Martinez v. County of Tulare et al

Filing 49

ORDER on AMENDED STIPULATED PROTECTIVE ORDER. Order signed by Magistrate Judge Sheila K. Oberto on 4/5/2017. (Timken, A)

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1 2 3 4 5 ARTURO J. GONZÁLEZ (CA SBN 121490) CAITLIN SINCLAIRE BLYTHE (CA SBN 265024) ALEXANDRA E. LAKS (CA SBN 291861) MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: 415.268.7000 6 7 Attorneys for Plaintiff MARIA EVA MARTINEZ UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 8 9 10 MARIA EVA MARTINEZ, Plaintiff, v. 11 12 TULARE COUNTY, SAN DIEGO COUNTY, and DOES 1-100, Defendants. Case No. 16-cv-01140-DAD-SKO AMENDED STIPULATED PROTECTIVE ORDER AND ORDER 13 14 15 1. INTRODUCTION 16 1.1 Purposes and Limitations 17 Disclosure and discovery activity in this action are likely to involve production of 18 confidential, proprietary, or private information for which special protection from public disclosure 19 and from use for any purpose other than prosecuting this litigation may be warranted. The 20 documents that warrant protection that have been identified to date include documents of 21 identification (such as passports and driver licenses) and California Law Enforcement 22 Telecommunications System (CLETS) information and records. Accordingly, the parties hereby 23 stipulate to and petition the Court to enter the following Stipulated Protective Order, which the 24 parties agree is necessary to ensure protection of protected materials. The parties acknowledge that 25 this Order does not confer blanket protections on all disclosures or responses to discovery and that 26 the protection it affords from public disclosure and use extends only to the limited information or 27 items that are entitled to confidential treatment under the applicable legal principles. 28 /// AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 1 1.2 2 As set forth above, Defendant County of San Diego will be producing CLETS information Good Cause Statement 3 and records, which are unavailable to the general public. Access to CLETS information and records 4 is strictly prohibited unless authorized by law. San Diego County contends restrictions on access to 5 such information are necessary because disclosure may jeopardize the security of CLETS, the 6 effectiveness of law enforcement efforts that rely on CLETS, and disclosure in this action may 7 invoke individual privacy rights. San Diego County accordingly believes that it cannot provide 8 CLETS information and records pertaining to Plaintiff Maria Eva Martinez absent a court order. 9 Mrs. Martinez will be producing documents, including her passport and driver license, which 10 contain personal and confidential information that is unavailable to the general public. The 11 disclosure of this information to the public may violate Mrs. Martinez’s privacy rights. Given the 12 sensitive nature of these documents and the potential harm Mrs. Martinez would face if the 13 documents were disseminated publicly (including identity theft), Mrs. Martinez believes it is 14 prudent to ensure that a protective order is in place before she produces copies of her passport and 15 driver license. 16 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 17 disputes over confidentiality, to adequately protect information the parties are entitled or required to 18 keep confidential, to ensure that the parties are permitted reasonable and necessary uses of such 19 materials in preparation for and in the conduct of the litigation, to address their handling at the end 20 of the litigation and to serve the ends of justice, a protective order for such information is justified 21 in this matter. 22 2. 23 24 25 DEFINITIONS 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is 26 generated, stored or maintained) or tangible things that contain confidential or sensitive personal 27 information or that qualify for protection under Federal Rule of Civil Procedure 26(c), and as 28 specified above in the Good Cause Statement. AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 2 1 2 3 4 5 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their support staff). 2.4 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 2.5 Disclosure or Discovery Material: all items or information, regardless of the 6 medium or manner in which it is generated, stored, or maintained (including, among other things, 7 testimony, transcripts, and tangible things), that are produced or generated in disclosures or 8 responses to discovery in this matter. 9 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to 10 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 11 consultant in this action. 12 13 14 2.7 House Counsel: attorneys who are employees of a party to this action. House Counsel does not include Outside Counsel of Record or any other outside counsel. 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal 15 entity not named as a Party to this action, including Tulare County, against whom judgment has 16 already been entered in this matter. 17 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this 18 action but are retained to represent or advise a party to this action and have appeared in this action 19 on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party. 20 2.10 Party: any party to this action, including all of its officers, directors, employees, 21 consultants, retained experts, and Outside Counsel of Record (and their support staffs), but 22 excluding Tulare County, against whom judgment has already been entered in this matter. 23 24 25 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 2.12 Professional Vendors: persons or entities that provide litigation support services 26 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 27 storing, or retrieving data in any form or medium) and their employees and subcontractors. 28 2.13 Protected Material: any Disclosure or Discovery Material that is designated as AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 3 1 “CONFIDENTIAL.” 2.14 2 Receiving Party: a Party that receives Disclosure or Discovery Material from a 3 Producing Party. 4 3. SCOPE The protections conferred by this Stipulation and Order cover not only Protected Material 5 6 (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all 7 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 8 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 9 However, the protections conferred by this Stipulation and Order do not cover the following 10 information: (a) any information that is in the public domain at the time of disclosure to a Receiving 11 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 12 publication not involving a violation of this Order, including becoming part of the public record 13 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 14 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 15 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 16 Protected Material at trial shall be governed by a separate agreement or order. 17 4. DURATION Even after final disposition of this litigation, the confidentiality obligations imposed by this 18 19 Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 20 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and 21 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion 22 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the 23 time limits for filing any motions or applications for extension of time pursuant to applicable law. 24 5. 25 DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or 26 Non-Party that designates information or items for protection under this Order must take care to 27 limit any such designation to specific material that qualifies under the appropriate standards. The 28 Designating Party must designate for protection only those parts of material, documents, items, or AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 4 1 oral or written communications that qualify – so that other portions of the material, documents, 2 items, or communications for which protection is not warranted are not swept unjustifiably within 3 the ambit of this Order. 4 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown 5 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 6 encumber or retard the case development process or to impose unnecessary expenses and burdens 7 on other parties) expose the Designating Party to sanctions. 8 9 10 11 If it comes to a Designating Party’s attention that information or items that it designated for protection do not qualify for protection, that Designating Party must promptly notify all other Parties that it is withdrawing the mistaken designation. 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 12 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 13 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 14 designated before the material is disclosed or produced. 15 16 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic documents, but 17 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 18 affix the legend “CONFIDENTIAL – Subject to Protective Order in Martinez v. Tulare County, et 19 al., United States District Court, Eastern District of California, Case No.: 16-cv-01140-DAD-SKO” 20 to each page that contains protected material. A Party or Non-Party that makes original documents 21 or materials available for inspection need not designate them for protection until after the inspecting 22 Party has indicated which material it would like copied and produced. During the inspection and 23 before the designation, all of the material made available for inspection shall be deemed 24 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied and 25 produced, the Producing Party must determine which documents, or portions thereof, qualify for 26 protection under this Order. Then, before producing the specified documents, the Producing Party 27 must affix the “CONFIDENTIAL – Subject to Protective Order in Martinez v. Tulare County, et al., 28 United States District Court, Eastern District of California, Case No.: 16-cv-01140-DAD-SKO” AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 5 1 legend to each page that contains Protected Material. If only a portion or portions of the material on 2 a page qualifies for protection, the Producing Party also must clearly identify the protected 3 portion(s) (e.g., by making appropriate markings in the margins). (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 4 5 Designating Party identify on the record, before the close of the deposition, hearing, or other 6 proceeding, all protected testimony, or alternatively, that the Designating Party identify protected 7 testimony by notifying all Parties, in writing, of the specific pages and lines of the transcript or 8 recording that should be protected, within 14 days of receipt of a transcript or recording of a 9 deposition. All transcripts or recordings of depositions shall be treated as protected for 14 days after 10 receipt of the transcript or recording, or until either written notice of confidentiality designations by 11 any Party or written notice that no such designations will be made is received from such Parties, 12 whichever occurs first. (c) for information produced in some form other than documentary and for any other 13 14 tangible items, that the Producing Party affix in a prominent place on the exterior of the container or 15 containers in which the information or item is stored the legend “CONFIDENTIAL – Subject to 16 Protective Order in Martinez v. Tulare County, et al., United States District Court, Eastern District 17 of California, Case No.: 16-cv-01140-DAD-SKO.” If only a portion or portions of the information 18 or item warrant protection, the Producing Party, to the extent practicable, shall identify the protected 19 portion(s). 20 5.3 Inadvertent Failures to Designate. An inadvertent failure to designate qualified 21 information or items does not waive the Designating Party’s right to secure protection under this 22 Order for such material. Upon correction of a designation, the Receiving Party must make 23 reasonable efforts to assure that the material is treated in accordance with the provisions of this 24 Order. 25 6. 26 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 27 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 28 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 6 1 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to 2 challenge a confidentiality designation by electing not to mount a challenge promptly after the 3 original designation is disclosed. 4 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 5 by providing written notice of each designation it is challenging and describing the basis for each 6 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 7 recite that the challenge to confidentiality is being made in accordance with this specific paragraph 8 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must 9 begin the process by conferring directly via telephone within three days of the date of receipt of 10 notice. In conferring, the Challenging Party must explain the basis for its belief that the 11 confidentiality designation was not proper and must give the Designating Party an opportunity to 12 review the designated material, to reconsider the circumstances, and, if no change in designation is 13 offered, to explain the basis for the chosen designation. A Challenging Party may proceed to the 14 next stage of the challenge process only if it has engaged in this meet and confer process first or 15 establishes that the Designating Party is unwilling to participate in the meet and confer process in a 16 timely manner. 17 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 18 intervention, the Challenging Party may file a motion challenging a confidentiality designation 19 within fourteen days of the initial notice of challenge or within seven days of the parties agreeing 20 that the meet and confer process will not resolve their dispute (or, if one party refuses entirely to 21 participate, within seven days of reaching an impasse after making reasonable efforts to obtain the 22 other party’s participation), whichever is later, if there is good cause for the challenge. Any motion 23 brought pursuant to this provision must be accompanied by a competent declaration affirming that 24 the movant has complied with the meet and confer requirements imposed by the preceding 25 paragraph. 26 The burden of persuasion in any such challenge proceeding shall be on the Designating 27 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 28 unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions. AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 7 1 All parties shall continue to afford the material in question the level of protection to which it is 2 entitled under the Producing Party’s designation until the court rules on the challenge. 3 7. 4 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 5 produced by another Party or by a Non-Party in connection with this case only for prosecuting, 6 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to 7 the categories of persons and under the conditions described in this Order. When the litigation has 8 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 9 DISPOSITION). 10 11 12 Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Order. 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered 13 by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any 14 information or item designated “CONFIDENTIAL” only to: 15 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees 16 of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information 17 for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is 18 attached hereto as Exhibit A; 19 (b) the officers, directors, and employees (including House Counsel) of the Receiving 20 Party to whom disclosure is reasonably necessary for this litigation and who have signed the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 23 reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement 24 to Be Bound” (Exhibit A); 25 (d) the court and its personnel; 26 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, and 27 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have 28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 8 1 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 2 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 3 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed 4 deposition testimony or exhibits to depositions that reveal Protected Material must be separately 5 bound by the court reporter and may not be disclosed to anyone except as permitted under this 6 Stipulated Protective Order. (g) the author or recipient of a document containing the information or a custodian or 7 8 other person who otherwise possessed or knew the information. 9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 10 LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation that compels 12 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party 13 must: (a) promptly notify in writing the Designating Party. Such notification shall include a 14 15 copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to issue in the 16 17 other litigation that some or all of the material covered by the subpoena or order is subject to this 18 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued by the 19 20 Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the subpoena 21 22 or court order shall not produce any information designated in this action as “CONFIDENTIAL” 23 before a determination by the court from which the subpoena or order issued, unless the Party has 24 obtained the Designating Party’s permission. The Designating Party shall bear the burden and 25 expense of seeking protection in that court of its confidential material – and nothing in these 26 provisions should be construed as authorizing or encouraging a Receiving Party in this action to 27 disobey a lawful directive from another court. 28 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 9 1 LITIGATION 2 (a) The terms of this Order are applicable to information produced by a Non-Party in 3 this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 4 connection with this litigation is protected by the remedies and relief provided by this Order. 5 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional 6 protections. 7 (b) In the event that a Party is required, by a valid discovery request, to produce a Non- 8 Party’s confidential information in its possession, and the Party is subject to an agreement with the 9 Non-Party not to produce the Non-Party’s confidential information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non-Party that some or 10 11 all of the information requested is subject to a confidentiality agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 12 13 in this litigation, the relevant discovery request(s), and a reasonably specific description of the 14 information requested; and 15 (3) make the information requested available for inspection by the Non-Party. 16 (c) If the Non-Party fails to object or seek a protective order from this court within 14 17 days of receiving the notice and accompanying information, the Receiving Party may produce the 18 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely 19 seeks a protective order, the Receiving Party shall not produce any information in its possession or 20 control that is subject to the confidentiality agreement with the Non-Party before a determination by 21 the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of 22 seeking protection in this court of its Protected Material. 23 10. 24 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 25 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 26 the Receiving Party must immediately (a) notify in writing the Designating Party of the 27 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected 28 Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 10 1 terms of this Order, and (d) request such person or persons to execute the “Acknowledgment and 2 Agreement to Be Bound” that is attached hereto as Exhibit A. 3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 4 MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain inadvertently 6 produced material is subject to a claim of privilege or other protection, the obligations of the 7 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 8 12. 12.1 9 10 MISCELLANEOUS Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the court in the future. 12.2 11 Right to Assert Other Objections. By stipulating to the entry of this Protective Order 12 no Party waives any right it otherwise would have to object to disclosing or producing any 13 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 14 Party waives any right to object on any ground to use in evidence of any of the material covered by 15 this Protective Order. 12.3 16 Filing Protected Material. Without written permission from the Designating Party or 17 a court order secured after appropriate notice to all interested persons, a Party may not file in the 18 public record in this action any Protected Material. A Party that seeks to file under seal any 19 Protected Material must comply with Civil Local Rule 141. Protected Material may only be filed 20 under seal pursuant to a court order authorizing the sealing of the specific Protected Material at 21 issue. If a Receiving Party's request to file Protected Material under seal pursuant to Civil Local 22 Rule 141 is denied by the court, then the Receiving Party may file the information in the public 23 record pursuant to Civil Local Rule 141 unless otherwise instructed by the court. 24 13. 25 FINAL DISPOSITION Within 60 days after the final disposition of this action, as defined in paragraph 4, each 26 Receiving Party must return all Protected Material to the Producing Party or destroy such material. 27 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 28 summaries, and any other format reproducing or capturing any of the Protected Material. Whether AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 11 1 the Protected Material is returned or destroyed, the Receiving Party must submit a written 2 certification to the Producing Party (and, if not the same person or entity, to the Designating Party) 3 by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material 4 that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, 5 abstracts, compilations, summaries or any other format reproducing or capturing any of the 6 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy 7 of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 8 correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant 9 and expert work product, even if such materials contain Protected Material. Any such archival 10 copies that contain or constitute Protected Material remain subject to this Protective Order as set 11 forth in Section 4 (DURATION). 12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 14 DATED: April 4, 2017 /s/Caitlin Sinclaire Blythe CAITLIN SINCLAIRE BLYTHE Attorneys for Plaintiff DATED: April 4, 2017 /s/Robert A. Ortiz (as authorized 04/04/2017) ROBERT A. ORTIZ Attorneys for Defendant 15 16 17 18 19 20 21 ORDER IT IS SO ORDERED. 22 23 Dated: April 5, 2017 /s/ Sheila K. Oberto UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28 AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 12 . 1 2 EXHIBIT A 3 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4 I, _____________________________ [print or type full name], of _________________ [print or 5 type full address], declare under penalty of perjury that I have read in its entirety and understand 6 the Stipulated Protective Order that was issued by the United States District Court for the Eastern 7 District of California on [date] in the case of Maria Eva Martinez v. Tulare County, San Diego 8 County, and DOES 1-100, No. 16-cv-01140-DAD-SKO. I agree to comply with and to be bound 9 by all the terms of this Stipulated Protective Order and I understand and acknowledge that failure 10 to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly 11 promise that I will not disclose in any manner any information or item that is subject to this 12 Stipulated Protective Order to any person or entity except in strict compliance with the 13 provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the Eastern 15 District of California for the purpose of enforcing the terms of this Stipulated Protective Order, 16 even if such enforcement proceedings occur after termination of this action. 17 I hereby appoint __________________________ [print or type full name] of 18 ____________________________________ [print or type full address and telephone number] as 19 my California agent for service of process in connection with this action or any proceedings 20 related to enforcement of this Stipulated Protective Order. 21 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28 AMENDED STIPULATED PROTECTIVE ORDER CASE NO. 16-CV-01140-DAD-SKO 13

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