Chanel, Inc. v. Royals Closet et al

Filing 20

PROTECTIVE ORDER by Magistrate Judge Michael R. Wilner re Stipulation for Protective Order 19 . (see document for details) (hr)

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1 2 3 4 5 6 7 8 9 10 11 12 13 Brent H. Blakely (SBN 157292) Tara A. Currie (SBN 323984) BLAKELY LAW GROUP 1334 Parkview Avenue, Suite 280 Manhattan Beach, California 90266 Telephone: (310) 546-7400 Facsimile: (310) 546-7401 Attorneys for Plaintiff Chanel, Inc. Omid E. Khalifeh, SBN 267340 Ariana Santoro, SBN 300767 Louise Jillian Paris, SBN 347801 OMNI LEGAL GROUP 2029 Century Park E, Suite 438 Los Angeles, California 90067 Telephone: (310) 276-6664 Facsimile: (310) 305-1550 Attorneys for Defendant Royal’s Closet 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 Chanel, Inc., 17 Plaintiff, 18 v. 19 Royal’s Closet, et al. 20 Defendant. 21 Case No. 2:23-cv-10375-JFW-MRW STIPULATED PROTECTIVE ORDER (MRW VERSION 4/19) Check if submitted without material modifications to MRW form 22 23 24 1. INTRODUCTION 25 1.1 26 Discovery in this action is likely to involve production of confidential, PURPOSES AND LIMITATIONS 27 proprietary, or private information for which special protection from public 28 disclosure and from use for any purpose other than prosecuting this litigation may 1 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 2 enter the following Stipulated Protective Order. The parties acknowledge that this 3 Order does not confer blanket protections on all disclosures or responses to 4 discovery and that the protection it affords from public disclosure and use extends 5 only to the limited information or items that are entitled to confidential treatment 6 under the applicable legal principles. The parties further acknowledge, as set forth 7 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 8 file confidential information under seal; Civil Local Rule 79-5 sets forth the 9 procedures that must be followed and the standards that will be applied when a party 10 11 seeks permission from the court to file material under seal. 1.2 GOOD CAUSE STATEMENT 12 This trademark infringement and counterfeiting action is likely to involve 13 trade secrets, customer and pricing lists, and other valuable research, development, 14 commercial, financial, technical and/or proprietary information for which special 15 protection from public disclosure, from disclosure of certain designated information 16 to party representatives, and from use for any purpose other than prosecution of this 17 action is warranted. Such confidential and proprietary materials and information 18 consist of, among other things, confidential business or financial information, 19 information regarding confidential business practices, or other confidential research, 20 development, or commercial information (including information implicating 21 privacy rights of third parties, such as consumer purchasers of the products at issue), 22 information otherwise generally unavailable to the public, or which may be 23 privileged or otherwise protected from disclosure under state or federal statutes, 24 court rules, case decisions, or common law. 25 Accordingly, to expedite the flow of information, to facilitate the prompt 26 resolution of disputes over confidentiality of discovery materials, to adequately 27 protect information the parties are entitled to keep confidential, to ensure that the 28 parties are permitted reasonable necessary uses of such material in preparation for 2 1 and in the conduct of trial, to address their handling at the end of the litigation, and 2 serve the ends of justice, a protective order for such information is justified in this 3 matter. It is the intent of the parties that information will not be designated as 4 confidential for tactical reasons and that nothing be so designated without a good 5 faith belief that it has been maintained in a confidential, non-public manner, and 6 there is good cause why it should not be part of the public record of this case. 7 8 9 10 11 12 13 2. DEFINITIONS 2.1 Action: Chanel, Inc. v. Royal’s Closet, et al., Case No. 2:23-cv-10375- JFW-MRW 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 14 how it is generated, stored or maintained) or tangible things that qualify for 15 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 16 the Good Cause Statement. 17 18 19 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 20 items that it produces in disclosures or in responses to discovery as 21 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 22 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 1 2.7 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. 4 2.8 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. 7 2.9 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 8 Information or Items: extremely sensitive “Confidential Information or Items,” 9 disclosure of which to another Party or Non-Party would create a substantial risk of 10 serious competitive harm that could not be avoided by less restrictive means, as 11 detailed in the Good Cause statement above. 12 13 14 2.10 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.11 Outside Counsel of Record: attorneys who are not employees of a 15 party to this Action but are retained to represent or advise a party to this Action and 16 have appeared in this Action on behalf of that party or are affiliated with a law firm 17 which has appeared on behalf of that party, and includes support staff. 18 2.12 Party: any party to this Action, including all of its officers, directors, 19 employees, consultants, retained experts, and Outside Counsel of Record (and their 20 support staffs). 21 22 2.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 23 2.14 Professional Vendors: persons or entities that provide litigation 24 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 25 demonstrations, and organizing, storing, or retrieving data in any form or medium) 26 and their employees and subcontractors. 27 28 4 2.15 Protected Material: any Disclosure or Discovery Material that is 1 2 designated as “CONFIDENTIAL” or as “HIGHLY CONFIDENTIAL – 3 ATTORNEYS’ EYES ONLY”. 2.16 Receiving Party: a Party that receives Disclosure or Discovery 4 5 Material from a Producing Party. 6 7 3. 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. Any use of Protected Material at trial will be governed by the orders of the 13 14 trial judge. This Order does not govern the use of Protected Material at trial. 15 16 4. DURATION Even after final disposition of this litigation, the confidentiality obligations 17 18 imposed by this Order will remain in effect until a Designating Party agrees 19 otherwise in writing or a court order otherwise directs. Final disposition will be 20 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 21 or without prejudice; and (2) final judgment herein after the completion and 22 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 23 including the time limits for filing any motions or applications for extension of time 24 pursuant to applicable law. 25 26 27 28 5. DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-Party that designates information or items for protection under 5 1 this Order must take care to limit any such designation to specific material that 2 qualifies under the appropriate standards. The Designating Party must designate for 3 protection only those parts of material, documents, items, or oral or written 4 communications that qualify so that other portions of the material, documents, 5 items, or communications for which protection is not warranted are not swept 6 unjustifiably within the ambit of this Order. 7 Mass, indiscriminate, or routinized designations are prohibited. Designations 8 that are shown to be clearly unjustified or that have been made for an improper 9 purpose (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating 11 Party to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic documents, 22 but excluding transcripts of depositions or other pretrial or trial proceedings), that 23 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” or 24 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (hereinafter 25 “CONFIDENTIALITY legend”), to each page that contains protected material. If 26 only a portion or portions of the material on a page qualifies for protection, the 27 Producing Party also must clearly identify the protected portion(s) (e.g., by making 28 appropriate markings in the margins). 6 A Party or Non-Party that makes original documents available for 1 2 inspection need not designate them for protection until after the inspecting Party has 3 indicated which documents it would like copied and produced. During the 4 inspection and before the designation, all of the material made available for 5 inspection will be deemed “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 6 ONLY.” After the inspecting Party has identified the documents it wants copied 7 and produced, the Producing Party must determine which documents, or portions 8 thereof, qualify for protection under this Order. Then, before producing the specified 9 documents, the Producing Party must affix the appropriate “CONFIDENTIALITY 10 legend” to each page that contains Protected Material. If only a portion or portions 11 of the material on a page qualifies for protection, the Producing Party also must 12 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 13 margins). 14 (b) for testimony given in depositions that the Designating Party identify the 15 Disclosure or Discovery Material on the record, before the close of the deposition all 16 protected testimony. 17 (c) for information produced in some form other than documentary and for 18 any other tangible items, that the Producing Party affix in a prominent place on the 19 exterior of the container or containers in which the information is stored the legend 20 appropriate “CONFIDENTIALITY legend” If only a portion or portions of the 21 information warrants protection, the Producing Party, to the extent practicable, will 22 identify the protected portion(s). 23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 24 failure to designate qualified information or items does not, standing alone, waive 25 the Designating Party’s right to secure protection under this Order for such material. 26 Upon timely correction of a designation, the Receiving Party must make reasonable 27 efforts to assure that the material is treated in accordance with the provisions of this 28 Order. 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 will initiate the dispute 6 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 7 et seq. 6.3 8 The burden of persuasion in any such challenge proceeding will be on 9 the Designating Party. Frivolous challenges, and those made for an improper 10 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 11 parties) may expose the Challenging Party to sanctions. Unless the Designating 12 Party has waived or withdrawn the confidentiality designation, all parties will 13 continue to afford the material in question the level of protection to which it is 14 entitled under the Producing Party’s designation until the Court rules on the 15 challenge. 16 17 18 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 19 disclosed or produced by another Party or by a Non-Party in connection with this 20 Action only for prosecuting, defending, or attempting to settle this Action. Such 21 Protected Material may be disclosed only to the categories of persons and under the 22 conditions described in this Order. When the Action has been terminated, a 23 Receiving Party must comply with the provisions of section 13 below (FINAL 24 DISPOSITION). 25 Protected Material must be stored and maintained by a Receiving Party at a 26 location and in a secure manner that ensures that access is limited to the persons 27 authorized under this Order. 28 8 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 otherwise ordered by the court or permitted in writing by the Designating Party, a 3 Receiving Party may disclose any information or item designated 4 “CONFIDENTIAL” only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 6 well as employees of said Outside Counsel of Record to whom it is reasonably 7 necessary to disclose the information for this Action; 8 (b) the officers, directors, and employees (including House Counsel) of 9 the Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (d) the Court and its personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and Professional 16 Vendors to whom disclosure is reasonably necessary for this Action and who have 17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 19 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 20 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 21 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 22 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 23 will not be permitted to keep any confidential information unless they sign the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 25 agreed by the Designating Party or ordered by the court. Pages of transcribed 26 deposition testimony or exhibits to depositions that reveal Protected Material may 27 be separately bound by the court reporter and may not be disclosed to anyone except 28 as permitted under this Stipulated Protective Order; and 9 (i) any mediator or settlement officer, and their supporting personnel, 1 2 mutually agreed upon by any of the parties engaged in settlement discussions. 7.3 3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 4 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in 5 writing by the Designating Party, a Receiving Party may disclose any information or 6 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only 7 to: 8 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 9 employees of said Outside Counsel of Record to whom it is reasonably necessary to 10 disclose the information for this litigation and who have signed the “Acknowledgment 11 and Agreement to Be Bound” that is attached hereto as Exhibit A; 12 (b) Experts of the Receiving Party (1) to whom disclosure is reasonably 13 necessary for this litigation and (2) who have signed the “Acknowledgment and 14 Agreement to Be Bound” (Exhibit A); 15 (c) the court and its personnel; 16 (d) court reporters and their staff, professional jury or trial consultants, and 17 Professional Vendors to whom disclosure is reasonably necessary for this litigation 18 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 19 A); (e) the author or recipient of a document containing the information or a 20 21 custodian or other person who otherwise possessed or knew the information; and (f) 22 23 any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 24 25 26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 27 IN OTHER LITIGATION 28 10 If a Party is served with a subpoena or a court order issued in other litigation 1 2 that compels disclosure of any information or items designated in this Action as 3 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 4 ONLY,” that Party must: (a) promptly notify in writing the Designating Party. Such notification 5 6 will include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order 7 8 to issue in the other litigation that some or all of the material covered by the 9 subpoena or order is subject to this Protective Order. Such notification will include 10 a copy of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be 11 12 pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with 13 14 the subpoena or court order will not produce any information designated in this 15 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 16 EYES ONLY” before a determination by the court from which the subpoena or 17 order issued, unless the Party has obtained the Designating Party’s permission. The 18 Designating Party will bear the burden and expense of seeking protection in that 19 court of its confidential material and nothing in these provisions should be construed 20 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 21 directive from another court. 22 23 9. 24 PRODUCED IN THIS LITIGATION 25 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 27 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by 28 Non-Parties in connection with this litigation is protected by the remedies and relief 11 1 provided by this Order. Nothing in these provisions should be construed as 2 prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 produce a Non-Party’s confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Party’s 6 confidential information, then the Party will: (1) promptly notify in writing the Requesting Party and the Non-Party 7 8 that some or all of the information requested is subject to a confidentiality 9 agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated 10 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and (3) make the information requested available for inspection by the 13 14 Non-Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 16 14 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party will 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party will bear the burden and expense 22 of seeking protection in this court of its Protected Material. 23 24 25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 12 1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the “Acknowledgment and 4 Agreement to Be Bound” that is attached hereto as Exhibit A. 5 6 11. 7 PROTECTED MATERIAL When a Producing Party gives notice to Receiving Parties that certain 8 9 INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 12 procedure may be established in an e-discovery order that provides for production 13 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 14 (e), insofar as the parties reach an agreement on the effect of disclosure of a 15 communication or information covered by the attorney-client privilege or work 16 product protection, the parties may incorporate their agreement in the stipulated 17 protective order submitted to the court. 18 19 20 21 22 12. 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. 12.2 Right to Assert Other Objections. By stipulating to the entry of this 23 Protective Order no Party waives any right it otherwise would have to object to 24 disclosing or producing any information or item on any ground not addressed in this 25 Stipulated Protective Order. Similarly, no Party waives any right to object on any 26 ground to use in evidence of any of the material covered by this Protective Order. 27 28 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material must comply with Civil Local Rule 79-5. Protected Material may 13 1 only be filed under seal pursuant to a court order authorizing the sealing of the 2 specific Protected Material at issue. If a Party's request to file Protected Material 3 under seal is denied by the court, then the Receiving Party may file the information 4 in the public record unless otherwise instructed by the court. 5 6 7 13. FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 4, within 60 8 days of a written request by the Designating Party, each Receiving Party must return 9 all Protected Material to the Producing Party or destroy such material. As used in 10 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 11 summaries, and any other format reproducing or capturing any of the Protected 12 Material. Whether the Protected Material is returned or destroyed, the Receiving 13 Party must submit a written certification to the Producing Party (and, if not the same 14 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 15 (by category, where appropriate) all the Protected Material that was returned or 16 destroyed and (2) affirms that the Receiving Party has not retained any copies, 17 abstracts, compilations, summaries or any other format reproducing or capturing any 18 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 19 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 20 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 21 reports, attorney work product, and consultant and expert work product, even if such 22 materials contain Protected Material. Any such archival copies that contain or 23 constitute Protected Material remain subject to this Protective Order as set forth in 24 Section 4 (DURATION). 25 26 27 28 14 1 14. Any willful violation of this Order may be punished by civil or criminal 2 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 3 authorities, or other appropriate action at the discretion of the Court. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 BLAKELY LAW GROUP 8 9 10 11 Dated: May 9, 2024 12 13 __/s/ Tara A. Currie___________ Brent H. Blakely Tara A. Currie Attorneys for Plaintiff Chanel, Inc. 14 15 OMNI LEGAL GROUP 16 17 18 Dated: May 9, 2024 19 20 21 __/s/ Louise Jillian Paris__________ Omid E. Khalifeh Ariana Santoro Louise Jillian Paris Attorneys for Defendant Royal’s Closet 22 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 25 26 27 5/10/2024 DATED:_______________ __________________________________ HON. MICHAEL R. WILNER United States Magistrate Judge 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 for the Central District of California on ____________in the case of 8 Chanel, Inc. v. Royal’s Closet, Case No. 2:23-cv-10375-JFW-MRW. I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order and 10 I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 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 and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 16

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