Dieter Hartmann v. Tyler Bates et al

Filing 18

PROTECTIVE ORDER by Magistrate Judge Michael R. Wilner. re Stipulation for Protective Order 17 (vm)

1
2
3
4
5
6
7
8

Peter Anderson, Esq., Cal. Bar No. 88891
[e-mail]
Alonzo Wickers IV, Esq., Cal. Bar No. 169454
[e-mail]
Nicolette Vairo, Esq., Cal. Bar No. 311592
[e-mail]
DAVIS WRIGHT TREMAINE LLP
865 South Figueroa Street, Suite 2400
Los Angeles, CA 90017-2566
Tel: [phone]
Fax: [phone]
Attorney for Defendants
FOCUS FEATURES, LLC, and
FOCUS FEATURES PRODUCTIONS, LLC

9
10

UNITED STATES DISTRICT COURT

11

CENTRAL DISTRICT OF CALIFORNIA
DIETER HARTMANN,

12

Plaintiff,

13
v.

14

TYLER BATES; TYLER BATES
MUSIC INC.; FOCUS FEATURES,
LLC; FOCUS FEATURES
PRODUCTIONS, LLC,

15
16
17

Defendants.

18

Case No. 2:19-cv-05273-AB(MRWx)
STIPULATED PROTECTIVE
ORDER
(MRW VERSION 4/19)
Check if submitted without
material modifications to MRW form

19
20
21

1.

INTRODUCTION

22

1.1

PURPOSES AND LIMITATIONS

23

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

24

proprietary, or private information for which special protection from public disclosure

25

and from use for any purpose other than prosecuting this litigation may be warranted.

26

Accordingly, the parties hereby stipulate to and petition the Court to enter the

27

following Stipulated Protective Order. The parties acknowledge that this Order does

28

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

1

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

2

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

3

legal principles. The parties further acknowledge, as set forth in Section 12.3, below,

4

that this Stipulated Protective Order does not entitle them to file confidential

5

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

6

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

7

the court to file material under seal.

8

1.2

9

This case involves claims of copyright infringement relating to the creation and

10

distribution of certain recorded musical compositions. As a result, this action is likely

11

to involve trade secrets, customer and pricing lists and other valuable research,

12

development, commercial, financial, technical and/or proprietary information for

13

which special protection from public disclosure and from use for any purpose other

14

than prosecution of this action is warranted. Such confidential and proprietary

15

materials and information consist of, among other things, confidential business or

16

financial information, information regarding confidential business practices, or other

17

confidential research, development, or commercial information (including

18

information implicating privacy rights of third parties), information otherwise

19

generally unavailable to the public, or which may be privileged or otherwise protected

20

from disclosure under state or federal statutes, court rules, case decisions, or common

21

law, and material or information that is subject to a written independent obligation of

22

confidentiality. Accordingly, to expedite the flow of information, to facilitate the

23

prompt resolution of disputes over confidentiality of discovery materials, to

24

adequately protect information the parties are entitled to keep confidential, to ensure

25

that the parties are permitted reasonable necessary uses of such material in preparation

26

for and in the conduct of trial, to address their handling at the end of the litigation,

27

and serve the ends of justice, a protective order for such information is justified in this

28

matter. It is the intent of the parties that information will not be designated as

GOOD CAUSE STATEMENT

2

1

confidential for tactical reasons and that nothing be so designated without a good faith

2

belief that it has been maintained in a confidential, non-public manner, and there is

3

good cause why it should not be part of the public record of this case.

4
5

2.

DEFINITIONS

6

2.1

Action: this pending federal lawsuit.

7

2.2

Challenging Party: a Party or Non-Party that challenges the designation

8
9

of information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless of

10

how it is generated, stored or maintained) or tangible things that qualify for

11

protection under Federal Rule of Civil Procedure 26(c), and as specified above in

12

the Good Cause Statement

13
14
15

2.4

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

support staff).
2.5

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

16

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

17

“CONFIDENTIAL.”

18

2.6

Disclosure or Discovery Material: all items or information, regardless

19

of the medium or manner in which it is generated, stored, or maintained (including,

20

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

21

generated in disclosures or responses to discovery in this matter.

22

2.7

Expert: a person with specialized knowledge or experience in a matter

23

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

24

an expert witness or as a consultant in this Action.

25

2.8

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

26

House Counsel does not include Outside Counsel of Record or any other outside

27

counsel.

28
3

1
2

2.9

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

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

3

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

4

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

5

appeared in this Action on behalf of that party or are affiliated with a law firm which

6

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

7

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

8

employees, consultants, retained experts, and Outside Counsel of Record (and their

9

support staffs).

10
11

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

12

2.13 Professional Vendors: persons or entities that provide litigation support

13

services (e.g., photocopying, videotaping, translating, preparing exhibits or

14

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

15

and their employees and subcontractors.

16

2.14 Protected Material:

17

designated as “CONFIDENTIAL.”

18
19

any Disclosure or Discovery Material that is

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

20
21

3.

SCOPE

22

The protections conferred by this Stipulation and Order cover not only

23

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

24

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

25

Protected Material; and (3) any testimony, conversations, or presentations by Parties

26

or their Counsel that might reveal Protected Material.

27
28

Any use of Protected Material at trial will be governed by the orders of the trial
judge. This Order does not govern the use of Protected Material at trial.
4

1
2

4.

DURATION

3

Even after final disposition of this litigation, the confidentiality obligations

4

imposed by this Order will remain in effect until a Designating Party agrees otherwise

5

in writing or a court order otherwise directs. Final disposition will be deemed to be

6

the later of (1) dismissal of all claims and defenses in this Action, with or without

7

prejudice; and (2) final judgment herein after the completion and exhaustion of all

8

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

9

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

10

applicable law.

11
12
13

5.

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

14

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

15

Order must take care to limit any such designation to specific material that qualifies

16

under the appropriate standards. The Designating Party must designate for protection

17

only those parts of material, documents, items, or oral or written communications that

18

qualify so that other portions of the material, documents, items, or communications

19

for which protection is not warranted are not swept unjustifiably within the ambit of

20

this Order.

21

Mass, indiscriminate, or routinized designations are prohibited. Designations

22

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

23

purpose (e.g., to unnecessarily encumber the case development process or to impose

24

unnecessary expenses and burdens on other parties) may expose the Designating Party

25

to sanctions.

26

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

27

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

28

promptly notify all other Parties that it is withdrawing the inapplicable designation.
5

1

5.2

Manner and Timing of Designations. Except as otherwise provided in

2

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

3

stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

4

under this Order must be clearly so designated before the material is disclosed or

5

produced.

6

Designation in conformity with this Order requires:

7

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

8

but excluding transcripts of depositions or other pretrial or trial proceedings), that the

9

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

10

“CONFIDENTIAL legend”), to each page that contains protected material. If only a

11

portion or portions of the material on a page qualifies for protection, the Producing

12

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

13

markings in the margins).

14

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

15

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

16

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

17

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

18

deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

19

it wants copied and produced, the Producing Party must determine which documents,

20

or portions thereof, qualify for protection under this Order. Then, before producing

21

the specified documents, the Producing Party must affix the “CONFIDENTIAL

22

legend” to each page that contains Protected Material. If only a portion or portions

23

of the material on a page qualifies for protection, the Producing Party also must clearly

24

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

25

margins).

26

(b) for testimony given in depositions Parties and deponents may, within thirty

27

(30) days after receiving a transcript of a deposition, designate pages of the transcript

28

(and exhibits thereto) as Confidential to the extent the Party or deponent believes they
6

1

contain material or information entitled to that protection. Confidential information

2

within the deposition transcript may be designated only by sending a letter indicating

3

the page and line numbers of the deposition transcript that the Party or deponent

4

designates as Confidential to the party who took the deposition and to the court

5

reporter. Until the expiration of the 30-day period during which such designations

6

may be made, the transcript of the deposition will be treated as subject to protection

7

as Confidential under this Stipulated Protective Order. Further, to avoid misuse of

8

audiovisual recordings of depositions to embarrass or harass a party or witness, and

9

consistent with the limitations of California Rule of Professional Conduct 3.6

10

(adopted by this Court under Local Rule 83-3.1.2) upon extrajudicial statements likely

11

to materially prejudice an adjudicative proceeding, all audiovisual recordings of

12

depositions shall be used solely for the prosecution or defense of this action and shall

13

not be posted on the Internet or otherwise publicly exhibited, publicly distributed, or

14

disclosed to anyone other than Parties, House Counsel and Experts, other than if

15

played in open court in, or otherwise used in the prosecution or defense of, this action

16

or the action styled entitled Kurt Oldman, et al. vs. Tyler Bates, et al., Los Angeles

17

Superior Court Case No. 18STCV01060 (the “State Case”), or as may be permitted

18

by further order of this Court or the Court in the State Case. The foregoing provision

19

does not, however, authorize the State Court in the State Action to permit the use or

20

disclosure of material or information that has been designated “CONFIDENTIAL”

21

pursuant to this Stipulated Protective Order and appears in the audiovisual recordings,

22

and, instead, any use or disclosure of that material or information designated

23

“CONFIDENTIAL” shall be governed by paragraph 8 of this Stipulated Protective

24

Order.

25

(c) for information produced in some form other than documentary and for any

26

other tangible items, that the Producing Party affix in a prominent place on the exterior

27

of the container or containers in which the information is stored the legend

28

“CONFIDENTIAL.” If only a portion or portions of the information warrants
7

1

protection, the Producing Party, to the extent practicable, will identify the protected

2

portion(s).

3

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

4

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

5

Designating Party’s right to secure protection under this Order for such material.

6

Upon timely correction of a designation, the Receiving Party must make reasonable

7

efforts to assure that the material is treated in accordance with the provisions of this

8

Order.

9
10

6.

11

CHALLENGING CONFIDENTIALITY DESIGNATIONS
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 will initiate the dispute

15

resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1

16

et seq.

17

6.3

The burden of persuasion in any such challenge proceeding will be on

18

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

19

(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

20

expose the Challenging Party to sanctions. Unless the Designating Party has waived

21

or withdrawn the confidentiality designation, all parties will continue to afford the

22

material in question the level of protection to which it is entitled under the Producing

23

Party’s designation until the Court rules on the challenge.

24
25
26

7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is

27

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

28

Action only for prosecuting, defending, or attempting to settle this Action. Such
8

1

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

2

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

3

Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

4

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

5

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

6

authorized under this Order.

7

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

8

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

9

Receiving

10

Party

may

disclose

any

information

or

item

designated

“CONFIDENTIAL” only to:

11

(a) the Receiving Party and the Receiving Party’s Outside Counsel of

12

Record in this Action, as well as employees of said Outside Counsel of Record to

13

whom it is reasonably necessary to disclose the information for this Action;

14
15

(b) the officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably necessary for this Action;

16

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

17

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

18

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

19

(d) the Court and its personnel;

20

(e) court reporters and their staff;

21

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

22

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

23

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

24
25

(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;

26

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

27

Action to whom disclosure is reasonably necessary provided: (1) the deposing party

28

requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
9

1

not be permitted to keep any confidential information unless they sign the

2

“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

3

agreed by the Designating Party or ordered by the court. Pages of transcribed

4

deposition testimony or exhibits to depositions that reveal Protected Material may be

5

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

6

permitted under this Stipulated Protective Order; and

7
8

(i) any mediator or settlement officer, and their supporting personnel, mutually
agreed upon by any of the parties engaged in settlement discussions.

9
10

8.

11

ORDERED PRODUCED, OR OTHERWISE SOUGHT TO BE USED, IN OTHER

12

LITIGATION

PROTECTED MATERIAL SUBPOENAED, SOUGHT IN DISCOVERY,

13

If a Party is served with a subpoena, discovery request, or a court order issued

14

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

15

this Action as “CONFIDENTIAL,” or if a Party wishes to disclose in other litigation

16

any information or items designated in this Action as “CONFIDENTIAL,” that Party

17

must:

18

(a) promptly notify in writing the Designating Party prior to the disclosure.

19

Such notification will include, as applicable, a copy of the subpoena, discovery

20

request, or court order or a description of the proposed disclosure;

21

(b) in the case of a subpoena, discovery request, or court order compelling

22

disclosure, promptly notify in writing the party who caused the subpoena, discovery

23

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

24

by the subpoena, discovery request, or order is subject to this Protective Order. Such

25

notification will include a copy of this Stipulated Protective Order; and

26
27

(c) cooperate with respect to all reasonable procedures sought to be pursued
by the Designating Party whose Protected Material may be affected.

28
10

1

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

2

the subpoena, discovery request, or court order or who seeks to disclose information

3

or items designated in this Action as “CONFIDENTIAL,” will not produce any

4

information designated in this Action as “CONFIDENTIAL” before a determination

5

by the court in the other litigation, unless the Party has obtained the Designating

6

Party’s permission. The Designating Party will bear the burden and expense of

7

seeking protection in that court of its confidential material and nothing in these

8

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

9

this Action to disobey a lawful directive from another court.

10
11

9.

12

PRODUCED IN THIS LITIGATION

13

A

NON-PARTY’S

PROTECTED

MATERIAL

SOUGHT

TO

BE

(a) The terms of this Order are applicable to information produced by a

14

Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

15

produced by Non-Parties in connection with this litigation is protected by the

16

remedies and relief provided by this Order. Nothing in these provisions should be

17

construed as prohibiting a Non-Party from seeking additional protections.

18

(b) In the event that a Party is required, by a valid discovery request, to

19

produce a Non-Party’s confidential information in its possession, and the Party is

20

subject to an agreement with the Non-Party not to produce the Non-Party’s

21

confidential information, then the Party will:

22

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

23

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

24

with a Non-Party;

25

(2) promptly provide the Non-Party with a copy of the Stipulated

26

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

27

specific description of the information requested; and

28
11

1
2

(3) make the information requested available for inspection by the NonParty, if requested.

3

(c) If the Non-Party fails to seek a protective order from this court within

4

14 days of receiving the notice and accompanying information, the Receiving Party

5

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

6

request. If the Non-Party timely seeks a protective order, the Receiving Party will not

7

produce any information in its possession or control that is subject to the

8

confidentiality agreement with the Non-Party before a determination by the court.

9

Absent a court order to the contrary, the Non-Party will bear the burden and expense

10

of seeking protection in this court of its Protected Material.

11
12

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

13

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

14

Protected Material to any person or in any circumstance not authorized under this

15

Stipulated Protective Order, the Receiving Party must immediately (a) notify in

16

writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

17

to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

18

persons to whom unauthorized disclosures were made of all the terms of this Order,

19

and (d) request such person or persons to execute the “Acknowledgment and

20

Agreement to Be Bound” that is attached hereto as Exhibit A.

21
22

11.

23

PROTECTED MATERIAL

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

24

When a Producing Party gives notice to Receiving Parties that certain

25

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

26

the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

27

Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

28

may be established in an e-discovery order that provides for production without prior
12

1

privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

2

parties reach an agreement on the effect of disclosure of a communication or

3

information covered by the attorney-client privilege or work product protection, the

4

parties may incorporate their agreement in the stipulated protective order submitted

5

to the court.

6
7

12.

8
9

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.

10

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

11

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

12

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

13

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

14

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

15

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

16

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

17

only be filed under seal pursuant to a court order authorizing the sealing of the specific

18

Protected Material at issue. If a Party's request to file Protected Material under seal

19

is denied by the court, then the Receiving Party may file the information in the public

20

record unless otherwise instructed by the court.

21
22

13.

FINAL DISPOSITION

23

After the final disposition of this Action, as defined in paragraph 4, within 60

24

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

25

all Protected Material to the Producing Party or destroy such material. As used in this

26

subdivision, “all Protected Material” includes all copies, abstracts, compilations,

27

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

28

Material. Whether the Protected Material is returned or destroyed, the Receiving
13

1

Party must submit a written certification to the Producing Party (and, if not the same

2

person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

3

(by category, where appropriate) all the Protected Material that was returned or

4

destroyed and (2) affirms that the Receiving Party has not retained any copies,

5

abstracts, compilations, summaries or any other format reproducing or capturing any

6

of the Protected Material. Notwithstanding this provision, Counsel are entitled to

7

retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

8

transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

9

reports, attorney work product, and consultant and expert work product, even if such

10

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

11

constitute Protected Material remain subject to this Protective Order as set forth in

12

Section 4 (DURATION).

13
14

14.

15

contempt proceedings, financial or evidentiary sanctions, reference to disciplinary

16

authorities, or other appropriate action at the discretion of the Court.

Any willful violation of this Order may be punished by civil or criminal

17
18

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

19

DATED: September __, 2019

GUTMAN LAW

20
21

By:
___________
Alan S. Gutman
John Juenger
Attorneys for Plaintiff Dieter Hartmann

22
23
24

Dated: September __, 2019

THEODORA ORINGER PC

25
26
27
28

By:
Edward E. Johnson
Katherine J. Flores
Attorneys for Defendants Tyler Bates and
Tyler Bates Music, Inc.
14

1

Dated: September __, 2019

DAVIS WRIGHT TREMAINE LLP

2
3

By:
_________
Peter Anderson
Alonzo Wickers IV
Nicolette Vairo
Attorneys for Defendants Focus Features,
LLC and Focus Features Productions, LLC

4
5
6
7
8
9
10

Attestation Regarding Signatures
The undersigned attests that all signatories listed, and on whose behalf this
filing is submitted, concur in this filing’s content and have authorized its filing.

11
12

Dated: October 7, 2019

13

____________________________
Peter Anderson, Esq.

14
15
16
17

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

18
19
20
21

DATED: October 7, 2019

__________________________________
HON. MICHAEL R. WILNER
United States Magistrate Judge

22
23
24
25
26
27
28
15

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3
4

I, _____________________________ [full name], of _________________

5

[full address], declare under penalty of perjury that I have read in its entirety and

6

understand the Stipulated Protective Order that was issued by the United States

7

District Court Hartmann v. Bates, et al. Case No. 2:19-cv-05273-AB-MRWx. I agree

8

to comply with and to be bound by all the terms of this Stipulated Protective Order

9

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

10

sanctions and punishment in the nature of contempt. I solemnly promise that I will

11

not disclose in any manner any information or item that is subject to this Stipulated

12

Protective Order to any person or entity except in strict compliance with the

13

provisions of this Order.

14

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

15

for the Central District of California for the purpose of enforcing the terms of this

16

Stipulated Protective Order, even if such enforcement proceedings occur after

17

termination of this action. I hereby appoint __________________________ [full

18

name] of _______________________________________ [full address and

19

telephone number] as my California agent for service of process in connection with

20

this action or any proceedings related to enforcement of this Stipulated Protective

21

Order.

22

Date: ______________________________________

23

City and State where signed: _________________________________

24
25

Printed name: _______________________________

26
27

Signature: __________________________________

28
16