Ashraf Abadir v. County of Riverside et al

Filing 19


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1 Eugene P. Ramirez (State Bar No. 134865) 2 Michael Watts (State Bar No. 312210) 3 MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 4 801 S. Figueroa St, 15th Floor Los Angeles, California 90017-3012 5 Telephone: (213) 624-6900 Facsimile: (213) 624-6999 6 Attorneys for Defendants, COUNTY OF 7 RIVERSIDE, RIVERSIDE COUNTY SHERIFF'S DEPARTMENT, and 8 DEPUTY SHERIFF BRYCE HUBBARD 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 ASHRAF ABADIR, Plaintiff, 13 14 Case No. 5:17-CV-02120-DOC (SPx) STIPULATED PROTECTIVE ORDER v. 15 COUNTY OF RIVERSIDE, a public entity; RIVERSIDE COUNTY 16 SHERIFF'S DEPARTMENT, a public entity, DEPUTY SHERIFF 17 HUBBARD, individually and as a Deputy Sheriff, and DOES 1-100, 18 Defendants. 19 20 1. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary or private information for which special protection from public 23 disclosure and from use for any purpose other than prosecuting this litigation may 24 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 25 enter the following Stipulated Protective Order. The parties acknowledge that this 26 Order does not confer blanket protections on all disclosures or responses to 27 discovery and that the protection it affords from public disclosure and use extends 28 only to the limited information or items that are entitled to confidential treatment Case No. 5:17-CV-02120-DOC (SPx) STIPULATED PROTECTIVE ORDER 1 under the applicable legal principles. 2 The parties further acknowledge, as set forth in Section 13.3, below, that this 3 Stipulated Protective Order does not entitle them to file confidential information 4 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed 5 and the standards that will be applied when a party seeks permission from the court 6 to file material under seal. 7 2. GOOD CAUSE STATEMENT 8 This action is likely to involve materials pertaining to the defendants' 9 investigation and prosecution of Ashraf Abadir, including information which may 10 be contained in internal law enforcement files and identifying information relating 11 to law enforcement officials for which special protection from public disclosure and 12 from use for any purpose other than prosecution of this action is warranted. Such 13 confidential materials and information consist of, among other things, materials 14 pertaining to the investigation and prosecution of Ashraf Abadir (including 15 information implicating privacy rights of defendants and third parties), information 16 otherwise generally unavailable to the public, or materials which may be privileged 17 or otherwise protected from disclosure under state or federal statutes, court rules, 18 case decisions, or common law, including law enforcement personnel files. 19 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 20 of disputes over confidentiality of discovery materials, to adequately protect 21 information the parties are entitled to keep confidential, to ensure that the parties are 22 permitted reasonable necessary uses of such material in preparation for and in the 23 conduct of trial, to address their handling at the end of the litigation, and serve the 24 ends of justice, a protective order for such information is justified in this matter. It is 25 the intent of the parties that information will not be designated as confidential for 26 tactical reasons and that nothing be so designated without a good faith belief that it 27 has been maintained in a confidential, non-public manner, and there is good cause 28 why it should not be part of the public record of this case. Case No. 5:17-CV-02120-DOC (SPx) 2 STIPULATED PROTECTIVE ORDER 1 3. DEFINITIONS 2 3.1 Action: Ashraf Abadir v. County of Riverside, et al., 5:17-cv-02120- 3 DOC-SPx. 4 3.2 Challenging Party: a Party or Non-Party that challenges the designation 5 of information or items under this Order. 6 3.3 “CONFIDENTIAL” Information or Items: information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for 8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 9 the Good Cause Statement. 10 3.4 Counsel: Outside Counsel of Record and House Counsel (as well as 11 their support staff). 12 3.5 Designating Party: a Party or Non-Party that designates information or 13 items that it produces in disclosures or in responses to discovery as 14 “CONFIDENTIAL.” 15 3.6 Disclosure or Discovery Material: all items or information, regardless 16 of the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced or 18 generated in disclosures or responses to discovery in this matter. 19 3.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as 21 an expert witness or as a consultant in this Action. 22 3.8 House Counsel: attorneys who are employees of a party to this Action. 23 House Counsel does not include Outside Counsel of Record or any other outside 24 counsel. 25 3.9 Non-Party: any natural person, partnership, corporation, association, or 26 other legal entity not named as a Party to this action. 27 3.10 Outside Counsel of Record: attorneys who are not employees of a party 28 to this Action but are retained to represent or advise a party to this Action and have Case No. 5:17-CV-02120-DOC (SPx) 3 STIPULATED PROTECTIVE ORDER 1 appeared in this Action on behalf of that party or are affiliated with a law firm which 2 has appeared on behalf of that party, and includes support staff. 3 3.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 3.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 3.13 Professional Vendors: persons or entities that provide litigation support 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 and their employees and subcontractors. 12 3.14 Protected Material: any Disclosure or Discovery Material that is 13 designated as “CONFIDENTIAL.” 14 3.15 Receiving Party: a Party that receives Disclosure or Discovery Material 15 from a Producing Party. 16 4. SCOPE 17 The protections conferred by this Stipulation and Order cover not only 18 Protected Material (as defined above), but also (1) any information copied or 19 extracted from Protected Material; (2) all copies, excerpts, summaries, or 20 compilations of Protected Material; and (3) any testimony, conversations, or 21 presentations by Parties or their Counsel that might reveal Protected Material. 22 Any use of Protected Material at trial shall be governed by the orders of the 23 trial judge. This Order does not govern the use of Protected Material at trial. 24 5. DURATION 25 Even after final disposition of this litigation, the confidentiality obligations 26 imposed by this Order shall remain in effect until a Designating Party agrees 27 otherwise in writing or a court order otherwise directs. Final disposition shall be 28 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with Case No. 5:17-CV-02120-DOC (SPx) 4 STIPULATED PROTECTIVE ORDER 1 or without prejudice; and (2) final judgment herein after the completion and 2 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 3 including the time limits for filing any motions or applications for extension of time 4 pursuant to applicable law. 5 6. DESIGNATING PROTECTED MATERIAL 6 6.1 7 Each Party or Non-Party that designates information or items for protection Exercise of Restraint and Care in Designating Material for Protection 8 under this Order must take care to limit any such designation to specific material 9 that qualifies under the appropriate standards. The Designating Party must designate 10 for protection only those parts of material, documents, items, or oral or written 11 communications that qualify so that other portions of the material, documents, 12 items, or communications for which protection is not warranted are not swept 13 unjustifiably within the ambit of this Order. 14 Mass, indiscriminate, or routinized designations are prohibited. Designations 15 that are shown to be clearly unjustified or that have been made for an improper 16 purpose (e.g., to unnecessarily encumber the case development process or to impose 17 unnecessary expenses and burdens on other parties) may expose the Designating 18 Party to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 designated for protection do not qualify for protection, that Designating Party must 21 promptly notify all other Parties that it is withdrawing the inapplicable designation. 22 6.2 Manner and Timing of Designations. 23 Except as otherwise provided in this Order (see, e.g., second paragraph of 24 section 6.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery 25 Material that qualifies for protection under this Order must be clearly so designated 26 before the material is disclosed or produced. 27 28 Designation in conformity with this Order requires: (a) Information in Documentary Form Case No. 5:17-CV-02120-DOC (SPx) 5 STIPULATED PROTECTIVE ORDER 1 For information in documentary form (e.g., paper or electronic documents, 2 but excluding transcripts of depositions or other pretrial or trial proceedings), that 3 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 4 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 5 portion or portions of the material on a page qualifies for protection, the Producing 6 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 7 markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and 11 before the designation, all of the material made available for inspection shall be 12 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 13 documents it wants copied and produced, the Producing Party must determine which 14 documents, or portions thereof, qualify for protection under this Order. Then, before 15 producing the specified documents, the Producing Party must affix the 16 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 17 portion or portions of the material on a page qualifies for protection, the Producing 18 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 19 markings in the margins). 20 21 (b) Testimony Given in Depositions For testimony given in depositions, that the Designating Party identify the 22 Disclosure or Discovery Material on the record, before the close of the deposition all 23 protected testimony. 24 (c) Information Produced in Some Form other than Documentary and 25 for Any Other Tangible Items 26 For information produced in some form other than documentary and for any 27 other tangible items, that the Producing Party affix in a prominent place on the 28 exterior of the container or containers in which the information is stored the legend Case No. 5:17-CV-02120-DOC (SPx) 6 STIPULATED PROTECTIVE ORDER 1 “CONFIDENTIAL.” If only a portion or portions of the information warrants 2 protection, the Producing Party, to the extent practicable, shall identify the protected 3 portion(s). 4 6.3 Inadvertent Failures to Designate. 5 If timely corrected, an inadvertent failure to designate qualified information 6 or items does not, standing alone, waive the Designating Party’s right to secure 7 protection under this Order for such material. Upon timely correction of a 8 designation, the Receiving Party must make reasonable efforts to assure that the 9 material is treated in accordance with the provisions of this Order. 10 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 7.1 12 Any Party or Non-Party may challenge a designation of confidentiality at any Timing of Challenges 13 time that is consistent with the Court’s Scheduling Order. 14 7.2 Meet and Confer 15 The Challenging Party shall initiate the dispute resolution process under 16 Local Rule 37.1 et seq. 17 7.3 Burden of Persuasion 18 The burden of persuasion in any such challenge proceeding shall be on the 19 Designating Party. Frivolous challenges, and those made for an improper purpose 20 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 21 expose the Challenging Party to sanctions. Unless the Designating Party has waived 22 or withdrawn the confidentiality designation, all parties shall continue to afford the 23 material in question the level of protection to which it is entitled under the 24 Producing Party’s designation until the Court rules on the challenge. 25 8. ACCESS TO AND USE OF PROTECTED MATERIAL 26 8.1 27 A Receiving Party may use Protected Material that is disclosed or produced Basic Principles 28 by another Party or by a Non-Party in connection with this Action only for Case No. 5:17-CV-02120-DOC (SPx) 7 STIPULATED PROTECTIVE ORDER 1 prosecuting, defending, or attempting to settle this Action. Such Protected Material 2 may be disclosed only to the categories of persons and under the conditions 3 described in this Order. When the Action has been terminated, a Receiving Party 4 must comply with the provisions of Section 14, FINAL DISPOSITION, below. 5 Protected Material must be stored and maintained by a Receiving Party at a 6 location and in a secure manner that ensures that access is limited to the persons 7 authorized under this Order. 8 8.2 Disclosure of "CONFIDENTIAL" Information or Items 9 Unless otherwise ordered by the court or permitted in writing by the 10 Designating Party, a Receiving Party may disclose any information or item 11 designated “CONFIDENTIAL” only to: 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 13 well as employees of said Outside Counsel of Record to whom it is reasonably 14 necessary to disclose the information for this Action; 15 (b) the officers, directors, and employees (including House Counsel) of 16 the Receiving Party to whom disclosure is reasonably necessary for this Action; 17 (c) Experts (as defined in this Order) of the Receiving Party to whom 18 disclosure is reasonably necessary for this Action and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (d) the court and its personnel; 21 (e) court reporters and their staff; 22 (f) professional jury or trial consultants, mock jurors, and Professional 23 Vendors to whom disclosure is reasonably necessary for this Action and who have 24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (g) the author or recipient of a document containing the information or 26 a custodian or other person who otherwise possessed or knew the information; 27 (h) during their depositions, witnesses ,and attorneys for witnesses, in 28 the Action to whom disclosure is reasonably necessary provided: (1) the deposing Case No. 5:17-CV-02120-DOC (SPx) 8 STIPULATED PROTECTIVE ORDER 1 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 2 they will not be permitted to keep any confidential information unless they sign the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 4 agreed by the Designating Party or ordered by the court. Pages of transcribed 5 deposition testimony or exhibits to depositions that reveal Protected Material may 6 be separately bound by the court reporter and may not be disclosed to anyone except 7 as permitted under this Stipulated Protective Order; and (i) any mediator or settlement officer, and their supporting personnel, 8 9 mutually agreed upon by any of the parties engaged in settlement discussions. 10 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED 11 PRODUCED IN OTHER LITIGATION 12 9.1 Subpoena or Court Order in Other Litigation 13 If a Party is served with a subpoena or a court order issued in other litigation 14 that compels disclosure of any information or items designated in this Action as 15 “CONFIDENTIAL,” that Party must: 16 (a) promptly notify in writing the Designating Party. Such notification 17 shall include a copy of the subpoena or court order; 18 (b) promptly notify in writing the party who caused the subpoena or 19 order to issue in the other litigation that some or all of the material covered by the 20 subpoena or order is subject to this Protective Order. Such notification shall include 21 a copy of this Stipulated Protective Order; and 22 (c) cooperate with respect to all reasonable procedures sought to be 23 pursued by the Designating Party whose Protected Material may be affected. 24 If the Designating Party timely seeks a protective order, the Party served with 25 the subpoena or court order shall not produce any information designated in this 26 action as “CONFIDENTIAL” before a determination by the court from which the 27 subpoena or order issued, unless the Party has obtained the Designating Party’s 28 permission. The Designating Party shall bear the burden and expense of seeking Case No. 5:17-CV-02120-DOC (SPx) 9 STIPULATED PROTECTIVE ORDER 1 protection in that court of its confidential material and nothing in these provisions 2 should be construed as authorizing or encouraging a Receiving Party in this Action 3 to disobey a lawful directive from another court. 4 10. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 5 PRODUCED IN THIS LITIGATION 6 10.1 NON-PARTY INFORMATION 7 The terms of this Order are applicable to information produced by a Non- 8 Party in this Action and designated as “CONFIDENTIAL.” Such information 9 produced by Non-Parties in connection with this litigation is protected by the 10 remedies and relief provided by this Order. Nothing in these provisions should be 11 construed as prohibiting a Non-Party from seeking additional protections. 12 In the event that a Party is required, by a valid discovery request, to produce a 13 Non-Party’s confidential information in its possession, and the Party is subject to an 14 agreement with the Non-Party not to produce the Non-Party’s confidential 15 information, then the Party shall: 16 (a) promptly notify in writing the Requesting Party and the Non-Party 17 that some or all of the information requested is subject to a confidentiality 18 agreement with a Non-Party; 19 (b) promptly provide the Non-Party with a copy of the Stipulated 20 Protective Order in this Action, the relevant discovery request(s), and a reasonably 21 specific description of the information requested; and 22 (c) make the information requested available for inspection by the Non- 23 Party, if requested. 24 If the Non-Party fails to seek a protective order from this court within 14 days 25 of receiving the notice and accompanying information, the Receiving Party may 26 produce the Non-Party’s confidential information responsive to the discovery 27 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 28 not produce any information in its possession or control that is subject to the Case No. 5:17-CV-02120-DOC (SPx) 10 STIPULATED PROTECTIVE ORDER 1 confidentiality agreement with the Non-Party before a determination by the court. 2 Absent a court order to the contrary, the Non-Party shall bear the burden and 3 expense of seeking protection in this court of its Protected Material. 4 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 6 Protected Material to any person or in any circumstance not authorized under this 7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 8 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 9 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 10 persons to whom unauthorized disclosures were made of all the terms of this Order, 11 and (d) request such person or persons to execute the “Acknowledgment and 12 Agreement to Be Bound” that is attached hereto as Exhibit A. 13 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 14 PROTECTED MATERIAL 15 When a Producing Party gives notice to Receiving Parties that certain 16 inadvertently produced material is subject to a claim of privilege or other protection, 17 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 18 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 19 may be established in an e-discovery order that provides for production without 20 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 21 as the parties reach an agreement on the effect of disclosure of a communication or 22 information covered by the attorney-client privilege or work product protection, the 23 parties may incorporate their agreement in the stipulated protective order submitted 24 to the court. 25 13. MISCELLANEOUS 26 13.1 Right to Further Relief. 27 Nothing in this Order abridges the right of any person to seek its modification 28 by the Court in the future. Case No. 5:17-CV-02120-DOC (SPx) 11 STIPULATED PROTECTIVE ORDER 1 13.2 Right to Assert Other Objections. 2 By stipulating to the entry of this Protective Order, no Party waives any right 3 it otherwise would have to object to disclosing or producing any information or item 4 on any ground not addressed in this Stipulated Protective Order. Similarly, no Party 5 waives any right to object on any ground to use in evidence of any of the material 6 covered by this Protective Order. 7 13.3 Filing Protected Material. 8 A Party that seeks to file under seal any Protected Material must comply with 9 Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a 10 court order authorizing the sealing of the specific Protected Material at issue. If a 11 Party's request to file Protected Material under seal is denied by the court, then the 12 Receiving Party may file the information in the public record unless otherwise 13 instructed by the court. 14 14. FINAL DISPOSITION 15 After the final disposition of this Action, as defined in Section 4, within 60 16 days of a written request by the Designating Party, each Receiving Party must return 17 all Protected Material to the Producing Party or destroy such material. As used in 18 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 19 summaries, and any other format reproducing or capturing any of the Protected 20 Material. Whether the Protected Material is returned or destroyed, the Receiving 21 Party must submit a written certification to the Producing Party (and, if not the same 22 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 23 (by category, where appropriate) all the Protected Material that was returned or 24 destroyed and (2) affirms that the Receiving Party has not retained any copies, 25 abstracts, compilations, summaries or any other format reproducing or capturing any 26 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 27 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 28 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert Case No. 5:17-CV-02120-DOC (SPx) 12 STIPULATED PROTECTIVE ORDER 1 reports, attorney work product, and consultant and expert work product, even if such 2 materials contain Protected Material. Any such archival copies that contain or 3 constitute Protected Material remain subject to this Protective Order as set forth in 4 Section 5, DURATION. 5 15. VIOLATIONS 6 Any violation of this Order may be punished by any and all appropriate 7 measures including, without limitation, contempt proceedings and/or monetary 8 sanctions. IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 10 11 DATED: January 3, 2018 12 MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 13 14 By: 15 16 17 18 /s/Michael R. Watts Eugene P. Ramirez, Esq. Michael R. Watts, Esq. Attorneys for Defendants, COUNTY OF RIVERSIDE, RIVERSIDE COUNTY SHERIFF'S DEPARTMENT, and DEPUTY SHERIFF BRYCE HUBBARD 19 20 DATED: January 3, 2018 CUTLER LEGAL, A LAW FIRM 21 22 By: 23 24 25 /s/Carolina Veronica Cutler Carolina Veronica Cutler, Esq. Attorney for Plaintiff, ASHRAF ABADIR /// 26 27 28 Case No. 5:17-CV-02120-DOC (SPx) 13 STIPULATED PROTECTIVE ORDER 1 2 E-SIGNATURE AFFIRMATION Pursuant to the United States District Court, Central District of California 3 Local Rule 5-4.3.4, I attest that all other signatories listed, and on whose behalf the 4 filing is submitted, concur in the filing’s content and have authorized the filing. 5 6 DATED: January 3, 2018 7 MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 8 9 10 11 12 13 By: /s/Michael R. Watts Eugene P. Ramirez Michael R. Watts Attorneys for Defendants, COUNTY OF RIVERSIDE, RIVERSIDE COUNTY SHERIFF'S DEPARTMENT, and DEPUTY SHERIFF BRYCE HUBBARD 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. 5:17-CV-02120-DOC (SPx) 14 STIPULATED PROTECTIVE ORDER 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 DATED: January 9, 2018 3 4 5 6 By: Hon. Sheri Pym 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 Case No. 5:17-CV-02120-DOC (SPx) 15 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of ___________ Ashraf Abadir v. County of Riverside, et 8 al., Case No. 5:17-CV-02120-DOC (SPx). I agree to comply with and to be bound 9 by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the 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 __________________________ [print or 18 type full name] of _______________________________________ [print or type 19 full address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this 21 Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 Printed name: _______________________________ 25 Signature: __________________________________ 26 27 28 Case No. 5:17-CV-02120-DOC (SPx) 16 STIPULATED PROTECTIVE ORDER

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