Adams et al v. City and County of San Francisco et al

Filing 63

STIPULATED PROTECTIVE ORDER re 61 STIPULATION WITH PROPOSED ORDER for Protective Order filed by Granville McCollough, Patrick Tuohy, Lisette Adams, City and County of San Francisco. Signed by Judge Yvonne Gonzalez Rogers on 8/21/14. (fs, COURT STAFF) (Filed on 8/21/2014)

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1 2 3 4 5 6 DENNIS J. HERRERA, State Bar #139669 City Attorney ELIZABETH SALVESON, State Bar #83788 Chief Labor Attorney JONATHAN C. ROLNICK, State Bar #151814 Deputy City Attorneys Fox Plaza 1390 Market Street, Fifth Floor San Francisco, California 94102-5408 Telephone: (415) 554-3815 Facsimile: (415) 554-4248 E-Mail: 7 8 9 Attorneys for Defendant CITY AND COUNTY OF SAN FRANCISCO 10 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 14 LISETTE ADAMS, GRANVILLE MCCOLLOUGH and PATRICK TUOHY, 15 Plaintiff(s), 16 vs. 17 18 19 20 Case No. CV-13-4689 YGR STIPULATED PROTECTIVE ORDER THE CITY AND COUNTY OF SAN FRANCISCO and THE CITY AND COUNTY OF SAN FRANCISCO SHERIFF’S DEPARTMENT, Defendant(s). 21 22 IT IS HEREBY STIPULATED by and between plaintiffs LISETTE ADAMS, GRANVILLE 23 MCCOLLOUGH and PATRICK TUOHY and defendant CITY AND COUNTY OF SAN 24 FRANCISCO, through their respective counsel. 25 26 27 28 STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 1 1 1. 2 Disclosure and discovery activity in this action are likely to involve production of PURPOSES AND LIMITATIONS 3 confidential, proprietary, or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation would be warranted. Accordingly, 5 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective 6 Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures 7 or responses to discovery and that the protection it affords extends only to the limited information or 8 items that are entitled under the applicable legal principles to treatment as confidential. The parties 9 further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order creates 10 no entitlement to file confidential information under seal; Civil Local Rule 79-5 sets forth the 11 procedures that must be followed and reflects the standards that will be applied when a party seeks 12 permission from the court to file material under seal. 13 2. DEFINITIONS 14 2.1 Challenging Party: a Party or Non-Party that challenges the designation of 15 16 information or items under this Order. 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is 17 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 18 Civil Procedure 26(c). 19 20 21 22 23 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 medium 24 or manner in which it is generated, stored, or maintained (including, among other things, testimony, 25 transcripts, and tangible things), that are produced or generated in disclosures or responses to 26 discovery in this matter. 27 28 STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 2 1 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the 2 litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 3 consultant in this action. 4 5 6 7 8 9 10 11 12 13 14 15 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 entity not named as a Party to this action. 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action but are retained to represent or advise a party to this action and have appeared in this action on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party. 2.10 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs). 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 (e.g., 16 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, 17 or retrieving data in any form or medium) and their employees and subcontractors. 18 19 20 2.13 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 21 Producing Party. 22 3. 23 The protections conferred by this Stipulation and Order cover not only Protected Material (as SCOPE 24 defined above), but also (1) any information copied or extracted from Protected Material; (2) all 25 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 26 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 27 However, the protections conferred by this Stipulation and Order do not cover the following 28 information: (a) any information that is in the public domain at the time of disclosure to a Receiving STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 3 1 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 2 publication not involving a violation of this Order, including becoming part of the public record 3 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 4 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 5 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 6 Protected Material at trial shall be governed by a separate agreement or order. 7 4. 8 Even after final disposition of this litigation, the confidentiality obligations imposed by this 9 DURATION Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 10 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and 11 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion 12 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the time 13 limits for filing any motions or applications for extension of time pursuant to applicable law. 14 15 5. DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 16 Party or Non-Party that designates information or items for protection under this Order must take care 17 to limit any such designation to specific material that qualifies under the appropriate standards. The 18 Designating Party must take care to designate for protection only those parts of material, documents, 19 items, or oral or written communications that qualify – so that other portions of the material, 20 documents, items, or communications for which protection is not warranted are not swept 21 unjustifiably within the ambit of this Order. 22 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown 23 to be clearly unjustified, or that have been made for an improper purpose (e.g., to unnecessarily 24 encumber or retard the case development process, or to impose unnecessary expenses and burdens on 25 other parties), expose the Designating Party to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it designated for 27 protection do not qualify for protection, that Designating Party must promptly notify all other parties 28 that it is withdrawing the mistaken designation. STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 4 1 5.2 Manner and Timing of Designations. Except as otherwise provided in this 2 Order (see, e.g., second paragraph of section 5.2(a), below), or as otherwise stipulated or ordered, 3 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 4 designated before the material is disclosed or produced. 5 6 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic documents, but 7 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 8 affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion 9 or portions of the material on a page qualifies for protection, the Producing Party also must clearly 10 11 identify the protected portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-Party that makes original documents or materials available for inspection need 12 not designate them for protection until after the inspecting Party has indicated which material it 13 would like copied and produced. During the inspection and before the designation, all of the material 14 made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 15 identified the documents it wants copied and produced, the Producing Party must determine which 16 documents, or portions thereof, qualify for protection under this Order. Then, before producing the 17 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page that 18 contains Protected Material. If only a portion or portions of the material on a page qualifies for 19 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making 20 appropriate markings in the margins). 21 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 22 Designating Party identify on the record, before the close of the deposition, hearing, or other 23 proceeding, all protected testimony. 24 (c) for information produced in some form other than documentary and for any other 25 tangible items, that the Producing Party affix in a prominent place on the exterior of the container or 26 containers in which the information or item is stored the legend “CONFIDENTIAL.” If only portions 27 of the information or item warrant protection, the Producing Party, to the extent practicable, shall 28 identify the protected portions. STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 5 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 2 designate qualified information or items does not, standing alone, waive the Designating Party’s right 3 to secure protection under this Order for such material. Upon timely correction of a designation, the 4 Receiving Party must make reasonable efforts to assure that the material is treated in accordance with 5 the provisions of this Order. 6 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 8 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 9 designation is necessary to avoid foreseeable substantial unfairness, unnecessary economic burdens, 10 or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a 11 confidentiality designation by electing not to mount a challenge promptly after the original 12 designation is disclosed. 13 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 14 process by providing written notice of each designation it is challenging and describing the basis for 15 each challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 16 recite that the challenge to confidentiality is being made in accordance with this specific paragraph of 17 the Protective Order. The parties shall attempt to resolve each challenge in good faith and must begin 18 the process by conferring directly (in person; other forms of communication are not sufficient) within 19 14 days of the date of service of notice. In conferring, the Challenging Party must explain the basis 20 for its belief that the confidentiality designation was not proper and must give the Designating Party 21 an opportunity to review the designated material, to reconsider the circumstances, and, if no change in 22 designation is offered, to explain the basis for the chosen designation. A Challenging Party may 23 proceed to the next stage of the challenge process only if it has engaged in this meet and confer 24 process first or establishes that the Designating Party is unwilling to participate in the meet and 25 confer process in a timely manner. 26 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 27 intervention, the parties shall follow paragraph 8 of Judge Gonzalez Rogers’ Standing Order in Civil 28 Cases regarding Discovery and Discovery Motions. The Parties may file a joint letter brief regarding STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 6 1 the confidentiality designation within 21 days of the initial notice of challenge or within 14 days of 2 the parties agreeing that the meet and confer process will not resolve their dispute, whichever is 3 earlier. Failure by a Designating Party to file such a discovery dispute letter within the applicable 21 4 or 14 day period (set forth above) with the Court shall automatically waive the confidentiality 5 designation for each challenged designation. If, after submitting a joint letter brief, the Court allows 6 that a motion may be filed, any such motion must be accompanied by a competent declaration 7 affirming that the movant has complied with the meet and confer requirements imposed in the 8 preceding paragraph. The Court, in its discretion, may elect to transfer the discovery matter to a 9 Magistrate Judge. 10 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. 11 Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary 12 expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the 13 Designating Party has waived the confidentiality designation by failing to file a letter brief to retain 14 confidentiality as described above, all parties shall continue to afford the material in question the 15 level of protection to which it is entitled under the Producing Party’s designation until the Court rules 16 on the challenge. 17 7. 18 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 19 disclosed or produced by another Party or by a Non-Party in connection with this case only for 20 prosecuting, defending, or attempting to settle this litigation. Such Protected Material may be 21 disclosed only to the categories of persons and under the conditions described in this Order. When 22 the litigation has been terminated, a Receiving Party must comply with the provisions of section 13, 23 below (FINAL DISPOSITION). 24 25 26 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 27 ordered by the court or permitted in writing by the Designating Party, a Receiving Party may disclose 28 any information or item designated “CONFIDENTIAL” only to: STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 7 1 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 2 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the 3 information for this litigation and who have signed the “Acknowledgement and Agreement to Be 4 Bound” that is attached hereto as Exhibit A; 5 (b) the officers, directors, and employees (including House Counsel) of the 6 Receiving Party to whom disclosure is reasonably necessary for this litigation and who have signed 7 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 9 10 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (d) the Court and its personnel; 12 (e) court reporters, their staffs, and professional jury or trial consultants, mock 13 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation and 14 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (f) during their depositions, witnesses in the action to whom disclosure is 16 reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound” 17 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of 18 transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be 19 separately bound by the court reporter and may not be disclosed to anyone except as permitted under 20 this Stipulated Protective Order. 21 22 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information. 23 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 25 If a Party is served with a subpoena or an order issued in other litigation that compels 26 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party 27 must: 28 STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 8 1 2 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order to issue in the 4 other litigation that some or all of the material covered by the subpoena or order is subject to this 5 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 6 7 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 8 If the Designating Party timely seeks a protective order, the Party served with the subpoena or 9 court order shall not produce any information designated in this action as “CONFIDENTIAL” before 10 a determination by the court from which the subpoena or order issued, unless the Party has obtained 11 the Designating Party’s permission. The Designating Party shall bear the burden and expense of 12 seeking protection in that court of its confidential material – and nothing in these provisions should 13 be construed as authorizing or encouraging a Receiving Party in this action to disobey a lawful 14 directive from another court. 15 16 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 17 (a) The terms of this Order are applicable to information produced by a Non-Party in 18 this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 19 connection with this litigation is protected by the remedies and relief provided by this Order. Nothing 20 in these provisions should be construed as prohibiting a Non-Party from seeking additional 21 protections. 22 (b) In the event that a Party is required, by a valid discovery request, to produce a 23 Non-Party’s confidential information in its possession, and the Party is subject to an agreement with 24 the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 25 26 (1) promptly notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; 27 28 STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 9 1 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 2 Order in this litigation, the relevant discovery request(s), and a reasonably specific description of the 3 information requested; and 4 (3) make the information requested available for inspection by the Non-Party. 5 (c) If the Non-Party fails to object or seek a protective order from this court within 14 6 days of receiving the notice and accompanying information, the Receiving Party may produce the 7 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely 8 seeks a protective order, the Receiving Party shall not produce any information in its possession or 9 control that is subject to the confidentiality agreement with the Non-Party before a determination by 10 the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of 11 seeking protection in this court of its Protected Material. 12 10. 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 15 the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized 16 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 17 inform the person or persons to whom unauthorized disclosures were made of all the terms of this 18 Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be 19 Bound” that is attached hereto as Exhibit A. 20 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 22 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced 23 material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties 24 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to 25 modify whatever procedure may be established in an e-discovery order that provides for production 26 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 27 parties reach an agreement on the effect of disclosure of a communication or information covered by 28 STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 10 1 the attorney-client privilege or work product protection, the parties may incorporate their agreement 2 in the stipulated protective order submitted to the court. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek 5 6 its modification by the court in the future. 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order 7 no Party waives any right it otherwise would have to object to disclosing or producing any 8 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 9 Party waives any right to object on any ground to use in evidence of any of the material covered by 10 11 this Protective Order. 12.3 Filing Protected Material. Without written permission from the Designating Party or a 12 court order secured after appropriate notice to all interested persons, a Party may not file in the public 13 record in this action any Protected Material. A Party that seeks to file under seal any Protected 14 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal 15 pursuant to a court order authorizing the sealing of the specific Protected Material at issue. Pursuant 16 to Civil Local Rule 79-5, a sealing order will issue only upon a request establishing that the Protected 17 Material at issue is privileged, protectable as a trade secret, or otherwise entitled to protection under 18 the law. If a Receiving Party's request to file Protected Material under seal pursuant to Civil Local 19 Rule 79-5(d) is denied by the court, then the Receiving Party may file the information in the public 20 record pursuant to Civil Local Rule 79-5(e) unless otherwise instructed by the court. 21 13. 22 Within 60 days after the final disposition of this action, as defined in paragraph 4, each FINAL DISPOSITION 23 Receiving Party must return all Protected Material to the Producing Party or destroy such material. 24 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 25 summaries, and any other format reproducing or capturing any of the Protected Material. Whether the 26 Protected Material is returned or destroyed, the Receiving Party must submit a written certification to 27 the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 day 28 deadline that (1) identifies (by category, where appropriate) all the Protected Material that was STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 11 1 returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, 2 compilations, summaries or any other format reproducing or capturing any of the Protected Material. 3 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, 4 motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 5 deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work 6 product, even if such materials contain Protected Material. Any such archival copies that contain or 7 constitute Protected Material remain subject to this Protective Order as set forth in Section 4 8 (DURATION). 9 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 10 11 Dated: August 21, 2014 LEONARD CARDER, LLC 12 By: /s/ Elizabeth Morris ELIZABETH MORRIS 13 14 Attorneys for Plaintiffs 15 16 17 Dated: August 21, 2014 DENNIS J. HERRERA City Attorney ELIZABETH SALVESON Chief Labor Attorney JONATHAN ROLNICK Deputy City Attorneys 18 19 20 21 By: /s/ Jonathan Rolnick1 JONATHAN ROLNICK 22 23 Attorneys for Defendants CITY AND COUNTY OF SAN FRANCISCO 24 25 26 1 27 Pursuant to Local Rule 5-1(i)(3) deputy city attorney Jonathan Rolnick obtained authorization from the other signatory to file this document. 28 STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 12 1 PURSUANT TO THE STIPULATION OF THE PARTIES, IT IS SO ORDERED. 2 3 Dated: August 21, 2014 4 By: 5 YVONNE GONZALEZ ROGERS U.S. DISTRICT COURT JUDGE 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 13 1 EXHIBIT A: ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 I, _____________________________ [print or type full name], of _________________ [print 4 or type full address], declare under penalty of perjury that I have read in its entirety and understand 5 the Stipulated Protective Order that was issued by the United States District Court for the Northern 6 District of California on [date] ____ in the case of Adams, et. al v. City and County of San Francisco, 7 et. al, U.S. District Court Case No. CV-13-4689 YGR. I agree to comply with and to be bound by 8 all the terms of this Stipulated Protective Order and I understand and acknowledge that failure to so 9 comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise 10 that I will not disclose in any manner any information or item that is subject to this Stipulated 11 Protective Order to any person or entity except in strict compliance with the provisions of this Order. 12 I further agree to submit to the jurisdiction of the United States District Court for the Northern 13 District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even 14 if such enforcement proceedings occur after termination of this action. 15 I hereby appoint __________________________ [print or type full name] of 16 _______________________________________ [print or type full address and telephone number] as 17 my California agent for service of process in connection with this action or any proceedings related to 18 enforcement of this Stipulated Protective Order. 19 Date: _________________________________ City and State where sworn and signed: 20 _________________________________ Printed name: ______________________________ 21 Signature: __________________________________ 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER Case No. CV-13-4689 YGR 14

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