distinguishing “good cause” showing for sealing 16 documents produced in discovery from “compelling reasons” standard when merits- 17 related documents are part of court record
How later courts described this case
- distinguishing “good cause” showing for sealing 16 documents produced in discovery from “compelling reasons” standard when merits- 17 related documents are part of court record
Written by the judges who cited it.
The opinion
1 GREENE, BROILLET & WHEELER LLP
2
CHRISTINE D. SPAGNOLI (SBN 126353)
CSPAGNOLI@GBW.LAW
3 222 N. PACIFIC COAST HIGHWAY, SUITE 2100
P.O. BOX 955
4 EL SEGUNDO, CA 90245
5 TEL.: (310) 576-1200 / FAX: (310) 576-1220
6 NELSON & FRAENKEL, LLP
Gretchen Nelson (SBN 112566)
7 gnelson@nflawfirm.com
Gabriel S. Barenfeld (SBN 224146)
8 gbarenfeld@nflawfirm.com
601 So. Figueroa St., Suite 2050
9 Los Angeles, CA 90017
Tel: (844) 622-6469
10 Fax: (213) 622-6019
11
[Additional Counsel on Signature Page]
12
C ounsel for Plaintiff & the Proposed Classes
13
UNITED STATES DISTRICT COURT
14
CENTRAL DISTRICT OF CALIFORNIA
15
16
MARGARET STEVENS, individually Case No.: 2:20-cv-07373-MCS(ASx)
17 and on behalf of all others similarly
situated, PROTECTIVE ORDER
18
Plaintiff, CLASS ACTION
19
20 vs.
21
BRITAX CHILD SAFETY, INC.,
22
Defendant.
23
24
25
26
27
28
1 Plaintiff Margaret Stevens and Defendant Britax Child Safety, Inc. (“Britax’’)
2 ||(together, “Parties”), by and through their undersigned attorneys of record, hereby
3 || stipulate and agree to the following terms.
4 PRELIMINARY MATTERS
5 A. Purposes and Limitations
6 Informal document exchange and discovery in this action is likely to involve
7 || production of confidential, proprietary, or private information for which special
8 || protection from public disclosure and from use for any purpose other than prosecuting
9 || this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition
10 Court to enter the following Stipulated Protective Order. The Parties agree to be
11 || bound by the terms of the Stipulated Protective Order pending Court approval. The
12 || parties acknowledge that this Order does not confer blanket protections on all disclosures
13 || or responses to discovery and that the protection it affords from public disclosure and use
14 |] extends only to the limited information or items that are entitled to confidential treatment
15 under the applicable legal principles. The parties further acknowledge, as set forth in
16 ||Section 12.3, below, that this Stipulated Protective Order does not entitle them to file
17 || confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that
18 || must be followed and the standards that will be applied when a party seeks permission
19 || from the court to file material under seal.
20 B. Good Cause Statement
21 This action 1s likely to involve trade secrets, customer and pricing lists and other
22 || valuable research, development, commercial, financial, technical and/or proprietary
23 ||information for which special protection from public disclosure and from use for any
24 || purpose other than prosecution of this action is warranted. Such confidential and
25 || proprietary materials and information consist of, among other things, confidential
26 || business or financial information, information regarding confidential business practices,
27 |/or other confidential research, development, or commercial information (including
28 information implicating privacy rights of third parties), information otherwise generally
1 unavailable to the public, or which may be privileged or otherwise protected from
2 disclosure under state or federal statutes, court rules, case decisions, or common law.
3 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of
4 disputes over confidentiality of discovery materials, to adequately protect information the
5 parties are entitled to keep confidential, to ensure that the parties are permitted reasonable
6 necessary uses of such material in preparation for and in the conduct of trial, to address
7 their handling at the end of the litigation, and serve the ends of justice, a protective order
8 for such information is justified in this matter. It is the intent of the parties that
9 information will not be designated as confidential for tactical reasons and that nothing be
10 so designated without a good faith belief that it has been maintained in a confidential,
11 non-public manner, and there is good cause why it should not be part of the public record
12 of this case.
13 2. DEFINITIONS
14 2.1 Action: this pending federal lawsuit – Margaret Stevens v. Britax Child Safety
15 Inc., Case No. 2:20-cv-07373-MCS-AS.
16 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
17 information or items under this Order.
18 2.3 “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), and as specified above in the Good Cause
21 Statement.
22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
23 support staff).
24 2.5 Designating Party: a Party or Non-Party that designates information or items
25 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
26 2.6 Disclosure or Discovery Material: all items or information, regardless of
27
28
1 the medium or manner in which it is generated, stored, or maintained (including, among
2 other things, testimony, transcripts, and tangible things), that are produced or generated in
3 disclosures or responses to discovery in this matter.
4 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent
5 to the litigation who has been retained by a Party or its counsel to serve as an expert
6 witness or as a consultant in this Action.
7 2.8 House Counsel: attorneys who are employees of a party to this Action. House
8 Counsel does not include Outside Counsel of Record or any other outside counsel.
9 2.9 Non-Party: any natural person, partnership, corporation, association, or other
10 legal entity not named as a Party to this action.
11 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this
12 Action but are retained to represent or advise a party to this Action and have appeared in
13 this Action on behalf of that party or are affiliated with a law firm which has appeared on
14 behalf of that party, and includes support staff.
15 2.11 Party: any party to this Action, including all of its officers, directors,
16 employees, consultants, retained experts, and Outside Counsel of Record (and their
17 support staffs).
18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
19 Material in this Action.
20 2.13 Professional Vendors: persons or entities that provide litigation support
21 services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
23 their employees and subcontractors.
24 2.14 Protected Material: any Disclosure or Discovery Material that is designated as
25 “CONFIDENTIAL.”
26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from
27 a Producing Party.
28
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only Protected
3 Material (as defined above), but also (1) any information copied or extracted from
4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
5 Material; and (3) any testimony, conversations, or presentations by Parties or their
6 Counsel that might reveal Protected Material. Any use of Protected Material at trial shall
7 be governed by the orders of the trial judge. This Order does not govern the use of
8 Protected Material at trial.
9 4. DURATION
10 Once a case proceeds to trial, all of the information that was designated as
11 confidential or maintained pursuant to this protective order becomes public and will be
12 presumptively available to all members of the public, including the press, unless
13 compelling reasons supported by specific factual findings to proceed otherwise are made
14 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu,
15 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing
16 documents produced in discovery from “compelling reasons” standard when merits-
17 related documents are part of court record). Accordingly, the terms of this protective
18 order do not extend beyond the commencement of the trial.
19 Even after final disposition of this litigation, the confidentiality obligations
20 imposed by this Order shall remain in effect until a Designating Party agrees otherwise in
21 writing or a court order otherwise directs. Final disposition shall be deemed to be the later
22 of (1) dismissal of all claims and defenses in this Action, with or without prejudice; and
23 (2) final judgment herein after the completion and exhaustion of all appeals, rehearings,
24 remands, trials, or reviews of this Action, including the time limits for filing any motions
25 or applications for extension of time pursuant to applicable law.
26 5. DESIGNATING PROTECTED MATERIAL
27 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
28 Party or Non-Party that designates information or items for protection under this Order
1 must take care to limit any such designation to specific material that qualifies under the
2 appropriate standards. The Designating Party must designate for protection only those
3 parts of material, documents, items, or oral or written communications that qualify so that
4 other portions of the material, documents, items, or communications for which protection
5 is not warranted are not swept unjustifiably within the ambit of this Order. Mass,
6 indiscriminate, or routinized designations are prohibited. Designations that are shown to
7 be clearly unjustified or that have been made for an improper purpose (e.g., to
8 unnecessarily encumber the case development process or to impose unnecessary expenses
9 and burdens on other parties) may expose the Designating Party to sanctions. If it comes
10 to a Designating Party’s attention that information or items that it designated for
11 protection do not qualify for protection, that Designating Party must promptly notify all
12 other Parties that it is withdrawing the inapplicable designation.
13 5.2 Manner and Timing of Designations. Except as otherwise provided in this
14 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
15 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
16 must be clearly so designated before the material is disclosed or produced. Designation in
17 conformity with this Order requires:
18 (a) for information in documentary form (e.g., paper or electronic documents, but
19 excluding transcripts of depositions or other pretrial or trial proceedings), that the
20 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
21 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
22 portion or portions of the material on a page qualifies for protection, the Producing Party
23 also must clearly identify the protected portion(s) (e.g., by making appropriate markings
24 in the margins). A Party or Non-Party that makes original documents available for
25 inspection need not designate them for protection until after the inspecting Party has
26 indicated which documents it would like copied and produced. During the inspection and
27 before the designation, all of the material made available for inspection shall be deemed
28 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
1 copied and produced, the Producing Party must determine which documents, or portions
2 thereof, qualify for protection under this Order. Then, before producing the specified
3 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
4 that contains Protected Material. If only a portion or portions of the material on a page
5 qualifies for protection, the Producing Party also must clearly identify the protected
6 portion(s) (e.g., by making appropriate markings in the margins).
7 (b) for testimony given in depositions that the Designating Party identify the
8 Disclosure or Discovery Material on the record, before the close of the deposition all
9 protected testimony.
10 (c) for information produced in some form other than documentary and for any
11 other tangible items, that the Producing Party affix in a prominent place on the exterior of
12 the container or containers in which the information is stored the legend
13 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,
14 the Producing Party, to the extent practicable, shall identify the protected portion(s).
15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
16 designate qualified information or items does not, standing alone, waive the Designating
17 Party’s right to secure protection under this Order for such material. Upon timely
18 correction of a designation, the Receiving Party must make reasonable efforts to assure
19 that the material is treated in accordance with the provisions of this Order.
20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
21 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
22 confidentiality at any time that is consistent with the Court’s Scheduling Order.
23 6.2 Meet and Confer. The Challenging Party shall initiate the informal dispute
24 resolution process set forth in the Court’s Procedures and Schedules. see
25 http://www.cacd.uscourts.gov/honorable-alka-sagar.
26 6.3 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., to
28 harass or impose unnecessary expenses and burdens on other parties) may expose the
1 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
2 the confidentiality designation, all parties shall continue to afford the material in question
3 the level of protection to which it is entitled under the Producing Party’s designation until
4 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 Action
8 only for prosecuting, defending, or attempting to settle this Action. Such Protected
9 Material may be disclosed only to the categories of persons and under the conditions
10 described in this Order. When the Action has been terminated, a Receiving Party must
11 comply with the provisions of section 13 below (FINAL DISPOSITION). Protected
12 Material must be stored and maintained by a Receiving Party at a location and in a secure
13 manner that ensures that access is limited to the persons authorized under 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 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
23 reasonably necessary for this Action and who have signed the “Acknowledgment and
24 Agreement to Be Bound” (Exhibit A);
25 (d) the court and its personnel;
26 (e) court reporters and their staff;
27
28
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
8 the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted
9 to keep any confidential information unless they sign the “Acknowledgment and
10 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party
11 or ordered by the court. Pages of transcribed deposition testimony or exhibits to
12 depositions that reveal Protected Material may be separately bound by the court reporter
13 and may not be disclosed to anyone except as permitted under this Stipulated Protective
14 Order; and
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
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 issue
25 in the other litigation that some or all of the material covered by the subpoena or order is
26 subject to this Protective Order. Such notification shall include a copy of this Stipulated
27 Protective Order; and
28
1 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
2 Designating Party whose Protected Material may be affected. If the Designating Party
3 timely seeks a protective order, the Party served with the subpoena or court order shall
4 not produce any information designated in this action as “CONFIDENTIAL” before a
5 determination by the court from which the subpoena or order issued, unless the Party has
6 obtained the Designating Party’s permission. The Designating Party shall bear the burden
7 and expense of seeking protection in that court of its confidential material and nothing in
8 these provisions should be construed as authorizing or encouraging a Receiving Party in
9 this Action to disobey a lawful directive from another court.
10 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
11 IN THIS LITIGATION
12 (a) The terms of this Order are applicable to information produced by a Non-Party
13 in this Action and designated as “CONFIDENTIAL.” Such information produced by
14 Non-Parties in connection with this litigation is protected by the remedies and relief
15 provided by this Order. Nothing in these provisions should be construed as prohibiting a
16 Non-Party from seeking additional protections.
17 (b) In the event that a Party is required, by a valid discovery request, to produce a
18 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 a
23 Non-Party;
24 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
25 Order in this Action, the relevant discovery request(s), and a reasonably specific
26 description of the information requested; and
27 (3) make the information requested available for inspection by the Non-Party, if
28 requested.
1 (c) If the Non-Party fails to seek a protective order from this court within 14 days
2 of receiving the notice and accompanying information, the Receiving Party may produce
3 the Non-Party’s confidential information responsive to the discovery
4 request. If the Non-Party timely seeks a protective order, the Receiving Party shall not
5 produce 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 order
7 to the contrary, the Non-Party shall bear the burden and expense of seeking protection in
8 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) request
16 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
17 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 inadvertently
21 produced material is subject to a claim of privilege or other protection, the obligations of
22 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
23 This provision is not intended to modify whatever procedure may be established in an e-
24 discovery order that provides for production without prior privilege review. Pursuant to
25 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the
26 effect of disclosure of a communication or information covered by the attorney-client
27 privilege or work product protection, the parties may incorporate their agreement in the
28 stipulated protective order submitted to the court.
1 12. MISCELLANEOUS
2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person
3 to seek its modification by the Court in the future.
4 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
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.
9 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
10 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
11 under seal pursuant to a court order authorizing the sealing of the specific Protected
12 Material at issue. If a Party’s request to file Protected Material under seal is denied by the
13 court, then the Receiving Party may file the information in the public record unless
14 otherwise instructed by the court.
15 13. FINAL DISPOSITION
16 After the final disposition of this Action, as defined in paragraph 4, within 60 days
17 of a written request by the Designating Party, each Receiving Party must return all
18 Protected Material to the Producing Party or destroy such material. As used in this
19 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
20 summaries, and any other format reproducing or capturing any of the Protected Material.
21 Whether the Protected Material is returned or destroyed, the Receiving Party must submit
22 a written certification to the Producing Party (and, if not the same person or entity, to the
23 Designating Party) by the 60 day deadline that (1) identifies (by category, where
24 appropriate) all the Protected Material that was returned or destroyed and (2)affirms that
25 the Receiving Party has not retained any copies, abstracts, compilations, summaries or
26 any other format reproducing or capturing any of the Protected Material. Notwithstanding
27 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion
28 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
1 deposition and trial exhibits, expert reports, attorney work product, and consultant and
2 expert work product, even if such materials contain Protected Material. Any such archival
3 copies that contain or constitute Protected Material remain subject to this Protective
4 Order as set forth in Section 4 (DURATION).
5 14. VIOLATION
6 Any violation of this Order may be punished by any and all appropriate measures
7 including, without limitation, contempt proceedings and/or monetary sanctions.
8 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
9
10
DATED: September 30, 2021 NELSON & FRAENKEL LLP
11
12
By: /s/ Gabriel S. Barenfeld
13
Gretchen Nelson
14 Gabriel S. Barenfeld
15
GREENE BROILLET & WHEELER LLP
16
Christine D. Spagnoli
17
LEVIN, PAPANTONIO, THOMAS,
18
MITCHELL, RAFFERTY & PROCTOR, P.A.
19 Troy A. Rafferty (PHV)
20 trafferty@levinlaw.com
316 S. Baylen St., Suite 600
21
Pensacola, FL 32502
22 Tel: (850) 435-7140
Fax: (850) 436-6140
23
24 Attorneys for Plaintiff & the Proposed Classes
25
26
27
28
1
DATED: September 30, 2021 FOLEY & LARDNER LLP
2
3
By: /s/ Erik Swanholt
4
Erik K. Swanholt (SBN 198042)
5 eswanholt@foley.com
555 South Flower Street, Suite 3300
6
Los Angeles, CA 90071-2418
7 Tel: (213) 972-4614
8
9 *Pursuant to L.R. 5-4.3.4(a)(2)(i), the undersigned attorney hereby attests that all
10 other signatories listed, and on whose behalf the filing is submitted, concur in the filing’s
11 content and have authorized the filing.
12
13 DATED: September 30, 2021 NELSON & FRAENKEL LLP
14
15
16 By: /s/ Gabriel S. Barenfeld
Gabriel S. Barenfeld
17
Attorneys Plaintiff & the Proposed Classes
18
19
ORDER
20
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21
22
DATED: September 30, 2021
23
24
25
/ s / Sagar
26 Honorable Alka Sagar
United States Magistrate Judge
27
28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND BY
3 STIPULATED PROTECTIVE ORDER, ENTERED IN THE CASE OF
4 MARGARET STEVENS, et al. v. BRITAX CHILD SAFETY, INC., U.S. DISTRICT
5 COURT CASE NO. 2:20-CV-07373-MCS-AS
6 I, _____________________________ [print or type full name], of
7 _________________ [print or type full address], declare under penalty of perjury that I
8 have read in its entirety and understand the Stipulated Protective Order that was issued by
9 the United States District Court for the Central District of California on _________ [date]
10 in the case of Margaret Stevens, et al. v. Britax Child Safety, Inc., Case No. 2:20-cv-
11 07373-MCS(ASx). I agree to comply with and to be bound by all the terms of this
12 Stipulated Protective Order and I understand and acknowledge that failure to so comply
13 could expose me to sanctions and punishment in the nature of contempt. I solemnly
14 promise that I will not disclose in any manner any information or item that is subject to
15 this Stipulated Protective Order to any person or entity except in strict compliance with
16 the provisions of this Order.
17 I further agree to submit to the jurisdiction of the United States District Court for
18 the Central District of California in the case of Margaret Stevens, et al. v. Britax Child
19 Safety, Inc., Case No. 2:20-cv-07373-MCS(ASx), for the purpose of enforcing the terms
20 of this Stipulated Protective Order, even if such enforcement proceedings occur after
21 termination of this action. I hereby appoint __________________________ [print or type
22 full name] of _______________________________________ [print or type full address
23 and telephone number] as my California agent for service of process in connection with
24 this action or any proceedings related to enforcement of this Stipulated Protective Order.
25 Date: ______________________________________
26 City and State where sworn and signed: ________________________________
27 Printed name: _______________________________
28 Signature: __________________________________