Johnson v. San Benito County et al

Filing 25

Order by Hon. Lucy H. Koh granting 22 Stipulation for Protective Order.(lhklc3, COURT STAFF) (Filed on 3/22/2013)

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1 2 3 4 5 6 JOHN HOUSTON SCOTT, Esq. (SBN 72578) LIZABETH N. DE VRIES, Esq. (SBN 227215) SCOTT LAW FIRM 1388 Sutter Street, Ste. 715 San Francisco, CA 94109 Telephone: (415) 561-9601 Facsimile: (415) 561-9609 Email: Email: Attorney for Plaintiff BRETT JOHNSON 7 8 9 10 11 MICHAEL C. SERVERIAN, Esq. (SBN 133203) RANKIN, LANDSNESS, LAHDE, SERVERIAN & STOCK 96 No. Third Street, Suite 500 San Jose, California 95112-7709 Telephone : (408) 293-0463 Facsimile : (408) 293-9514 Email: 12 13 14 15 16 17 Attorneys for Defendants COUNTY OF SAN BENITO and TONY LAMONICA MARK DAVIS, Esq. ( SBN: 79936) DAVIS,& YOUNG APLC 1960 The Alameda, Suite 210 San Jose, California 95126 408.244.2166 Ph. / 408.244.7815 Fax Email: 18 19 Attorney for Defendant PATRICK TURTURICI 20 IN THE UNITED STATES DISTRICT COURT 21 NORTHERN DISTRICT OF CALIFORNIA - SAN JOSE DIVISION 22 BRETT JOHNSON, Plaintiff, 23 24 vs. 25 SAN BENITO COUNTY, PATRICK TURTURICI, TONY LAMONICA, and DOES 1-20, inclusive, 26 27 Defendants. ) ) ) ) ) ) ) ) ) ) ) ) Case No. CV 12-3691 LHK o footer STIPULATED PROTECTIVE ORDER 28 1 STIPULATED PROTECTIVE ORDER 1 1. 2 PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production of 3 confidential, proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the 6 following Stipulated Protective Order. The parties acknowledge that this Order does not 7 confer blanket protections on all disclosures or responses to discovery and that the 8 protection it affords from public disclosure and use extends only to the limited information 9 or items that are entitled to confidential treatment under the applicable legal principles. 10 The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated 11 Protective Order does not entitle them to file confidential information under seal; Civil 12 Local Rule 79-5 and General Order 62 set forth the procedures that must be followed and 13 the standards that will be applied when a party seeks permission from the court to file 14 material under seal. 15 2. 16 17 18 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 19 generated, stored or maintained) or tangible things that qualify for protection under 20 Federal Rule of Civil Procedure 26(c). 21 22 23 24 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.” 25 2.5 Disclosure or Discovery Material: all items or information, regardless of the 26 medium or manner in which it is generated, stored, or maintained (including, among other 27 things, testimony, transcripts, and tangible things), that are produced or generated in 28 disclosures or responses to discovery in this matter. 2 STIPULATED PROTECTIVE ORDER 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent 1 2 to the litigation who has been retained by a Party or its counsel to serve as an expert 3 witness or as a consultant in this action. 2.7 House Counsel: attorneys who are employees of a party to this action. House 4 5 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 6 7 legal entity not named as a Party to this action. 8 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this 9 action but are retained to represent or advise a party to this action and have appeared in 10 this action on behalf of that party or are affiliated with a law firm which has appeared on 11 behalf of that party. 12 2.10 Party: any party to this action, including all of its officers, directors, employees, 13 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 14 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 15 Material in this action. 16 2.12 Professional Vendors: persons or entities that provide litigation support services 17 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and 18 organizing, storing, or retrieving data in any form or medium) and their employees and 19 subcontractors. 2.13 Protected Material: any Disclosure or Discovery Material that is designated as 20 21 “CONFIDENTIAL.” 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 22 23 Producing Party. 24 3. 25 SCOPE The protections conferred by this Stipulation and Order cover not only Protected 26 Material (as defined above), but also (1) any information copied or extracted from 27 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 28 Material; and (3) any testimony, conversations, or presentations by Parties or their 3 STIPULATED PROTECTIVE ORDER 1 Counsel that might reveal Protected Material. However, the protections conferred by this 2 Stipulation and Order do not cover the following information: (a) any information that is in 3 the public domain at the time of disclosure to a Receiving Party or becomes part of the 4 public domain after its disclosure to a Receiving Party as a result of publication not 5 involving a violation of this Order, including becoming part of the public record through trial 6 or otherwise; and (b) any information known to the Receiving Party prior to the disclosure 7 or obtained by the Receiving Party after the disclosure from a source who obtained the 8 information lawfully and under no obligation of confidentiality to the Designating Party. 9 Any use of Protected Material at trial shall be governed by a separate agreement or order. 10 4. 11 DURATION Even after final disposition of this litigation, the confidentiality obligations imposed by 12 this Order shall remain in effect until a Designating Party agrees otherwise in writing or a 13 court order otherwise directs. Final disposition shall be deemed to be the later of (1) 14 dismissal of all claims and defenses in this action, with or without prejudice; and (2) final 15 judgment herein after the completion and exhaustion of all appeals, rehearings, remands, 16 trials, or reviews of this action, including the time limits for filing any motions or 17 applications for extension of time pursuant to applicable law. 18 5. DESIGNATING PROTECTED MATERIAL 19 5.1 Exercise of Restraint and Care in Designating Material for Protection: Each Party 20 or Non-Party that designates information or items for protection under this Order must take 21 care to limit any such designation to specific material that qualifies under the appropriate 22 standards. The Designating Party must designate for protection only those parts of 23 material, documents, items, or oral or written communications that qualify – so that other 24 portions of the material, documents, items, or communications for which protection is not 25 warranted are not swept unjustifiably within the ambit of this Order. 26 Mass, indiscriminate, or routinized designations are prohibited. Designations that are 27 shown to be clearly unjustified or that have been made for an improper purpose (e.g., to 28 unnecessarily encumber or retard the case development process or to impose 4 STIPULATED PROTECTIVE ORDER 1 unnecessary expenses and burdens on other parties) expose the Designating Party to 2 sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 designated for protection do not qualify for protection, that Designating Party must 5 promptly notify all other Parties that it is withdrawing the mistaken designation. 6 5.2 Manner and Timing of Designations: Except as otherwise provided in this Order 7 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 8 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 9 must be clearly so designated before the material is disclosed or produced. 10 11 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic documents, 12 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 13 Producing Party affix the legend “CONFIDENTIAL” to each page that contains protected 14 material. If only a portion or portions of the material on a page qualifies for protection, the 15 Producing Party also must clearly identify the protected portion(s) (e.g., by making 16 appropriate markings in the margins). 17 A Party or Non-Party that makes original documents or materials available for 18 inspection need not designate them for protection until after the inspecting Party has 19 indicated which material it would like copied and produced. During the inspection and 20 before the designation, all of the material made available for inspection shall be deemed 21 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied 22 and produced, the Producing Party must determine which documents, or portions thereof, 23 qualify for protection under this Order. Then, before producing the specified documents, 24 the Producing Party must affix the “CONFIDENTIAL” legend to each page that contains 25 Protected Material. If only a portion or portions of the material on a page qualifies for 26 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by 27 making appropriate markings in the margins). 28 5 STIPULATED PROTECTIVE ORDER (b) for testimony given in deposition or in other pretrial or trial proceedings, 1 2 that the Designating Party identify on the record, before the close of the deposition, 3 hearing, or other proceeding, all protected testimony. (c) for information produced in some form other than documentary and for any 4 5 other tangible items, that the Producing Party affix in a prominent place on the exterior of 6 the container or containers in which the information or item is stored the legend 7 “CONFIDENTIAL.” If only a portion or portions of the information or item warrant 8 protection, the Producing Party, to the extent practicable, shall identify the protected 9 portion(s). 5.3 Inadvertent Failures to Designate: If timely corrected, an inadvertent failure to 10 11 designate qualified information or items does not, standing alone, waive the Designating 12 Party’s right to secure protection under this Order for such material. Upon timely correction 13 of a designation, the Receiving Party must make reasonable efforts to assure that the 14 material is treated in accordance with the provisions of this Order. 15 6. 16 CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges: Any Party or Non-Party may challenge a designation of 17 confidentiality at any time. Unless a prompt challenge to a Designating Party’s 18 confidentiality designation is necessary to avoid foreseeable, substantial unfairness, 19 unnecessary economic burdens, or a significant disruption or delay of the litigation, a Party 20 does not waive its right to challenge a confidentiality designation by electing not to mount 21 a challenge promptly after the original designation is disclosed. 22 6.2 Meet and Confer: The Challenging Party shall initiate the dispute resolution 23 process by providing written notice of each designation it is challenging and describing the 24 basis for each challenge. To avoid ambiguity as to whether a challenge has been made, 25 the written notice must recite that the challenge to confidentiality is being made in 26 accordance with this specific paragraph of the Protective Order. The parties shall attempt 27 to resolve each challenge in good faith and must begin the process by conferring directly 28 (in voice to voice dialogue; other forms of communication are not sufficient) within 14 days 6 STIPULATED PROTECTIVE ORDER 1 of the date of service of notice. In conferring, the Challenging Party must explain the basis 2 for its belief that the confidentiality designation was not proper and must give the 3 Designating Party an opportunity to review the designated material, to reconsider the 4 circumstances, and, if no change in designation is offered, to explain the basis for the 5 chosen designation. A Challenging Party may proceed to the next stage of the challenge 6 process only if it has engaged in this meet and confer process first or establishes that the 7 Designating Party is unwilling to participate in the meet and confer process in a timely 8 manner. 9 6.3 Judicial Intervention: If the Parties cannot resolve a challenge without court 10 intervention, the Designating Party shall file and serve a motion to retain confidentiality 11 under Civil Local Rule 7 (and in compliance with Civil Local Rule 79-5 and General Order 12 62, if applicable) within 21 days of the initial notice of challenge or within 14 days of the 13 parties agreeing that the meet and confer process will not resolve their dispute, whichever 14 is earlier. Each such motion must be accompanied by a competent declaration affirming 15 that the movant has complied with the meet and confer requirements imposed in the 16 preceding paragraph. Failure by the Designating Party to make such a motion including 17 the required declaration within 21 days (or 14 days, if applicable) shall automatically waive 18 the confidentiality designation for each challenged designation. In addition, the 19 Challenging Party may file a motion challenging a confidentiality designation at any time if 20 there is good cause for doing so, including a challenge to the designation of a deposition 21 transcript or any portions thereof. Any motion brought pursuant to this provision must be 22 accompanied by a competent declaration affirming that the movant has complied with the 23 meet and confer requirements imposed by the preceding paragraph. 24 The burden of persuasion in any such challenge proceeding shall be on the 25 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 26 to harass or impose unnecessary expenses and burdens on other parties) may expose the 27 Challenging Party to sanctions. Unless the Designating Party has waived the 28 confidentiality designation by failing to file a motion to retain confidentiality as described 7 STIPULATED PROTECTIVE ORDER 1 above, all parties shall continue to afford the material in question the level of protection to 2 which it is entitled under the Producing Party’s designation until the court rules on the 3 challenge. 4 7. 5 ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles: A Receiving Party may use Protected Material that is disclosed 6 or produced by another Party or by a Non-Party in connection with this case only for 7 prosecuting, defending, or attempting to settle this litigation. Such Protected Material may 8 be disclosed only to the categories of persons and under the conditions described in this 9 Order. When the litigation has been terminated, a Receiving Party must comply with the 10 11 provisions of section 13 below (FINAL DISPOSITION). Protected Material must be stored and maintained by a Receiving Party at a location 12 and in a secure manner that ensures that access is limited to the persons authorized 13 under this Order. 14 7.2 Disclosure of “CONFIDENTIAL” Information or Items: Unless otherwise ordered 15 by the court or permitted in writing by the Designating Party, a Receiving Party may 16 disclose any information or item designated “CONFIDENTIAL” only to: 17 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 18 employees of said Outside Counsel of Record to whom it is reasonably necessary to 19 disclose the information for this litigation and who have signed the “Acknowledgment and 20 Agreement to Be Bound” that is attached hereto as Exhibit A; 21 (b) the officers, directors, and employees (including House Counsel) of the 22 Receiving Party to whom disclosure is reasonably necessary for this litigation and who 23 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably necessary for this litigation and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the court and its personnel; 28 8 STIPULATED PROTECTIVE ORDER (e) court reporters and their staff, professional jury or trial consultants, mock 1 2 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this 3 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 4 A); (f) during their depositions, witnesses in the action to whom disclosure is 5 6 reasonably necessary and who have signed the “Acknowledgment and Agreement to Be 7 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the 8 court. Pages of transcribed deposition testimony or exhibits to depositions that reveal 9 Protected Material must be separately bound by the court reporter and may not be 10 disclosed to anyone except as permitted under this Stipulated Protective Order. (g) the author or recipient of a document containing the information or a 11 12 custodian or other person who otherwise possessed or knew the information. 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 14 LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation that 16 compels disclosure of any information or items designated in this action as 17 “CONFIDENTIAL,” that Party must: 18 19 20 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to 21 issue in the other litigation that some or all of the material covered by the subpoena or 22 order is subject to this Protective Order. Such notification shall include a copy of this 23 Stipulated Protective Order; and 24 25 26 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the 27 subpoena or court order shall not produce any information designated in this action as 28 “CONFIDENTIAL” before a determination by the court from which the subpoena or order 9 STIPULATED PROTECTIVE ORDER 1 issued, unless the Party has obtained the Designating Party’s permission. The Designating 2 Party shall bear the burden and expense of seeking protection in that court of its 3 confidential material – and nothing in these provisions should be construed as authorizing 4 or encouraging a Receiving Party in this action to disobey a lawful directive from another 5 court. 6 9. 7 8 9 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.” Such information produced by 10 Non-Parties in connection with this litigation is protected by the remedies and relief 11 provided by this Order. Nothing in these provisions should be construed as prohibiting a 12 Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party’s confidential information in its possession, and the Party is subject 15 to an agreement with the Non-Party not to produce the Non-Party’s confidential 16 information, then the Party shall: 17 (1) promptly notify in writing the Requesting Party and the Non-Party 18 that some or all of the information requested is subject to a 19 confidentiality agreement with a Non-Party; 20 (2) promptly provide the Non-Party with a copy of the Stipulated 21 Protective Order in this litigation, the relevant discovery request(s), 22 and a reasonably specific description of the information requested; 23 and 24 (3) make the information requested available for inspection by the 25 Non-Party. 26 (c) If the Non-Party fails to object or seek a protective order from this court 27 within 14 days of receiving the notice and accompanying information, the Receiving Party 28 may produce the Non-Party’s confidential information responsive to the discovery request. 10 STIPULATED PROTECTIVE ORDER 1 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 2 information in its possession or control that is subject to the confidentiality agreement with 3 the Non-Party before a determination by the court.(1) Absent a court order to the contrary, 4 the Non-Party shall bear the burden and expense of seeking protection in this court of its 5 Protected Material. 6 10. 7 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the 10 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 11 unauthorized copies of the Protected Material, (c) inform the person or persons to whom 12 unauthorized disclosures were made of all the terms of this Order, and (d) request such 13 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is 14 attached hereto as Exhibit A. 15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 16 MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain inadvertently 18 produced material is subject to a claim of privilege or other protection, the obligations of 19 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 20 This provision is not intended to modify whatever procedure may be established in an e- 21 discovery order that provides for production without prior privilege review. Pursuant to 22 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 23 effect of disclosure of a communication or information covered by the attorney-client 24 privilege or work product protection, the parties may incorporate their agreement in the 25 stipulated protective order submitted to the court. 26 27 28 1. The purpose of this provision is to alert the interested parties to the existence of confidentiality rights of a Non-Party and to afford the Non-Party an opportunity to protect its confidentiality interests in this court. 11 STIPULATED PROTECTIVE ORDER 1 12. 2 3 MISCELLANEOUS 12.1 Right to Further Relief: Nothing in this Order abridges the right of any person to seek its modification by the court in the future. 12.2 Right to Assert Other Objections: By stipulating to the entry of this Protective 4 5 Order no Party waives any right it otherwise would have to object to disclosing or 6 producing any information or item on any ground not addressed in this Stipulated 7 Protective Order. Similarly, no Party waives any right to object on any ground to use in 8 evidence of any of the material covered by this Protective Order. 12.3 Filing Protected Material: Without written permission from the Designating 9 10 Party or a court order secured after appropriate notice to all interested persons, a Party 11 may not file in the public record in this action any Protected Material. A Party that seeks to 12 file under seal any Protected Material must comply with Civil Local Rule 79-5 and General 13 Order 62. Protected Material may only be filed under seal pursuant to a court order 14 authorizing the sealing of the specific Protected Material at issue. Pursuant to Civil Local 15 Rule 79-5 and General Order 62, a sealing order will issue only upon a request 16 establishing that the Protected Material at issue is privileged, protectable as a trade secret, 17 or otherwise entitled to protection under the law. If a Receiving Party's request to file 18 Protected Material under seal pursuant to Civil Local Rule 79-5(d) and General Order 62 is 19 denied by the court, then the Receiving Party may file the information in the public record 20 pursuant to Civil Local Rule 79-5(e) unless otherwise instructed by the court. 21 13. 22 FINAL DISPOSITION Within 60 days after the final disposition of this action, as defined in paragraph 4, 23 each Receiving Party must return all Protected Material to the Producing Party or destroy 24 such material. As used in this subdivision, “all Protected Material” includes all copies, 25 abstracts, compilations, summaries, and any other format reproducing or capturing any of 26 the Protected Material. Whether the Protected Material is returned or destroyed, the 27 Receiving Party must submit a written certification to the Producing Party (and, if not the 28 same person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 12 STIPULATED PROTECTIVE ORDER 1 (by category, where appropriate) all the Protected Material that was returned or destroyed 2 and (2)affirms that the Receiving Party has not retained any copies, abstracts, 3 compilations, summaries or any other format reproducing or capturing any of the Protected 4 Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of 5 all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 6 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 7 consultant and expert work product, even if such materials contain Protected Material. Any 8 such archival copies that contain or constitute Protected Material remain subject to this 9 Protective Order as set forth in Section 4 (DURATION). 10 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 11 Dated: March 20, 2013 SCOTT LAW FIRM By: /s/ LIZABETH N. DE VRIES LIZABETH N. DE VRIES Attorney for Plaintiff 12 13 14 15 Dated: March 20, 2013 RANKIN, LANDSNESS, LAHDE, SERVERIAN & STOCK 16 By: /s/ Michael C. Serverian MICHAEL C. SERVERIAN Attorney for Defendants 17 18 19 20 Dated: March 20, 2013 DAVIS &YOUNG, APLC 21 By: /s/ Mark Davis MARK DAVIS Attorney for Defendant PATRICK TURTURICI 22 23 24 25 PURSUANT TO STIPULATION, IT IS SO ORDERED. 26 March 22, 2013 DATED: __________________ ____________________________ HONORABLE LUCY H. KOH Judge of the U.S. District Court 27 28 13 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of _________________ 4 [print or type full address], declare under penalty of perjury that I have read in its entirety 5 and understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Northern District of California on __________ in the case of BRETT 7 JOHNSON v SAN BENITO COUNTY, PATRICK TURTURICI, TONY LAMONICA, et al., 8 Case No. CV 12-3691 LHK. I agree to comply with and to be bound by all the terms of this 9 Stipulated Protective Order and I understand and acknowledge that failure to so comply 10 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. I further agree to submit to the jurisdiction of the United States District Court for the 14 15 Northern District of California for the purpose of enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of this 17 action. 18 I hereby appoint __________________________ [print or type full name] of 19 ___________________ [print or type full address and telephone number] as my California 20 agent for service of process in connection with this action or any proceedings related to 21 enforcement of this Stipulated Protective Order. 22 Date: _______________ 23 City and State where sworn and signed: _________________________________ 24 Signature: __________________________ 25 Printed name: _______________________ 26 27 28 14 STIPULATED PROTECTIVE ORDER

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