# MSC.Software Corporation v. Heroux Devtek Inc.

> District Court, C.D. California · March 2, 2020

URL: https://www.frixlaw.com/law-library/cases/10037160

## Case

- **Court:** District Court, C.D. California
- **Decided:** March 2, 2020
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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THE UNITED STATES DISTRICT COURT
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FOR THE CENTRAL DISTRICT OF CALIFORNIA
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11 (SOUTHERN DIVISION)
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13 MSC.SOFTWARE CORPORATION, a CASE NO: 8:19-cv-01987-JVS-DFM
Delaware corporation,
14 JOINT STIPULATION FOR
15 Plaintiff, PROTECTIVE ORDER

16 vs.
17 Judge: Hon. James V. Selna
HÉROUX-DEVTEK, INC. a Quebec Trial Date: March 23, 2021
18 Canada Corporation
19
Defendants.
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22 TO THE COURT, ALL PARTIES AND THEIR RESPECTIVE COUNSEL OF
23 RECORD:
24
25 Plaintiff MSC.Software, Inc. (“Plaintiff”) and Defendant Héroux-Devtek, Inc.
26 (“Defendant”), through their counsel of record, submit the following stipulated
27 protective order to facilitate the exchange of information for which the respective
28 designating party considers to be confidential in discovery in this case:
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public disclosure
4 and from use for any purpose other than prosecuting this litigation may be warranted.
5 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
7 not 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
9 information or items that are entitled to confidential treatment under the applicable
10 legal principles.
11 B. GOOD CAUSE STATEMENT
12 This action is likely to involve confidential and commercially sensitive pricing
13 information and information regarding proprietary, confidential, and commercially
14 sensitive licensing and pricing practices related to the licensing of commercial
15 software as well as confidential and commercially sensitive information regarding the
16 internal business practices and procedures of both Plaintiff and Defendant for which
17 special protection from public disclosure and from use for any purpose other than
18 prosecution of this action is warranted. Such confidential and proprietary materials and
19 information consist of, among other things, confidential business or financial
20 information, information regarding confidential business practices, or other
21 confidential research, development, or commercial information (including information
22 implicating privacy rights of third parties), information otherwise generally
23 unavailable to the public, or which may be privileged or otherwise protected from
24 disclosure under state or federal statutes, court rules, case decisions, or common law.
25 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of
26 disputes over confidentiality of discovery materials, to adequately protect information
27 the parties are entitled to keep confidential, to ensure that the parties are permitted
28 reasonable necessary uses of such material in preparation for and in the conduct of
2 a protective order for such information is justified in this matter. It is the intent of the
3 parties that information will not be designated as confidential for tactical reasons and
4 that nothing be so designated without a good faith belief that it has been maintained in
5 a confidential, non-public manner, and there is good cause why it should not be part of
6 the public record of this case.
7 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
8 SEAL
9 The parties further acknowledge, as set forth in Section 12.3, below, that this
10 Stipulated Protective Order does not entitle them to file confidential information under
11 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
12 standards that will be applied when a party seeks permission from the court to file
13 material under seal.
14 There is a strong presumption that the public has a right of access to judicial
15 proceedings and records in civil cases. In connection with non-dispositive motions,
16 good cause must be shown to support a filing under seal. See Kamakana v. City and
17 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
18 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,
19 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good
20 cause showing), and a specific showing of good cause or compelling reasons with
21 proper evidentiary support and legal justification, must be made with respect to
22 Protected Material that a party seeks to file under seal. The parties’ mere designation
23 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the
24 submission of competent evidence by declaration, establishing that the material sought
25 to be filed under seal qualifies as confidential, privileged, or otherwise protectable—
26 constitute good cause.
27 Further, if a party requests sealing related to a dispositive motion or trial, then
28 compelling reasons, not only good cause, for the sealing must be shown, and the relief
2 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
3 or type of information, document, or thing sought to be filed or introduced under seal
4 in connection with a dispositive motion or trial, the party seeking protection must
5 articulate compelling reasons, supported by specific facts and legal justification, for the
6 requested sealing order. Again, competent evidence supporting the application to file
7 documents under seal must be provided by declaration.
8 Any document that is not confidential, privileged, or otherwise protectable in its
9 entirety will not be filed under seal if the confidential portions can be redacted. If
10 documents can be redacted, then a redacted version for public viewing, omitting only
11 the confidential, privileged, or otherwise protectable portions of the document, shall be
12 filed. Any application that seeks to file documents under seal in their entirety should
13 include an explanation of why redaction is not feasible.
14 2. DEFINITIONS
15 2.1 Action: MSC.Software Corporation v. Héroux-Devtek, Inc., in the U.S.
16 District Court for the Central District of California, Case No. 8:19-cv-01987-JVS-
17 DFM.
18 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
19 information or items under this Order.
20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
21 it is generated, stored or maintained) or tangible things that qualify for protection
22 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
23 Statement.
24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
25 support staff).
26 2.5 Designating Party: a Party or Non-Party that designates information or
27 items that it produces in disclosures or in responses to discovery as
28 “CONFIDENTIAL.”
2 the medium or manner in which it is generated, stored, or maintained (including,
3 among other things, testimony, transcripts, and tangible things), that are produced or
4 generated in disclosures or responses to discovery in this matter.
5 2.7 Expert: a person with specialized knowledge or experience in a matter
6 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
7 expert witness or as a consultant in this Action.
8 2.8 House Counsel: attorneys who are employees of a party to this Action.
9 House Counsel does not include Outside Counsel of Record or any other outside
10 counsel.
11 2.9 Non-Party: any natural person, partnership, corporation, association or
12 other legal entity not named as a Party to this action.
13 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
14 this Action but are retained to represent or advise a party to this Action and have
15 appeared in this Action on behalf of that party or are affiliated with a law firm that has
16 appeared on behalf of that party, and includes support staff.
17 2.11 Party: any party to this Action, including all of its officers, directors,
18 employees, consultants, retained experts, and Outside Counsel of Record (and their
19 support staffs).
20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
21 Discovery Material in this Action.
22 2.13 Professional Vendors: persons or entities that provide litigation support
23 services (e.g., photocopying, videotaping, translating, preparing exhibits or
24 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
25 their employees and subcontractors.
26 2.14 Protected Material: any Disclosure or Discovery Material that is
27 designated as “CONFIDENTIAL.”
28 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
2 3. SCOPE
3 The protections conferred by this Stipulation and Order cover not only Protected
4 Material (as defined above), but also (1) any information copied or extracted from
5 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
6 Material; and (3) any testimony, conversations, or presentations by Parties or their
7 Counsel that might reveal Protected Material.
8 Any use of Protected Material at trial shall be governed by the orders of the trial
9 judge. This Order does not govern the use of Protected Material at trial.
10 4. DURATION
11 Once a case proceeds to trial, information that was designated as
12 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as
13 an exhibit at trial becomes public and will be presumptively available to all members
14 of the public, including the press, unless compelling reasons supported by specific
15 factual findings to proceed otherwise are made to the trial judge in advance of the trial.
16 See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
17 documents produced in discovery from “compelling reasons” standard when merits-
18 related documents are part of court record). Accordingly, the terms of this protective
19 order do not extend beyond the commencement of the trial.
20 5. DESIGNATING PROTECTED MATERIAL
21 5.1 Exercise of Restraint and Care in Designating Material for Protection.
22 Each Party or Non-Party that designates information or items for protection under this
23 Order must take care to limit any such designation to specific material that qualifies
24 under the appropriate standards. The Designating Party must designate for protection
25 only those parts of material, documents, items or oral or written communications that
26 qualify so that other portions of the material, documents, items or communications for
27 which protection is not warranted are not swept unjustifiably within the ambit of this
28 Order.
2 are shown to be clearly unjustified or that have been made for an improper purpose
3 (e.g., to unnecessarily encumber the case development process or to impose
4 unnecessary expenses and burdens on other parties) may expose the Designating Party
5 to sanctions.
6 If it comes to a Designating Party’s attention that information or items that it
7 designated for protection do not qualify for protection, that Designating Party must
8 promptly notify all other Parties that it is withdrawing the inapplicable designation.
9 5.2 Manner and Timing of Designations. Except as otherwise provided in this
10 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
11 or ordered, Disclosure or Discovery Material that qualifies for protection under this
12 Order must be clearly so designated before the material is disclosed or produced.
13 Designation in conformity with this Order requires:
14 (a) for information in documentary form (e.g., paper or electronic
15 documents, but excluding transcripts of depositions or other pretrial or trial
16 proceedings), that the Producing Party affix at a minimum, the legend
17 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
18 contains protected material. If only a portion of the material on a page qualifies for
19 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
20 by making appropriate markings in the margins).
21 A Party or Non-Party that makes original documents available for inspection
22 need not designate them for protection until after the inspecting Party has indicated
23 which documents it would like copied and produced. During the inspection and before
24 the designation, all of the material made available for inspection shall be deemed
25 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
26 copied and produced, the Producing Party must determine which documents, or
27 portions thereof, qualify for protection under this Order. Then, before producing the
28 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to
2 qualifies for protection, the Producing Party also must clearly identify the protected
3 portion(s) (e.g., by making appropriate markings in the margins).
4 (b) for testimony given in depositions that the Designating Party identifies
5 the Disclosure or Discovery Material on the record, before the close of the deposition
6 all protected testimony.
7 (c) for information produced in some form other than documentary and
8 for any other tangible items, that the Producing Party affix in a prominent place on the
9 exterior of the container or containers in which the information is stored the legend
10 “CONFIDENTIAL.” If only a portion or portions of the information warrants
11 protection, the Producing Party, to the extent practicable, shall identify the protected
12 portion(s).
13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
14 failure to designate qualified information or items does not, standing alone, waive the
15 Designating Party’s right to secure protection under this Order for such material. Upon
16 timely correction of a designation, the Receiving Party must make reasonable efforts to
17 assure that the material is treated in accordance with the provisions of this Order.
18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
20 designation of confidentiality at any time that is consistent with the Court’s Scheduling
21 Order.
22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
23 resolution process under Local Rule 37-1 et seq.
24 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
25 stipulation pursuant to Local Rule 37-2.
26 6.4 The burden of persuasion in any such challenge proceeding shall be on the
27 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
28 to harass or impose unnecessary expenses and burdens on other parties) may expose
2 withdrawn the confidentiality designation, all parties shall continue to afford the
3 material in question the level of protection to which it is entitled under the Producing
4 Party’s designation until the Court rules on the challenge.
5 7. ACCESS TO AND USE OF PROTECTED MATERIAL
6 7.1 Basic Principles. A Receiving Party may use Protected Material that is
7 disclosed or produced by another Party or by a Non-Party in connection with this
8 Action only for prosecuting, defending or attempting to settle this Action. Such
9 Protected Material may be disclosed only to the categories of persons and under the
10 conditions described in this Order. When the Action has been terminated, a Receiving
11 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
12 Protected Material must be stored and maintained by a Receiving Party at a
13 location and in a secure manner that ensures that access is limited to the persons
14 authorized under this Order.
15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
16 ordered by the court or permitted in writing by the Designating Party, a Receiving
17 Party may disclose any information or item designated “CONFIDENTIAL” only to:
18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
19 well as employees of said Outside Counsel of Record to whom it is reasonably
20 necessary to disclose the information for this Action;
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22 (b) the officers, directors, and employees (including House Counsel) of
23 the Receiving Party to whom disclosure is reasonably necessary for this Action;
24 (c) Experts (as defined in this Order) of the Receiving Party to whom
25 disclosure is reasonably necessary for this Action and who have signed the
26 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (d) the court and its personnel;
28 (e) court reporters and their staff;
2 Vendors to whom disclosure is reasonably necessary for this Action and who have
3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (g) the author or recipient of a document containing the information or a
5 custodian or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses, and attorneys for witnesses, in the
7 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
8 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
9 not be permitted to keep any confidential information unless they sign the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
11 by the Designating Party or ordered by the court. Pages of transcribed deposition
12 testimony or exhibits to depositions that reveal Protected Material may be separately
13 bound by the court reporter and may not be disclosed to anyone except as permitted
14 under this Stipulated Protective Order; and
15 (i) any mediator or settlement officer, and their supporting personnel,
16 mutually agreed upon by any of the parties engaged in settlement discussions.
17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
18 OTHER LITIGATION
19 If a Party is served with a subpoena or a court order issued in other litigation that
20 compels disclosure of any information or items designated in this Action as
21 “CONFIDENTIAL,” that Party must:
22 (a) promptly notify in writing the Designating Party. Such notification shall
23 include a copy of the subpoena or court order;
24 (b) promptly notify in writing the party who caused the subpoena or order to
25 issue in the other litigation that some or all of the material covered by the subpoena or
26 order is subject to this Protective Order. Such notification shall include a copy of this
27 Stipulated Protective Order; and
28 (c) cooperate with respect to all reasonable procedures sought to be pursued by
2 If the Designating Party timely seeks a protective order, the Party served with
3 the subpoena or court order shall not produce any information designated in this action
4 as “CONFIDENTIAL” before a determination by the court from which the subpoena
5 or order issued, unless the Party has obtained the Designating Party’s permission. The
6 Designating Party shall bear the burden and expense of seeking protection in that court
7 of its confidential material and nothing in these provisions should be construed as
8 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
9 directive from another court.
10 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
11 PRODUCED IN THIS LITIGATION
12 (a) The terms of this Order are applicable to information produced by a Non-
13 Party in this Action and designated as “CONFIDENTIAL.” Such information
14 produced by Non-Parties in connection with this litigation is protected by the remedies
15 and relief provided by this Order. Nothing in these provisions should be construed as
16 prohibiting a Non-Party from seeking additional protections.
17 (b) In the event that a Party is required, by a valid discovery request, to produce
18 a Non-Party’s confidential information in its possession, and the Party is subject to an
19 agreement with the Non-Party not to produce the Non-Party’s confidential information,
20 then the Party shall:
21 (1) promptly notify in writing the Requesting Party and the Non-Party that
22 some or all of the information requested is subject to a confidentiality agreement with
23 a Non-Party;
24 (2) promptly provide the Non-Party with a copy of the Stipulated
25 Protective Order in this Action, the relevant discovery request(s), and a reasonably
26 specific description of the information requested; and
27 (3) make the information requested available for inspection by the Non-
28 Party, if requested.
2 days of receiving the notice and accompanying information, the Receiving Party may
3 produce the Non-Party’s confidential information responsive to the discovery request.
4 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
5 any information in its possession or control that is subject to the confidentiality
6 agreement with the Non-Party before a determination by the court. Absent a court
7 order to the contrary, the Non-Party shall bear the burden and expense of seeking
8 protection in this court of its Protected Material.
9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
11 Protected Material to any person or in any circumstance not authorized under this
12 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
13 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
14 all unauthorized copies of the Protected Material, (c) inform the person or persons to
15 whom unauthorized disclosures were made of all the terms of this Order, and (d)
16 request such person or persons to execute the “Acknowledgment and Agreement to Be
17 Bound” that is attached hereto as Exhibit A.
18 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
19 PROTECTED MATERIAL
20 When a Producing Party gives notice to Receiving Parties that certain
21 inadvertently produced material is subject to a claim of privilege or other protection,
22 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
23 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
24 may be established in an e-discovery order that provides for production without prior
25 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
26 parties reach an agreement on the effect of disclosure of a communication or
27 information covered by the attorney-client privilege or work product protection, the
28 parties may incorporate their agreement in the stipulated protective order submitted to
2 12. MISCELLANEOUS
3 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
4 person to seek its modification by the Court in the future.
5 12.2 Right to Assert Other Objections. By stipulating to the entry of this
6 Protective Order, no Party waives any right it otherwise would have to object to
7 disclosing or producing any information or item on any ground not addressed in this
8 Stipulated Protective Order. Similarly, no Party waives any right to object on any
9 ground to use in evidence of any of the material covered by this Protective Order.
10 12.3 Filing Protected Material. A Party that seeks to file under seal any
11 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
12 only be filed under seal pursuant to a court order authorizing the sealing of the specific
13 Protected Material at issue. If a Party’s request to file Protected Material under seal is
14 denied by the court, then the Receiving Party may file the information in the public
15 record unless otherwise instructed by the court.
16 13. FINAL DISPOSITION
17 After the final disposition of this Action, as defined in paragraph 4, within 60
18 days of a written request by the Designating Party, each Receiving Party must return
19 all Protected Material to the Producing Party or destroy such material. As used in this
20 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
21 summaries, and any other format reproducing or capturing any of the Protected
22 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
23 must submit a written certification to the Producing Party (and, if not the same person
24 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
25 category, where appropriate) all the Protected Material that was returned or destroyed
26 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
27 compilations, summaries or any other format reproducing or capturing any of the
28 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
2 legal memoranda, correspondence, deposition and trial exhibits, expert reports,
3 attorney work product, and consultant and expert work product, even if such materials
4 contain Protected Material. Any such archival copies that contain or constitute
5 Protected Material remain subject to this Protective Order as set forth in Section 4
6 (DURATION).
7 14. VIOLATION
8 Any violation of this Order may be punished by appropriate measures including,
9 without limitation, contempt proceedings and/or monetary sanctions.
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11 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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Dated: February 20, 2020 LTL ATTORNEYS LLP
14
15 By: /s/ Vincent M. Pollmeier
16 LTL ATTORNEYS LLP
Vincent M. Pollmeier (SBN 210684)
17
vincent.pollmeier@ltlattorneys.com
18 Kevin Bringuel (SBN 196279)
Kevin.Bringuel@ltlattorneys.com
19
300 South Grand Ave., 14th Floor
20 Los Angeles, CA 90071
Tel: 213-612-8900
21
Fax: 213-612-3773
22
Attorneys for Plaintiff
23
MSC.SOFTWARE CORPORATION
24

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26 By: /s/ Keith G. Adams
Keith G. Adams (SBN 240497)
27
Kadams@mpbf.com
28 Jeff C. Hsu (SBN 267132)
JHsu@mpbf.com
1
MURPHY, PEARSON, BRADLEY & FEENEY
2 550 S. Hope St., Suite 650
3 Los Angeles, CA 90071
Telephone: (213) 327-3500
4 Facsimile: (213) 627-2445
5
Michael A. Roberts (admitted pro hac vice)
6 MRoberts @ graydonlaw.com
7 GRAYDON HEAD & RITCHEY LLP
312 Walnut St., Suite 1800
8 Cincinnati, OH 45202
9 Telephone: (513) 629-2799
Facsimile: (513) 333-4330
10
11
Attorneys for Plaintiff,
12 HEROUX-DEVTEK, Inc.
13
14 I hereby attest that all signatories listed above, and on whose behalf the filing is
15 || submitted, concur in the filing’s content and have authorized the filing.
16
17 || Dated: February 20, 2020 LTL ATTORNEYS LLP
18
19 By:__/s/ Vincent M. Pollmeier
LTL ATTORNEYS LLP
20
*! || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
| DATED: March 2, 2020
23
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, Hon. Douglas F. McCormick
United States Magistrate Judge
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2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, __________________________________________ [print or type full name],
4 of _______________________________ [print or type full address], declare under
5 penalty of perjury that I have read in its entirety and understand the Stipulated
6 Protective Order that was issued by the United States District Court for the Central
7 District of California on _________ in the case of MSC.SOFTWARE
8 CORPORATION v. HÉROUX-DEVTEK, INC., Case No. 8:19-cv-01987-JVS-DFM.
9 I agree to comply with and to be bound by all the terms of this Stipulated Protective
10 Order and I understand and acknowledge that failure to so comply could expose me to
11 sanctions and punishment in the nature of contempt. I solemnly promise that I will not
12 disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the provisions
14 of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for
16 the Central District of California for enforcing the terms of this Stipulated Protective
17 Order, even if such enforcement proceedings occur after termination of this action.
18 I hereby appoint _____________________________________ [print or type
19 full name] of ______________________________________________________ [print
20 or type full address and telephone number] as my California agent for service of
21 process in connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23
24 Date: __________________________________
25 City and State where sworn and signed:
26 ______________________________________
27 Printed name _________________________________________
28 Signature: ___________________________________________
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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10037160. Public record. Not legal advice.