Jennifer Hyatt v. County of Ventura, et al

Filing 21

STIPULATED PROTECTIVE ORDER by Magistrate Judge Paul L. Abrams. NOTE CHANGES MADE BY THE COURT. 20 (ch)

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1 LEROY SMITH, State Bar No. 107702 County Counsel, County of Ventura 2 EMILY T. GARDNER, State Bar No. 246980 Assistant County Counsel 3 Emily.Gardner@ventura.org 800 South Victoria Avenue, L/C #1830 4 Ventura, California 93009 Telephone: (805) 654-2573 (805) 654-2185 5 Facsimile: 6 Attorneys for Defendants County of Ventura, Ventura County Sheriff’s Office, Ventura County 7 Sheriff Geoff Dean 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 JENNIFER HYATT, ) ) Plaintiff, ) ) vs. ) ) COUNTY OF VENTURA; ) VENTURA COUNTY SHERIFF’S ) OFFICE; VENTURA COUNTY ) SHERIFF GEOFF DEAN in his ) official capacity; DOES 1-15 in each ) of their individual and official ) capacities, ) ) Defendants. ) ) ) Case No. 2:18-CV-3877 PA (PLAx) STIPULATED PROTECTIVE ORDER Complaint Served: May 31, 2018 Current Response Date: June 20, 2018 New Response Date: July 11, 2018 Judge: Hon. Percy Anderson A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary or private information for which special protection from public disclosure and from use for any purpose other than prosecuting or defending this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order (“Order”).1/ The parties acknowledge that this Order does not confer blanket protections on all 26 27 1/ This Stipulated Protective Order is based substantially on the model protective order provided under Magistrate Judge Alexander F. MacKinnon’s 28 Procedures. 1 STIPULATED PROTECTIVE ORDER 1 disclosures or responses to discovery and that the protection it affords from public 2 disclosure and use extends only to the limited information or items that are entitled 3 to confidential treatment under the applicable legal principles. 4 B. GOOD CAUSE STATEMENT 5 This action is likely to involve information otherwise generally unavailable 6 to the public, or which may be privileged or otherwise protected from disclosure 7 under state or federal statutes, court rules, case decisions, or common law, 8 including but not limited to video footage and photographs of plaintiff without her 9 hijab and peace officer personnel records. Accordingly, to expedite the flow of 10 information, to facilitate the prompt resolution of disputes over confidentiality of 11 discovery materials, to adequately protect information the parties are entitled to 12 keep confidential, to ensure that the parties are permitted reasonable necessary uses 13 of such material in preparation for and in the conduct of trial, to address their 14 handling at the end of the litigation, and serve the ends of justice, a protective order 15 for such information is justified in this matter. It is the intent of the parties that 16 information will not be designated as confidential for tactical reasons and that 17 nothing be so designated without a good faith belief that it has been maintained in 18 a confidential, non-public manner, and there is good cause why it should not be 19 part of the public record of this case. 20 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING 21 UNDER SEAL 22 The parties further acknowledge, as set forth in section 12.3, below, that this 23 Order does not entitle them to file confidential information under seal; Local Civil 24 Rule 79-5 sets forth the procedures that must be followed and the standards that 25 will be applied when a party seeks permission from the court to file material under 26 seal. 27 / / / 28 / / / 2 STIPULATED PROTECTIVE ORDER 1 There is a strong presumption that the public has a right of access to judicial 2 proceedings and records in civil cases. In connection with non-dispositive 3 motions, good cause must be shown to support a filing under seal. (See Kamakana 4 v. City and County of Honolulu (9th Cir. 2006) 447 F.3d 1172, 1176 5 (“Kamakana”), Phillips ex rel. Estates of Byrd v. Gen. Motors Corp. (9th Cir. 6 2002) 307 F.3d 1206, 1210-11, Makar-Welbon v. Sony Electronics, Inc. (E.D. Wis. 7 1999) 187 F.R.D. 576, 577 [even stipulated protective orders require good cause 8 showing].) A specific showing of good cause or compelling reasons with proper 9 evidentiary support and legal justification must be made with respect to protected 10 material that a party seeks to file under seal. The parties’ mere designation of 11 Disclosure or Discovery Material as CONFIDENTIAL does not – without the 12 submission of competent evidence by declaration, establishing that the material 13 sought to be filed under seal qualifies as confidential, privileged, or otherwise 14 protectable – constitute good cause. 15 Further, if a party requests sealing related to a dispositive motion or trial, 16 then compelling reasons, not only good cause, for the sealing must be shown, and 17 the relief sought shall be narrowly tailored to serve the specific interest to be 18 protected. (See Pintos v. Pacific Creditors Ass’n. (9th Cir. 2010) 605 F.3d 665, 19 677-679.) For each item or type of information, document, or thing sought to be 20 filed or introduced under seal in connection with a dispositive motion or trial, the 21 party seeking protection must articulate compelling reasons, supported by specific 22 facts and legal justification, for the requested sealing order. Again, competent 23 evidence supporting the application to file documents under seal must be provided 24 by declaration. 25 Any document that is not confidential, privileged, or otherwise protectable 26 in its entirety will not be filed under seal if the confidential portions can be 27 redacted. If documents can be redacted, then a redacted version for public 28 / / / 3 STIPULATED PROTECTIVE ORDER 1 viewing, omitting only the confidential, privileged, or otherwise protectable 2 portions of the document, shall be filed. Any application that seeks to file 3 documents under seal in their entirety should include an explanation of why 4 redaction is not feasible. 5 2. DEFINITIONS 6 2.1 Action: Jennifer Hyatt v. County of Ventura, et al.; Case No. 2:18-cv- 7 03877-PA (PLAx). 8 2.2 Challenging Party: A party or non-party that challenges the designation 9 of information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of 11 how it is generated, stored or maintained) or tangible things that qualify for 12 protection under Federal Rules of Civil Procedure rule 26(c), and as specified above 13 in the good cause statement. 14 2.4 Counsel: Counsel of record and in-house attorneys employed by a party 15 (as well as their support staff). 16 2.5 Designating Party: A party or non-party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: All items or information, regardless 20 of the medium or manner in which it is generated, stored, or maintained 21 (including, among other things, testimony, transcripts, and tangible things), that are 22 produced or generated in disclosures or responses to discovery in this matter. 23 2.7 Expert: A person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a party or its counsel to serve as 25 an expert witness or as a consultant in this action. 26 2.8 Non-Party: Any natural person, partnership, corporation, association or 27 other legal entity not named as a party to this action. 28 / / / 4 STIPULATED PROTECTIVE ORDER 1 2.9 Outside Counsel of Record: Attorneys who are retained to represent or 2 advise a party to this action and have appeared in this action on behalf of that 3 party or are affiliated with a law firm or other entity that has appeared on behalf of 4 that party, and includes support staff. 5 2.10 Party: Any party to this action, including all of its officers, directors, 6 employees, consultants, retained experts, and outside counsel of record (and their 7 support staff). 8 2.11 Producing Party: A party or non-party that produces disclosure or 9 discovery material in this action. 10 2.12 Professional Vendors: Persons or entities that provide litigation support 11 services (e.g., photocopying, videotaping, translating, preparing exhibits or 12 demonstrations, and organizing, storing, or retrieving data in any form or 13 medium) and their employees and subcontractors. 14 2.13 Protected Material: Any disclosure or discovery material that is 15 designated as “CONFIDENTIAL.” 16 2.14 Receiving Party: A party that receives disclosure or discovery material 17 from a producing party. 18 3. SCOPE 19 The protections conferred by this Order cover not only Protected Material (as 20 defined above), but also (1) any information copied or extracted from Protected 21 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 22 and (3) any testimony, conversations, or presentations by parties or their Counsel 23 that might reveal Protected Material. 24 Any use of Protected Material at trial shall be governed by the orders of the 25 trial judge. This Order does not govern the use of Protected Material at trial. 26 4. DURATION 27 Once a case proceeds to trial, information that was designated as 28 CONFIDENTIAL or maintained pursuant to this Order used or introduced as an 5 STIPULATED PROTECTIVE ORDER 1 exhibit at trial becomes public and will be presumptively available to all members 2 of the public, including the press, unless compelling reasons supported by specific 3 factual findings to proceed otherwise are made to the trial judge in advance of the 4 trial. (See Kamakana, supra, 447 F.3d at pp. 1180-81 [distinguishing “good cause” 5 showing for sealing documents produced in discovery from “compelling reasons” 6 standard when merits-related documents are part of court record].) Accordingly, the 7 terms of this Order do not extend beyond the commencement of the trial. 8 5. DESIGNATING PROTECTED MATERIAL 9 5.1 Exercise of Restraint and Care in Designating Material for Protection. 10 Each Party or Non-Party that designates information or items for protection under 11 this Order must take care to limit any such designation to specific material that 12 qualifies under the appropriate standards. The Designating Party must designate for 13 protection only those parts of material, documents, items or oral or written 14 communications that qualify so that other portions of the material, documents, items 15 or communications for which protection is not warranted are not swept unjustifiably 16 within the ambit of this Order. 17 Mass, indiscriminate or routinized designations are prohibited. Designations 18 that are shown to be clearly unjustified or that have been made for an improper 19 purpose (e.g., to unnecessarily encumber the case development process or to impose 20 unnecessary expenses and burdens on other parties) may expose the Designating 21 Party to sanctions. 22 If it comes to a Designating Party’s attention that information or items that it 23 designated for protection do not qualify for protection, that Designating Party must 24 promptly notify all other Parties that it is withdrawing the inapplicable designation. 25 5.2 Manner and Timing of Designations. Except as otherwise provided in 26 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 27 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 28 / / / 6 STIPULATED PROTECTIVE ORDER 1 under this Order must be clearly so designated before the material is disclosed or 2 produced. 3 Designation in conformity with this order requires: 4 (a) For information in documentary form (e.g., paper or electronic 5 documents, but excluding transcripts of depositions or other pretrial or trial 6 proceedings), that the Producing Party affix, at a minimum, the legend 7 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) to each page that 8 contains Protected Material. If only a portion of the material on a page qualifies for 9 protection, the Producing Party also must clearly identify the protected portion(s) 10 (e.g., by making appropriate markings in the margins). 11 A Party or Non-Party that makes original documents available for inspection 12 need not designate them for protection until after the inspecting Party has indicated 13 which documents it would like copied and produced. During the inspection and 14 before the designation, all of the material made available for inspection shall be 15 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 16 documents it wants copied and produced, the Producing Party must determine 17 which documents, or portions thereof, qualify for protection under this Order. 18 Then, before producing the specified documents, the Producing Party must affix the 19 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 20 portion of the material on a page qualifies for protection, the Producing Party also 21 must clearly identify the protected portion(s) (e.g., by making appropriate markings 22 in the margins). 23 (b) For testimony given in depositions, that the Designating Party 24 identifies the Disclosure or Discovery Material and all protected testimonies on the 25 record, before the close of the deposition. 26 (c) For information produced in some form other than documentary and 27 for any other tangible items, that the Producing Party affix in a prominent place on 28 the exterior of the container or containers in which the information is stored the 7 STIPULATED PROTECTIVE ORDER 1 legend “CONFIDENTIAL.” If only a portion or portions of the information 2 warrants protection, the Producing Party, to the extent practicable, shall identify the 3 protected portion(s). 4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 5 failure to designate qualified information or items does not, standing alone, waive 6 the Designating Party’s right to secure protection under this Order for such material. 7 Upon timely correction of a designation, the Receiving Party must make reasonable 8 efforts to assure that the material is treated in accordance with the provisions of this 9 Order. 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 12 designation of confidentiality at any time that is consistent with the court’s 13 Scheduling Order. 14 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 15 resolution process under Local Rule 37-1 et seq. 16 6.3 Joint Stipulation. Any challenge submitted to the court shall be via a 17 joint stipulation pursuant to Local Rule 37-2. 18 6.4 The burden of persuasion in any such challenge proceeding shall be on 19 the Designating Party. Frivolous challenges and those made for an improper 20 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 21 parties) may expose the Challenging Party to sanctions. Unless the Designating 22 Party has waived or withdrawn the confidentiality designation, all parties shall 23 continue to afford the material in question the level of protection to which it is 24 entitled under the Producing Party’s designation until the court rules on the 25 challenge. 26 7. ACCESS TO AND USE OF PROTECTED MATERIAL 27 7.1 Basic Principles. A Receiving Party may use Protected Material that is 28 disclosed or produced by another Party or by a Non-Party in connection with this 8 STIPULATED PROTECTIVE ORDER 1 Action only for prosecuting, defending or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the action has been terminated, a 4 Receiving Party must comply with the provisions of section 13 below (FINAL 5 DISPOSITION). 6 Protected Material must be stored and maintained by a Receiving Party at a 7 location and in a secure manner that ensures that access is limited to the persons 8 authorized under this Order. 9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 10 otherwise ordered by the court or permitted in writing by the Designating Party, a 11 Receiving Party may disclose any information or item designated 12 “CONFIDENTIAL” only to: 13 (a) The Receiving Party’s Counsel of Record in this action, as well as 14 employees of said Counsel of Record to whom it is reasonably necessary to disclose 15 the information for this action; 16 (b) The officers, directors, and employees (including in-house counsel) of 17 the Receiving Party to whom disclosure is reasonably necessary for this Action; 18 (c) Experts (as defined in this Order) of the Receiving Party to whom 19 disclosure is reasonably necessary for this Action and who have signed the 20 Acknowledgment and Agreement to Be Bound attached hereto as Exhibit A 21 (“Acknowledgment and Agreement to Be Bound”); 22 (d) The court and its personnel; 23 (e) Court reporters and their staff; 24 (f) Professional jury or trial consultants, mock jurors and Professional 25 Vendors to whom disclosure is reasonably necessary for this action and who have 26 signed the Acknowledgment and Agreement to Be Bound; 27 (g) The author or recipient of a document containing the information or 28 custodian or other person who otherwise possessed or knew the information; 9 STIPULATED PROTECTIVE ORDER 1 (h) During their depositions, witnesses, and attorneys for witnesses, in the 2 action to whom disclosure is reasonably necessary provided: (1) the deposing 3 party requests that the witness sign the Acknowledgment and Agreement to Be 4 Bound; and (2) they will not be permitted to keep any “CONFIDENTIAL” 5 Information unless they sign the Acknowledgment and Agreement to Be Bound, 6 unless otherwise agreed by the designating party or ordered by the court. Pages of 7 transcribed deposition testimony or exhibits to depositions that reveal Protected 8 Material may be separately bound by the court reporter and may not be disclosed to 9 anyone except as permitted under this Order; and 10 (i) Any mediator or settlement officer, and their supporting personnel, 11 mutually agreed upon by any of the parties engaged in settlement discussions. 12 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 13 PRODUCED IN OTHER LITIGATION 14 If a Party is served with a subpoena or a court order issued in other litigation 15 that compels disclosure of any information or items designated in this action as 16 “CONFIDENTIAL,” that party must: 17 (a) Promptly notify in writing the Designating Party. Such notification 18 shall include a copy of the subpoena or court order; 19 (b) Promptly notify in writing the Party who caused the subpoena or order 20 to issue in the other litigation that some or all of the material covered by the 21 subpoena or order is subject to this Order. Such notification shall include a copy of 22 this Order; and 23 (c) Cooperate with respect to all reasonable procedures sought to be 24 pursued by the Designating Party whose Protected Material may be affected. 25 If the Designating Party timely seeks a protective order, the Party served with 26 the subpoena or court order shall not produce any information designated in this 27 action as “CONFIDENTIAL” before a determination by the court from which the 28 10 STIPULATED PROTECTIVE ORDER 1 subpoena or order issued, unless the party has obtained the Designating Party’s 2 permission. The Designating Party shall bear the burden and expense of seeking 3 protection in that court of its “CONFIDENTIAL” Material and nothing in these 4 provisions should be construed as authorizing or encouraging a Receiving Party in 5 this action to disobey a lawful directive from another court. 6 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 (a) The terms of this Order are applicable to information produced by a 9 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 10 produced by Non-Parties in connection with this litigation is protected by the 11 remedies and relief provided by this Order. Nothing in these provisions should be 12 construed as prohibiting a Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party’s “CONFIDENTIAL” Information in its possession, and the 15 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 16 “CONFIDENTIAL” Information, then the Party shall: 17 (1) Promptly notify in writing the requesting Party and the Non- 18 Party that some or all of the information requested is subject to a confidentiality 19 agreement with a Non-Party; 20 (2) Promptly provide the Non-Party with a copy of this Order, the 21 relevant discovery request(s), and a reasonably specific description of the 22 information requested; and 23 (3) Make the information requested available for inspection by the 24 Non-Party, if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 26 14 days of receiving the notice and accompanying information, the Receiving Party 27 may produce the Non-Party’s “CONFIDENTIAL” Information responsive to the 28 discovery request. If the Non-Party timely seeks a protective order, the Receiving 11 STIPULATED PROTECTIVE ORDER 1 Party shall not produce any information in its possession or control that is subject to 2 the confidentiality agreement with the Non-Party before a determination by the 3 court. Absent a court order to the contrary, the Non-Party shall bear the burden and 4 expense of seeking protection in this court of its Protected Material. 5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 Protected Material to any person or in any circumstance not authorized under this 8 Order, the Receiving Party must immediately (a) notify in writing the Designating 9 Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 10 unauthorized copies of the Protected Material, (c) inform the person or persons to 11 whom unauthorized disclosures were made of all the terms of this Order, and (d) 12 request such person or persons to execute the Acknowledgment and Agreement to 13 Be Bound that is attached hereto as Exhibit A. 14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other protection, 18 the obligations of the Receiving Parties are those set forth in Federal Rules of Civil 19 Procedure rule 26(b)(5)(B). This provision is not intended to modify whatever 20 procedure may be established in an e-discovery order that provides for production 21 without prior privilege review. Pursuant to Federal Rules of Evidence rule 502(d) 22 and (e), insofar as the Parties reach an agreement on the effect of disclosure of a 23 communication or information covered by the attorney-client privilege or work 24 product protection, the Parties may incorporate their agreement in the stipulated 25 protective order submitted to the court. 26 12. MISCELLANEOUS 27 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 28 person to seek its modification by the court in the future. 12 STIPULATED PROTECTIVE ORDER 1 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2 Order, no Party waives any right it otherwise would have to object to disclosing or 3 producing any information or item on any ground not addressed in this Order. 4 Similarly, no Party waives any right to object on any ground to use in evidence of 5 any of the material covered by this Order. 6 12.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Local Civil Rule 79-5. Protected Material 8 may only be filed under seal pursuant to a court order authorizing the sealing of the 9 specific Protected Material at issue. If a Party’s request to file Protected Material 10 under seal is denied by the court, then the Receiving Party may file the information 11 in the public record unless otherwise instructed by the court. Good cause must be 12 shown for the under seal filing. 13 13. FINAL DISPOSITION 14 After the final disposition of this action, as defined in paragraph 4, within 60 15 days of a written request by the Designating Party, each Receiving Party must 16 return all Protected Material to the Producing Party or destroy such material. As 17 used in this subdivision, “all Protected Material” includes all copies, abstracts, 18 compilations, summaries and any other format reproducing or capturing any of the 19 Protected Material. Whether the Protected Material is returned or destroyed, the 20 Receiving Party must submit a written certification to the Producing Party (and, if 21 not the same person or entity, to the Designating Party) by the 60-day deadline that 22 (1) identifies (by category, where appropriate) all the Protected Material that was 23 returned or destroyed and (2) affirms that the Receiving Party has not retained any 24 copies, abstracts, compilations, summaries or any other format reproducing or 25 capturing any of the Protected Material. Notwithstanding this provision, counsel 26 are entitled to retain an archival copy of all pleadings, motion papers, trial, 27 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 28 and trial exhibits, expert reports, attorney work product, and consultant and expert 13 STIPULATED PROTECTIVE ORDER 1 work product, even if such materials contain Protected Material. Any such archival 2 copies that contain or constitute Protected Material remain subject to this Order as 3 set forth in section 4 (DURATION). 4 14. VIOLATION 5 Any violation of this Order may be punished by appropriate measures 6 including, without limitation, contempt proceedings and/or monetary sanctions. 7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 ERIN DARLING Law Offices of Erin Darling 9 10 Dated: July 30, 2018 By 11 12 /s/ ERIN DARLING Attorney at Law Attorneys for Plaintiff Jennifer Hyatt 13 LEROY SMITH County Counsel, County of Ventura 14 15 16 Dated: July 30, 2018 By /s/ EMILY T. GARDNER Assistant County Counsel 17 18 Attorneys for Defendants County of Ventura, Ventura County Sheriff’s Office and Ventura County Sheriff Geoff Dean 19 20 21 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 23 24 Dated: August 1, 2018 ____________________________________ Hon. Paul L. Abrams United States Magistrate Judge 25 26 27 28 14 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of [print or type full address], declare under 4 penalty of perjury that I have read in its entirety and understand the Stipulated 5 Protective Order that was issued by the United States District Court for the Central 6 District of California on [date] in the case of _________________________ [insert 7 formal name of the case and the number and initials assigned to it by the court]. I 8 agree to comply with and to be bound by all the terms of this Stipulated Protective 9 Order and I understand and acknowledge that failure to so comply could expose me 10 to sanctions and punishment in the nature of contempt. I solemnly promise that I 11 will not disclose in any manner any information or item that is subject to this 12 Stipulated Protective Order to any person or entity except in strict compliance with 13 the provisions of this order. I further agree to submit to the jurisdiction of the 14 United States District Court for the Central District of California for enforcing the 15 terms of this Stipulated Protective Order, even if such enforcement proceedings 16 occur after termination of this action. I hereby appoint ______________________ 17 [print or type full name] of _________________________ [print or type full 18 address and telephone number] as my California agent for service of process in 19 connection with this action or any proceedings related to enforcement of this 20 Stipulated Protective Order. 21 Date: ______________________________ 22 City and State where sworn and signed: 23 ____________________________________ 24 Printed name: _________________________ 25 Signature: 26 ___________________________________ 27 28 15 STIPULATED PROTECTIVE ORDER

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