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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Paul Hastings LLP
Bradford K. Newman (SBN 178902)
Jessica E. Mendelson (SBN 280388)
1117 S. California Avenue
Palo Alto, CA 94304
Telephone : [phone]
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 : [phone]
Facsimile : 1(310) 229-9901

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Attorneys for DONIKA SCHNELL, MICHAEL KINNICK,
SHARMILA SOLANKI and BRYAN NANCE

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Sims Funk, PLC
Samuel P. Funk
Mark Lenihan
3310 West End Avenue, #410
Nashville, TN 37203
Telephone : [phone]
Facsimile : 1(615) 649-8565
Peter J. Gimino III (SBN 198926)
[e-mail]
The Gimino Law Office
1 Park Plaza, Suite 600
Irvine, CA 92614
Telephone: [phone]
Facsimile: [phone]
Attorneys for GREGORY RATLIFF

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION

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CASE NO.: 8:17-CV-00633-CJC-JCG

OPUS BANK,
Plaintiff,

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STIPULATED PROTECTIVE
ORDER

v.

Honorable Jay C. Gandhi

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DONIKA SCHNELL, MICHAEL
KINNICK, SHARMILA SOLANKI,
BRYAN NANCE, and GREGORY
RATLIFF,

Action Filed: April 7, 2017
Trial Date: TBD

Defendants.
___________________________________

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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

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discovery and that the protection it affords from public disclosure and use extends

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only to the limited information or items that are entitled to confidential treatment

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under the applicable legal principles. The parties further acknowledge, as set forth

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in Section 12.3, below, that this Stipulated Protective Order does not entitle them to

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file confidential information under seal; Civil Local Rule 79-5 sets forth the

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procedures that must be followed and the standards that will be applied when a

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party seeks permission from the court to file material under seal.

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B.

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GOOD CAUSE STATEMENT

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This action is likely to involve trade secrets, customer and pricing lists and

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other valuable research, development, commercial, financial, technical and/or

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proprietary information for which special protection from public disclosure and

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from use for any purpose other than prosecution of this action is warranted. Such

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confidential and proprietary materials and information consist of, among other

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things, confidential business or financial information, information regarding

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confidential business practices, strategies, or other confidential research,

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development, or commercial information (including information implicating

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privacy rights of third parties), as well as information otherwise generally

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unavailable to the public, or which may be privileged or otherwise protected from

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disclosure under state or federal statutes, court rules, case decisions, or common

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law.

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Accordingly, to expedite the flow of information, to facilitate the prompt

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resolution of disputes over confidentiality of discovery materials, to adequately

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protect information the parties are entitled to keep confidential, to ensure that the

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parties are permitted reasonable necessary uses of such material in preparation for

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and in the conduct of trial, to address their handling at the end of the litigation, and

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serve the ends of justice, a protective order for such information is justified in this

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matter. It is the intent of the parties that information will not be designated as
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1

confidential for tactica reasons and that nothing be so design
al
nated without a good
d

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faith belief that it has been mai
s
intained in a confidential, non
n-public m
manner, and

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there is good cause wh it should not be pa of the public recor of this c
hy
d
art
rd
case.

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2.

DEFINITIONS
2.1

Action: This federa litigation, Opus Bank v. Don Schne Michael
T
al
nika
ell,

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Kinnick, Sharmial Solanki, Bry Nance and Gregory Ratliff Case No 8:17-cvK
yan
ff,
o.

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00
0633-CJC-JCG.

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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

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ho it is generated, stored or maintai ned) or tan
ow
g
r
ngible thin that q
ngs
qualify for

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pr
rotection under Fede Rule of Civil Procedure 26
eral
o
6(c), and a specifie above in
as
ed

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the Good Cause Statem
ment.

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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

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items that it produ
uces in disclosures or in responses to discovery as

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“CONFIDENTIAL.”

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2.6

re
overy Mat erial: all it
tems or inf
formation, regardless
,
Disclosur or Disco

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of the medium or man
f
nner in whi it is generated, st
ich
tored, or m
maintained (including
g,

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among other things, te
estimony, transcripts, and tangible thing that are produced
gs),
e

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or generated in disclos
r
sures or res
sponses to discovery in this ma
atter.

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2.7

Expert: a person with special
lized knowledge or e
experience in a matter

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pe
ertinent to the litigati who ha been reta
ion
as
ained by a Party or it counsel to serve as
ts

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an expert witness or as a consultant in this Action.
s

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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

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counsel.
2.9

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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.

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2.10 Outside Counsel of Record: attorneys who are not employees of a
C
f

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pa to this Action bu are retain to represent or advise a par to this A
arty
ut
ned
rty
Action and

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ha appeared in this Action on behalf of t
ave
A
that party or are affil
liated with a law firm
m

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which has appeared on behalf of that party, and includes support staff.
n
f

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2.11 Party: an party to this Action, including all of i officers directors
ny
o
its
s,
s,

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employees, consultant retained experts, a Outside Counsel of Record (and their
ts,
d
and
d

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support staffs).
2.12 Producing Party: a Party or Non-Part that pro
g
ty
oduces Dis
sclosure or

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Discovery Material in this Action
n.
2.13 Profession Vendo
nal
ors:

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persons or entities tha provide litigation
at
e

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support services (e.g., photocopying, videotaping, translating, preparing exhibits or

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de
emonstrations, and organizing, storing, or retrieving data in a form o medium)
any
or

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and their em
mployees an subcont
nd
tractors.

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2.14 Protected Material:
d
:

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de
esignated as “CONFI
IDENTIAL
L.”
2.15 Receiving Party:
g

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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.

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3.

PE
SCOP

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The protections conferred by this Stipulation and Or
s
rder cover not only
r

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as
but
Protected Material (a defined above), b also (1) any information copied or

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extracted from Protected Ma
aterial; (2) all copi
ies, excer
rpts, summ
maries, or

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5

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compilations of Prot
tected Ma
aterial; and (3) any testimony convers
y,
sations, or

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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

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trial judge. This Order does not govern the use of Pr
r
e
rotected Ma
aterial at tr
rial.

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4.

DURATION

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Even after fina disposition of this litigation, the confid
n
al
dentiality obligations

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der
emain in effect until a Desig
gnating Pa
arty agrees
imposed by this Ord shall re

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ot
therwise in writing or a court order otherwise directs. Final dispositio shall be
o
l
on

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de
eemed to be the late of (1) di
b
er
ismissal o f all claims and def
fenses in th Action
his
n,

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with or without prejud
dice; and (2) final judgment herein after the comp
r
pletion and
d

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exhaustion of all appeals, rehea
arings, re mands, trials, or rev
views of th Action
his
n,

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including the time limits for filin any mo tions or applications for extension of time
ng

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pu
ursuant to applicable law.
a

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5.

DESIGNATING PROTEC
G
CTED MA
ATERIAL
5.1

Exercise of Restrain and Care in Designating Ma
nt
aterial for Protection
n.

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arty
esignates information or items for protec
ction under
Each Party or Non-Pa that de

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this Order must take care to lim any such design
mit
nation to s
specific material that

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qu
ualifies under the app
propriate st
tandards. The Designating Par must de
rty
esignate for

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pr
rotection only those parts of material, documents, items, or oral or written
e
f
,

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communications that qualify so that other portions of the m
o
material, d
documents,

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items, or communications for which protection is not warr
ranted are not swept

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un
njustifiably within the ambit of this Order.
f

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Mass, indiscrim
minate, or ro
outinized designations are proh
hibited. De
esignations

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that are shown to be clearly un
njustified or that hav been m
ve
made for an improper
n

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pu
urpose (e.g., to unn
necessarily encumber the case develop
y
pment process or to

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impose unnecessary expenses and burdens on other partie may e
es)
expose the

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Designating Party to sanctions.

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If it comes to a Designatin Party’s attention that inform
ng
mation or it
tems that it

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esignated for protecti do not qualify for protection, that De
ion
esignating Party must
de

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pr
romptly notify all oth Parties that it is withdrawing the inapp
her
plicable de
esignation.

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5.2

Manner and Timing of Designations. Except as o
a
g
otherwise p
provided in
n

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this Order (see, e.g., second pa
aragraph of section 5.2(a) belo
ow), or as otherwise
s

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stipulated or ordered, Disclosure or Discovery Material that qu
e
ualifies for protection
r

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un
nder this Order must be clearly so designated before the ma
t
y
aterial is d
disclosed or

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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

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do
ocuments, but exclu
uding tran
nscripts of depositions or ot
ther pretri or trial
ial

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pr
roceedings), that th Produ
he
ucing Part affix at a min
ty
nimum, th legend
he

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“CONFIDENTIAL” (hereinafte “CONFI
(
er
IDENTIAL legend”), to each page that
h

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contains protected material. If only a portion or por
o
rtions of th material on a page
he
l

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qu
ualifies for protection the Prod
n,
ducing Part also must clearly i
ty
identify the protected

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po
ortion(s) (e.g., by ma
aking appro
opriate markings in the margins
s).

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A Par or Nonrty
-Party that makes original documents available for inspection
t
r
n

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ne not designate the for prot
eed
em
tection unt after the inspectin Party ha indicated
til
ng
as

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which documents it would like copied and produced. Durin the insp
w
ng
pection and

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be
efore the designation all of th materia made available for inspectio shall be
d
n,
he
al
on

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de
eemed “CONFIDEN
NTIAL.” After the inspecting Party has iden
ntified the

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do
ocuments it wants copied and produced, the Pro
c
d
oducing Party must determine

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which documents, or portions thereof, qualify for protectio under t
on
this Order.

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Then, before producin the specified documents, the Producing Party mu affix the
ng
g
ust

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“CONFIDENTIAL leg
gend” to ea page that contain Protecte Material If only a
ach
ns
ed
l.

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po
ortion or portions of the materi on a page qualifies for prote
ial
ection, the Producing
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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)

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for te
estimony given in d
g
depositions that the Designa
e
ating Party

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identify the Disclosure or Discov
e
very Material on the record, be
e
efore the c
close of the

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de
eposition all protected testimon
ny.
(c)

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for inf
formation produced in some form other th docum
p
han
mentary and
d

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for any other tangible items, tha the Prod ucing Party affix in a prominen place on
at
nt

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the exterior of the container or containers in which the infor
rmation is stored the

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legend “CONFIDENT
TIAL.” If only a portion or portions of the in
f
nformation

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warrants protection, th Producin Party, to the extent practicab shall i
he
ng
ble,
identify the

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pr
rotected portion(s).
5.3

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rected, an i
inadverten
nt
Inadvertent Failures to Designate. If timely corr

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failure to designate qu
ualified inf
formation or items d
does not, standing alone, waive

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the Designating Party right to secure protection under t
y’s
this Order for such
r

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material. Upon timely correctio of a des
m
y
on
signation, the Receiv
ving Party must make

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reasonable efforts to assure tha the material is treated in accordance with the
at

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pr
rovisions of this Orde
er.

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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.

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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

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the Designating Party Frivolo challenges, and those ma for an improper
y.
ous
ade
n

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pu
urpose (e.g., to hara or imp
ass
pose unnecessary ex
xpenses an burdens on other
nd

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pa
arties) may expose the Challen
t
nging Party to sanctions. Un
nless the D
Designating
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1

Party has waived or withdrawn the confidentiality designation, all pa
n
arties shall

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continue to afford the material in question the level of prote
e
ection to w
which it is

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entitled under the Pr
roducing Party’s de
P
esignation until the Court rul on the
les

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challenge.

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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

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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

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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

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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

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Protected Mater must be stored a maintained by a Receiving Party at a
rial
b
and
g

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ure
r
imited to t persons
the
location and in a secu manner that ensures that access is li

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authorized under this Order.
O

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7.2

Disclosur of “CO
re
ONFIDENT
TIAL” Information or Items
s.

Unless

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ot
therwise ordered by the court or permitted in writi by the Designatin Party, a
o
ing
ng

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Receiving

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“CONFIDENTIAL” only to:
o

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(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

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well as employees of said Outside Coun
f
nsel of Record to wh
hom it is reasonably

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ne
ecessary to disclose the informa
t
ation for this Action;
;

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(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

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di
isclosure is reasona
ably neces
ssary for this Action and who have signed the

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“Acknowledgment and Agreeme to Be B
d
ent
Bound” (Exhibit A);
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(d)

the court and its personnel;

2

(e)

court reporters and their staff;

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(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)

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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)

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during their depositions, witnesses, and attorneys for witnesses, in

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the Action to whom disclosure is reasonably necessary provided: (1) the deposing

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party requests that the witness sign the form attached as Exhibit 1 hereto; and

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(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

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except as permitted under this Stipulated Protective Order; and
(i)

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any mediator or settlement officer, and their supporting personnel,

mutually agreed upon by any of the parties engaged in settlement discussions.

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8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

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IN OTHER LITIGATION

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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

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“CONFIDENTIAL,” that Party must:

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(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)

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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.

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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;

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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.

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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.

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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

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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