United States of America v. Southern California Edison Company et al

Filing 27

STIPULATED PROTECTIVE ORDER by Magistrate Judge A. Joel Richlin re Stipulation for Protective Order 26 . (See Order for details). (et)

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1 2 3 4 5 6 7 8 9 10 11 JOSEPH T. MCNALLY First Assistant United States Attorney DAVID M. HARRIS Assistant United States Attorney Chief, Civil Division JOANNE S. OSINOFF Assistant United States Attorney Chief, Complex and Defensive Litigation Section SARAH QUIST (Cal. Bar No. 288264) JOSEPH W. TURSI (Cal. Bar No. 300063) Assistant United States Attorneys Federal Building, Suite 7516 300 North Los Angeles Street Los Angeles, California 90012 Telephone: (213) 894-0609 | 3989 Facsimile: (213) 894-7819 E-mail: Sarah.Quist@usdoj.gov Joseph.Tursi@usdoj.gov Attorneys for Plaintiff UNITED STATES OF AMERICA 12 13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA 15 WESTERN DIVISION 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES OF AMERICA, v. Case No. 2:23-cv-07254-FLA-AJR Plaintiff, DISCOVERY MATTER SOUTHERN CALIFORNIA EDISON COMPANY, et al., Defendants. [PROPOSED] STIPULATED PROTECTIVE ORDER Honorable A. Joel Richlin United States Magistrate Judge 1 2 1. GENERAL 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 production of confidential, proprietary, or private information for which special 4 protection from public disclosure and from use for any purpose other than prosecuting 5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 6 petition the Court to enter the following Stipulated Protective Order. The parties 7 acknowledge that this Order does not confer blanket protections on all disclosures or 8 responses to discovery and that the protection it affords from public disclosure and 9 use extends only to the limited information or items that are entitled to confidential 10 treatment under the applicable legal principles. The parties further acknowledge, as 11 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle 12 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 13 procedures that must be followed and the standards that will be applied when a party 14 seeks permission from the court to file material under seal. 15 1.2 Good Cause Statement. 16 This action is likely to involve financial, technical, proprietary, and/or trade 17 secret information for which special protection from public disclosure and from use 18 for any purpose other than prosecution of this action is warranted. Such confidential 19 and proprietary materials and information consist of, among other things, trade 20 secrets, confidential business or financial information; personally identifying 21 information about witnesses, including dates of birth, social security numbers, 22 driver’s license numbers, home addresses, and phone numbers; and information 23 otherwise generally unavailable to the public, such as images of law enforcement 24 officers, or which may be privileged or otherwise protected from disclosure under 25 state or federal statutes, court rules, case decisions, or common law. Accordingly, to 26 expedite the flow of information, to facilitate the prompt resolution of disputes over 27 confidentiality of discovery materials, to adequately protect information the parties 28 are entitled to keep confidential, to ensure that the parties are permitted reasonable 2 1 necessary uses of such material in preparation for and in the conduct of trial, to 2 address their handling at the end of the litigation, and to serve the ends of justice, a 3 protective order for such information is justified in this matter. It is the intent of the 4 parties that information will not be designated as confidential for tactical reasons 5 and that nothing be so designated without a good faith belief that it has been 6 maintained in a confidential, non-public manner, and there is good cause why it 7 should not be part of the public record of this case. 8 2. 9 DEFINITIONS 2.1 Action: This pending federal lawsuit, captioned United States of 10 America v. Southern California Edison Company, et al., United States District Court, 11 Central District of California, Case No. 2:23-cv-07254-FLA-AJR. 12 13 14 2.2 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for protection 16 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 17 Cause Statement. 18 2.4 19 20 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 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” 23 2.6 Disclosure or Discovery Material: all items or information, regardless 24 of the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced or 26 generated in disclosures or responses to discovery in this matter. 27 28 3 2.7 1 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 2.8 4 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 2.9 7 8 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm that 12 has appeared on behalf of that party, including support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 16 17 Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES 24 ONLY.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 25 26 from a Producing Party. 27 // 28 // 4 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or extracted 4 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 5 Protected Material; and (3) any testimony, conversations, or presentations by Parties 6 or their Counsel that might reveal Protected Material, other than during a court 7 hearing or at trial. 8 Any use of Protected Material during a court hearing or at trial shall be 9 governed by the orders of the trial judge. This Order does not govern the use of 10 Protected Material during a court hearing or at trial. 11 4. DURATION Even after final disposition of this litigation, the confidentiality obligations 12 13 imposed by this Order shall remain in effect until a Designating Party agrees 14 otherwise in writing or a court order otherwise directs. Final disposition shall be 15 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 16 or without prejudice; and (2) final judgment herein after the completion and 17 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 18 including the time limits for filing any motions or applications for extension of time 19 pursuant to applicable law. 20 5. 21 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 22 Each Party or Non-Party that designates information or items for protection under this 23 Order must take care to limit any such designation to specific material that qualifies 24 under the appropriate standards. The Designating Party must designate for protection 25 only those parts of material, documents, items, or oral or written communications that 26 qualify so that other portions of the material, documents, items, or communications 27 for which protection is not warranted are not swept unjustifiably within the ambit of 28 this Order. 5 1 Mass, indiscriminate, or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to impose 4 unnecessary expenses and burdens on other parties) may expose the Designating Party 5 to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 promptly notify all other Parties that it is withdrawing the inapplicable designation. 9 5.2 Manner and Timing of Designations. Except as otherwise provided in 10 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 12 under this Order must be clearly so designated before the material is disclosed or 13 produced. 14 Designation in conformity with this Order requires: 15 (a) for information in documentary form (e.g., paper or electronic 16 documents, but excluding transcripts of depositions or other pretrial or trial 17 proceedings), that the Producing Party affix, at a minimum, the legend 18 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY”, to each 19 page that contains protected material. If only a portion or portions of the material on 20 a page qualifies for protection, the Producing Party also must clearly identify the 21 protected portion(s) (e.g., by making appropriate markings in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and 25 before the designation, all of the material made available for inspection shall be 26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 27 it wants copied and produced, the Producing Party must determine which documents, 28 or portions thereof, qualify for protection under this Order. Then, before producing 6 1 the specified documents, the Producing Party must affix the “CONFIDENTIAL” or 2 “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” legend to each page that contains 3 Protected Material. If only a portion or portions of the material on a page qualifies 4 for protection, the Producing Party also must clearly identify the protected portion(s) 5 (e.g., by making appropriate markings in the margins). 6 (b) for testimony given in depositions, testimony may be designated as 7 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY” by 8 indicating such designation on the record at the time the testimony is given or by 9 sending written notice of how portions of the transcript of the testimony are 10 designated within 30 days of receipt of the transcript of the testimony. If no indication 11 is made on the record, all information disclosed during a deposition shall be deemed 12 “CONFIDENTIAL” until the time within which it may be appropriately designated 13 as provided for herein has passed. 14 (c) for information produced in some form other than documentary and 15 for any other tangible items, that the Producing Party affix in a prominent place on 16 the exterior of the container or containers in which the information is stored the legend 17 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY.” If only 18 a portion or portions of the information warrants protection, the Producing Party, to 19 the extent practicable, shall identify the protected portion(s). 5.3 20 Inadvertent Failures to Designate. If timely corrected, an inadvertent 21 failure to designate qualified information or items does not, standing alone, waive the 22 Designating Party’s right to secure protection under this Order for such material. 23 Upon timely correction of a designation, the Receiving Party must make reasonable 24 efforts to assure that the material is treated in accordance with the provisions of this 25 Order. 26 // 27 // 28 // 7 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 2 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 Scheduling Order. 6.2 5 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly 7 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 6.3 8 Burden. The burden of persuasion in any such challenge proceeding 9 shall be on the Designating Party. Frivolous challenges, and those made for an 10 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 11 other parties) may expose the Challenging Party to sanctions. Unless the Designating 12 Party has waived or withdrawn the confidentiality designation, all parties shall 13 continue to afford the material in question the level of protection to which it is entitled 14 under the Producing Party’s designation until the Court rules on the challenge. 15 7. 16 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 17 disclosed or produced by another Party or by a Non-Party in connection with this 18 Action only for prosecuting, defending, or attempting to settle this Action. Such 19 Protected Material may be disclosed only to the categories of persons and under the 20 conditions described in this Order. When the Action has been terminated, a Receiving 21 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 22 Protected Material must be stored and maintained by a Receiving Party at a 23 location and in a secure manner that ensures that access is limited to the persons 24 authorized under this Order. 25 7.2 Disclosure of “CONFIDENTIAL” or “CONFIDENTIAL- 26 ATTORNEYS’ EYES ONLY” Information or Items. Unless otherwise ordered by 27 the Court or permitted in writing by the Designating Party, a Receiving Party may 28 8 1 disclose any information or item designated “CONFIDENTIAL” 2 “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” only to: or 3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 4 well as employees of said Outside Counsel of Record to whom it is reasonably 5 necessary to disclose the information for this Action; 6 (b) the officers, directors, and employees (including House Counsel) of 7 the Receiving Party to whom disclosure is reasonably necessary for this Action; 8 except material designated “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” may 9 be disclosed only to the Receiving Party’s House Counsel and their administrative 10 staff to whom it is reasonably necessary to disclose the information in this Action; 11 (c) Experts (as defined in this Order) of the Receiving Party to whom 12 disclosure is reasonably necessary for this Action and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (d) the Court and its personnel; 15 (e) court reporters and their staff to whom disclosure is reasonably 16 necessary for this Action; 17 (f) professional jury or trial consultants, mock jurors, and Professional 18 Vendors to whom disclosure is reasonably necessary for this Action and who have 19 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 21 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 22 (h) during their depositions, witnesses, and attorneys for witnesses, in 23 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 24 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 25 will not be permitted to keep any confidential information unless they sign the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 27 agreed by the Designating Party or ordered by the Court. Pages of transcribed 28 deposition testimony or exhibits to depositions that reveal Protected Material may be 9 1 separately bound by the court reporter and may not be disclosed to anyone except as 2 permitted under this Stipulated Protective Order; and (i) any mediator or settlement officer, and their supporting personnel, 3 4 mutually agreed upon by any of the parties engaged in settlement discussions. 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 6 PRODUCED IN OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” that Party 10 must: (a) promptly notify in writing the Designating Party. Such notification shall 11 12 include a copy of the subpoena or court order; 13 (b) promptly notify in writing the party who caused the subpoena or order to 14 issue in the other litigation that some or all of the material covered by the subpoena 15 or order is subject to this Protective Order. Such notification shall include a copy of 16 this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued 17 18 by the Designating Party whose Protected Material may be affected. 19 If the Designating Party timely seeks a protective order, the Party served with 20 the subpoena or court order shall not produce any information designated in this action 21 as “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” before 22 a determination by the court from which the subpoena or order issued, unless the Party 23 has obtained the Designating Party’s permission. The Designating Party shall bear 24 the burden and expense of seeking protection in that court of its confidential material 25 and nothing in these provisions should be construed as authorizing or encouraging a 26 Receiving Party in this Action to disobey a lawful directive from another court. 27 // 28 // 10 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL” or “CONFIDENTIAL- 5 ATTORNEYS’ EYES ONLY.” 6 connection with this litigation is protected by the remedies and relief provided by this 7 Order. Nothing in these provisions should be construed as prohibiting a Non-Party 8 from seeking additional protections. Such information produced by Non-Parties in 9 (b) In the event that a Party is required, by a valid discovery request, to produce 10 a Non-Party’s confidential information in its possession, and the Party is subject to an 11 agreement with the Non-Party not to produce the Non-Party’s confidential 12 information, then the Party shall: 13 (1) promptly notify in writing the Requesting Party and the Non-Party 14 that some or all of the information requested is subject to a confidentiality agreement 15 with a Non-Party; 16 (2) promptly provide the Non-Party with a copy of the Stipulated 17 Protective Order in this Action, the relevant discovery request(s), and a reasonably 18 specific description of the information requested; and 19 20 (3) make the information requested available for inspection by the NonParty, if requested. 21 (c) If the Non-Party fails to seek a protective order from this Court within 14 22 days of receiving the notice and accompanying information, the Receiving Party may 23 produce the Non-Party’s confidential information responsive to the discovery request. 24 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 25 any information in its possession or control that is subject to the confidentiality 26 agreement with the Non-Party before a determination by the Court unless otherwise 27 required by the law or court order. Absent a court order to the contrary, the Non- 28 11 1 Party shall bear the burden and expense of seeking protection in this Court of its 2 Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 9 persons to whom unauthorized disclosures were made of all the terms of this Order, 10 and (d) request such person or persons to execute the “Acknowledgment and 11 Agreement to Be Bound” that is attached hereto as Exhibit A. 12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 13 PROTECTED MATERIAL 14 When a Producing Party gives notice to Receiving Parties that certain 15 inadvertently produced material is subject to a claim of privilege or other protection, 16 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 17 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 18 may be established in an e-discovery order that provides for production without prior 19 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 20 parties reach an agreement on the effect of disclosure of a communication or 21 information covered by the attorney-client privilege or work product protection, the 22 parties may incorporate their agreement in the stipulated protective order submitted 23 to the Court. 24 12. 25 26 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. 27 12.2 Right to Assert Other Objections. By stipulating to the entry of this 28 Protective Order, no Party waives any right it otherwise would have to object to 12 1 disclosing or producing any information or item on any ground not addressed in this 2 Stipulated Protective Order. Similarly, no Party waives any right to object on any 3 ground to use in evidence of any of the material covered by this Protective Order. 4 12.3 Filing Protected Material. A Party that seeks to file under seal any 5 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 6 only be filed under seal pursuant to a court order authorizing the sealing of the specific 7 Protected Material at issue; good cause must be shown in the request to file under 8 seal. If a Party’s request to file Protected Material under seal is denied by the Court, 9 then the Receiving Party may file the information in the public record unless 10 otherwise instructed by the Court. 11 13. FINAL DISPOSITION 12 After the final disposition of this Action, as defined in paragraph 4, within 60 13 days of a written request by the Designating Party, each Receiving Party must return 14 all Protected Material to the Producing Party or destroy such material. As used in this 15 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 16 summaries, and any other format reproducing or capturing any of the Protected 17 Material. Whether the Protected Material is returned or destroyed, the Receiving 18 Party must submit a written certification to the Producing Party (and, if not the same 19 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 20 (by category, where appropriate) all the Protected Material that was returned or 21 destroyed, and (2) affirms that the Receiving Party has not retained any copies, 22 abstracts, compilations, summaries or any other format reproducing or capturing any 23 of the Protected Material. Notwithstanding this provision, counsel are entitled to 24 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 25 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 26 reports, attorney work product, and consultant and expert work product, even if such 27 materials contain Protected Material. Any such archival copies that contain or 28 13 1 constitute Protected Material remain subject to this Protective Order as set forth in 2 Section 4 (DURATION). 3 14. VIOLATION OF ORDER 4 Any violation of this Order may be punished by any and all appropriate 5 measures including, without limitation, contempt proceedings and/or monetary 6 sanctions. 7 8 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 10 Respectfully submitted, Dated: May 7, 2024 11 12 13 14 15 JOSEPH T. MCNALLY First Assistant United States Attorney DAVID M. HARRIS Assistant United States Attorney Chief, Civil Division JOANNE S. OSINOFF Assistant United States Attorney Chief, Complex and Defensive Litigation Section 17 /s/ Joseph W. Tursi SARAH QUIST JOSEPH W. TURSI Assistant United States Attorneys 18 Attorneys for Plaintiff UNITED STATES OF AMERICA 16 19 20 21 22 23 24 Dated: May 7, 2024 HUESTON HENNIGAN LLP /s/ Brandon Marsh John C. Hueston Douglas J. Dixon Brandon Marsh* Attorneys for Defendant Southern California Edison Company 25 26 27 28 14 1 Dated: May 7, 2024 CARLSON, CALLADINE & PETERSON LLP 2 3 4 5 /s/ Colin C. Munro David Bona Colin C. Munro* Attorneys for Defendant Utility Tree Service, LLC 6 7 8 *Pursuant to Local Rule 5-4.3.4(2), the filer attests that all signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 4 5/7/24 DATED:_______________ __________________________________ HON. A. JOEL RICHLIN United States Magistrate Judge 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 16 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 for the Central District of California on ____________ [date] in the 8 case of United States of America v. Southern California Edison, et al., 2:23-cv- 9 07254-FLA-AJR. I agree to comply with and to be bound by all the terms of this 10 Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that 13 is subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [full 19 name] of _______________________________________ [full address, telephone 20 number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Stipulated Protective Order. 22 Date: ______________________________________ 23 24 City and State where signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 17

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