Opus Bank v. Donika Schnell et al

Filing 60

STIPULATED PROTECTIVEORDER by Magistrate Judge Jay C. Gandhi re Notice of Lodging Stipulated Protective Order #59 . (kh)

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1 2 3 4 5 6 7 8 9 10 11 12 Paul Hastings LLP Bradford K. Newman (SBN 178902) Jessica E. Mendelson (SBN 280388) 1117 S. California Avenue Palo Alto, CA 94304 Telephone : 1(650) 320-1800 Facsimile : 1(650) 320-1900 Attorneys for OPUS BANK Venable LLP Richard J. Frey (SBN 174120) Ryan M. Andrews (SBN 274106) 2049 Century Park East, Suite 2300 Los Angeles, CA 90067 Telephone : 1(310) 229-9630 Facsimile : 1(310) 229-9901 13 14 Attorneys for DONIKA SCHNELL, MICHAEL KINNICK, SHARMILA SOLANKI and BRYAN NANCE 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Sims Funk, PLC Samuel P. Funk Mark Lenihan 3310 West End Avenue, #410 Nashville, TN 37203 Telephone : 1(615) 292-9335 Facsimile : 1(615) 649-8565 Peter J. Gimino III (SBN 198926) pgimino@giminolaw.com The Gimino Law Office 1 Park Plaza, Suite 600 Irvine, CA 92614 Telephone: (949) 225-4446 Facsimile: (949)225-4447 Attorneys for GREGORY RATLIFF 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION 10 11 CASE NO.: 8:17-CV-00633-CJC-JCG OPUS BANK, Plaintiff, 12 13 STIPULATED PROTECTIVE ORDER v. Honorable Jay C. Gandhi 14 15 16 17 18 19 DONIKA SCHNELL, MICHAEL KINNICK, SHARMILA SOLANKI, BRYAN NANCE, and GREGORY RATLIFF, Action Filed: April 7, 2017 Trial Date: TBD Defendants. ___________________________________ 20 21 22 23 24 25 26 27 28 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to 2 1 discovery and that the protection it affords from public disclosure and use extends 2 only to the limited information or items that are entitled to confidential treatment 3 under the applicable legal principles. The parties further acknowledge, as set forth 4 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 5 file confidential information under seal; Civil Local Rule 79-5 sets forth the 6 procedures that must be followed and the standards that will be applied when a 7 party seeks permission from the court to file material under seal. 8 B. 9 GOOD CAUSE STATEMENT 10 This action is likely to involve trade secrets, customer and pricing lists and 11 other valuable research, development, commercial, financial, technical and/or 12 proprietary information for which special protection from public disclosure and 13 from use for any purpose other than prosecution of this action is warranted. Such 14 confidential and proprietary materials and information consist of, among other 15 things, confidential business or financial information, information regarding 16 confidential business practices, strategies, or other confidential research, 17 development, or commercial information (including information implicating 18 privacy rights of third parties), as well as information otherwise generally 19 unavailable to the public, or which may be privileged or otherwise protected from 20 disclosure under state or federal statutes, court rules, case decisions, or common 21 law. 22 Accordingly, to expedite the flow of information, to facilitate the prompt 23 resolution of disputes over confidentiality of discovery materials, to adequately 24 protect information the parties are entitled to keep confidential, to ensure that the 25 parties are permitted reasonable necessary uses of such material in preparation for 26 and in the conduct of trial, to address their handling at the end of the litigation, and 27 serve the ends of justice, a protective order for such information is justified in this 28 matter. It is the intent of the parties that information will not be designated as 3 1 confidential for tactica reasons and that nothing be so design al nated without a good d 2 faith belief that it has been mai s intained in a confidential, non n-public m manner, and 3 there is good cause wh it should not be pa of the public recor of this c hy d art rd case. 4 5 6 2. DEFINITIONS 2.1 Action: This federa litigation, Opus Bank v. Don Schne Michael T al nika ell, 7 Kinnick, Sharmial Solanki, Bry Nance and Gregory Ratliff Case No 8:17-cvK yan ff, o. 8 00 0633-CJC-JCG. 9 10 11 2.2 ing Party: Challengi a Par rty or Non-Party that chall lenges the de esignation of informa ation or items under t Order. this 2.3 “CONFID DENTIAL” Information or Items: inform ” mation (regardless of 12 ho it is generated, stored or maintai ned) or tan ow g r ngible thin that q ngs qualify for 13 pr rotection under Fede Rule of Civil Procedure 26 eral o 6(c), and a specifie above in as ed 14 the Good Cause Statem ment. 15 16 17 2.4 Counsel: Outside Counsel of Record a House Counsel (as well as C f and e their support staff). 2.5 ing gnates info ormation or Designati Party: a Party or Non-Party that desig 18 items that it produ uces in disclosures or in responses to discovery as 19 “CONFIDENTIAL.” 20 2.6 re overy Mat erial: all it tems or inf formation, regardless , Disclosur or Disco 21 of the medium or man f nner in whi it is generated, st ich tored, or m maintained (including g, 22 among other things, te estimony, transcripts, and tangible thing that are produced gs), e 23 or generated in disclos r sures or res sponses to discovery in this ma atter. 24 2.7 Expert: a person with special lized knowledge or e experience in a matter 25 pe ertinent to the litigati who ha been reta ion as ained by a Party or it counsel to serve as ts 26 an expert witness or as a consultant in this Action. s 27 28 4 2.8 1 House Co ounsel: att torneys wh are employees of a party to t Action ho this n. 2 House Counsel does not include Outside Counsel of Record or any oth outside n e her 3 counsel. 2.9 4 5 Non-Party any na y: atural person, partnership, corp poration, a association n, or other legal entity no named as a Party to this actio r ot a on. 6 2.10 Outside Counsel of Record: attorneys who are not employees of a C f 7 pa to this Action bu are retain to represent or advise a par to this A arty ut ned rty Action and 8 ha appeared in this Action on behalf of t ave A that party or are affil liated with a law firm m 9 which has appeared on behalf of that party, and includes support staff. n f 10 2.11 Party: an party to this Action, including all of i officers directors ny o its s, s, 11 employees, consultant retained experts, a Outside Counsel of Record (and their ts, d and d 12 support staffs). 2.12 Producing Party: a Party or Non-Part that pro g ty oduces Dis sclosure or 13 14 Discovery Material in this Action n. 2.13 Profession Vendo nal ors: 15 persons or entities tha provide litigation at e 16 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 de emonstrations, and organizing, storing, or retrieving data in a form o medium) any or 18 and their em mployees an subcont nd tractors. 19 2.14 Protected Material: d : 20 de esignated as “CONFI IDENTIAL L.” 2.15 Receiving Party: g 21 22 any Disclosure or Discov very Mater rial that is losure or Discovery a Party that receives Discl Material from a Produ M ucing Party y. 23 24 3. PE SCOP 25 The protections conferred by this Stipulation and Or s rder cover not only r 26 as but Protected Material (a defined above), b also (1) any information copied or 27 extracted from Protected Ma aterial; (2) all copi ies, excer rpts, summ maries, or 28 5 1 compilations of Prot tected Ma aterial; and (3) any testimony convers y, sations, or 2 pr resentations by Partie or their Counsel th might r es C hat reveal Prote ected Mate erial. Any use of Prot tected Mat terial at trial shall be governed by the or d rders of the 3 4 trial judge. This Order does not govern the use of Pr r e rotected Ma aterial at tr rial. 5 6 4. DURATION 7 Even after fina disposition of this litigation, the confid n al dentiality obligations 8 der emain in effect until a Desig gnating Pa arty agrees imposed by this Ord shall re 9 ot therwise in writing or a court order otherwise directs. Final dispositio shall be o l on 10 de eemed to be the late of (1) di b er ismissal o f all claims and def fenses in th Action his n, 11 with or without prejud dice; and (2) final judgment herein after the comp r pletion and d 12 exhaustion of all appeals, rehea arings, re mands, trials, or rev views of th Action his n, 13 including the time limits for filin any mo tions or applications for extension of time ng 14 pu ursuant to applicable law. a 15 16 17 5. DESIGNATING PROTEC G CTED MA ATERIAL 5.1 Exercise of Restrain and Care in Designating Ma nt aterial for Protection n. 18 arty esignates information or items for protec ction under Each Party or Non-Pa that de 19 this Order must take care to lim any such design mit nation to s specific material that 20 qu ualifies under the app propriate st tandards. The Designating Par must de rty esignate for 21 pr rotection only those parts of material, documents, items, or oral or written e f , 22 communications that qualify so that other portions of the m o material, d documents, 23 items, or communications for which protection is not warr ranted are not swept 24 un njustifiably within the ambit of this Order. f 25 Mass, indiscrim minate, or ro outinized designations are proh hibited. De esignations 26 that are shown to be clearly un njustified or that hav been m ve made for an improper n 27 pu urpose (e.g., to unn necessarily encumber the case develop y pment process or to 28 6 1 impose unnecessary expenses and burdens on other partie may e es) expose the 2 Designating Party to sanctions. 3 If it comes to a Designatin Party’s attention that inform ng mation or it tems that it 4 esignated for protecti do not qualify for protection, that De ion esignating Party must de 5 pr romptly notify all oth Parties that it is withdrawing the inapp her plicable de esignation. 6 5.2 Manner and Timing of Designations. Except as o a g otherwise p provided in n 7 this Order (see, e.g., second pa aragraph of section 5.2(a) belo ow), or as otherwise s 8 stipulated or ordered, Disclosure or Discovery Material that qu e ualifies for protection r 9 un nder this Order must be clearly so designated before the ma t y aterial is d disclosed or 10 11 12 pr roduced. c y Designation in conformity with this Order requires: (a) for in nformation in docu mentary fo orm (e.g., paper or electronic 13 do ocuments, but exclu uding tran nscripts of depositions or ot ther pretri or trial ial 14 pr roceedings), that th Produ he ucing Part affix at a min ty nimum, th legend he 15 “CONFIDENTIAL” (hereinafte “CONFI ( er IDENTIAL legend”), to each page that h 16 contains protected material. If only a portion or por o rtions of th material on a page he l 17 qu ualifies for protection the Prod n, ducing Part also must clearly i ty identify the protected 18 po ortion(s) (e.g., by ma aking appro opriate markings in the margins s). 19 A Par or Nonrty -Party that makes original documents available for inspection t r n 20 ne not designate the for prot eed em tection unt after the inspectin Party ha indicated til ng as 21 which documents it would like copied and produced. Durin the insp w ng pection and 22 be efore the designation all of th materia made available for inspectio shall be d n, he al on 23 de eemed “CONFIDEN NTIAL.” After the inspecting Party has iden ntified the 24 do ocuments it wants copied and produced, the Pro c d oducing Party must determine 25 which documents, or portions thereof, qualify for protectio under t on this Order. 26 Then, before producin the specified documents, the Producing Party mu affix the ng g ust 27 “CONFIDENTIAL leg gend” to ea page that contain Protecte Material If only a ach ns ed l. 28 po ortion or portions of the materi on a page qualifies for prote ial ection, the Producing 7 1 Party also must cle early iden ntify the protected portion(s) (e.g., b making ) by g 2 appropriate markings in the marg i gins). (b) 3 for te estimony given in d g depositions that the Designa e ating Party 4 identify the Disclosure or Discov e very Material on the record, be e efore the c close of the 5 de eposition all protected testimon ny. (c) 6 for inf formation produced in some form other th docum p han mentary and d 7 for any other tangible items, tha the Prod ucing Party affix in a prominen place on at nt 8 the exterior of the container or containers in which the infor rmation is stored the 9 legend “CONFIDENT TIAL.” If only a portion or portions of the in f nformation 10 warrants protection, th Producin Party, to the extent practicab shall i he ng ble, identify the 11 pr rotected portion(s). 5.3 12 rected, an i inadverten nt Inadvertent Failures to Designate. If timely corr 13 failure to designate qu ualified inf formation or items d does not, standing alone, waive 14 the Designating Party right to secure protection under t y’s this Order for such r 15 material. Upon timely correctio of a des m y on signation, the Receiv ving Party must make 16 reasonable efforts to assure tha the material is treated in accordance with the at 17 pr rovisions of this Orde er. 18 19 20 6. CHALLENGIN CONFIDENTIALITY DESIGNATIO NG ONS 6.1 Timing of Challen o nges. Any Party or Non-Par may c y rty challenge a 21 esignation of confid dentiality at any tim that is consisten with th Court’s me nt he de 22 Scheduling Order. 23 24 25 6.2 d allenging Party shall initiate t dispute l the Meet and Confer. The Cha resolution process und Local Rule 37.1 et seq. der R 6.3 The burde of persu en uasion in any such challenge pr roceeding shall be on 26 the Designating Party Frivolo challenges, and those ma for an improper y. ous ade n 27 pu urpose (e.g., to hara or imp ass pose unnecessary ex xpenses an burdens on other nd 28 pa arties) may expose the Challen t nging Party to sanctions. Un nless the D Designating 8 1 Party has waived or withdrawn the confidentiality designation, all pa n arties shall 2 continue to afford the material in question the level of prote e ection to w which it is 3 entitled under the Pr roducing Party’s de P esignation until the Court rul on the les 4 challenge. 5 6 7 7. ND O L ACCESS TO AN USE OF PROTECTED MATERIAL 7.1 Basic Prin nciples. A Receiving Party may use Prot tected Mate erial that is 8 isclosed or produced by another Party or by a Non d n-Party in connection with this di 9 Action only for prose y ecuting, defending, or attempting to settl this Act le tion. Such 10 Protected Material ma be disclo ay osed only t the categories of p to persons and under the d 11 conditions described in this Order. O 12 Receiving Party must comply with the provisions of sectio 13 below (FINAL t on w L 13 DISPOSITION). Wh hen the Action has been term s minated, a 14 Protected Mater must be stored a maintained by a Receiving Party at a rial b and g 15 ure r imited to t persons the location and in a secu manner that ensures that access is li 16 authorized under this Order. O 17 7.2 Disclosur of “CO re ONFIDENT TIAL” Information or Items s. Unless 18 ot therwise ordered by the court or permitted in writi by the Designatin Party, a o ing ng 19 Receiving 20 “CONFIDENTIAL” only to: o 21 (a) Party may m disc close any information or r item designated the Re eceiving Pa arty’s Outs side Counsel of Reco in this Action, as ord 22 well as employees of said Outside Coun f nsel of Record to wh hom it is reasonably 23 ne ecessary to disclose the informa t ation for this Action; ; 24 25 26 (b) the off ficers, dire ectors, and employees (includin House C ng Counsel) of the Receiving Party to whom dis sclosure is reasonably necessary for this A y Action; (c) Expert (as defin in this Order) of the Rece ts ned s eiving Party to whom y m 27 di isclosure is reasona ably neces ssary for this Action and who have signed the 28 “Acknowledgment and Agreeme to Be B d ent Bound” (Exhibit A); 9 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 4 Vendors to whom disclosure is reasonably necessary for this Action and who have 5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) 6 7 the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; (h) 8 during their depositions, witnesses, and attorneys for witnesses, in 9 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 10 party requests that the witness sign the form attached as Exhibit 1 hereto; and 11 (2) they will not be permitted to keep any confidential information unless they sign 12 the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 13 agreed by the Designating Party or ordered by the court. Pages of transcribed 14 deposition testimony or exhibits to depositions that reveal Protected Material may 15 be separately bound by the court reporter and may not be disclosed to anyone 16 except as permitted under this Stipulated Protective Order; and (i) 17 18 any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 19 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 21 IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 23 that compels disclosure of any information or items designated in this Action as 24 “CONFIDENTIAL,” that Party must: 25 26 27 28 (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 issue in the other litigation that some or all of the material covered by the 10 1 subpoena or order is subject to this Protective Order. 2 include a copy of this Stipulated Protective Order; and (c) 3 4 Such notification shall cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 5 If the Designating Party timely seeks a protective order, the Party served with 6 the subpoena or court order shall not produce any information designated in this 7 action as “CONFIDENTIAL” before a determination by the court from which the 8 subpoena or order issued, unless the Party has obtained the Designating Party’s 9 permission. The Designating Party shall bear the burden and expense of seeking 10 protection in that court of its confidential material and nothing in these provisions 11 should be construed as authorizing or encouraging a Receiving Party in this Action 12 to disobey a lawful directive from another court. 13 14 9. 15 PRODUCED IN THIS LITIGATION 16 A NON-PARTY’S (a) PROTECTED MATERIAL SOUGHT TO BE The terms of this Order are applicable to information produced by a 17 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 18 produced by Non-Parties in connection with this litigation is protected by the 19 remedies and relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional protections. 21 (b) In the event that a Party is required, by a valid discovery request, to 22 produce a Non-Party’s confidential information in its possession, and the Party is 23 subject to an agreement with the Non-Party not to produce the Non-Party’s 24 confidential information, then the Party shall: 25 (1) promptly notify in writing the Requesting Party and the Non- 26 Party that some or all of the information requested is subject to a confidentiality 27 agreement with a Non-Party; 28 11 (2) 1 promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a reasonably 3 specific description of the information requested; and (3) 4 5 make the information requested available for inspection by the Non-Party, if requested. (c) 6 If the Non-Party fails to seek a protective order from this court 7 within 14 days of receiving the notice and accompanying information, the 8 Receiving Party may produce the Non-Party’s confidential information responsive 9 to the discovery request. If the Non-Party timely seeks a protective order, the 10 Receiving Party shall not produce any information in its possession or control that 11 is subject to the confidentiality agreement with the Non-Party before a 12 determination by the court. Absent a court order to the contrary, the Non-Party 13 shall bear the burden and expense of seeking protection in this court of its Protected 14 Material. 15 16 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 17 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 18 Protected Material to any person or in any circumstance not authorized under this 19 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 20 writing the Designating Party of the unauthorized disclosures, (b) use its best 21 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 22 person or persons to whom unauthorized disclosures were made of all the terms of 23 this Order, and (d) request such person or persons to execute the “Acknowledgment 24 and Agreement to Be Bound” that is attached hereto as Exhibit A. 25 26 27 28 12 INADVERTEN PRODU NT UCTION OF PRIVILEGED OR OTH HERWISE E 1 11. 2 PROTECTED MATER RIAL 3 When a Produ ucing Party gives notice to Receiving Parties th certain y hat 4 inadvertently produce materia is subj ed al ject to a claim of privilege or other f e 5 pr rotection, the obligat tions of th Receiving Parties are those set forth in Federal he s e 6 Rule of Civil Procedu 26(b)( ure (5)(B). This provision is not intended to modify t 7 whatever procedure may be est m tablished in an e-discovery ord that pr n der rovides for 8 pr roduction without pr privile review Pursuant to Feder Rule of Evidence rior ege w. ral 9 50 02(d) and (e), insofar as the parties reach an agreem r h ment on th effect of disclosure he f 10 of a communication or informati covered by the attorney-client privile or work f r ion ege 11 pr roduct protection, th parties may incorporate their agreem he m ment in the stipulated e 12 pr rotective order submi itted to the court. e 13 14 15 16 12 2. MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the r F right of any pe erson to seek its mod dification by the Court in the future. b 17 12.2 Right to Assert Oth Objections. By stipulating to the en of this her g ntry 18 Protective Order no Party waiv any right it otherwise wou have to object to P ves uld o 19 di isclosing or producin any inf ng formation or item on any grou not ad und ddressed in 20 this Stipulated Protect tive Order. Similarly no Party waives a right to object on . y, any o 21 any ground to use in evidence of any of the mater covere by this Protective rial ed 22 Order. 23 12.3 Filing Pro otected Material. A Party tha seeks to file unde seal any at o er 24 ust y . ed Protected Material mu comply with Civil Local Rule 79-5. Protecte Material 25 may only be filed under seal pur m rsuant to a court order authoriz zing the sea aling of the 26 specific Protected Material at issue. If a Party’s request to fil Protecte Material le ed 27 un nder seal is denied by the court then the Receiving Party may file the in y t, y nformation 28 in the public record un nless otherw instru wise ucted by the court. 13 3 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 3 60 days of a written request by the Designating Party, each Receiving Party must 4 return all Protected Material to the Producing Party or destroy such material. As 5 used in this subdivision, “all Protected Material” includes all copies, abstracts, 6 compilations, summaries, and any other format reproducing or capturing any of the 7 Protected Material. Whether the Protected Material is returned or destroyed, the 8 Receiving Party must submit a written certification to the Producing Party (and, if 9 not the same person or entity, to the Designating Party) by the 60 day deadline that 10 (1) identifies (by category, where appropriate) all the Protected Material that was 11 returned or destroyed and (2) affirms that the Receiving Party has not retained any 12 copies, abstracts, compilations, summaries or any other format reproducing or 13 capturing any of the Protected Material. Notwithstanding this provision, Counsel 14 are entitled to retain an archival copy of all pleadings, motion papers, trial, 15 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 16 and trial exhibits, expert reports, attorney work product, and consultant and expert 17 work product, even if such materials contain Protected Material. Any such archival 18 copies that contain or constitute Protected Material remain subject to this Protective 19 Order as set forth in Section 4 (DURATION). 20 21 14. Any violation of this Order may be punished by any and all appropriate 22 measures including, without limitation, contempt proceedings and/or monetary 23 sanctions. 24 25 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 26 27 DATED _____November 3, 2017________ 28 14 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 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 ______________ [insert formal name of the case and the 8 number and initials assigned to it by the court]. I agree to comply with and to be 9 bound 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 11 punishment in the nature of contempt. I solemnly promise that I will not disclose in 12 any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. 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, 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 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 16

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