ACT 898 Products Inc v. WS Industries Inc et al
Filing
32
STIPULATED PROTECTIVE ORDER by Magistrate Judge Jay C. Gandhi re Stipulation for Protective Order 30 . (kh)
1
2
3
4
Brian K. Stewart, Esq. (State Bar No. 126412)
Rebecca S. King, Esq. (State Bar No. 305902)
COLLINS COLLINS MUIR + STEWART LLP
1100 El Centro Street
South Pasadena, CA 91030
(626) 243-1100 – FAX (626) 243-1111
5
6
Attorneys for Defendants
W.S. INDUSTRIES, INC. and VINH LAM
7
8
UNITED STATES DISTRICT COURT
9
FOR THE CENTRAL DISTRICT OF CALIFORNIA
10
11
12
A.C.T. 898 PRODUCTS, INC., a
California Corporation,
13
14
Plaintiff,
vs.
15
16
17
18
19
W.S. INDUSTRIES, INC.; VINH
LAM, an individual; and DOES 1
through 10, inclusive,
Defendants
)
)
)
)
)
)
)
)
)
)
)
)
)
CASE NO. 8:16-CV-00476-DOC-JCG
[Assigned to Judge David O. Carter, Dept.
9D]
STIPULATED PROTECTIVE ORDER
Complaint Filed: 03/11/16
Trial Date:
None
20
21
1. A. PURPOSES AND LIMITATIONS
22
Discovery in this action is likely to involve production of confidential,
23
proprietary, or private information for which special protection from public
24
disclosure and from use for any purpose other than prosecuting this litigation may be
25
warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
26
the following Stipulated Protective Order. The parties acknowledge that this Order
27
does not confer blanket protections on all disclosures or responses to discovery and
28
that the protection it affords from public disclosure and use extends only to the
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
1
STIPULATION TO PROTECTIVE ORDER
1
limited information or items that are entitled to confidential treatment under the
2
applicable legal principles. The parties further acknowledge, as set forth in Section
3
12.3, below, that this Stipulated Protective Order does not entitle them to file
4
confidential information under seal; Civil Local Rule 79-5 sets forth the procedures
5
that must be followed and the standards that will be applied when a party seeks
6
permission from the court to file material under seal.
7
B. GOOD CAUSE STATEMENT
8
This action is likely to involve trade secrets, customer and pricing lists and
9
other valuable research, development, commercial, financial, technical and/or
10
proprietary information for which special protection from public disclosure and from
11
use for any purpose other than prosecution of this action is warranted. Such
12
confidential and proprietary materials and information consist of, among other things,
13
confidential business or financial information, information regarding confidential
14
business practices, or other confidential research, development, or commercial
15
information, information otherwise generally unavailable to the public, or which may
16
be privileged or otherwise protected from disclosure under state or federal statutes,
17
court rules, case decisions, or common law.
18
Accordingly, to expedite the flow of information, to facilitate the prompt
19
resolution of disputes over confidentiality of discovery materials, to adequately
20
protect information the parties are entitled to keep confidential, to ensure that the
21
parties are permitted reasonable necessary uses of such material in preparation for
22
and in the conduct of trial, to address their handling at the end of the litigation, and
23
serve the ends of justice, a protective order for such information is justified in this
24
matter. It is the intent of the parties that information will not be designated as
25
confidential for tactical reasons and that nothing be so designated without a good
26
faith belief that it has been maintained in a confidential, non-public manner, and there
27
is good cause why it should not be part of the public record of this case.
28
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
2
STIPULATION TO PROTECTIVE ORDER
1
2. DEFINITIONS
2
2.1 Action: this pending federal law suit
3
2.2 Challenging Party: a Party or Non-Party that challenges the designation of
4
information or items under this Order.
5
2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
6
it is generated, stored or maintained) or tangible things that qualify for protection
7
under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
8
Cause Statement.
9
10
2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
support staff).
11
2.5 Designating Party: a Party or Non-Party that designates information or
12
items that it produces in disclosures or in responses to discovery as
13
“CONFIDENTIAL” or “ATTORNEYS EYES ONLY.”
14
2.6 Disclosure or Discovery Material: all items or information, regardless of
15
the medium or manner in which it is generated, stored, or maintained (including,
16
among other things, testimony, transcripts, and tangible things), that are produced or
17
generated in disclosures or responses to discovery in this matter.
18
2.7 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
20
an expert witness or as a consultant in this Action.
21
2.8 House Counsel: attorneys who are employees of a party to this Action.
22
House Counsel does not include Outside Counsel of Record or any other outside
23
counsel.
24
25
2.9 Non-Party: any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.
26
2.10 Outside Counsel of Record: attorneys who are not employees of a party to
27
this Action but are retained to represent or advise a party to this Action and have
28
appeared in this Action on behalf of that party or are affiliated with a law firm which
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
3
STIPULATION TO PROTECTIVE ORDER
1
has appeared on behalf of that party, and includes support staff.
2
2.11 Party: any party to this Action, including all of its officers, directors,
3
employees, consultants, retained experts, and Outside Counsel of Record (and their
4
support staffs).
5
6
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
7
2.13 Professional Vendors: persons or entities that provide litigation support
8
services (e.g., photocopying, videotaping, translating, preparing exhibits or
9
demonstrations, and organizing, storing, or retrieving data in any form or medium)
10
and their employees and subcontractors.
11
12
13
14
2.14 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL” or “ATTORNEYS EYES ONLY.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
from a Producing Party.
15
16
3. 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
23
Any use of Protected Material at trial shall be governed by the orders of the
trial judge. This Order does not govern the use of Protected Material at trial.
24
25
4. DURATION
26
Even after final disposition of this litigation, the confidentiality obligations
27
imposed by this Order shall remain in effect until a Designating Party agrees
28
otherwise in writing or a court order otherwise directs. Final disposition shall be
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
4
STIPULATION TO PROTECTIVE ORDER
1
deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
2
or without prejudice; and (2) final judgment herein after the completion and
3
exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
4
including the time limits for filing any motions or applications for extension of time
5
pursuant to applicable law.
6
7
5. DESIGNATING PROTECTED MATERIAL
8
5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
9
Party or Non-Party that designates information or items for protection under this
10
Order must take care to limit any such designation to specific material that qualifies
11
under the appropriate standards. The Designating Party must designate for protection
12
only those parts of material, documents, items, or oral or written communications that
13
qualify so that other portions of the material, documents, items, or communications
14
for which protection is not warranted are not swept unjustifiably within the ambit of
15
this Order.
16
Mass, indiscriminate, or routinized designations are prohibited. Designations
17
that are shown to be clearly unjustified or that have been made for an improper
18
purpose (e.g., to unnecessarily encumber the case development process or to impose
19
unnecessary expenses and burdens on other parties) may expose the Designating
20
Party to sanctions.
21
If it comes to a Designating Party’s attention that information or items that it
22
designated for protection do not qualify for protection, that Designating Party must
23
promptly notify all other Parties that it is withdrawing the inapplicable designation.
24
5.2 Manner and Timing of Designations. Except as otherwise provided in this
25
Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
26
or ordered, Disclosure or Discovery Material that qualifies for protection under this
27
Order must be clearly so designated before the material is disclosed or produced.
28
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
Designation in conformity with this Order requires:
5
STIPULATION TO PROTECTIVE ORDER
1
(a) for information in documentary form (e.g., paper or electronic documents,
2
but excluding transcripts of depositions or other pretrial or trial proceedings), that the
3
Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
4
“CONFIDENTIAL legend”). Stamping the “CONFIDENTIAL legend” on the cover
5
of any multipage document shall designate all pages of the document as confidential,
6
unless otherwise indicated by the producing party. If only a portion or portions of the
7
material on a page qualifies for protection, the Producing Party also must clearly
8
identify the protected portion(s) (e.g., by making appropriate markings in the
9
margins).
10
A Party or Non-Party that makes original documents available for inspection
11
need not designate them for protection until after the inspecting Party has indicated
12
which documents it would like copied and produced. During the inspection and
13
before the designation, all of the material made available for inspection shall be
14
deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
15
it wants copied and produced, the Producing Party must determine which documents,
16
or portions thereof, qualify for protection under this Order. Then, before producing
17
the specified documents, the Producing Party must affix the “CONFIDENTIAL
18
legend” to each page that contains Protected Material. If only a portion or portions of
19
the material on a page qualifies for protection, the Producing Party also must clearly
20
identify the protected portion(s) (e.g., by making appropriate markings in the
21
margins).
22
(b) for testimony given in depositions that the Designating Party identify the
23
Disclosure or Discovery Material on the record, before the close of the deposition all
24
protected testimony. Due to the fact that the parties are direct competitors,
25
depositions of a party or an officer, director, or employee of a party shall be taken
26
only in the presence of counsel for a party (including the paralegal, clerical, and
27
secretarial staff employed by such counsel), court reporter(s) employed in this action,
28
and any other person as to whom the parties in writing agree.
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
6
STIPULATION TO PROTECTIVE ORDER
1
(c) for information produced in some form other than documentary and for any
2
other tangible items, that the Producing Party affix in a prominent place on the
3
exterior of the container or containers in which the information is stored the legend
4
“CONFIDENTIAL.” If only a portion or portions of the information warrants
5
protection, the Producing Party, to the extent practicable, shall identify the protected
6
portion(s).
7
(d) The parties may further designate certain discovery material or testimony
8
of a highly confidential and/or proprietary nature as “CONFIDENTIAL—
9
ATTORNEY'S EYES ONLY” (hereinafter “Attorney's Eyes Only Material”). Under
10
the terms of this order, the party making the designation is certifying to the court that
11
there is a good faith basis both in law and in fact for the designation within the
12
meaning of Federal Rule of Civil Procedure 26(c).
13
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
14
failure to designate qualified information or items does not, standing alone, waive the
15
Designating Party’s right to secure protection under this Order for such material.
16
Upon timely correction of a designation, the Receiving Party must make reasonable
17
efforts to assure that the material is treated in accordance with the provisions of this
18
Order.
19
20
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
21
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
22
designation of confidentiality at any time that is consistent with the Court’s
23
Scheduling Order.
24
25
6.2 Meet and Confer. The Challenging Party shall initiate the dispute
resolution process under Local Rule 37.1 et seq.
26
6.3 The burden of persuasion in any such challenge proceeding shall be on the
27
Designating Party. Frivolous challenges, and those made for an improper purpose
28
(e.g., to harass or impose unnecessary expenses and burdens on other parties) may
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
7
STIPULATION TO PROTECTIVE ORDER
1
expose the Challenging Party to sanctions. Unless the Designating Party has waived
2
or withdrawn the confidentiality designation, all parties shall continue to afford the
3
material in question the level of protection to which it is entitled under the Producing
4
Party’s designation until the Court rules on the challenge.
5
6
7. ACCESS TO AND USE OF PROTECTED MATERIAL
7
7.1 Basic Principles. A Receiving Party may use Protected Material that is
8
disclosed or produced by another Party or by a Non-Party in connection with this
9
Action only for prosecuting, defending, or attempting to settle this Action. Such
10
Protected Material may be disclosed only to the categories of persons and under the
11
conditions described in this Order. When the Action has been terminated, a
12
Receiving Party must comply with the provisions of section 13 below (FINAL
13
DISPOSITION).
14
Protected Material must be stored and maintained by a Receiving Party at a
15
location and in a secure manner that ensures that access is limited to the persons
16
authorized under this Order.
17
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
18
ordered by the court or permitted in writing by the Designating Party, a Receiving
19
Party may disclose any information or item designated “CONFIDENTIAL” only to:
20
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
21
employees of said Outside Counsel of Record to whom it is reasonably necessary to
22
disclose the information for this Action;
23
24
(b) the officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably necessary for this Action;
25
(c) Experts (as defined in this Order) of the Receiving Party to whom
26
disclosure is reasonably necessary for this Action and who have signed the
27
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
28
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
(d) the court and its personnel;
8
STIPULATION TO PROTECTIVE ORDER
1
(e) court reporters and their staff;
2
(f) professional jury or trial consultants, mock jurors, and Professional Vendors
3
to whom disclosure is reasonably necessary for this Action and who have signed the
4
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
5
6
7
8
(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(h) any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions; and
9
(i) any other person as to whom the parties in writing agree.
10
7.3 Disclosure of “Attorney’s Eyes Only Material”.
11
Attorney's Eyes Only Material, and the information contained therein, shall be
12
disclosed only to the Court, to counsel for the parties (including the paralegal,
13
clerical, and secretarial staff employed by such counsel), and to experts or
14
consultants (together with their clerical staff) retained by such counsel to assist in the
15
prosecution, defense, or settlement of this action. Attorney’s eyes only material shall
16
not be disclosed to a party, or to an officer, director or employee of a party unless
17
otherwise agreed or ordered. If disclosure of Attorney's Eyes Only Material is made
18
pursuant to this paragraph, all other provisions in this order with respect to
19
confidentiality shall also apply.
20
21
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
22
OTHER LITIGATION
23
If a Party is served with a subpoena or a court order issued in other litigation
24
that compels disclosure of any information or items designated in this Action as
25
“CONFIDENTIAL,” that Party must:
26
27
28
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
(a) promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or order to
9
STIPULATION TO PROTECTIVE ORDER
1
issue in the other litigation that some or all of the material covered by the subpoena
2
or order is subject to this Protective Order. Such notification shall include a copy of
3
this Stipulated Protective Order; and
4
5
(c) cooperate with respect to all reasonable procedures sought to be pursued by
the Designating Party whose Protected Material may be affected.
6
If the Designating Party timely seeks a protective order, the Party served with
7
the subpoena or court order shall not produce any information designated in this
8
action as “CONFIDENTIAL” before a determination by the court from which the
9
subpoena or order issued, unless the Party has obtained the Designating Party’s
10
permission. The Designating Party shall bear the burden and expense of seeking
11
protection in that court of its confidential material and nothing in these provisions
12
should be construed as authorizing or encouraging a Receiving Party in this Action to
13
disobey a lawful directive from another court.
14
15
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
16
IN THIS LITIGATION
17
(a) The terms of this Order are applicable to information produced by a Non-
18
Party in this Action and designated as “CONFIDENTIAL.” Such information
19
produced by Non-Parties in connection with this litigation is protected by the
20
remedies and relief provided by this Order. Nothing in these provisions should be
21
construed as prohibiting a Non-Party from seeking additional protections.
22
(b) In the event that a Party is required, by a valid discovery request, to
23
produce a Non-Party’s confidential information in its possession, and the Party is
24
subject to an agreement with the Non-Party not to produce the Non-Party’s
25
confidential information, then the Party shall:
26
(1) promptly notify in writing the Requesting Party and the Non-Party
27
that some or all of the information requested is subject to a confidentiality
28
agreement with a Non-Party;
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
10
STIPULATION TO PROTECTIVE ORDER
1
(2) promptly provide the Non-Party with a copy of the Stipulated
2
Protective Order in this Action, the relevant discovery request(s), and a
3
reasonably specific description of the information requested; and
4
(3) make the information requested available for inspection by the Non-
5
Party, if requested.
6
(c) If the Non-Party fails to seek a protective order from this court within 14
7
days of receiving the notice and accompanying information, the Receiving Party may
8
produce the Non-Party’s confidential information responsive to the discovery
9
request. If the Non-Party timely seeks a protective order, the Receiving Party shall
10
not produce any information in its possession or control that is subject to the
11
confidentiality agreement with the Non-Party before a determination by the court.
12
Absent a court order to the contrary, the Non-Party shall bear the burden and expense
13
of seeking protection in this court of its Protected Material.
14
15
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
16
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
17
Protected Material to any person or in any circumstance not authorized under this
18
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
19
writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
20
to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
21
persons to whom unauthorized disclosures were made of all the terms of this Order,
22
and (d) request such person or persons to execute the “Acknowledgment and
23
Agreement to Be Bound” that is attached hereto as Exhibit A.
24
25
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
26
PROTECTED MATERIAL
27
When a Producing Party gives notice to Receiving Parties that certain
28
inadvertently produced material is subject to a claim of privilege or other protection,
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
11
STIPULATION TO PROTECTIVE ORDER
1
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
2
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
3
may be established in an e-discovery order that provides for production without prior
4
privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
5
parties reach an agreement on the effect of disclosure of a communication or
6
information covered by the attorney-client privilege or work product protection, the
7
parties may incorporate their agreement in the stipulated protective order submitted
8
to the court.
9
10
11
12
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.
13
12.2 Right to Assert Other Objections. By stipulating to the entry of this
14
Protective Order no Party waives any right it otherwise would have to object to
15
disclosing or producing any information or item on any ground not addressed in this
16
Stipulated Protective Order. Similarly, no Party waives any right to object on any
17
ground to use in evidence of any of the material covered by this Protective Order.
18
12.3 Filing Protected Material. A Party that seeks to file under seal any
19
Protected Material must comply with Civil Local Rule 79-5. Protected Material may
20
only be filed under seal pursuant to a court order authorizing the sealing of the
21
specific Protected Material at issue. If a Party's request to file Protected Material
22
under seal is denied by the court, then the Receiving Party may file the information in
23
the public record unless otherwise instructed by the court.
24
25
13. FINAL DISPOSITION
26
After the final disposition of this Action, as defined in paragraph 4, within 60
27
days of a written request by the Designating Party, each Receiving Party must return
28
all Protected Material to the Producing Party or destroy such material. As used in this
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
12
STIPULATION TO PROTECTIVE ORDER
1
subdivision, “all Protected Material” includes all copies, abstracts, compilations,
2
summaries, and any other format reproducing or capturing any of the Protected
3
Material. Whether the Protected Material is returned or destroyed, the Receiving
4
Party must submit a written certification to the Producing Party (and, if not the same
5
person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
6
(by category, where appropriate) all the Protected Material that was returned or
7
destroyed and (2)affirms that the Receiving Party has not retained any copies,
8
abstracts, compilations, summaries or any other format reproducing or capturing any
9
of the Protected Material. Notwithstanding this provision, Counsel are entitled to
10
retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
11
transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
12
reports, attorney work product, and consultant and expert work product, even if such
13
materials contain Protected Material. Any such archival copies that contain or
14
constitute Protected Material remain subject to this Protective Order as set forth in
15
Section 4 (DURATION).
16
//
17
//
18
//
19
//
20
//
21
//
22
//
23
//
24
//
25
//
26
//
27
//
28
//
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
13
STIPULATION TO PROTECTIVE ORDER
1
EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3
I,
4
_________________ [print or type full address], declare under penalty of perjury that
5
I have read in its entirety and understand the Stipulated Protective Order that was
6
issued by the United States District Court for the Central District of California on
7
[date] in the case of A.C.T. 898 PRODUCTS, INC. vs. W.S. INDUSTRIES, INC.
8
(CASE NO. 8:16-CV-00476-DOC-JCG), I agree to comply with and to be bound by
9
all the terms of this Stipulated Protective Order and I understand and acknowledge
10
that failure to so comply could expose me to sanctions and punishment in the nature
11
of contempt. I solemnly promise that I will not disclose in any manner any
12
information or item that is subject to this Stipulated Protective Order to any person or
13
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 for the
15
Central District of California for the purpose of enforcing the terms of this Stipulated
16
Protective Order, even if such enforcement proceedings occur after termination of
17
this action. I hereby appoint __________________________ [print or type full
18
name] of _______________________________________ [print or type full address
19
and telephone number] as my California agent for service of process in connection
20
with this action or any proceedings related to enforcement of this Stipulated
21
Protective Order.
22
Date: ______________________________________
23
City and State where sworn and signed: _________________________________
_____________________________
[print
or
type
24
25
Printed name: _______________________________
26
27
Signature: __________________________________
28
Collins Collins
Muir + Stewart LLP
1100 El Centro Street
So. Pasadena, CA 91030
Phone (626) 243-1100
Fax
(626) 243-1111
15
STIPULATION TO PROTECTIVE ORDER
full
name],
of
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?