Gregory P Stokes et al v. Citimortgage, Inc et al
Filing
30
STIPULATED PROTECTIVE ORDER by Magistrate Judge Jean P. Rosenbluth re Stipulation for Protective Order 29 . (See Order for details) (bem)
1
5
HOWARD LAW, PC
VINCENT D. HOWARD (SBN 232478)
vhoward@howardlawpc.com
GREGORY H. D. ALUMIT (SBN 257124)
galumit@howardlawpc.com
2099 S. State College Blvd. Suite 360
Anaheim, CA 92806
Tel.: (800) 872-5925
Fax: (888) 533-7310
6
Attorneys for Plaintiffs
7
MAYER BROWN LLP
Evan Wooten (SBN 247340)
ewooten@mayerbrown.com
350 S. Grand Avenue, 25th Floor
Los Angeles, CA 90071-1503
Tel. (213) 229-9500
Fax: (213) 625-0248
2
3
4
8
9
10
11
12
13
14
15
16
17
MAYER BROWN LLP
Debra Bogo-Ernst (Admitted Pro Hac Vice)
dernst@mayerbrown.com
Michael Bornhorst (Pro Hac Vice Application to follow)
mbornhorst@mayerbrown.com
71 S. Wacker Dr.
Chicago, IL 60606-7463
Tel: (312) 782-0600
Fax: (312) 701-7711
Attorneys for Defendant
CITIMORTGAGE, INC.
18
UNITED STATES DISTRICT COURT
19
CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION
20
21
GREGORY P. STOKES and
MARIAN N. STOKES,
22
Plaintiffs,
23
24
25
26
Hon. Beverly Reid O’Connell
Hon. Jean P. Rosenbluth, Magistrate Judge
STIPULATED PROTECTIVE ORDER
v.
CITIMORTGAGE, INC. and DOES
1-10, inclusive,
27
CASE NO.: 8.16-cv-01121 BRO (JPRx)
Complaint Filed: June 16, 2016
Trial Date: September 12, 2017
Defendants.
28
-0722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
Subject to the approval of this Court, the parties hereby stipulate to the
1
2
following protective order:
3
1.
PURPOSES AND LIMITATIONS
4
Discovery in this action is likely to involve production of confidential,
5
proprietary, or private information for which special protection from public
6
disclosure and from use for any purpose other than prosecuting this litigation would
7
be warranted. Specifically, the discovery potentially includes, but is not limited to:
8
information maintained in confidence relating to defendant Citimortgage, Inc. and
9
other non-parties, the disclosure of which could place them at a competitive
10
disadvantage; and deposition testimony from corporate representatives regarding the
11
servicing of Plaintiffs’ loans. Accordingly, the parties hereby stipulate to and petition
12
the Court to enter the following Stipulated Protective Order.
13
acknowledge that this Order does not confer blanket protections on all disclosures or
14
responses to discovery and that the protection it affords extends only to the limited
15
categories of information or items identified in Section 2.3, infra. The parties further
16
acknowledge that if they wish to seek protection for additional categories of
17
information in the future, they first will request to modify this Stipulated Protective
18
Order and no modification of this Stipulated Protective Order shall have the force or
19
effect of a Court order until and unless the Court approves the modification. The
20
parties further acknowledge, as set forth in Section 10, below, that this Stipulated
21
Protective Order creates no entitlement to file confidential information under seal;
22
Central District Civil Local Rule 79-5 sets forth the procedures that must be followed
23
and reflects the standards that will be applied when a party seeks permission from the
24
court to file material under seal. This Stipulated Protective Order does not modify
25
any of the relevant procedures set forth in the Civil Local Rules.
26
2.
27
28
The parties
DEFINITIONS
2.1
Party: any party to this action, including all of its officers, directors,
employees, consultants, retained experts, and outside counsel (as well as their support
-1722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
2
staffs).
2.2
Disclosure or Discovery Material: all items or information, regardless of
3
the medium or manner generated, stored, or maintained (including, among other
4
things, testimony, transcripts, or tangible things) that are produced or generated in
5
disclosures or responses to discovery in this matter.
6
2.3
“Confidential” information or items: For the purposes of this Order,
7
“Confidential” information or items means information that qualifies as such under
8
applicable law, including:
(a)
9
Proprietary guides and policy manuals, including, but not limited
10
to, any of Defendant’s loan modification guides, loan parameters, matrices and
11
guideline eligibility notices applicable to the Plaintiffs’ loans.
(b)
12
13
Information that constitutes a trade secret in accordance with Cal.
Civil Code § 3426.1;
(c)
14
Information, materials, and/or other documents reflecting non-
15
public business or financial strategies, and/or confidential competitive information
16
which, if disclosed, would result in prejudice or harm to the disclosing party;
17
(d)
Information otherwise generally unavailable to the public; and
18
(e)
Any other information that qualifies for protection under
19
standards developed under Fed. R. Civ. P. 26(c), including but not limited to,
20
information subject to federal or state privacy rights and information protected from
21
disclosure under state or federal statutes, court rules, case decisions, or common law.
22
Defendant seeks protection from unrestricted disclosure of this
23
Confidential information to avoid the harm of competitive disadvantage of disclosure
24
of this information to competitors and other contracting parties and potential
25
contracting parties in the industry.
26
unrestricted disclosure in order to avoid violating contractual confidentiality
27
provisions.
Defendant further seeks protection from
28
-2722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
2.4
1
2
from a Producing Party.
2.5
3
4
2.6
2.7
Designating Party: a Party or non-party that designates information or
Protected Material:
any Disclosure or Discovery Material that is
designated as “Confidential.”
2.8
9
10
a Party or non-party that produces Disclosure or
items that it produces in disclosures or in responses to discovery as “Confidential.”
7
8
Producing Party:
Discovery Material in this action.
5
6
Receiving Party: a Party that receives Disclosure or Discovery Material
Outside Counsel: attorneys who are not employees of a Party but who
are retained to represent or advise a Party in this action.
11
2.9
12
2.10 Counsel (without qualifier): Outside Counsel and House Counsel (as
13
House Counsel: attorneys who are employees of a Party.
well as their support staffs).
14
2.11 Expert: a person with specialized knowledge or experience in a matter
15
pertinent to the litigation who has been retained by a Party or its Counsel to serve as
16
an expert witness or as a consultant in this action and who is not a past or a current
17
employee of a Party or a current employee of a competitor of a Party and who, at the
18
time of retention, is not anticipated to become an employee of a Party or a competitor
19
of a Party. This definition includes a professional jury or trial consultant retained in
20
connection with this litigation.
21
2.12 Professional Vendors: persons or entities, including their employees and
22
subcontractors, that provide litigation support services (e.g., photocopying;
23
videotaping; translating; preparing exhibits or demonstrations; organizing, storing,
24
retrieving data in any form or medium; etc.) to a Party and their employees and
25
subcontractors.
26
3.
27
28
SCOPE
This Order does not apply to information, Protected Material or otherwise,
presented at court proceedings and/or trial.
-3722649915.3
The protections conferred by this
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
Stipulated Protective Order apply to information exchanged in discovery.
The
2
protections conferred by this Stipulated Protective Order cover not only Protected
3
Material (as defined above), but also any information copied or extracted therefrom,
4
as well as all copies, excerpts, summaries, or compilations thereof, plus testimony,
5
conversations, or presentations by parties or counsel to or in court or in other settings
6
that might reveal Protected Material.
7
4.
DURATION
8
This Order applies only to information exchanged in discovery. Even after the
9
termination of this litigation, the confidentiality obligations imposed by this Order
10
shall remain in effect until the Designating Party that produced the Protected Material
11
at issue agrees otherwise in writing or a court order otherwise directs.
12
appropriate time, the parties will seek a separate order for other proceedings, such as
13
pre-trial and post-judgment matters.
14
5.
15
At the
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection.
16
Each Designating Party must take reasonable care to designate for protection only
17
that Discovery or Disclosure Material that the Party reasonably believes to qualify for
18
protection under this Order. Mass, indiscriminate, or routinized designations are
19
prohibited. If it comes to a Party’s or a non-party’s attention that information or
20
items that it designated for protection do not qualify for the protection initially
21
asserted, that Party or non-party must promptly notify all other Parties that it is
22
withdrawing the designation.
23
5.2
Manner and Timing of Designations. Except as otherwise provided in
24
this Order (see, e.g., second paragraph of section 5.2 (a), below), or as otherwise
25
stipulated or ordered, material that qualifies for protection under this Order should be
26
clearly so designated at the time the material is disclosed or produced. However, if
27
information which otherwise qualifies for protection under this order is produced or
28
disclosed without the proper designation, the producing party shall have seven (7)
-4722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
days from production or disclosure to make the appropriate designation. Nothing in
2
this Order concerning designation for protection, however, shall be interpreted as
3
controlling the form of production of any material by any Party or non-party.
4
Designation in conformity with this Order requires:
(a)
5
for information in documentary form (apart from transcripts of
6
depositions or other pretrial or trial proceedings), that the Producing Party affix the
7
legend "CONFIDENTIAL" at the top or bottom of each page that contains protected
8
material.
9
A Party or non-party that makes original documents or materials
10
available for inspection need not designate them for protection until after the
11
inspecting Party has indicated which material it would like copied and produced.
12
During the inspection and before the designation, all of the material made available
13
for inspection shall be deemed Protected Material. After the inspecting Party has
14
identified the documents it wants copied and produced, the Producing Party must
15
determine which documents qualify for protection under this Order, then, before
16
producing the specified documents, the Producing Party must affix the legend
17
“CONFIDENTIAL” at the top or bottom of each page that contains Protected
18
Material.
(b)
19
for testimony given in deposition, that the Party or non-party
20
offering or sponsoring the testimony take reasonable steps to identify on the record,
21
before the close of the deposition, the specific identity or the scope of all Protected
22
Materials in such testimony, and further specify any portions of the testimony that
23
qualify as “CONFIDENTIAL.” When it is impractical to identify separately each
24
portion of testimony that is entitled to protection, and when it appears that substantial
25
portions of the testimony may qualify for protection, the Party or non-party that
26
sponsors, offers, or gives the testimony may invoke on the record (before the
27
deposition is concluded) a right to have up to thirty (30) days after delivery of the
28
deposition transcript to identify the specific portions of the testimony as to which
-5722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
protection is sought. Only those portions of the testimony that are appropriately
2
designated for protection within the thirty (30) days after delivery of the deposition
3
transcript shall be covered by the provisions of this Stipulated Protective Order.
4
Transcript pages containing Protected Material must be separately bound by the court
5
reporter, who must affix to the top or bottom of each such page the legend
6
“CONFIDENTIAL” as instructed by the Party or nonparty offering or sponsoring the
7
witness or presenting the testimony.
(c)
8
for information produced in some form other than documentary,
9
and for any other tangible items, that the Producing Party affix in a prominent place
10
on the exterior of the container or containers in which the information or item is
11
stored the legend “CONFIDENTIAL.”
12
5.3
Inadvertent Failures to Designate. If any Confidential information is
13
inadvertently produced without being marked appropriately as Protected Material in
14
accordance with this Order, the Producing Party may thereafter designate such
15
material(s) as Confidential and the initial failure to so mark the material shall not be
16
deemed a waiver of its confidentiality.
17
If a Party inadvertently produces information that it later discovers, or in good
18
faith later asserts, to be subject to any legal privileges, including but not limited to,
19
the attorney-client privilege or work product doctrine, or is otherwise protected from
20
disclosure, the production of that information will not be presumed to constitute a
21
waiver of any applicable privileges or other protections. In these circumstances, the
22
Producing Party must promptly notify all Parties in writing of the inadvertent
23
production and the basis for the claim of privilege or other protection from
24
production, and request in writing the return or confirmed destruction of the
25
privileged or protected information.
26
notification, and in compliance with the receiving parties’ ethical obligations under
27
the law, all Receiving Parties who have not already reviewed such materials or who
28
have reviewed the materials but do not contest the applicability of the privilege
Within five (5) days of receiving such
-6722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
asserted must return or confirm destruction of all such materials, including copies
2
and/or summaries thereof.
3
applicability of a privilege asserted with respect to an inadvertently produced
4
document which the Receiving Party has already reviewed, the Receiving Party may
5
temporarily retain the document or documents at issue, segregated and not further
6
copied or disseminated, for the sole purpose of contesting the applicability of the
7
privilege asserted. Within two (2) business days of the issuance of a court order
8
deeming the contested documents at issue privileged, or protected from production,
9
the Receiving Party must return or confirm destruction of all such materials,
However, should a Receiving Party contest the
10
including copies and/or summaries thereof.
11
6.
12
CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Unless a prompt challenge to a Designating
13
Party’s designation of Protected Material is necessary to avoid foreseeable substantial
14
unfairness, unnecessary economic burdens, or a later significant disruption or delay
15
of the litigation, a Party does not waive its right to challenge a designation of
16
Protected Material by electing not to mount a challenge promptly after the original
17
designation is disclosed.
18
6.2
Meet and Confer.
A Party that elects to initiate a challenge to a
19
Designating Party’s designation of Protected Material must do so in good faith and
20
must begin the process by conferring with counsel for the Designating Party. In
21
conferring, the challenging Party must explain the basis for its belief that the
22
designation of Protected Material was not proper and must give the Designating Party
23
an opportunity to review the Protected Material at issue, to reconsider the
24
circumstances, and, if no change in designation is offered, to explain the basis for the
25
chosen designation.
26
challenge process only if it has engaged in this meet and confer process first.
A challenging Party may proceed to the next stage of the
27
28
-7722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
6.3
1
Judicial Intervention. A Party electing to challenge the designation of
2
material as “CONFIDENTIAL” must comply with the procedure established in Civil
3
Local Rules 37-1 and 37-2.
4
The burden of persuasion in any such challenge shall be on the Designating
5
Party. Until the court rules on the challenge, all Parties shall continue to afford the
6
material in question the level of protection to which it is entitled under the Producing
7
Party’s designation.
8
7.
9
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is
10
disclosed or produced by another Party or by a non-party in connection with this case
11
only for prosecuting, defending, or attempting to settle this litigation. Such Protected
12
Material may be disclosed only to the categories of persons and under the conditions
13
described in this Order. When the litigation has been terminated, a Receiving Party
14
must comply with the provisions of section 11 (FINAL DISPOSITION), below.
15
Protected Material must be stored and maintained by a Receiving Party at a location
16
and in a secure manner that ensures that access is limited to the persons authorized
17
under this Order.
18
7.2
Disclosure of “CONFIDENTIAL” Information or Items.
Unless
19
otherwise ordered by the Court or permitted in writing by the Designating Party, a
20
Receiving Party may disclose any information or item designated CONFIDENTIAL
21
only to:
(a)
22
the Receiving Party’s Outside Counsel of record in this action, as
23
well as employees of said Counsel to whom it is reasonably necessary to disclose the
24
information for this litigation;
25
(b)
26
the officers, directors, and employees (including House Counsel)
of the Receiving Party to whom disclosure is reasonably necessary for this litigation;
27
28
-8722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
(c)
1
Experts (as defined in this Order) of the Receiving Party to whom
2
disclosure is reasonably necessary for this litigation and who have signed the
3
“Agreement to Be Bound by Protective Order” which is attached as Exhibit A;
4
(d)
the Court and its personnel;
5
(e)
court reporters, their staffs, and Professional Vendors to whom
6
disclosure is reasonably necessary for this litigation;
7
(f)
mediators and their staff to whom disclosure is reasonably
8
necessary for this litigation;
9
(g)
deponents to whom disclosure is reasonably necessary, provided
10
they execute the Agreement attached hereto as Exhibit A. Pages of transcribed
11
deposition testimony or exhibits to depositions that reveal Protected Material must be
12
separately bound by the court reporter and may not be disclosed to anyone except as
13
permitted under this Stipulated Protective Order; and
(h)
14
the author or recipient of a document containing the information
15
or a custodian or other person who otherwise possessed or knew the information.
16
8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED
17
PRODUCED IN OTHER LITIGATION
18
If a Receiving Party is served with a subpoena or an order issued in other
19
litigation that would compel disclosure of any information or items designated in this
20
action as “CONFIDENTIAL,” the Receiving Party must so notify the Designating
21
Party, in writing (by email and/or fax, if possible) immediately and in no event more
22
than three (3) court days after receiving the subpoena or order. Such notification
23
must include a copy of the subpoena or court order.
24
The Receiving Party also must immediately inform in writing the Party who
25
caused the subpoena or order to issue in the other litigation that some or all the
26
material covered by the subpoena or order is the subject of this Protective Order. In
27
addition, the Receiving Party must deliver a copy of this Stipulated Protective Order
28
promptly to the Party in the other action that caused the subpoena or order to issue.
-9722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
The purpose of imposing these duties is to alert the interested parties to the
2
existence of this Protective Order and to afford the Designating Party in this case a
3
reasonable opportunity to try to protect its competitive or confidentiality interests, or
4
its rights or obligations, in the court from which the subpoena or order issued. The
5
Designating Party shall bear the burdens and the expenses of seeking protection in
6
that court of its confidential material – and nothing in this Stipulated Order should be
7
construed as authorizing or encouraging a Receiving Party in this action to disobey a
8
lawful subpoena issued in another action.
9
9.
UNAUTHORIZED DISCLOSURE OR USE OF PROTECTED
10
MATERIAL
11
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
12
Protected Material to any person or in any circumstance not authorized under this
13
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
14
writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
15
to retrieve all copies of the Protected Material, (c) inform the person or persons to
16
whom unauthorized disclosures were made of all the terms of this Order, and (d)
17
request such person or persons to execute the “Acknowledgment and Agreement to
18
Be Bound” that is attached hereto as Exhibit A.
19
“CONFIDENTIAL” under this Stipulated Protective Order may not be used by any
20
Party or its counsel for any purpose unrelated to the above-captioned action.
21
10.
Information designated as
FILING PROTECTED MATERIAL
22
In accordance with Local Rule 79-5.1, if any papers to be filed with the Court
23
contain information and/or documents that have been designated “Confidential,” the
24
proposed filing shall be accompanied by an application to file the papers or the
25
portion thereof containing the designated information or documents (if such portion
26
is segregable) under seal; and the application shall be directed to the judge to whom
27
the papers are directed. For motions, the Parties shall publicly file a redacted version
28
of the motion and supporting papers. This Order is entered into without prejudice to
-10722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
the right of any Designating Party or non-party to knowingly waive the applicability
2
of this order to any Protected Materials to file papers that contain, reference, or attach
3
such Protected Materials with the Court or for any other purpose.
4
Prior to filing papers with the Court that contain, reference, or attach Protected
5
Materials, a Receiving Party may request, in writing, by specific identification of the
6
Protected Materials proposed to be filed, that the Designating Party waive the
7
applicability of this order to such Protected Materials, either in whole or in part (such
8
as by redaction of Confidential information in such Protected Materials), so as to
9
eliminate the need for an application to file under seal. The Designating Party shall
10
be under no obligation to accept such a request, in whole or in part, but shall respond
11
to any such request within five (5) calendar days.
12
11.
FINAL DISPOSITION
13
Unless otherwise ordered or agreed in writing by the Producing Party, within
14
sixty (60) days after the final termination of this action, each Receiving Party must
15
return all Protected Material to the Producing Party. As used in this subdivision, "all
16
Protected Material" includes all copies, abstracts, compilations, summaries or any
17
other form of reproducing or capturing any of the Protected Material.
18
permission in writing from the Designating Party, the Receiving Party may destroy
19
some or all of the Protected Material instead of returning it. Whether the Protected
20
Material is returned or destroyed, the Receiving Party must submit a written
21
certification to the Producing Party (and, if not the same person or entity, to the
22
Designating Party) by the sixty-day deadline that identifies (by category, where
23
appropriate) all the Protected Material that was returned or destroyed and that affirms
24
that the Receiving Party has not retained any copies, abstracts, compilations,
25
summaries or other forms of reproducing or capturing any of the Protected Material.
26
Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
27
pleadings, motion papers, transcripts, legal memoranda, correspondence or attorney
28
work product, even if such materials contain Protected Material. Any such archival
-11722649915.3
With
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
copies that contain or constitute Protected Material remain subject to this Protective
2
Order as set forth in Section 4 (DURATION), above.
3
12.
MISCELLANEOUS
4
12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
5
abridges the right of any person to seek its modification by the Court in the future,
6
however, no such modification shall have the force or effect of a Court order until
7
and unless the Court approves the modification.
8
12.2 Right to Assert Other Objections. By stipulating to the entry of this
9
Protective Order no Party waives any right it otherwise would have to object to
10
disclosing or producing any information or item on any ground not addressed in this
11
Stipulated Protective Order. Similarly, no Party waives any right to object on any
12
ground to use in evidence of any of the material covered by this Protective Order.
13
SO STIPULATED:
14
15
DATED: January 19, 2017
HOWARD LAW PC
16
18
/s/ Vincent D. Howard
Vincent D. Howard
Gregory H. D. Alumit
19
Attorneys for Plaintiffs
17
20
DATED: January 19, 2017
21
MAYER BROWN LLP
/s Evan M. Wooten
Evan Wooten
Debra Bogo-Ernst (admitted pro hac vice)
Michael Bornhorst (pro hac pending)
22
23
24
Attorneys for Defendant
25
26
Pursuant to Local Rule 5-4.3.4(a)(2)(ii), the filer hereby attests that all other
27
signatories to this document concur in the content of, and have authorized, this filing.
28
-12722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
ORDER
2
3
4
The parties having stipulated to the foregoing and good cause appearing, IT IS
SO ORDERED.
5
6
Dated: January 19, 2017
Honorable Jean P. Rosenbluth
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
-13722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
1
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
I,
__________________________
[print
or
type
full
name],
of
3
____________________________________________________ [print or type full
4
address], declare under penalty of perjury that I have read in its entirety and
5
understand the Stipulated Protective Order that was issued by the United States
6
District Court for the Central District of California in the case of Gregory P. Stokes
7
and Marian N. Stokes v. Citimortgage, Inc. on ________________ [Date]. I agree to
8
comply with and to be bound by all the terms of this Stipulated Protective Order and I
9
understand and acknowledge that failure to so comply could expose me to sanctions
10
and punishment in the nature of contempt. I solemnly promise that I will not disclose
11
in any manner any information or item that is subject to this Stipulated Protective
12
Order to any person or entity except in strict compliance with the provisions of this
13
Order, even if such enforcement proceedings occur after termination of this action.
14
I further agree to submit to the jurisdiction of the United States District
15
Court for the Central District of California for the purpose of enforcing the terms of
16
this Stipulated Protective Order.
17
I hereby appoint ___________________________ [print or type full name]
18
of ___________________________________________________ [print or type full
19
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
25
Printed Name: ________________________
26
27
Signature: ____________________________
28
-14722649915.3
Stipulated Protective Order
Case No.: 8.16-cv-01121 BRO (JPRx)
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?