# Thompson v. Saukhla

> District Court, E.D. California · February 18, 2020

URL: https://www.frixlaw.com/law-library/cases/10017116

## Case

- **Court:** District Court, E.D. California
- **Decided:** February 18, 2020
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 UNITED STATES DISTRICT COURT
2 EASTERN DISTRICT OF CALIFORNIA
3

4
FELICIA THOMPSON
Case No. 2:18-cv-2422 WBS-KJN
5

6 Plaintiff, STIPULATED PROTECTIVE ORDER

7 v.
Trial Date: November 24, 2020
8 Action Filed: September 3, 2018
NARINDER SAUKHLA, et al.,
9

10 Defendants.

11
12 1. PURPOSES AND LIMITATIONS
13 Disclosure and discovery activity in this action are likely to involve production of
14 confidential, proprietary, or private information for which special protection from public disclosure
15 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly,
16 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective
17 Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures
18 or responses to discovery and that the protection it affords from public disclosure and use extends
19 only to the limited information or items that are entitled to confidential treatment under the
20 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, below, that
21 this Stipulated Protective Order does not entitle them to file confidential information under seal;
22 Local Rule 141 sets forth the procedures that must be followed and the standards that will be applied
23 when a party seeks permission from the court to file material under seal.
24 The following Stipulated Protective Order shall govern the use and disclosure of the
25 documents and materials listed herein, and any other documents that are designated “confidential”
26 by the producing party.
27
1 2. DEFINITIONS
2 2.1 Challenging Party: a Party or Non-Party that challenges the designation of
3 information or items under this Order.
4 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is
5 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of
6 Civil Procedure 26(c) and for which public disclosure is likely to result in particularized harm, or is
7 privileged under law, and/or violates privacy interests. This information may include:
8 a. information regarding Plaintiff’s medical history disclosed in
9 communications between the decedent and Plaintiff;
10 b. intimate details of Plaintiff’s personal relationships with those other than
11 decedent disclosed in communications between the decedent and Plaintiff;
12 c. intimate details of decedent’s personal relationships with those other than
13 Plaintiff disclosed in communications between the decedent and Plaintiff;
14 d. employment records that would otherwise be privileged.
15 Other items may be included as Confidential for purposes of this order by agreement of the
16 parties or by court order on noticed motion.
17 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well
18 as their support staff).
19 2.4 Designating Party: a Party or Non-Party that designates information or items that it
20 produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
21 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium
22 or manner in which it is generated, stored, or maintained (including, among other things, testimony,
23 transcripts, and tangible things), that are produced or generated in disclosures or responses to
24 discovery in this matter.
25 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to
26 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
27 consultant in this action.
1 Counsel does not include Outside Counsel of Record or any other outside counsel.
2 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal
3 entity not named as a Party to this action.
4 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action
5 but are retained to represent or advise a party to this action and have appeared in this action on
6 behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
7 2.10 Party: any party to this action, including all of its officers, directors, employees,
8 consultants, retained experts, and Outside Counsel of Record (and their support staffs).
9 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
10 Material in this action.
11 2.12 Professional Vendors: persons or entities that provide litigation support services
12 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing,
13 storing, or retrieving data in any form or medium) and their employees and subcontractors.
14 2.13 Protected Material: any Disclosure or Discovery Material that is designated as
15 “CONFIDENTIAL.”
16 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a
17 Producing Party.
18 3. SCOPE
19 The protections conferred by this Stipulation and Order cover not only Protected Material (as
20 defined above), but also (1) any information copied or extracted from Protected Material; (2) all
21 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
22 conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
23 However, the protections conferred by this Stipulation and Order do not cover the following
24 information: (a) any information that is in the public domain at the time of disclosure to a Receiving
25 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of
26 publication not involving a violation of this Order, including becoming part of the public record
27 through trial or otherwise; and (b) any information known to the Receiving Party prior to the
1 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of
2 Protected Material at trial shall be governed by a separate agreement or order.
3 4. DURATION
4 Even after final disposition of this litigation, the confidentiality obligations imposed by this
5 Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order
6 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and
7 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion
8 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the
9 time limits for filing any motions or applications for extension of time pursuant to applicable law.
10 5. DESIGNATING PROTECTED MATERIAL
11 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or
12 Non-Party that designates information or items for protection under this Order must take care to
13 limit any such designation to specific material that qualifies under the appropriate standards. The
14 Designating Party must designate for protection only those parts of material, documents, items, or
15 oral or written communications that qualify – so that other portions of the material, documents,
16 items, or communications for which protection is not warranted are not swept unjustifiably within
17 the ambit of this Order.
18 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown
19 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily
20 encumber or retard the case development process or to impose unnecessary expenses and burdens on
21 other parties) expose the Designating Party to sanctions.
22 If it comes to a Designating Party’s attention that information or items that it designated for
23 protection do not qualify for protection, that Designating Party must promptly notify all other Parties
24 that it is withdrawing the mistaken designation.
25 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order
26 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
27 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
1 Designation in conformity with this Order requires:
2 (a) for information in documentary form (e.g., paper or electronic documents, but
3 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party
4 affix the legend “CONFIDENTIAL” to each page that contains protected material. A Party or Non-
5 Party that makes original documents or materials available for inspection need not designate them
6 for protection until after the inspecting Party has indicated which material it would like copied and
7 produced. During the inspection and before the designation, all of the material made available for
8 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified the
9 documents it wants copied and produced, the Producing Party must determine which documents, or
10 portions thereof, qualify for protection under this Order. Then, before producing the specified
11 documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page that
12 contains Protected Material.
13 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the
14 Designating Party identify on the record, before the close of the deposition, hearing, or other
15 proceeding, all protected testimony.
16 (c) for information produced in some form other than documentary and for any other
17 tangible items, that the Producing Party affix in a prominent place on the exterior of the container or
18 containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a
19 portion or portions of the information or item warrant protection, the Producing Party, to the extent
20 practicable, shall identify the protected portion(s).
21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
22 designate qualified information or items does not, standing alone, waive the Designating Party’s
23 right to secure protection under this Order for such material. Upon timely correction of a
24 designation, the Receiving Party must make reasonable efforts to assure that the material is treated in
25 accordance with the provisions of this Order.
26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
27 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
1 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens,
2 or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a
3 confidentiality designation by electing not to mount a challenge promptly after the original
4 designation is disclosed.
5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process
6 by providing written notice of each designation it is challenging and describing the basis for each
7 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must
8 recite that the challenge to confidentiality is being made in accordance with this specific paragraph
9 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must
10 begin the process by conferring directly (in voice to voice dialogue; other forms of communication
11 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging
12 Party must explain the basis for its belief that the confidentiality designation was not proper and
13 must give the Designating Party an opportunity to review the designated material, to reconsider the
14 circumstances, and, if no change in designation is offered, to explain the basis for the chosen
15 designation. A Challenging Party may proceed to the next stage of the challenge process only if it
16 has engaged in this meet and confer process first or establishes that the Designating Party is
17 unwilling to participate in the meet and confer process in a timely manner.
18 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court
19 intervention, the Designating Party shall file and serve a motion to retain confidentiality under Local
20 Rule 230 and 251 (and in compliance with Local Rule 141 and 141.1, if applicable) within 21 days
21 of the initial notice of challenge or within 14 days of the parties agreeing that the meet and confer
22 process will not resolve their dispute, whichever is earlier. Each such motion must be accompanied
23 by a competent declaration affirming that the movant has complied with the meet and confer
24 requirements imposed in the preceding paragraph. Failure by the Designating Party to make such a
25 motion including the required declaration within 21 days (or 14 days, if applicable) shall
26 automatically waive the confidentiality designation for each challenged designation. In addition, the
27 Challenging Party may file a motion challenging a confidentiality designation at any time if there is
1 portions thereof. Any motion brought pursuant to this provision must be accompanied by a
2 competent declaration affirming that the movant has complied with the meet and confer
3 requirements imposed by the preceding paragraph.
4 The burden of persuasion in any such challenge proceeding shall be on the Designating
5 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
6 unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions.
7 Unless the Designating Party has waived the confidentiality designation by failing to file a motion to
8 retain confidentiality as described above, all parties shall continue to afford the material in question
9 the level of protection to which it is entitled under the Producing Party’s designation until the court
10 rules on the challenge.
11 7. ACCESS TO AND USE OF PROTECTED MATERIAL
12 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or
13 produced by another Party or by a Non-Party in connection with this case only for prosecuting,
14 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to
15 the categories of persons and under the conditions described in this Order. When the litigation has
16 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
17 DISPOSITION).
18 Protected Material must be stored and maintained by a Receiving Party at a location and in a
19 secure manner that ensures that access is limited to the persons authorized under this Order.
20 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by
21 the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
22 information or item designated “CONFIDENTIAL” only to:
23 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees
24 of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for
25 this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is
26 attached hereto as Exhibit A;
27 (b) the officers, directors, and employees (including House Counsel) of the Receiving
1 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
2 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
3 reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement
4 to Be Bound” (Exhibit A);
5 (d) the court and its personnel;
6 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, and
7 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have
8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (f) during their depositions, witnesses in the action to whom disclosure is reasonably
10 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
11 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed
12 deposition testimony or exhibits to depositions that reveal Protected Material must be separately
13 bound by the court reporter and may not be disclosed to anyone except as permitted under this
14 Stipulated Protective Order.
15 (g) the author or recipient of a document containing the information or a custodian or
16 other person who otherwise possessed or knew the information.
17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
18 LITIGATION
19 If a Party is served with a subpoena or a court order issued in other litigation that compels
20 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
21 must:
22 (a) promptly notify in writing the Designating Party. Such notification shall include a
23 copy of the subpoena or court order;
24 (b) promptly notify in writing the party who caused the subpoena or order to issue in the
25 other litigation that some or all of the material covered by the subpoena or order is subject to this
26 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and
27 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
1 If the Designating Party timely seeks a protective order, the Party served with the subpoena
2 or court order shall not produce any information designated in this action as “CONFIDENTIAL”
3 before a determination by the court from which the subpoena or order issued, unless the Party has
4 obtained the Designating Party’s permission. The Designating Party shall bear the burden and
5 expense of seeking protection in that court of its confidential material – and nothing in these
6 provisions should be construed as authorizing or encouraging a Receiving Party in this action to
7 disobey a lawful directive from another court.
8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
9 LITIGATION
10 (a) The terms of this Order are applicable to information produced by a Non-Party in this
11 action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in
12 connection with this litigation is protected by the remedies and relief provided by this Order.
13 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional
14 protections.
15 (b) In the event that a Party is required, by a valid discovery request, to produce a Non-
16 Party’s confidential information in its possession, and the Party is subject to an agreement with the
17 Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
18 (1) promptly notify in writing the Requesting Party and the Non-Party that some or
19 all of the information requested is subject to a confidentiality agreement with a Non-Party;
20 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in
21 this litigation, the relevant discovery request(s), and a reasonably specific description of the
22 information requested; and
23 (3) make the information requested available for inspection by the Non-Party.
24 (c) If the Non-Party fails to object or seek a protective order from this court within 14
25 days of receiving the notice and accompanying information, the Receiving Party may produce the
26 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely
27 seeks a protective order, the Receiving Party shall not produce any information in its possession or
1 the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of
2 seeking protection in this court of its Protected Material.
3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
5 Material to any person or in any circumstance not authorized under this Stipulated Protective Order,
6 the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized
7 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c)
8 inform the person or persons to whom unauthorized disclosures were made of all the terms of this
9 Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to
10 Be Bound” that is attached hereto as Exhibit A.
11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
12 MATERIAL
13 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced
14 material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties
15 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to
16 modify whatever procedure may be established in an e-discovery order that provides for production
17 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
18 parties reach an agreement on the effect of disclosure of a communication or information covered by
19 the attorney-client privilege or work product protection, the parties may incorporate their agreement
20 in the stipulated protective order submitted to the court.
21 12. MISCELLANEOUS
22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek
23 its modification by the court in the future.
24 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order
25 no Party waives any right it otherwise would have to object to disclosing or producing any
26 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
27 Party waives any right to object on any ground to use in evidence of any of the material covered by
1 12.3 Filing Protected Material. Without written permission from the Designating Party or a
2 court order secured after appropriate notice to all interested persons, a Party may not file in the
3 public record in this action any Protected Material. A Party that seeks to file under seal any Protected
4 Material must comply with Local Rule 141. Protected Material may only be filed under seal pursuant
5 to a court order authorizing the sealing of the specific Protected Material at issue. Pursuant to Local
6 Rule 141, a sealing order will issue only upon a request establishing that the Protected Material at
7 issue is entitled to protection under the law.
8 13. FINAL DISPOSITION
9 Within 60 days after the final disposition of this action, as defined in paragraph 4, each
10 Receiving Party must return all Protected Material to the Producing Party or destroy such material.
11 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
12 summaries, and any other format reproducing or capturing any of the Protected Material. Whether
13 the Protected Material is returned or destroyed, the Receiving Party must submit a written
14 certification to the Producing Party (and, if not the same person or entity, to the Designating Party)
15 by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material
16 that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies,
17 abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected
18 Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
19 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
20 correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant
21 and expert work product, even if such materials contain Protected Material. Any such archival copies
22 that contain or constitute Protected Material remain subject to this Protective Order as set forth in
23 Section 4 (DURATION).
24 14. REMEDIES
25 Any party believing that this order is being violated may move for a court order of
26 enforcement. The motion shall be subject to all local rules governing motions concerning
27 discovery disputes, including but not limited to meet and confer requirements. Said motion may be
1 15. LOCAL RULE 141.1 STATEMENT
2 In accordance with the provisions of Local Rule 141.1, the parties state as follows:
3 (1) The information eligible for a protective order in this case are:
4 a. information regarding Plaintiff’s medical history disclosed in
5 communications between the decedent and Plaintiff;
6 b. intimate details of Plaintiff’s personal relationships with those other
7 than decedent disclosed in communications between the decedent and
8 Plaintiff;
9 c. intimate details of decedent’s personal relationships with those other
10 than Plaintiff disclosed in communications between the decedent and
11 Plaintiff;
12 d. employment records that would otherwise be privileged.
13 (2) A particularized need exists as to these categories as follows:
14 a. These records contain confidential and personal information;
15 b. These records contain information of third parties to this lawsuit that are
16 confidential and personal in nature.
17 (3) A court order is needed to ensure the privacy and confidentiality of this
18 information is enforceable during and after the litigation has ended.
19
20 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

21
DATED: ___2/11/2020_____ ______s/Carter C. White_______________
22 Carter C. White, Attorney for Plaintiff

23
DATED: ___2/11/2020____ ______s/Diana Esquivel________________
24 Diana Esquivel, Attorney for Defendants
Briggs, Cortez, Galvan, Haile, and Saukhla
25
DATED: ___2/11/2020____ ______s/Nicole Cahill__________________
26
Nicole Cahill, Attorney for Defendants Naidoo
27 and Portugal
1 ORDER
2 The Court has reviewed the parties’ stipulated protective order, which complies with the
3 relevant authorities and the Court’s applicable local rule. See L.R. 141.1(c);' see also Phillips ex
4 |} rel. Estates of Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210 (9th Cir. 2002) “Generally, the
5 public can gain access to litigation documents and information produced during discovery unless
6 || the party opposing disclosure shows ‘good cause’ why a protective order is necessary.”)
7 Therefore, the Court GRANTS the request subject to the following clarification.
8 It is unclear as to the parties’ intent concerning the duration of the Court’s jurisdiction
9 || regarding this protective order. The Local Rules indicate that once this action is closed, “unless
10 otherwise ordered, the Court will not retain jurisdiction over enforcement of the terms of any
11 protective order filed in that action.” L.R. 141.1(f). Courts in the district generally do not agree to
12 retain jurisdiction after closure of the case, and the Court sees no reason to do so here. See, e.g.,
13 MD Helicopters, Inc. v. Aerometals, Inc., 2017 WL 495778 (E.D. Cal., February 03, 2017). Thus,
14 || for clarity, the undersigned informs the parties that once the case is closed, the Court will not
15 || retain jurisdiction over this protective order.
16 Dated: February 18, 2020
M7 Al Norra
18 EKENDALLJ. WEA
UNITED STATES MAGISTRATE JUDGE
19 thom.2422
20
YO
' The Court’s Local Rules instruct the parties, when requesting a protective order, to
22 || include in their submission:
23 (1) A description of the types of information eligible for protection under the
24 order, with the description provided in general terms sufficient to reveal the
nature of the information (e.g., customer list, formula for soda, diary of a
25 troubled child);
(2) A showing of particularized need for protection as to each category of
26 information proposed to be covered by the order; and
(3) A showing as to why the need for protection should be addressed by a court
order, as opposed to a private agreement between or among the parties.
28 |! Local Rule 141.1(c).

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of _________________ [print or
4 type full address], declare under penalty of perjury that I have read in its entirety and understand the
5 Stipulated Protective Order that was issued by the United States District Court for the Eastern
6 District of California on [date] in the case of ___________ [insert formal name of the case and the
7 number and initials assigned to it by the court]. I agree to comply with and to be bound by all the
8 terms of this Stipulated Protective Order and I understand and acknowledge that failure to so comply
9 could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I
10 will not disclose in any manner any information or item that is subject to this Stipulated Protective
11 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 Eastern District
13 of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such
14 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
18 to enforcement of this Stipulated Protective Order.
19
20 Date: ______________________________________
21 City and State where sworn and signed: _________________________________
22
23 Printed name: _______________________________
24
25 Signature: __________________________________
26
27

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10017116. Public record. Not legal advice.