# Knature Co., Inc. v. Duc Heung Group, Inc.

> District Court, C.D. California · September 1, 2020

URL: https://www.frixlaw.com/law-library/cases/10038908

## Case

- **Court:** District Court, C.D. California
- **Decided:** September 1, 2020
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 Dale J. Park (SBN 136158)
LAW OFFICES OF DALE J. PARK
2 3333 Wilshire Boulevard, Suite 320
Los Angeles, CA 90010
3
TEL (213) 389-5900
4 FAX (213) 383-7758
EMAIL: daleparklawyer@gmail.com
5
Attorneys for Defendants
6 DUC HEUNG GROUP, INC., JUSTIN BAEK and STEVE BAEK

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10

11 KNATURE CO., INC., ) Case No: 2:20-cv-03877-DMG-AFM
)
12 Plaintiff, )
13 Vs. ) ) [ Pp Rro Op To Ese Cd T] IS VT EIP OU RL DA ET RE 1D
14 DUC HEUNG GROUP, INC., a California ) )
15 C JUo Srp To Ir Nat i Bo An, E d Kb ,a aJ nB i nIN diT vE idR uN alA ; ST TIO EVN EA L; ) )
16 B AEK, an individual; et al. ) )
17 Defendants. )
)
18 )

19
20
1. A. PURPOSES AND LIMITATIONS
21 Discovery in this action is likely to involve production of confidential, proprietary
22 or private information for which special protection from public disclosure and from use for
23 any purpose other than prosecuting this litigation may be warranted. Accordingly, the
24

25 __________________________
26
1 This Stipulated Protective Order is based substantially on the model
27
protective order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures.
28

1
1 pparties hereby stipulate to and petition the Court to enter the following Stipulated
2 Protective Order. The parties acknowledge that this Order does not confer blanket
3
__________________________
4
1 This Stipulated Protective Order is based substantially on the model
5
protective order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures.
6
7 protections on all disclosures or responses to discovery and that the protection it affords
8 from public disclosure and use extends only to the limited information or items that are
9 entitled to confidential treatment under the applicable legal principles.
10 B. GOOD CAUSE STATEMENT
11
This action is likely to involve trade secrets, customer and pricing lists and other
12
valuable research, development, commercial, financial, technical and/or proprietary
13
information for which special protection from public disclosure and from use for any
14
purpose other than prosecution of this action is warranted. Such confidential and
15
proprietary materials and information consist of, among other things, confidential business
16
or financial information, information regarding confidential business practices, or other
17
confidential research, development, or commercial information (including information
18
implicating privacy rights of third parties), information otherwise generally unavailable to
19
the public, or which may be privileged or otherwise protected from disclosure under state
20
or federal statutes, court rules, case decisions, or common law. Accordingly, to expedite
21
the flow of information, to facilitate the prompt resolution of disputes over confidentiality
22
of discovery materials, to adequately protect information the parties are entitled to keep
23
confidential, to ensure that the parties are permitted reasonable necessary uses of such
24
material in preparation for and in the conduct of trial, to address their handling at the end
25
of the litigation, and serve the ends of justice, a protective order for such information is
26
justified in this matter. It is the intent of the parties that information will not be designated
27
as confidential for tactical reasons and that nothing be so designated without a good faith
28

2
1 belief that it has been maintained in a confidential, non-public manner, and there is good
2 cause why it should not be part of the public record of this case.
3
C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
4
The parties further acknowledge, as set forth in Section 12.3, below, that this
5
Stipulated Protective Order does not entitle them to file confidential information under
6
seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
7
standards that will be applied when a party seeks permission from the court to file material
8
under seal. There is a strong presumption that the public has a right of access to judicial
9
proceedings and records in civil cases. In connection with non-dispositive motions, good
10
cause must be shown to support a filing under seal. See Kamakana v. City and County of
11
Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d
12
1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577
13
(E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and a
14
specific showing of good cause or compelling reasons with proper evidentiary support and
15
legal justification, must be made with respect to Protected Material that a party seeks to
16
file under seal. The parties’ mere designation of Disclosure or Discovery Material as
17
CONFIDENTIAL does not— without the submission of competent evidence by
18
declaration, establishing that the material sought to be filed under seal qualifies as
19
confidential, privileged, or otherwise protectable—constitute good cause.
20
21 Further, if a party requests sealing related to a dispositive motion or trial, then
22 compelling reasons, not only good cause, for the sealing must be shown, and the relief
23 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos v.
24 Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of
25 information, document, or thing sought to be filed or introduced under seal in connection
26 with a dispositive motion or trial, the party seeking protection must articulate compelling
27 reasons, supported by specific facts and legal justification, for the requested sealing order.
28 Again, competent evidence supporting the application to file documents under seal must
be provided by declaration. Any document that is not confidential, privileged, or otherwise
3
1 protectable in its entirety will not be filed under seal if the confidential portions can be
2 redacted. If documents can be redacted, then a redacted version for public viewing,
3 omitting only the confidential, privileged, or otherwise protectable portions of the
4 document, shall be filed. Any application that seeks to file documents under seal in their
5 entirety should include an explanation of why redaction is not feasible.
6
2. DEFINITIONS
7
2.1 Action: this pending federal lawsuit
8
9 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
10 information or items under this Order.
11 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is
12 generated, stored or maintained) or tangible things that qualify for protection under
13 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
14 Statement.
15
2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
16
support staff).
17
2.5 Designating Party: a Party or Non-Party that designates information or items
18
that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
19
20 2.6 Disclosure or Discovery Material: all items or information, regardless of the
21 medium or manner in which it is generated, stored, or maintained (including, among other
22 things, testimony, transcripts, and tangible things), that are produced or generated in
23 disclosures or responses to discovery in this matter.
24 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent
25 to the litigation who has been retained by a Party or its counsel to serve as an expert
26 witness or as a consultant in this Action.
27
2.8 House Counsel: attorneys who are employees of a party to this Action. House
28
Counsel does not include Outside Counsel of Record or any other outside counsel.

4
1 2.9 Non-Party: any natural person, partnership, corporation, association or other
2 legal entity not named as a Party to this action.
3
2.10 Outside Counsel of Record: attorneys who are not employees of a party to this
4
Action but are retained to represent or advise a party to this Action and have appeared in
5
this Action on behalf of that party or are affiliated with a law firm that has appeared on
6
behalf of that party, and includes support staff.
7
2.11 Party: any party to this Action, including all of its officers, directors,
8
employees, consultants, retained experts, and Outside Counsel of Record (and their
9
support staffs).
10
11 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
12 Material in this Action.
13 2.13 Professional Vendors: persons or entities that provide litigation support
14 services (e.g., photocopying, videotaping, translating, preparing exhibits or
15 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
16 their employees and subcontractors.
17
2.14 Protected Material: any Disclosure or Discovery Material that is designated as
18
“CONFIDENTIAL.”
19
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a
20
Producing Party.
21
22 3. SCOPE
23 The protections conferred by this Stipulation and Order cover not only Protected
24 Material (as defined above), but also (1) any information copied or extracted from
25 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
26 Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel
27 that might reveal Protected Material. Any use of Protected Material at trial shall be
28

5
1 governed by the orders of the trial judge. This Order does not govern the use of Protected
2 Material at trial.
3

4
4. DURATION
5
6 Once a case proceeds to trial, information that was designated as CONFIDENTIAL
7 or maintained pursuant to this protective order used or introduced as an exhibit at trial
8 becomes public and will be presumptively available to all members of the public,
9 including the press, unless compelling reasons supported by specific factual findings to
10 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana, 447
11 F.3d at 1180-81 (distinguishing “good cause” showing for sealing documents produced in
12 discovery from “compelling reasons” standard when merits-related documents are part of
13 court record). Accordingly, the terms of this protective order do not extend beyond the
14 commencement of the trial.
15 5. DESIGNATING PROTECTED MATERIAL
16
5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
17
Party or Non-Party that designates information or items for protection under this Order
18
must take care to limit any such designation to specific material that qualifies under the
19
appropriate standards. The Designating Party must designate for protection only those
20
parts of material, documents, items or oral or written communications that qualify so that
21
other portions of the material, documents, items or communications for which protection is
22
not warranted are not swept unjustifiably within the ambit of this Order.
23
Mass, indiscriminate or routinized designations are prohibited. Designations that are
24
shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
25
unnecessarily encumber the case development process or to impose unnecessary expenses
26
and burdens on other parties) may expose the Designating Party to sanctions.
27
28

6
1 If it comes to a Designating Party’s attention that information or items that it
2 designated for protection do not qualify for protection, that Designating Party must
3 promptly notify all other Parties that it is withdrawing the inapplicable designation.
4
5.2 Manner and Timing of Designations. Except as otherwise provided in this Order
5
(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
6
Disclosure or Discovery Material that qualifies for protection under this Order must be
7
clearly so designated before the material is disclosed or produced.
8
Designation in conformity with this Order requires:
9
10 (a) for information in documentary form (e.g., paper or electronic documents,
11 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
12 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
13 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
14 portion of the material on a page qualifies for protection, the Producing Party also must
15 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
16 margins).
17 (b) A Party or Non-Party that makes original documents available for inspection
18 need not designate them for protection until after the inspecting Party has indicated which
19 documents it would like copied and produced. During the inspection and before the
20 designation, all of the material made available for inspection shall be deemed
21 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
22 copied and produced, the Producing Party must determine which documents, or portions
23 thereof, qualify for protection under this Order. Then, before producing the specified
24 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
25 that contains Protected Material. If only a portion 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

7
1 (b) for testimony given in depositions that the Designating Party identifies the
2 Disclosure or Discovery Material on the record, before the close of the deposition all
3 protected testimony.
4
(c) for information produced in some form other than documentary and for any
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 is stored the legend
7
“CONFIDENTIAL.” If only a portion or portions of the information warrants protection,
8
the Producing Party, to the extent practicable, shall identify the protected portion(s).
9
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
10
designate qualified information or items does not, standing alone, waive the Designating
11
Party’s right to secure protection under this Order for such material. Upon timely
12
correction of a designation, the Receiving Party must make reasonable efforts to assure
13
that the material is treated in accordance with the provisions of this Order.
14
15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
17 confidentiality at any time that is consistent with the Court’s Scheduling Order.
18
6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
19
process under Local Rule 37-1 et seq.
20
6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
21
stipulation pursuant to Local Rule 37-2.
22
23 6.4 The burden of persuasion in any such challenge proceeding shall be on the
24 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to
25 harass or impose unnecessary expenses and burdens on other parties) may expose the
26 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the
27 confidentiality designation, all parties shall continue to afford the material in question the
28

8
1 level of protection to which it is entitled under the Producing Party’s designation until the
2 Court rules on the challenge.
3
7. ACCESS TO AND USE OF PROTECTED MATERIAL
4
7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed
5
or produced by another Party or by a Non-Party in connection with this Action only for
6
prosecuting, defending or attempting to settle this Action. Such Protected Material may be
7
disclosed only to the categories of persons and under the conditions described in this
8
Order. When the Action has been terminated, a Receiving Party must comply with the
9
provisions of section 13 below (FINAL DISPOSITION).
10
11 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 under
13 this Order.
14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
15 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
16 may 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 Action;
20
(b) the officers, directors, and employees (including House Counsel) of the
21
Receiving Party to whom disclosure is reasonably necessary for this Action;
22
23 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
24 reasonably necessary for this Action and who have signed the “Acknowledgment and
25 Agreement to Be Bound” (Exhibit A);
26 (d) the court and its personnel;
27
(e) court reporters and their staff;
28

9
1 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to
2 whom disclosure is reasonably necessary for this Action and who have signed the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4
(g) the author or recipient of a document containing the information or a custodian
5
or other person who otherwise possessed or knew the information;
6
(h) during their depositions, witnesses, and attorneys for witnesses, in the Action to
7
whom disclosure is reasonably necessary provided: (1) the deposing party requests that the
8
witness sign the form attached as Exhibit 1 hereto; and (2) they will not be permitted to
9
keep any confidential information unless they sign the “Acknowledgment and Agreement
10
to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by
11
the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal
12
Protected Material may be separately bound by the court reporter and may not be disclosed
13
to anyone except as permitted under this Stipulated Protective Order; and
14
15 (i) any mediator or settlement officer, and their supporting personnel, mutually
16 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 include
23
a copy of the subpoena or court order;
24
25 (b) promptly notify in writing the party who caused the subpoena or order to issue
26 in the other litigation that some or all of the material covered by the subpoena or order is
27 subject to this Protective Order. Such notification shall include a copy of this Stipulated
28 Protective Order; and

10
1 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
2 Designating Party whose Protected Material may be affected.
3
If the Designating Party timely seeks a protective order, the Party served with the
4
subpoena or court order shall not produce any information designated in this action as
5
“CONFIDENTIAL” before a determination by the court from which the subpoena or
6
order issued, unless the Party has obtained the Designating Party’s permission. The
7
Designating Party shall bear the burden and expense of seeking protection in that court of
8
its confidential material and nothing in these provisions should be construed as authorizing
9
or encouraging a Receiving Party in this Action to disobey a lawful directive from another
10 court.
11
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
12
IN THIS LITIGATION
13
14 (a) The terms of this Order are applicable to information produced by a Non-Party
15 in this Action and designated as “CONFIDENTIAL.” Such information produced by Non-
16 Parties in connection with this litigation is protected by the remedies and relief provided
17 by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party
18 from seeking additional protections.
19 (b) In the event that a Party is required, by a valid discovery request, to produce a
20 Non-Party’s confidential information in its possession, and the Party is subject to an
21 agreement with the Non-Party not to produce the Non-Party’s confidential information,
22 then the Party shall:
23
(1) promptly notify in writing the Requesting Party and the Non-Party that some or
24
all of the information requested is subject to a confidentiality agreement with a Non-Party;
25
(2) promptly provide the Non-Party with a copy of the Stipulated Protective Order
26
in this Action, the relevant discovery request(s), and a reasonably specific description of
27
the information requested; and
28

11
1 (3) make the information requested available for inspection by the Non-Party, if
2 requested.
3
(c) If the Non-Party fails to seek a protective order from this court within 14 days of
4
receiving the notice and accompanying information, the Receiving Party may produce the
5
Non-Party’s confidential information responsive to the discovery request. If the Non-Party
6
timely seeks a protective order, the Receiving Party shall not produce any information in
7
its possession or control that is subject to the confidentiality agreement with the Non-Party
8
before a determination by the court. Absent a court order to the contrary, the Non-Party
9
shall bear the burden and expense of seeking protection in this court of its Protected
10 Material.
11
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
12
13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
14 Protected Material to any person or in any circumstance not authorized under this
15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the
16 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all
17 unauthorized copies of the Protected Material, (c) inform the person or persons to whom
18 unauthorized disclosures were made of all the terms of this Order, and (d) request such
19 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is
20 attached hereto as Exhibit A.
21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
22 PROTECTED MATERIAL
23
When a Producing Party gives notice to Receiving Parties that certain inadvertently
24
produced material is subject to a claim of privilege or other protection, the obligations of
25
the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
26
This provision is not intended to modify whatever procedure may be established in an e-
27
discovery order that provides for production without prior privilege review. Pursuant to
28
Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the

12
1 effect of disclosure of a communication or information covered by the attorney-client
2 privilege or work product protection, the parties may incorporate their agreement in the
3 stipulated protective order submitted to the court.
4
12. MISCELLANEOUS
5
12.1 Right to Further Relief. Nothing in this Order abridges the right of any person
6
to seek its modification by the Court in the future.
7
8 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
9 Order, no Party waives any right it otherwise would have to object to disclosing or
10 producing any information or item on any ground not addressed in this Stipulated
11 Protective Order. Similarly, no Party waives any right to object on any ground to use in
12 evidence of any of the material covered by this Protective Order.
13 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
14 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed
15 under seal pursuant to a court order authorizing the sealing of the specific Protected
16 Material at issue. If a Party’s request to file Protected Material under seal is denied by the
17 court, then the Receiving Party may file the information in the public record unless
18 otherwise instructed by the court.
19
13. FINAL DISPOSITION
20
After the final disposition of this Action, as defined in paragraph 4, within 60 days
21
of a written request by the Designating Party, each Receiving Party must return all
22
Protected Material to the Producing Party or destroy such material. As used in this
23
subdivision, “all Protected Material” includes all copies, abstracts, compilations,
24
summaries, and any other format reproducing or capturing any of the Protected Material.
25
Whether the Protected Material is returned or destroyed, the Receiving Party must submit
26
a written certification to the Producing Party (and, if not the same person or entity, to the
27
Designating Party) by the 60 day deadline that (1) identifies (by category, where
28
appropriate) all the Protected Material that was returned or destroyed and (2) affirms that

13
1 the Receiving Party has not retained any copies, abstracts, compilations, summaries or any
2 other format reproducing or capturing any of the Protected Material. Notwithstanding this
3 provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers,
4 trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and
5 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
7 contain or constitute Protected Material remain subject to this Protective Order as set forth
8 in Section 4 (DURATION).
9

10

11
12 14. VIOLATION
13 Any violation of this Order may be punished by appropriate measures including,
14 without limitation, contempt proceedings and/or monetary sanctions.
15
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
16

17 Dated: August 26, 2020 LEE & ASSOCIATES, LAW OFFICE, APC
18
19 By: /s/ yong bom lee
20 Y Ao ttn og rn B eyo sm f oL re Pe, l aH iny to ifn f,g IC N. S K Ai Nm HEALING
21
22 Dated: August 26, 2020 LAW OFFICES OF DALE J. PARK
23
By:_/s/ Dale J. Park________________
24 DALE J. PARK, Attorneys for Defendants
DUC HEUNG GROUP, INC., JUSTIN BAEK
25 and STEVE BAEK

26

27
28 Dated: August 26, 2020 PARK LAW, APC

14
1 By: _/s/ Daniel M. Park
DANTEL M. PARK, Attorneys tor Defendants
2 HANNAM CHAIN USA, INC, and SUPER 1
; HANNAM, INC.
|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
5
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5 || DATED: 91/202,

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1. || HON. ALEXANDER F. MacKINNON
United States Magistrate Judge
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1 EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3

4
I, _____________________________ [print or type full name], of
5
_________________ [print or type full address], declare under penalty of perjury that I
6
have read in its entirety and understand the Stipulated Protective Order that was issued
7
by the United States District Court for the Central District of California on [date] in the
8
case of K Nature v. Duc Heung Group, Inc., et al., Case No: 2:20-cv-03877-DMG-
9
AFM.
10
I agree to comply with and to be bound by all the terms of this Stipulated
11
Protective Order and I understand and acknowledge that failure to so comply could
12
expose me to sanctions and punishment in the nature of contempt. I solemnly promise
13
that I will not disclose in any manner any information or item that is subject to this
14
Stipulated Protective Order to any person or entity except in strict compliance with the
15
provisions of this Order. I further agree to submit to the jurisdiction of the United States
16
District Court for the Central District of California for enforcing the terms of this
17
Stipulated Protective Order, even if such enforcement proceedings occur after
18
termination of this action.
19
20 I hereby appoint __________________________ [print or type full name] of
21 _______________________________________ [print or type full address and telephone
22 number] as my California agent for service of process in connection with this action or any
23 proceedings related to enforcement of this Stipulated Protective Order.
24 Date: ______________________________________
25
City and State where sworn and signed: _________________________________
26
Printed name: _______________________________
27
28 Signature: __________________________________

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1 Formatted: Space Before: 6 pt, Line spacing: Exactly
2 , IT IS SO ORDERED. 22.7 pt, Don't hyphenate, Tab stops: -0.5", Left
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4 Dated: ____________________ _________________________________
5 The Hon. Dolly M. Gee Formatted: Line spacing: single, Hyphenate, Tab stops:
United States District Judge Not at -0.5"
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Signature: __________________________________
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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10038908. Public record. Not legal advice.