KST Data, Inc. v. Northrop Grumman Systems Corporation, a Delaware corporation

Filing 32

PROTECTIVE ORDER by Magistrate Judge Patrick J. Walsh re Stipulation for Protective Order 31 . SEE ORDER. (im)

1 ERVIN COHEN & JESSUP LLP
Randall S. Leff (Bar No. 77148)
2
[e-mail]
9401 Wilshire Boulevard, Ninth Floor
3 Beverly Hills, California 90212-2974
Telephone: [phone]
4 Facsimile: [phone]
5 LATHAM & WATKINS LLP
David J. Schindler (Bar No. 130490)
6
[e-mail]
R. Peter Durning, Jr. (Bar No. 277968)
7
[e-mail]
355 South Grand Avenue, Suite 100
8 Los Angeles, California 90071-1560
Telephone: [phone]
9 Facsimile: [phone]
10 LATHAM & WATKINS LLP
Kyle R. Jefcoat (pro hac vice)
11
[e-mail]
555 Eleventh Street, NW, Suite 1000
12 Washington, D.C. 20004-1304
Telephone: [phone]
13 Facsimile: [phone]
14

Attorneys for Plaintiff
15 KST Data, Inc.
16
17

UNITED STATES DISTRICT COURT

18

CENTRAL DISTRICT OF CALIFORNIA

19
20 KST DATA, INC.,
a California corporation,
21
Plaintiff,
22
v.
23
NORTHROP GRUMMAN SYSTEMS
24 CORPORATION, a Delaware
corporation, and DOES 1 through 25,
25 inclusive,
Defendants.
26

CASE NO. 2:17-CV-5125-MWF(PJWx)
[Discovery Matter: referred to
The Hon. Patrick J. Walsh]
STIPULATED PROTECTIVE ORDER
Trial Date: June 11, 2019
Complaint Filed: June 14, 2017

27
28
STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1 I.
2

A.

PURPOSES AND LIMITATIONS

3

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

4 proprietary, or private information for which special protection from public
5 disclosure and from use for any purpose other than prosecuting this litigation may
6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
7 enter the following Stipulated Protective Order. The parties acknowledge that this
8 Order does not confer blanket protections on all disclosures or responses to
9 discovery and that the protection it affords from public disclosure and use extends
10 only to the limited information or items that are entitled to confidential treatment
11 under the applicable legal principles. The parties further acknowledge, as set forth
12 in Section 12.3, below, that this Stipulated Protective Order does not entitle them
13 to file confidential information under seal; Civil Local Rule 79-5 sets forth the
14 procedures that must be followed and the standards that will be applied when a
15 party seeks permission from the court to file material under seal.
16

B.

GOOD CAUSE STATEMENT

17

This action is likely to involve trade secrets, customer and pricing lists and

18 other valuable research, development, commercial, financial, technical and/or
19 proprietary information for which special protection from public disclosure and
20 from use for any purpose other than prosecution of this action is warranted. Such
21 confidential and proprietary materials and information consist of, among other
22 things, confidential business or financial information, information regarding
23 confidential business practices, or other confidential research, development, or
24 commercial information (including information implicating privacy rights of third
25 parties), information otherwise generally unavailable to the public, or which may
26 be privileged or otherwise protected from disclosure under state or federal statutes,
27 court rules, case decisions, or common law. Accordingly, to expedite the flow of
28 information, to facilitate the prompt resolution of disputes over confidentiality of
2
STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1 discovery materials, to adequately protect information the parties are entitled to
2 keep confidential, to ensure that the parties are permitted reasonable necessary uses
3 of such material in preparation for and in the conduct of trial, to address their
4 handling at the end of the litigation, and serve the ends of justice, a protective order
5 for such information is justified in this matter. It is the intent of the parties that
6 information will not be designated as confidential for tactical reasons and that
7 nothing be so designated without a good faith belief that it has been maintained in
8 a confidential, non-public manner, and there is good cause why it should not be
9 part of the public record of this case.
10 II.
11

DEFINITIONS
1.

Action: this pending federal lawsuit, KST Data, Inc. v.

12

Northrop Grumman Systems Corporation, United States

13

District Court for the Central District of California, Case No.

14

2:17-CV-5125-MW-PJW.

15

2.

16
17

Challenging Party: a Party or Non-Party that challenges the
designation of information or items under this Order.

3.

“CONFIDENTIAL” Information or Items: information

18

(regardless of how it is generated, stored or maintained) or

19

tangible things that qualify for protection under Federal Rule of

20

Civil Procedure 26(c), and as specified above in the Good

21

Cause Statement.

22

4.

23
24

Counsel: Outside Counsel of Record and House Counsel (as
well as their support staff).

5.

Designating Party: a Party or Non-Party that designates

25

information or items that it produces in disclosures or in

26

responses to discovery as “CONFIDENTIAL.”

27
28

6.

Disclosure or Discovery Material: all items or information,
regardless of the medium or manner in which it is generated,
3
STIPULATED PROTECTIVE ORDER

ATTORNEYS AT LAW
LOS ANGELES

1

stored, or maintained (including, among other things,

2

testimony, transcripts, and tangible things), that are produced or

3

generated in disclosures or responses to discovery in this

4

matter.

5

7.

Expert: a person with specialized knowledge or experience in a

6

matter pertinent to the litigation who has been retained by a

7

Party or its counsel to serve as an expert witness or as a

8

consultant in this Action.

9

8.

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

10

Action. House Counsel does not include Outside Counsel of

11

Record or any other outside counsel.

12

9.

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

13

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

14

action.

15

10.

Outside Counsel of Record: attorneys who are not employees

16

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

17

party to this Action and have appeared in this Action on behalf

18

of that party or are affiliated with a law firm which has

19

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

20

11.

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

21

directors, employees, consultants, retained experts, and Outside

22

Counsel of Record (and their support staffs).

23

12.

24
25

Producing Party: a Party or Non-Party that produces
Disclosure or Discovery Material in this Action.

13.

Professional Vendors: persons or entities that provide

26

litigation support services (e.g., photocopying, videotaping,

27

translating, preparing exhibits or demonstrations, and

28
4
STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1

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

2

and their employees and subcontractors.

3

14.

4

Protected Material: any Disclosure or Discovery Material that
is designated as “CONFIDENTIAL.”

5

15.

6

Receiving Party: a Party that receives Disclosure or Discovery
Material from a Producing Party.

7 III.

SCOPE

8

The protections conferred by this Stipulation and Order cover not only

9 Protected Material (as defined above), but also (1) any information copied or
10 extracted from Protected Material; (2) all copies, excerpts, summaries, or
11 compilations of Protected Material; and (3) any testimony, conversations, or
12 presentations by Parties or their Counsel that might reveal Protected Material.
13

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

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

DURATION

16

Even after final disposition of this litigation, the confidentiality obligations

17 imposed by this Order shall remain in effect until a Designating Party agrees
18 otherwise in writing or a court order otherwise directs. Final disposition shall be
19 deemed to be the later of (1) dismissal of all claims and defenses in this Action,
20 with or without prejudice; and (2) final judgment herein after the completion and
21 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
22 including the time limits for filing any motions or applications for extension of
23 time pursuant to applicable law.
24 V.

DESIGNATING PROTECTED MATERIAL

25

A.

26
27

Exercise of Restraint and Care in Designating Material for
Protection.

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

28 under this Order must take care to limit any such designation to specific material
5
STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1 that qualifies under the appropriate standards. The Designating Party must
2 designate for protection only those parts of material, documents, items, or oral or
3 written communications that qualify so that other portions of the material,
4 documents, items, or communications for which protection is not warranted are not
5 swept unjustifiably within the ambit of this Order.
6

Mass, indiscriminate, or routinized designations are prohibited. Designations

7 that are shown to be clearly unjustified or that have been made for an improper
8 purpose (e.g., to unnecessarily encumber the case development process or to
9 impose unnecessary expenses and burdens on other parties) may expose the
10 Designating Party to sanctions.
11

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

12 designated for protection do not qualify for protection, that Designating Party must
13 promptly notify all other Parties that it is withdrawing the inapplicable designation.
14

B.

Manner and Timing of Designations.

15

Except as otherwise provided in this Order (see, e.g., second paragraph of

16 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or
17 Discovery Material that qualifies for protection under this Order must be clearly so
18 designated before the material is disclosed or produced.
19
20

Designation in conformity with this Order requires:
1.

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

21

documents, but excluding transcripts of depositions or other

22

pretrial or trial proceedings), that the Producing Party affix at a

23

minimum, the legend “CONFIDENTIAL” (hereinafter

24

“CONFIDENTIAL legend”), to each page that contains

25

protected material. If only a portion or portions of the material

26

on a page qualifies for protection, the Producing Party also

27

must clearly identify the protected portion(s) (e.g., by making

28

appropriate markings in the margins).
6
STIPULATED PROTECTIVE ORDER

ATTORNEYS AT LAW
LOS ANGELES

1

2.

A Party or Non-Party that makes original documents available

2

for inspection need not designate them for protection until after

3

the inspecting Party has indicated which documents it would

4

like copied and produced. During the inspection and before the

5

designation, all of the material made available for inspection

6

shall be deemed “CONFIDENTIAL.” After the inspecting

7

Party has identified the documents it wants copied and

8

produced, the Producing Party must determine which

9

documents, or portions thereof, qualify for protection under this

10

Order. Then, before producing the specified documents, the

11

Producing Party must affix the “CONFIDENTIAL legend” to

12

each page that contains Protected Material. If only a portion or

13

portions of the material on a page qualifies for protection, the

14

Producing Party also must clearly identify the protected

15

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

16

margins).

17

3.

for testimony given in depositions that the Designating Party

18

identify the Disclosure or Discovery Material on the record,

19

before the close of the deposition all protected testimony.

20

4.

for information produced in some form other than documentary

21

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

22

in a prominent place on the exterior of the container or

23

containers in which the information is stored the legend

24

“CONFIDENTIAL.” If only a portion or portions of the

25

information warrants protection, the Producing Party, to the

26

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

27
28

5.

Inadvertent Failures to Designate. If timely corrected, an
inadvertent failure to designate qualified information or items
7
STIPULATED PROTECTIVE ORDER

ATTORNEYS AT LAW
LOS ANGELES

1

does not, standing alone, waive the Designating Party’s right to

2

secure protection under this Order for such material. Upon

3

timely correction of a designation, the Receiving Party must

4

make reasonable efforts to assure that the material is treated in

5

accordance with the provisions of this Order.

6 VI.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

7

A.

8

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

Timing of Challenges.

9 any time that is consistent with the Court’s Scheduling Order.
10

B.

Meet and Confer.

11

The Challenging Party shall initiate the dispute resolution process under

12 Local Rule 37.1 et seq.
13

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

14 Designating Party. Frivolous challenges, and those made for an improper purpose
15 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
16 expose the Challenging Party to sanctions. Unless the Designating Party has
17 waived or withdrawn the confidentiality designation, all parties shall continue to
18 afford the material in question the level of protection to which it is entitled under
19 the Producing Party’s designation until the Court rules on the challenge.
20 VII. ACCESS TO AND USE OF PROTECTED MATERIAL
21

A.

Basic Principles.

22

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

23 by another Party or by a Non-Party in connection with this Action only for
24 prosecuting, defending, or attempting to settle this Action. Such Protected Material
25 may be disclosed only to the categories of persons and under the conditions
26 described in this Order. When the Action has been terminated, a Receiving Party
27 must comply with the provisions of section 13 below (FINAL DISPOSITION).
28
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STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1

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

2 location and in a secure manner that ensures that access is limited to the persons
3 authorized under this Order.
4

B.

Disclosure of “CONFIDENTIAL” Information or Items.

5

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

6 Designating Party, a Receiving Party may disclose any information or item
7 designated “CONFIDENTIAL” only to:
8

1.

9

the Receiving Party’s Outside Counsel of Record in this Action,
as well as employees of said Outside Counsel of Record to

10

whom it is reasonably necessary to disclose the information for

11

this Action;

12

2.

the officers, directors, and employees (including House

13

Counsel) of the Receiving Party to whom disclosure is

14

reasonably necessary for this Action;

15

3.

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

16

whom disclosure is reasonably necessary for this Action and

17

who have signed the “Acknowledgment and Agreement to Be

18

Bound” (Exhibit A);

19

4.

the court and its personnel;

20

5.

court reporters and their staff;

21

6.

professional jury or trial consultants, mock jurors, and

22

Professional Vendors to whom disclosure is reasonably

23

necessary for this Action and who have signed the

24

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

25

7.

the author or recipient of a document containing the

26

information or a custodian or other person who otherwise

27

possessed or knew the information;

28
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STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1

8.

during their depositions, witnesses, and attorneys for witnesses,

2

in the Action to whom disclosure is reasonably necessary

3

provided: (1) the deposing party requests that the witness sign

4

the form attached as Exhibit 1 hereto; and (2) they will not be

5

permitted to keep any confidential information unless they sign

6

the “Acknowledgment and Agreement to Be Bound” (Exhibit

7

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

8

by the court. Pages of transcribed deposition testimony or

9

exhibits to depositions that reveal Protected Material may be

10

separately bound by the court reporter and may not be disclosed

11

to anyone except as permitted under this Stipulated Protective

12

Order; and

13

9.

any mediator or settlement officer, and their supporting

14

personnel, mutually agreed upon by any of the parties engaged

15

in settlement discussions.

16 VIII. PROTECTED MATERIAL SUBPOENAED OR ORDERED
17

PRODUCED IN OTHER LITIGATION

18

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

19 that compels disclosure of any information or items designated in this Action as
20 “CONFIDENTIAL,” that Party must:
21

1.

22
23

promptly notify in writing the Designating Party. Such
notification shall include a copy of the subpoena or court order;

2.

promptly notify in writing the party who caused the subpoena

24

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

25

material covered by the subpoena or order is subject to this

26

Protective Order. Such notification shall include a copy of this

27

Stipulated Protective Order; and

28
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STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1

3.

cooperate with respect to all reasonable procedures sought to be

2

pursued by the Designating Party whose Protected Material

3

may be affected.

4

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

5 with the subpoena or court order shall not produce any information designated in
6 this action as “CONFIDENTIAL” before a determination by the court from which
7 the subpoena or order issued, unless the Party has obtained the Designating Party’s
8 permission. The Designating Party shall bear the burden and expense of seeking
9 protection in that court of its confidential material and nothing in these provisions
10 should be construed as authorizing or encouraging a Receiving Party in this Action
11 to disobey a lawful directive from another court.
12 IX.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

13

PRODUCED IN THIS LITIGATION

14

1.

The terms of this Order are applicable to information produced

15

by a Non-Party in this Action and designated as

16

“CONFIDENTIAL.” Such information produced by Non-

17

Parties in connection with this litigation is protected by the

18

remedies and relief provided by this Order. Nothing in these

19

provisions should be construed as prohibiting a Non-Party from

20

seeking additional protections.

21

2.

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

22

request, to produce a Non-Party’s confidential information in its

23

possession, and the Party is subject to an agreement with the

24

Non-Party not to produce the Non-Party’s confidential

25

information, then the Party shall:

26
27

(1)

promptly notify in writing the Requesting Party
and the Non-Party that some or all of the

28
11
STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1

information requested is subject to a

2

confidentiality agreement with a Non-Party;

3

(2)

promptly provide the Non-Party with a copy of the

4

Stipulated Protective Order in this Action, the

5

relevant discovery request(s), and a reasonably

6

specific description of the information requested;

7

and

8

(3)

9
10

make the information requested available for
inspection by the Non-Party, if requested.

3.

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

11

within 14 days of receiving the notice and accompanying

12

information, the Receiving Party may produce the Non-Party’s

13

confidential information responsive to the discovery request. If

14

the Non-Party timely seeks a protective order, the Receiving

15

Party shall not produce any information in its possession or

16

control that is subject to the confidentiality agreement with the

17

Non-Party before a determination by the court. Absent a court

18

order to the contrary, the Non-Party shall bear the burden and

19

expense of seeking protection in this court of its Protected

20

Material.

21 X.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

22

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

23 disclosed Protected Material to any person or in any circumstance not authorized
24 under this Stipulated Protective Order, the Receiving Party must immediately (a)
25 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
26 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
27 the person or persons to whom unauthorized disclosures were made of all the terms
28 of this Order, and (d) request such person or persons to execute the
12
STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
2 A.
3 XI.

INADVERTENT PRODUCTION OF PRIVILEGED OR

4

OTHERWISE PROTECTED MATERIAL

5

When a Producing Party gives notice to Receiving Parties that certain

6 inadvertently produced material is subject to a claim of privilege or other
7 protection, the obligations of the Receiving Parties are those set forth in Federal
8 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
9 whatever procedure may be established in an e-discovery order that provides for
10 production without prior privilege review. Pursuant to Federal Rule of Evidence
11 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
12 of a communication or information covered by the attorney-client privilege or
13 work product protection, the parties may incorporate their agreement in the
14 stipulated protective order submitted to the court.
15 XII. MISCELLANEOUS
16

A.

Right to Further Relief.

17

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

18 modification by the Court in the future.
19

B.

Right to Assert Other Objections.

20

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

21 it otherwise would have to object to disclosing or producing any information or
22 item on any ground not addressed in this Stipulated Protective Order. Similarly, no
23 Party waives any right to object on any ground to use in evidence of any of the
24 material covered by this Protective Order.
25

C.

Filing Protected Material.

26

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

27 with Civil Local Rule 79-5. Protected Material may only be filed under seal
28 pursuant to a court order authorizing the sealing of the specific Protected Material
13
STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1 at issue. If a Party's request to file Protected Material under seal is denied by the
2 court, then the Receiving Party may file the information in the public record unless
3 otherwise instructed by the court.
4 XIII. FINAL DISPOSITION
5

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

6 60 days of a written request by the Designating Party, each Receiving Party must
7 return all Protected Material to the Producing Party or destroy such material. As
8 used in this subdivision, “all Protected Material” includes all copies, abstracts,
9 compilations, summaries, and any other format reproducing or capturing any of the
10 Protected Material. Whether the Protected Material is returned or destroyed, the
11 Receiving Party must submit a written certification to the Producing Party (and, if
12 not the same person or entity, to the Designating Party) by the 60 day deadline that
13 (1) identifies (by category, where appropriate) all the Protected Material that was
14 returned or destroyed and (2) affirms that the Receiving Party has not retained any
15 copies, abstracts, compilations, summaries or any other format reproducing or
16 capturing any of the Protected Material. Notwithstanding this provision, Counsel
17 are entitled to retain an archival copy of all pleadings, motion papers, trial,
18 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
19 and trial exhibits, expert reports, attorney work product, and consultant and expert
20 work product, even if such materials contain Protected Material. Any such archival
21 copies that contain or constitute Protected Material remain subject to this
22 Protective Order as set forth in Section 4 (DURATION).
23
24
25
26
27
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STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

1 XIV. ENFORCEMENT
2

Any violation of this Order may be punished by any and all appropriate

3 measures including, without limitation, contempt proceedings and/or monetary
4 sanctions.
5
6 Dated: September 25, 2017
7 PERKINS COIE LLP
Bruce V. Spiva
Andrew E. Shipley
8
Andrew J. Victor
Alisha C. Burgin
9
10
11 By /s/ Bruce V. Spiva______
Bruce V. Spiva
Attorneys for Defendant
12
Northrop Grumman
Systems Corporation
13
14

Respectfully submitted,
ERVIN COHEN & JESSUP LLP
Randall S. Leff
LATHAM & WATKINS LLP
David J. Schindler
Kyle R. Jefcoat
R. Peter Durning, Jr.
By /s/ R. Peter Durning, Jr__
R. Peter Durning, Jr.
Attorneys for Plaintiff
KST Data, Inc.

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

15
16 DATED: September 26, 2017
17
18
19 Honorable Patrick J. Walsh
United States Magistrate Judge
20
21
22
23
24

ATTESTATION
Pursuant to Local Rule 5-4.3.4(a)(2)(ii), I, R. Peter Durning, Jr., attest that
all other signatories listed, and on whose behalf this filing is submitted, concur in
this filing’s content and have authorized such filing.

25
26

By /s/ R. Peter Durning, Jr._______
R. Peter Durning, Jr.

27
28
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STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES

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
5 perjury that I have read in its entirety and understand the Stipulated Protective
6 Order that was issued by the United States District Court for the Central District of
7 California on [date] in the case of ___________________________ [insert formal
8 name of the case and the number and initials assigned to it by the court]. I
9 agree to comply with and to be bound by all the terms of this Stipulated Protective
10 Order and I understand and acknowledge that failure to so comply could expose
11 me to sanctions and punishment in the nature of contempt. I solemnly promise that
12 I will not disclose in any manner any information or item that is subject to this
13 Stipulated Protective Order to any person or entity except in strict compliance with
14 the provisions of this Order. I further agree to submit to the jurisdiction of the
15 United States District Court for the Central District of California for the purpose of
16 enforcing the terms of this Stipulated Protective Order, even if such enforcement
17 proceedings occur after termination of this action. I hereby appoint
18 _____________________

[print

or

type

full

name]

of

19 _______________________ [print or type full address and telephone number] as
20 my California agent for service of process in connection with this action or any
21 proceedings related to enforcement of this Stipulated Protective Order.
22 Date:
23 City and State where sworn and signed:
24 Printed name:
25 Signature:
26
27
28
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STIPULATED PROTECTIVE ORDER
ATTORNEYS AT LAW
LOS ANGELES