V.N. v. Upland Unified School District et al

Filing 27

ORDER APPROVING STIPULATION FOR PROTECTIVE ORDER by Magistrate Judge Kenly Kiya Kato re Stipulation for Protective Order 26 . (vp)

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1 2 3 4 5 6 2017-01-07 A. JOEL RICHLIN, CA Bar No. 246318 jrichlin@foley.com KIMBERLY A. KLINSPORT, CA Bar No. 259018 kklinsport@foley.com JOHN J. ATALLAH, CA Bar No. 294116 jatallah@foley.com FOLEY & LARDNER LLP 555 SOUTH FLOWER STREET, SUITE 3500 LOS ANGELES, CA 90071-2411 TEL: 213.972.4500; FAX: 213.486.0065 MARONEL BARAJAS, CA Bar No. 242044 Maronel.Barajas@drlcenter.org ANNA RIVERA, CA Bar No. 239601 8 Anna.Rivera@drlcenter.org DISABILITY RIGHTS LEGAL CENTER 9 350 SOUTH GRAND AVENUE, SUITE 1520 LOS ANGELES, CALIFORNIA 90071 10 TEL: (213) 736-1031; FAX: (213) 736-1428 7 11 Attorneys for Plaintiff V.N., a Minor, 12 by and through her Guardian Ad Litem HECTOR NUÑO 13 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA - EASTERN DIVISION ) ) ) ) Plaintiff, ) ) vs. ) ) UPLAND UNIFIED SCHOOL ) DISTRICT; DR. NANCY KELLY, in her ) official capacity as Superintendent of ) Upland Unified School District; and ) DOES 1-10, inclusive, ) ) Defendants. ) ) ) ) ) V.N., a Minor, by and through her 17 Guardian Ad Litem HECTOR NUÑO, Case No. 5:16-CV-1958 GHK (KKx) 18 PROTECTIVE ORDER 16 19 20 21 22 23 24 25 26 ORDER GRANTING STIPULATED [DISCOVERY MATTER REFERRED TO U.S. MAGISTRATE JUDGE] Complaint Filed: September 12, 2016 FAC Filed: November 4, 2016 U.S. Magistrate Judge Kenly Kiya Kato Location: George E. Brown Jr. Federal Building and United States Courthouse 3470 Twelfth Street Courtroom 3 or 4, 3rd Fl Riverside, CA 92501-3801 27 28 4835-1854-1118.1 STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary, 2 3 or private information for which special protection from public disclosure and from use 4 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 5 parties hereby stipulate to and petition the Court to enter the following Stipulated 6 Protective Order. The parties acknowledge that this Order does not confer blanket 7 protections on all disclosures or responses to discovery and that the protection it affords 8 from public disclosure and use extends only to the limited information or items that are 9 entitled to confidential treatment under the applicable legal principles. The parties 10 further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective 11 Order does not entitle them to file confidential information under seal; Civil Local Rule 12 79-5 sets forth the procedures that must be followed and the standards that will be applied 13 when a party seeks permission from the court to file material under seal. 14 B. GOOD CAUSE STATEMENT 15 This action is likely to involve certain confidential information related to minors, 16 as well as medical information relating to the Plaintiff’s disabilities, and employment and 17 personnel records pertaining to Defendants and their employees. Such confidential 18 materials and information consist of, among other things, academic records, medical 19 records, Section 504 plans, employment records, and personnel records. Accordingly, to 20 expedite the flow of information, to facilitate the prompt resolution of disputes over 21 confidentiality of discovery materials, to adequately protect information the parties are 22 entitled to keep confidential, to ensure that the parties are permitted reasonably necessary 23 uses of such material in preparation for and in the conduct of trial, to address their 24 handling at the end of the litigation, and serve the ends of justice, a protective order for 25 such information is justified in this matter. It is the intent of the parties that information 26 will not be designated as confidential for tactical reasons and that nothing be so 27 designated without a good faith belief that it has been maintained in a confidential, non- 28 public manner, and there is good cause why it should not be part of the public record of 4835-1854-1118.1 -1- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 this case. 2 2. DEFINITIONS 3 2.1 Action: This pending federal law suit. 4 2.2 Challenging Party: A Party or Non-Party that challenges the designation of 5 information or items under this Order. 2.3 6 “CONFIDENTIAL” Information or Items: Information (regardless of how it 7 is generated, stored or maintained) or tangible things that qualify for protection under 8 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 9 Statement. 2.4 10 11 support staff). 2.5 12 13 Counsel: Outside Counsel of Record and House Counsel (as well as their Designating Party: A Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 2.6 14 Disclosure or Discovery Material: All items or information, regardless of 15 the medium or manner in which it is generated, stored, or maintained (including, among 16 other things, testimony, transcripts, and tangible things), that are produced or generated in 17 disclosures or responses to discovery in this matter. 2.7 18 Expert: A person with specialized knowledge or experience in a matter 19 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 20 expert witness or as a consultant in this Action. 2.8 21 22 House Counsel does not include Outside Counsel of Record or any other outside counsel. 2.9 23 24 House Counsel: Attorneys who are employees of a party to this Action. Non-Party: Any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: Attorneys who are not employees of a party to 25 26 this Action but are retained to represent or advise a party to this Action and have 27 appeared in this Action on behalf of that party or are affiliated with a law firm which has 28 appeared on behalf of that party, and includes support staff. 4835-1854-1118.1 -2- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 2.11 Party: Any party to this Action, including all of its officers, directors, 2 employees, consultants, retained experts, and Outside Counsel of Record (and their 3 support staffs). 2.12 Producing Party: A Party or Non-Party that produces Disclosure or 4 5 Discovery Material in this Action. 2.13 Professional Vendors: Persons or entities that provide litigation support 6 7 services (e.g., photocopying, videotaping, translating, preparing exhibits or 8 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 9 their employees and subcontractors. 2.14 Protected Material: Any Disclosure or Discovery Material that is designated 10 11 as “CONFIDENTIAL.” 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material 12 13 from a Producing Party. 14 3. SCOPE 15 The protections conferred by this Stipulation and Order cover not only Protected 16 Material (as defined above), but also (1) any information copied or extracted from 17 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 18 Material; and (3) any testimony, conversations, or presentations by Parties or their 19 Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the trial 20 21 judge. This Order does not govern the use of Protected Material at trial. 22 4. DURATION 23 Even after final disposition of this litigation, the confidentiality obligations 24 imposed by this Order shall remain in effect until a Designating Party agrees otherwise in 25 writing or a court order otherwise directs. Final disposition shall be deemed to be the 26 later of (1) dismissal of all claims and defenses in this Action, with or without prejudice; 27 and (2) final judgment herein after the completion and exhaustion of all appeals, 28 rehearings, remands, trials, or reviews of this Action, including the time limits for filing 4835-1854-1118.1 -3- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 any motions or applications for extension of time pursuant to applicable law. 2 5. DESIGNATING PROTECTED MATERIAL 3 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 4 Party or Non-Party that designates information or items for protection under this Order 5 must take care to limit any such designation to specific material that qualifies under the 6 appropriate standards. The Designating Party must designate for protection only those 7 parts of material, documents, items, or oral or written communications that qualify so that 8 other portions of the material, documents, items, or communications for which protection 9 is not warranted are not swept unjustifiably within the ambit of this Order. Mass, indiscriminate, or routinized designations are prohibited. Designations that 10 11 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 12 to unnecessarily encumber the case development process or to impose unnecessary 13 expenses and burdens on other parties) may expose the Designating Party to sanctions. 14 If it comes to a Designating Party’s attention that information or items that it 15 designated for protection do not qualify for protection, that Designating Party must 16 promptly notify all other Parties that it is withdrawing the inapplicable designation. 5.2 17 Manner and Timing of Designations. Except as otherwise provided in this 18 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 19 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 20 must be clearly so designated before the material is disclosed or produced. 21 Designation in conformity with this Order requires: 22 (a) for information in documentary form (e.g., paper or electronic documents, but 23 excluding transcripts of depositions or other pretrial or trial proceedings), that the 24 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 25 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 26 portion or portions of the material on a page qualifies for protection, the Producing Party 27 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 28 in the margins). 4835-1854-1118.1 -4- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) A Party or Non-Party that makes original documents available for inspection need 1 2 not designate them for protection until after the inspecting Party has indicated which 3 documents it would like copied and produced. During the inspection and before the 4 designation, all of the material made available for inspection shall be deemed 5 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 6 copied and produced, the Producing Party must determine which documents, or portions 7 thereof, qualify for protection under this Order. Then, before producing the specified 8 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 9 that contains Protected Material. If only a portion or portions of the material on a page 10 qualifies for protection, the Producing Party also must clearly identify the protected 11 portion(s) (e.g., by making appropriate markings in the margins). (b) for testimony given in depositions, that the Designating Party identify the 12 13 Disclosure or Discovery Material on the record, before the close of the deposition all 14 protected testimony. (c) for information produced in some form other than documentary and for any 15 16 other tangible items, that the Producing Party affix in a prominent place on the exterior of 17 the container or containers in which the information is stored the legend 18 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 19 the Producing Party, to the extent practicable, shall identify the protected portion(s). 5.3 20 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 21 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. Upon 23 timely correction of a designation, the Receiving Party must make reasonable efforts to 24 assure that the material is treated in accordance with the provisions of this Order. 25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 26 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 27 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 28 4835-1854-1118.1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution -5- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 process under Local Rule 37.1, et seq. 6.3 2 The burden of persuasion in any such challenge proceeding shall be on the 3 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 4 to harass or impose unnecessary expenses and burdens on other parties) may expose the 5 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 6 the confidentiality designation, all parties shall continue to afford the material in question 7 the level of protection to which it is entitled under the Producing Party’s designation until 8 the Court rules on the challenge. 9 7. ACCESS TO AND USE OF PROTECTED MATERIAL 10 7.1 Basic Principles. A Receiving Party may use Protected Material that is 11 disclosed or produced by another Party or by a Non-Party in connection with this Action 12 only for prosecuting, defending, or attempting to settle this Action. Such Protected 13 Material may be disclosed only to the categories of persons and under the conditions 14 described in this Order. When the Action has been terminated, a Receiving Party must 15 comply with the provisions of section 13 below (FINAL DISPOSITION). Protected Material must be stored and maintained by a Receiving Party at a 16 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Order. 7.2 19 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 20 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 21 may disclose any information or item designated “CONFIDENTIAL” only to: (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 22 23 employees of said Outside Counsel of Record to whom it is reasonably necessary to 24 disclose the information for this Action; (b) the officers, directors, and employees (including House Counsel) of the 25 26 Receiving Party to whom disclosure is reasonably necessary for this Action; (c) Experts (as defined in this Order) of the Receiving Party who have signed the 27 28 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4835-1854-1118.1 -6- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 (d) the court and its personnel; 2 (e) court reporters and their staff; 3 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to 4 whom disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) the author or recipient of a document containing the information or a custodian 6 7 or other person who otherwise possessed or knew the information; (h) during their depositions, witnesses ,and attorneys for witnesses, in the Action 8 9 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that 10 the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted 11 to keep any confidential information unless they sign the “Acknowledgment and 12 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party 13 or ordered by the court. Pages of transcribed deposition testimony or exhibits to 14 depositions that reveal Protected Material may be separately bound by the court reporter 15 and may not be disclosed to anyone except as permitted under this Stipulated Protective 16 Order; and (i) any mediator or settlement officer, and their supporting personnel, mutually 17 18 agreed upon by any of the parties engaged in settlement discussions. 8. 19 20 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION If a Party is served with a subpoena or a court order issued in other litigation that 21 22 compels disclosure of any information or items designated in this Action as 23 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification shall 24 25 include a copy of the subpoena or court order; 26 (b) promptly notify in writing the party who caused the subpoena or order to issue 27 in the other litigation that some or all of the material covered by the subpoena or order is 28 subject to this Protective Order. Such notification shall include a copy of this Stipulated 4835-1854-1118.1 -7- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued by the 2 3 Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the 4 5 subpoena or court order shall not produce any information designated in this action as 6 “CONFIDENTIAL” before a determination by the court from which the subpoena or 7 order issued, unless the Party has obtained the Designating Party’s permission. The 8 Designating Party shall bear the burden and expense of seeking protection in that court of 9 its confidential material and nothing in these provisions should be construed as 10 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 11 from another court. 9. 12 13 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION (a) The terms of this Order are applicable to information produced by a Non-Party 14 15 in this Action and designated as “CONFIDENTIAL.” Such information produced by 16 Non-Parties in connection with this litigation is protected by the remedies and relief 17 provided by this Order. Nothing in these provisions should be construed as prohibiting a 18 Non-Party from seeking additional protections. (b) In the event that a Party is required, by a valid discovery request, to produce a 19 20 Non-Party’s confidential information in its possession, and the Party is subject to an 21 agreement with the Non-Party not to produce the Non-Party’s confidential information, 22 then the Party shall: 23 (1) promptly notify in writing the Requesting Party and the Non-Party that some 24 or all of the information requested is subject to a confidentiality agreement with a Non- 25 Party; (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 26 27 in this Action, the relevant discovery request(s), and a reasonably specific description of 28 the information requested; and 4835-1854-1118.1 -8- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) (3) make the information requested available for inspection by the Non-Party, if 1 2 requested. 3 (c) If the Non-Party fails to seek a protective order from this court within 14 days 4 of receiving the notice and accompanying information, the Receiving Party may produce 5 the Non-Party’s confidential information responsive to the discovery request. If the Non- 6 Party timely seeks a protective order, the Receiving Party shall not produce any 7 information in its possession or control that is subject to the confidentiality agreement 8 with the Non-Party before a determination by the court. Absent a court order to the 9 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 10 court of its Protected Material. 11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 13 Protected Material to any person or in any circumstance not authorized under this 14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 15 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 16 all unauthorized copies of the Protected Material, (c) inform the person or persons to 17 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 18 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 19 that is attached hereto as Exhibit A. 11. 20 21 INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL When a Producing Party gives notice to Receiving Parties that certain inadvertently 22 23 produced material is subject to a claim of privilege or other protection, the obligations of 24 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 25 This provision is not intended to modify whatever procedure may be established in an e- 26 discovery order that provides for production without prior privilege review. Pursuant to 27 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 28 effect of disclosure of a communication or information covered by the attorney-client 4835-1854-1118.1 -9- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 privilege or work product protection, the parties may incorporate their agreement in the 2 stipulated protective order submitted to the court. 3 12. 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 MISCELLANEOUS 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 6 7 Protective Order no Party waives any right it otherwise would have to object to disclosing 8 or producing any information or item on any ground not addressed in this Stipulated 9 Protective Order. Similarly, no Party waives any right to object on any ground to use in 10 evidence of any of the material covered by this Protective Order. 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 11 12 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 13 under seal pursuant to a court order authorizing the sealing of the specific Protected 14 Material at issue. If a Party’s request to file Protected Material under seal is denied by 15 the court, then the Receiving Party may file the information in the public record unless 16 otherwise instructed by the court. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 4, within 60 days 19 of a written request by the Designating Party, each Receiving Party must return all 20 Protected Material to the Producing Party or destroy such material. As used in this 21 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected Material. 23 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 24 a written certification to the Producing Party (and, if not the same person or entity, to the 25 Designating Party) by the 60 day deadline that (1) identifies (by category, where 26 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 27 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 28 any other format reproducing or capturing any of the Protected Material. 4835-1854-1118.1 -10- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 2 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 3 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 4 consultant and expert work product, even if such materials contain Protected Material. 5 Any such archival copies that contain or constitute Protected Material remain subject to 6 this Protective Order as set forth in Section 4 (DURATION). 14. 7 8 Any violation of this Order may be punished by any and all appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. 9 10 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 11 12 DATED: January 6, 2017 13 14 15 FOLEY & LARDNER LLP A. Joel Richlin Kimberly A. Klinsport John J. Atallah /S/ A. JOEL RICHLIN A. Joel Richlin Attorneys for Plaintiff V.N., a Minor, by and through her Guardian Ad Litem HECTOR NUÑO 16 17 18 19 20 DATED: January 6, 2017 POLLAK, VIDA & FISHER Judy L. McKelvey 21 22 23 /S/ JUDY L. McKELVEY Judy L. McKelvey Attorneys for Defendants Upland Unified School District and Nancy Kelley, Ed.D. 24 25 *Pursuant to Local Rule 5-4.3.4(a)(2)(i), I (A. Joel Richlin) attest that the other 26 signatories listed, and on whose behalf this filing is submitted, concur in the filing 27 content and have authorized this filing. 28 4835-1854-1118.1 -11- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 4 Dated: January 9, 2017 5 6 _____________________________________ HONORABLE KENLY KIYA KATO UNITED STATES MAGISTRATE JUDGE 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4835-1854-1118.1 -12- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx) 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 5 _________________ [print or type full address], declare under penalty of perjury that I 6 have read in its entirety and understand the Stipulated Protective Order that was issued by 7 the United States District Court for the Central District of California on ____________ 8 [date] in the case of V.N. v. Upland Unified School District, et al., Case No. 5:16-CV- 9 1958 GHK (KKx). 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 comply 11 could expose me to sanctions and punishment in the nature of contempt. I solemnly 12 promise that I will not disclose in any manner any information or item that is subject to 13 this Stipulated Protective Order to any person or entity except in strict compliance with 14 the provisions of this Order. I further agree to submit to the jurisdiction of the United States District Court for 15 16 the Central District of California for the purpose of enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and telephone 20 number] as my California agent for service of process in connection with this action or 21 any proceedings related to enforcement of this Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28 4835-1854-1118.1 -1- STIPULATED PROTECTIVE ORDER Case No. 5:16-CV-1958 GHK (KKx)

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