SGII, Inc. v. Soda Chanda Suon

Filing 17

PROTECTIVE ORDER by Magistrate Judge John D. Early re Stipulation for Protective Order 16 . (see document for details) (hr)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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SOUTHERN DIVISION

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SGII, INC. d/b/a SENEGENCE
INTERNATIONAL, a Delaware
corporation,

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Plaintiff,

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v.

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SODA CHANDA SUON, an
individual,
Defendant.

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) Case No. 8:21-cv-01168-DOC (JDEx)
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) STIPULATED PROTECTIVE
) ORDER
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Based on the parties’ Stipulation (Dkt. 16), and finding good cause
shown, the Court finds and orders as follows.

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1.

PURPOSES AND LIMITATIONS

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Discovery in this action is likely to involve production of confidential,

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proprietary or private information for which special protection from public

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disclosure and from use for any purpose other than pursuing this litigation may

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be warranted. Accordingly, the parties hereby stipulate to and petition the

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Court to enter the following Stipulated Protective Order. The parties

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acknowledge that this Order does not confer blanket protections on all

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disclosures or responses to discovery and that the protection it affords from

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public disclosure and use extends only to the limited information or items that

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are entitled to confidential treatment under the applicable legal principles.

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2.

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

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GOOD CAUSE STATEMENT

and other valuable research, development, commercial, financial, technical
and/or proprietary information for which special protection from public
disclosure and from use for any purpose other than prosecution of this action is
warranted. Such confidential and proprietary materials and information
consist of, among other things, confidential business or financial information,
information regarding confidential business practices, or other confidential
research, development, or commercial information (including information
implicating privacy rights of third parties), information otherwise generally
unavailable to the public, or which may be privileged or otherwise protected
from disclosure under state or federal statutes, court rules, case decisions, or

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common law. Accordingly, to expedite the flow of information, to facilitate the

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prompt resolution of disputes over confidentiality of discovery materials, to

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adequately protect information the parties are entitled to keep confidential, to

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ensure that the parties are permitted reasonable necessary uses of such material

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in preparation for and in the conduct of trial, to address their handling at the

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end of the litigation, and serve the ends of justice, a protective order for such

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information is justified in this matter. It is the intent of the parties that

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information will not be designated as confidential for tactical reasons and that

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nothing be so designated without a good faith belief that it has been

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maintained in a confidential, non-public manner, and there is good cause why

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it should not be part of the public record of this case.
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3.

ACKNOWLEDGMENT OF UNDER SEAL FILING
PROCEDURE

The parties further acknowledge, as set forth in Section 14.3, below, that

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this Stipulated Protective Order does not entitle them to file confidential

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information under seal; Local Civil Rule 79-5 sets forth the procedures that

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must be followed and the standards that will be applied when a party seeks

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permission from the court to file material under seal. There is a strong

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presumption that the public has a right of access to judicial proceedings and
records in civil cases. In connection with non-dispositive motions, good cause
must be shown to support a filing under seal. See Kamakana v. City and
County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.
Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony
Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
protective orders require good cause showing), and a specific showing of good
cause or compelling reasons with proper evidentiary support and legal
justification, must be made with respect to Protected Material that a party

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seeks to file under seal. The parties’ mere designation of Disclosure or

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Discovery Material as CONFIDENTIAL or HIGHLY CONFIDENTIAL --

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ATTORNEYS’ EYES ONLY does not— without the submission of

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competent evidence by declaration, establishing that the material sought to be

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filed under seal qualifies as confidential, privileged, or otherwise protectable—

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constitute good cause.

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Further, if a party requests sealing related to a dispositive motion or trial,

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then compelling reasons, not only good cause, for the sealing must be shown,

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and the relief sought shall be narrowly tailored to serve the specific interest to

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be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th

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Cir. 2010). For each item or type of information, document, or thing sought to
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be filed or introduced under seal, the party seeking protection must articulate

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compelling reasons, supported by specific facts and legal justification, for the

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requested sealing order. Again, competent evidence supporting the application

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to file documents under seal must be provided by declaration.

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Any document that is not confidential, privileged, or otherwise

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protectable in its entirety will not be filed under seal if the confidential portions

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can be redacted. If documents can be redacted, then a redacted version for

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public viewing, omitting only the confidential, privileged, or otherwise
protectable portions of the document, shall be filed. Any application that seeks
to file documents under seal in their entirety should include an explanation of
why redaction is not feasible.
4.

DEFINITIONS

4.1

Action: this pending federal lawsuit, styled SGII, Inc. v. Soda

Chanda Suon, Case No. 8:21-cv-01168-DOC-JDE, which was filed with the
court on July 6, 2021.
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Challenging Party: a Party or Non-Party that challenges the

designation of information or items under this Order.
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“CONFIDENTIAL” Information or Items: information

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(regardless of how it is generated, stored or maintained) or tangible things that

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qualify for protection under Federal Rule of Civil Procedure 26(c), and as

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specified in the Good Cause Statement. Any Party or other person providing

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discovery in this action may designate documents as “CONFIDENTIAL”

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upon making a good faith determination that the documents contain

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information protected from disclosure by statute or that should be protected

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from disclosure as confidential business or personal information, medical or

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psychiatric information, trade secrets, personnel records, or such other

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sensitive commercial information that is not publicly available. 4.4 “HIGHLY
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CONFIDENTIAL -- ATTORNEYS’ EYES ONLY” Information or Items:

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information or tangible things that qualify for protection under Federal Rule of

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Civil Procedure 26(c), and as specified in the Good Cause Statement that are

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extremely sensitive, the disclosure of which to another Party or Non-Party

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would create a substantial risk of serious harm to an individual or to the

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business or competitive position of the Designating Party.

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4.5

Counsel: Outside Counsel of Record and House Counsel (as well

as their support staff).
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Designating Party: a Party or Non-Party that designates

information or items that it produces in disclosures or in responses to discovery
as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’
EYES ONLY.”
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Disclosure or Discovery Material: all items or information,

regardless of the medium or manner in which it is generated, stored, or
maintained (including, among other things, testimony, transcripts, and tangible
things), that are produced or generated in disclosures or responses to discovery.
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Expert: a person with specialized knowledge or experience in a

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matter pertinent to the litigation who has been retained by a Party or its

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counsel to serve as an expert witness or as a consultant in this Action.

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House Counsel: attorneys who are employees of a party to this

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Action. House Counsel does not include Outside Counsel of Record or any

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other outside counsel.

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4.10 Non-Party: any natural person, partnership, corporation,
association or other legal entity not named as a Party to this action.
4.11 Outside Counsel of Record: attorneys who are not employees of a

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party to this Action but are retained to represent a party to this Action and

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have appeared in this Action on behalf of that party or are affiliated with a law
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firm that has appeared on behalf of that party, and includes support staff.
4.12 Party: any party to this Action, including all of its officers,

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directors, employees, consultants, retained experts, and Outside Counsel of

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Record (and their support staffs).

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4.13 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
4.14 Professional Vendors: persons or entities that provide litigation
support services (e.g., photocopying, videotaping, translating, preparing
exhibits or demonstrations, and organizing, storing, or retrieving data in any
form or medium) and their employees and subcontractors.
4.15 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -ATTORNEYS’ EYES ONLY.”
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Receiving Party: a Party that receives Disclosure or Discovery

Material from a Producing Party.
5.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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

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extracted from Protected Material; (2) all copies, excerpts, summaries, or

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compilations of Protected Material; and (3) any testimony, conversations, or

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presentations by Parties or their Counsel that might reveal Protected Material.

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Any use of Protected Material at trial shall be governed by the orders of

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the trial judge and other applicable authorities. This Order does not govern the

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use of Protected Material at trial.

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Once a case proceeds to trial, information that was designated as

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DURATION

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’
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EYES ONLY” or was maintained pursuant to this protective order used or

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introduced as an exhibit at trial becomes public and will be presumptively

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available to all members of the public, including the press, unless compelling

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reasons supported by specific factual findings to proceed otherwise are made to

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the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81

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(distinguishing “good cause” showing for sealing documents produced in

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discovery from “compelling reasons” standard when merits-related documents

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are part of court record). Accordingly, the terms of this protective order do not
extend beyond the commencement of the trial.
7.

DESIGNATING PROTECTED MATERIAL

7.1

Exercise of Restraint and Care in Designating Material for
Protection. Each Party or Non-Party that designates information

or items for protection under this Order must take care to limit any such
designation to specific material that qualifies under the appropriate standards.
The Designating Party must designate for protection only those parts of
material, documents, items or oral or written communications that qualify so

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that other portions of the material, documents, items or communications for

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which protection is not warranted are not swept unjustifiably within the ambit

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of this Order.

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Mass, indiscriminate or routinized designations are prohibited.

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Designations that are shown to be clearly unjustified or that have been made

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for an improper purpose (e.g., to unnecessarily encumber the case development

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process or to impose unnecessary expenses and burdens on other parties) may

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expose the Designating Party to sanctions.

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If it comes to a Designating Party’s attention that information or items

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that it designated for protection do not qualify for protection, that Designating

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Party must promptly notify all other Parties that it is withdrawing the
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inapplicable designation.
7.2

Manner and Timing of Designations. Except as otherwise

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provided in this Order, or as otherwise stipulated or ordered, Disclosure of

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Discovery Material that qualifies for protection under this Order must be

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clearly so designated before the material is disclosed or produced.

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Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic
documents, but excluding transcripts of depositions or other pretrial or trial
proceedings), that the Producing Party affix at a minimum, the legend
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or “HIGHLY
CONFIDENTIAL -- ATTORNEYS’ EYES ONLY” (hereinafter “AEO
legend”), to each page that contains protected material. If only a portion of the
material on a page qualifies for protection, the Producing Party also must
clearly identify the protected portion(s) (e.g., by making appropriate markings
in the margins).
A Party or Non-Party that makes original documents available for

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inspection need not designate them for protection until after the inspecting

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Party has indicated which documents it would like copied and produced.

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During the inspection and before the designation, all of the material made

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available for inspection shall be deemed “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL -- ATTORNEYS’ EYES ONLY.” After the inspecting

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Party has identified the documents it wants copied and produced, the

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Producing Party must determine which documents, or portions thereof, qualify

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for protection under this Order. Then, before producing the specified

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documents, the Producing Party must affix the “CONFIDENTIAL legend” or

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“AEO legend” to each page that contains Protected Material. If only a portion

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of the material on a page qualifies for protection, the Producing Party also
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must clearly identify the protected portion(s) (e.g., by making appropriate

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markings in the margins).

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(b) for testimony given in depositions that the Designating Party

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identifies the Disclosure or Discovery Material on the record, before the close

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of the deposition all protected testimony.

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(c) for information produced in some form other than

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documentary and for any other tangible items, that the Producing Party affix

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in a prominent place on the exterior of the container or containers in which the
information is stored the legend “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL -- ATTORNEYS’ EYES ONLY.” If only a portion or
portions of the information warrants protection, the Producing Party, to the
extent practicable, shall identify the protected portion(s).
7.3

Inadvertent Failures to Designate. If timely corrected, an

inadvertent failure to designate qualified information or items does not,
standing alone, waive the Designating Party’s right to secure protection under
this Order for such material. Upon timely correction of a designation, the

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Receiving Party must make reasonable efforts to assure that the material is

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treated in accordance with the provisions of this Order.

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8.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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8.1. Timing of Challenges. Any Party or Non-Party may challenge a

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designation of confidentiality at any time that is consistent with the Court’s

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Scheduling Order.

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8.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37-1 et seq.
8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
joint stipulation pursuant to Local Rule 37-2.
8.4 The burden of persuasion in any such challenge proceeding shall be
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on the Designating Party. Frivolous challenges, and those made for an

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improper purpose (e.g., to harass or impose unnecessary expenses and burdens

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on other parties) may expose the Challenging Party to sanctions. Unless the

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Designating Party has waived or withdrawn the confidentiality designation, all

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parties shall continue to afford the material in question the level of protection

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to which it is entitled under the Producing Party’s designation until the Court

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rules on the challenge.

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9.

ACCESS TO AND USE OF PROTECTED MATERIAL

9.1 Basic Principles. A Receiving Party may use Protected Material that
is disclosed or produced by another Party or by a Non-Party in connection
with this Action only for prosecuting, defending or attempting to settle this
Action. Such Protected Material may be disclosed only to the categories of
persons and under the conditions described in this Order. When the Action has
been terminated, a Receiving Party must comply with the provisions of section
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Protected Material must be stored and maintained by a Receiving Party

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at a location and in a secure manner that ensures that access is limited to the

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persons authorized under this Order.

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9.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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otherwise ordered by the court or permitted in writing by the Designating

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Party, a Receiving Party may disclose any information or item designated

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“CONFIDENTIAL” only to:

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(a) the Receiving Party’s Outside Counsel of Record in this

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Action, as well as employees of said Outside Counsel of Record to whom it is

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reasonably necessary to disclose the information for this Action;

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(b) the officers, directors, and employees (including House
Counsel) of the Receiving Party to whom disclosure is reasonably necessary
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for this Action;
(c) Experts (as defined in this Order) of the Receiving Party to

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whom disclosure is reasonably necessary for this Action and who have signed

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the Acknowledgment and Agreement to Be Bound by this Order (Exhibit A);

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(d) the court and its personnel;

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(e) court reporters and their staff to whom disclosure is reasonably

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necessary for this Action and who have signed the Acknowledgment and
Agreement to Be Bound by this Order (Exhibit A);
(f) professional jury or trial consultants, mock jurors, and
Professional Vendors to whom disclosure is reasonably necessary for this
Action and who have signed an Acknowledgment and Agreement to Be
Bound by this Order (Exhibit A);
(g) the author or recipient of a document containing the
information or a custodian or other person who otherwise possessed or knew
the information;
(h) during their depositions, witnesses, and attorneys for witnesses,

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

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deposing party requests that the witness sign an Acknowledgment and

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Agreement to Be Bound by this Order (Exhibit A); and (2) they will not be

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permitted to keep any confidential information unless they sign an

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Acknowledgment and Agreement to Be Bound by this Order, unless otherwise

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agreed by the Designating Party or ordered by the court. Pages of transcribed

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deposition testimony or exhibits to depositions that reveal Protected Material

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may be separately bound by the court reporter and may not be disclosed to

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anyone except as permitted under this Stipulated Protective Order;

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(i) any mediators or settlement officers and their supporting
personnel, mutually agreed upon by any of the parties engaged in settlement
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discussions; and

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(j) any other person or entity that Designating Party agrees to in
writing.

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9.3. Disclosure of “HIGHLY CONFIDENTIAL -- ATTORNEYS’

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EYES ONLY” Information or Items. Unless otherwise ordered by the court or

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permitted in writing by the Designating Party, a Receiving Party may disclose

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any information or item designated “HIGHLY CONFIDENTIAL --

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ATTORNEYS’ EYES ONLY” only to:
(a) the Receiving Party’s Outside Counsel of Record in this
Action, as well as employees of said Outside Counsel of Record to whom it is
reasonably necessary to disclose the information for this Action;
(b) SeneGence’s House Counsel;
(c) where the Receiving Party is SGII, Inc. d/b/a SeneGence
International (“SeneGence”), any employees of SeneGence to whom
disclosure is reasonably necessary for SeneGence’s Outside Counsel and
House Counsel to understand the information contained in the Protected

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Material (including, for example, to assist counsel in understanding whether

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the Protected Material contains, incorporates, or is derived from trade secrets

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or confidential information of SeneGence);

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(d) Experts (as defined in this Order) of the Receiving Party to

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whom disclosure is reasonably necessary for prosecution or defense of this

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Action and who have signed an Acknowledgment and Agreement to Be

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Bound by this Order (Exhibit A);

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(e) the Court and its personnel;

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(f) private court reporters and their staff to whom disclosure is

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reasonably necessary for this Action and who have signed an

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Acknowledgment and Agreement to Be Bound by this Order; (Exhibit A)
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(g) professional jury or trial consultants, mock jurors, and

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Professional Vendors to whom disclosure is reasonably necessary for this

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Action and who have signed an Acknowledgment and Agreement to Be

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Bound by this Order (Exhibit A);

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(h) any mediator or settlement officer, and their supporting

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personnel, mutually agreed upon by any of the parties engaged in settlement

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discussions; and

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(i) any other person or entity that Designating Party agrees to in
writing.
10.

PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION

If a Party is served with a subpoena or a court order issued in other
litigation that compels disclosure of any information or items designated in this
Action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -ATTORNEYS’ EYES ONLY,” that Party must:
(a) promptly notify in writing the Designating Party. Such
notification shall include a copy of the subpoena or court order;

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(b) promptly notify in writing the party who caused the subpoena

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or order to issue in the other litigation that some or all of the material covered

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by the subpoena or order is subject to this Protective Order. Such notification

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shall include a copy of this Stipulated Protective Order; and

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(c) cooperate with respect to all reasonable procedures sought to be

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pursued by the Designating Party whose Protected Material may be affected. If

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the Designating Party timely seeks a protective order, the Party served with the

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subpoena or court order shall not produce any information designated in this

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action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL --

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ATTORNEYS’ EYES ONLY” before a determination by the court from
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which the subpoena or order issued, unless the Party has obtained the

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Designating Party’s permission. The Designating Party shall bear the burden

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and expense of seeking protection in that court of its confidential material and

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nothing in these provisions should be construed as authorizing or encouraging

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a Receiving Party in this Action to disobey a lawful directive from another

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court.

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11.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
BE PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced

by a Non-Party in this Action and designated as “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY.” Such
information produced by Non-Parties in connection with this litigation is
protected by the remedies and relief provided by this Order. Nothing in these
provisions should be construed as prohibiting a Non-Party from seeking
additional protections.
(b) In the event that a Party is required, by a valid discovery

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request, to produce a Non-Party’s confidential information in its possession,

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and the Party is subject to an agreement with the Non-Party not to produce the

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Non-Party’s confidential information, then the Party shall:

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(1) promptly notify in writing the Requesting Party and the Non-

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Party that some or all of the information requested is subject to a

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confidentiality agreement with a Non-Party;

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(2) promptly provide the Non-Party with a copy of the Stipulated

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Protective Order in this Action, the relevant discovery request(s), and a

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reasonably specific description of the information requested; and

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(3) make the information requested available for inspection by the
Non-Party, if requested.
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(c) If the Non-Party fails to seek a protective order from this court

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within 14 days of receiving the notice and accompanying information, the

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Receiving Party may produce the Non-Party’s confidential information

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responsive to the discovery request. If the Non-Party timely seeks a protective

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order, the Receiving Party shall not produce any information in its possession

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or control that is subject to the confidentiality agreement with the Non-Party

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before a determination by the court. Absent a court order to the contrary, the

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Non-Party shall bear the burden and expense of seeking protection in this court
of its Protected Material.
12.

UNAUTHORIZED DISCLOSURE OF PROTECTED
MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it has
disclosed Protected Material to any person or in any circumstance not
authorized under this Stipulated Protective Order, the Receiving Party must
immediately (a) notify in writing the Designating Party of the unauthorized
disclosures, (b) use its best efforts to retrieve all unauthorized copies of the

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Protected Material, (c) inform the person or persons to whom unauthorized

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disclosures were made of all the terms of this Order, and (d) request such

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person or persons to execute an Acknowledgment and Agreement to Be Bound

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by this Order (Exhibit A).

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13.

INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

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inadvertently produced material is subject to a claim of privilege or other

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protection, the obligations of the Receiving Parties are those set forth in

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Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to

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modify whatever procedure may be established in an e-discovery order that
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provides for production without prior privilege review. Pursuant to Federal

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Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on

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the effect of disclosure of a communication or information covered by the

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attorney-client privilege or work product protection, the parties may

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incorporate their agreement in the stipulated protective order submitted to the

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court.

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14.

MISCELLANEOUS

14.1 Right to Further Relief. Nothing in this Order abridges the right of
any person to seek its modification by the Court in the future.
14.2 Right to Assert Other Objections. By stipulating to the entry of this
Protective Order, no Party waives any right it otherwise would have to object
to disclosing or producing any information or item on any ground not
addressed in this Stipulated Protective Order. Similarly, no Party waives any
right to object on any ground to use in evidence of any of the material covered
by this Protective Order.
14.3 Filing Protected Material. A Party that seeks to file under seal any

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Protected Material must comply with Local Civil Rule 79-5. Protected

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Material may only be filed under seal pursuant to a court order authorizing the

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sealing of the specific Protected Material. If a Party’s request to file Protected

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Material under seal is denied by the court, then the Receiving Party may file

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the information in the public record unless otherwise instructed by the court.

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15.

FINAL DISPOSITION

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After the final disposition of this Action, as defined in paragraph 6,

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within 60 days of a written request by the Designating Party, each Receiving

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Party must return all Protected Material to the Producing Party or destroy such

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material. As used in this subdivision, “all Protected Material” includes all

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copies, abstracts, compilations, summaries, and any other format reproducing
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or capturing any of the Protected Material. Whether the Protected Material is

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returned or destroyed, the Receiving Party must submit a written certification

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to the Producing Party (and, if not the same person or entity, to the

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Designating Party) by the 60-day deadline that (1) identifies (by category,

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where appropriate) all the Protected Material that was returned or destroyed

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and (2) affirms that the Receiving Party has not retained any copies, abstracts,

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compilations, summaries or any other format reproducing or capturing any of

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the Protected Material. Notwithstanding this provision, Counsel are entitled to
retain an archival copy of all pleadings, motion papers, trial, deposition, and
hearing transcripts, legal memoranda, correspondence, deposition and trial
exhibits, expert reports, attorney work product, and consultant and expert
work product, even if such materials contain Protected Material. Any such
archival copies that contain or constitute Protected Material remain subject to
this Protective Order as set forth in Section 6 (DURATION).
16.

VIOLATION

Any violation of this Order may be punished by appropriate measures

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including, without limitation, contempt proceedings and/or monetary

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sanctions.

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: July 16, 2021

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_________________________________
JOHN D. EARLY
United States Magistrate Judge

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1

EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, _________________________________ [print or type full name], of

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_________________ [print or type full address], declare under penalty of

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perjury that I have read in its entirety and understand the Stipulated Protective

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Order that was issued by the United States District Court for the Central

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District of California on _________[date] in the case of SGII, Inc. v. Soda

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Chanda Suon, C.D. Cal. Case No. 8:21-cv-01168-DOC-JDE. I agree to comply

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with and to be bound by all the terms of this Stipulated Protective Order and I

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understand and acknowledge that failure to so comply could expose me to

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sanctions and punishment in the nature of contempt. I solemnly promise that I

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will not disclose in any manner any information or item that is subject to this
Stipulated Protective Order to any person or entity except in strict compliance
with the provisions of this Order. I further agree to submit to the jurisdiction of
the United States District Court for the Central District of California for the
purpose of enforcing the terms of this Stipulated Protective Order, even if such
enforcement proceedings occur after termination of this action. I hereby
appoint _______________________________ [print or type full name] of
______________________________________________________ [print or type
full address and telephone number] as my California agent for service of
process in connection with this Action or any proceedings related to
enforcement of this Stipulated Protective Order.

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Date: __________

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City and State where sworn and signed:_________________________________

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Printed name: __________________ Signature: __________________________
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