ [print or type full name] of
_______________________________________ [print or type full address and
telephone number] as my California agent for service of process in connection
with this action or any proceedings related to enforcement of this Stipulated
Protective Order.
Date: ______________________________________
City and State where sworn and signed: _________________________________
Printed name: _______________________________
Signature: __________________________________