distinguishing 20 || “good cause” showing for sealing documents produced in discovery from “compelling 21 || reasons” standard when merits-related documents are part of court record
How later courts described this case
- distinguishing 20 || “good cause” showing for sealing documents produced in discovery from “compelling 21 || reasons” standard when merits-related documents are part of court record
Written by the judges who cited it.
The opinion
1 | ANTHONY K. MCCLAREN, Bar No. 232515
akm@ mlegal.law
2 || TAR 6 I. BOULAD, Bar No. 330965
tib@pmiegal law
3 || PERLEBERG MCCLAREN LLP
3415 South Sepulveda Blvd., Suite 1100
4 || Los Angeles, California 90034
Telephone: 323.741.6500
5 || Facsimile: 323.426.2405
6 || Attorneys for Plaintiff
7 JOHN MARTINEZ
8 || JON C. YONEMITSU, Bar No. 199026
{ygnemitsu@ hitler com
9 ARA ADELLE RITTER COLE, Bar No. 306515
kcole@littler.com
10 | LITTCER MENDELSON, P.C.
501 W. Broadway, Suite 900
Il || San Diego, CA 92101.3577
Telephone: 619.232.0441
12 || Facsimile: 619.232.4302
13 || Attorneys for Defendant
14 TROJAN BATTERY COMPANY, LLC
15 UNITED STATES DISTRICT COURT
16 CENTRAL DISTRICT OF CALIFORNIA
17 WESTERN DIVISION
18 || JOHN MARTINEZ, an individual, Case No. 2:21-CV-00436-DSF (ASx)
19 Plaintiff, PROTECTIVE ORDER
20 || y.
21 || TROJAN BATTERY COMPANY,
9 || LLC, a Delaware Limited Liability
Company, and DOES 1-25, inclusive,
23 Defendant.
24
25
26
27
28
1.
1 || 1. INTRODUCTION
2 A. PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential,
4 || proprietary, or private information for which special protection from public disclosure
5 || and from use for any purpose other than prosecuting this litigation may be warranted.
6 || Accordingly, the parties hereby stipulate to and petition the Court to enter the following
7 || Stipulated Protective Order. The parties acknowledge that this Order does not confer
8 || blanket protections on all disclosures or responses to discovery and that the protection
9 || it affords from public disclosure and use extends only to the limited information or items
10 || that are entitled to confidential treatment under the applicable legal principles. The
11 || parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated
12 || Protective Order does not entitle them to file confidential information under seal; Civil
13 || Local Rule 79-5 sets forth the procedures that must be followed and the standards that
14 || will be applied when a party seeks permission from the court to file material under seal.
15 B. GOOD CAUSE STATEMENT
16 This action involves whistleblower retaliation and wrongful termination claims
17 || arising from workplace safety policies, regulations and operations, including those
18 || surrounding the COVID-19 pandemic and is therefore likely to involve trade secrets,
19 || customer and pricing lists and other valuable research, development, commercial,
20 || financial, technical and/or proprietary information for which special protection from
21 || public disclosure and from use for any purpose other than prosecution of this action
22 || is warranted. Such confidential and proprietary materials and information is anticipated
23 || to include, among other things, potential discovery and disclosure of confidential
24 || personal, medical and/or employment information associated with exposure and/or
25 || infection rate(s) as well as confidential communications with regulatory agencies
26 || regarding safety protocols and implementation of preventative measures contingent on
27 || proprietary business operations and practices.
28° ///
2.
Such confidential and private information is otherwise generally unavailable to
2 || the public and/or is privileged or otherwise protected from disclosure under state or
3 || federal statutes, court rules, case decisions, or common law. Disclosure of the foregoing
4 || confidential information to the public without proper protection will result in serious
5 || violation of privacy of third parties and may lead to misuse of such information.
6 || Accordingly, to expedite the flow of information, to facilitate the prompt resolution of
7 || disputes over confidentiality of discovery materials, to adequately protect information
8 || the parties are entitled to keep confidential, to ensure that the parties are permitted
9 || reasonable necessary uses of such material in preparation for and in the conduct of trial,
10 || to address their handling at the end of the litigation, and serve the ends of justice, a
11 || protective order for such information is justified in this matter. It is the intent of the
12 || parties that information will not be designated as confidential for tactical reasons and
13 || that nothing be so designated without a good faith belief that it has been maintained in
14 || aconfidential, non-public manner, and there is good cause why it should not be part of
15 || the public record of this case.
16 |] 2. DEFINITIONS
17 2.1. Action: John Martinez v. Trojan Battery Company, LLC, Case No. 2:21-
18 || CV-00436-DSF-AS.
19 2.2. Challenging Party: a Party or Non-Party that challenges the designation
20 || of information or items under this Order.
21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
22 || itis generated, stored or maintained) or tangible things that qualify for protection under
23 || Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
24 || Statement
25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
26 || support staff).
27 | ///
28° ///
3.
1 2.5 Designating Party: a Party or Non-Party that designates information or
2 | items that it produces in disclosures or in responses to discovery as
3 || “CONFIDENTIAL.”
4 2.6 Disclosure or Discovery Material: all items or information, regardless of
5 || the medium or manner in which it is generated, stored, or maintained (including, among
6 || other things, testimony, transcripts, and tangible things), that are produced or generated
7 || in disclosures or responses to discovery in this matter.
8 2.7 Expert: a person with specialized knowledge or experience in a matter
9 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an
10 || expert witness or as a consultant in this Action.
11 2.8 House Counsel: attorneys who are employees of a party to this Action.
12 || House Counsel does not include Outside Counsel of Record or any other outside
13 || counsel.
14 2.9 Non-Party: any natural person, partnership, corporation, association, or
15 || other legal entity not named as a Party to this action.
16 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
17 || this Action but are retained to represent or advise a party to this Action and have
18 || appeared in this Action on behalf of that party or are affiliated with a law firm which
19 || has appeared on behalf of that party, and includes support staff.
20 2.11 Party: any party to this Action, including all of its officers, directors,
21 || employees, consultants, retained experts, and Outside Counsel of Record (and their
22 || support staffs).
23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
24 || Discovery Material in this Action.
25 2.13 Professional Vendors: persons or entities that provide litigation support
26 || services (e.g., photocopying, videotaping, translating, preparing exhibits or
27 || demonstrations, and organizing, storing, or retrieving data in any form or medium) and
28 © their employees and subcontractors.
4.
1 2.14 Protected Material: any Disclosure or Discovery Material that is
2 || designated as “CONFIDENTIAL.”
3 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
4 || from a Producing Party.
5 |} 3. SCOPE
6 The protections conferred by this Stipulation and Order cover not only Protected
7 || Material (as defined above), but also (1) any information copied or extracted from
8 || Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
9 || Material; and (3) any testimony, conversations, or presentations by Parties or their
10 || Counsel that might reveal Protected Material.
11 Any use of Protected Material at trial will be governed by the orders of the trial
12 || judge. This Order does not govern the use of Protected Material at trial.
4. DURATION
14 Once a case proceeds to trial, all of the information admitted or used during a
15 || public trial that was designated as confidential or maintained pursuant to this protective
16 || order becomes public and will be presumptively available to all members of the public,
17 || including the press, unless compelling reasons supported by specific factual findings to
18 || proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v.
19 || City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing
20 || “good cause” showing for sealing documents produced in discovery from “compelling
21 || reasons” standard when merits-related documents are part of court record).
22 || Accordingly, to the extent any material is subsequently used for or admitted during a
23 || public trial of this matter, the terms of this protective order do not extend beyond the
24 || commencement of such trial.
25 If the Action resolves prior to a public trial, even after final disposition of this
26 || litigation, the confidentiality obligations imposed by this Order will remain in effect
27 || until a Designating Party agrees otherwise in writing or a court order otherwise directs.
28 © Final disposition will be deemed to be the later of (1) dismissal of all claims and
5.
1 || defenses in this Action, with or without prejudice; and (2) final judgment herein after
2 || the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
3 || this Action, including the time limits for filing any motions or applications for extension
4 || of time pursuant to applicable law.
5 || 5. DESIGNATING PROTECTED MATERIAL
6 5.1 Exercise of Restraint and Care in Designating Material for Protection.
7 || Each Party or Non-Party that designates information or items for protection under this
8 || Order must take care to limit any such designation to specific material that qualifies
9 || under the appropriate standards. The Designating Party must designate for protection
10 || only those parts of material, documents, items, or oral or written communications that
11 || qualify so that other portions of the material, documents, items, or communications for
12 || which protection is not warranted are not swept unjustifiably within the ambit of this
13 || Order.
14 Mass, indiscriminate, or routinized designations are prohibited. Designations
15 || that are shown to be clearly unjustified or that have been made for an improper purpose
16 || (e.g., to unnecessarily encumber the case development process or to impose
17 || unnecessary expenses and burdens on other parties) may expose the Designating Party
18 || to sanctions.
19 If it comes to a Designating Party’s attention that information or items that it
20 || designated for protection do not qualify for protection, that Designating Party must
21 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
22 5.2. Manner and Timing of Designations. Except as otherwise provided in this
23 || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
24 || or ordered, Disclosure or Discovery Material that qualifies for protection under this
25 || Order must be clearly so designated before the material is disclosed or produced.
26 Designation in conformity with this Order requires:
27 (a) for information in documentary form (e.g., paper or electronic
28 © documents, but excluding transcripts of depositions or other pretrial or trial
6.
1 || proceedings), that the Producing Party affix at a minimum, the legend
2 | “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend’), to each page that
3 || contains protected material. If only a portion or portions of the material on a page
4 || qualifies for protection, the Producing Party also must clearly identify the protected
5 || portion(s) (e.g., by making appropriate markings in the margins).
6 A Party or Non-Party that makes original documents available for inspection
7 || need not designate them for protection until after the inspecting Party has indicated
8 || which documents it would like copied and produced. During the inspection and before
9 || the designation, all of the material made available for inspection will be deemed
10 || “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
11 || copied and produced, the Producing Party must determine which documents, or portions
12 || thereof, qualify for protection under this Order. Then, before producing the specified
13 || documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
14 || that contains Protected Material. If only a portion or portions of the material on a page
15 || qualifies for protection, the Producing Party also must clearly identify the protected
16 || portion(s) (e.g., by making appropriate markings in the margins).
17 (b) for testimony given in depositions that the Designating Party identify
18 || the Disclosure or Discovery Material on the record, before the close of the deposition
19 || all protected testimony.
20 (c) for information produced in some form other than documentary and
21 || for any other tangible items, that the Producing Party affix in a prominent place on the
22 || exterior of the container or containers in which the information is stored the legend
23 || “CONFIDENTIAL.” If only a portion or portions of the information warrants
24 || protection, the Producing Party, to the extent practicable, will identify the protected
25 || portion(s).
26 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent
27 || failure to designate qualified information or items does not, standing alone, waive the
28 Designating Party’s right to secure protection under this Order for such material. Upon
7.
1 || timely correction of a designation, the Receiving Party must make reasonable efforts to
2 || assure that the material is treated in accordance with the provisions of this Order.
3 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
5 || designation of confidentiality at any time that is consistent with the Court’s Scheduling
6 || Order.
7 6.2 Meetand Confer. The Challenging Party shall initiate the informal dispute
8 || resolution process set forth in the Court's Procedures and Schedules. see
9 || http://www.cacd.uscourts.gov/honorable-alka-sagar
10 6.3. The burden of persuasion in any such challenge proceeding will be on the
11 || Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
12 || to harass or impose unnecessary expenses and burdens on other parties) may expose the
13 || Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
14 || the confidentiality designation, all parties will continue to afford the material in question
15 || the level of protection to which it is entitled under the Producing Party’s designation
16 || until the Court rules on the challenge.
17 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL
18 7.1. Basic Principles. A Receiving Party may use Protected Material that is
19 || disclosed or produced by another Party or by a Non-Party in connection with this Action
20 || only for prosecuting, defending, or attempting to settle this Action. Such Protected
21 || Material may be disclosed only to the categories of persons and under the conditions
22 || described in this Order. When the Action has been terminated, a Receiving Party must
23 || comply with the provisions of section 13 below (FINAL DISPOSITION).
24 Protected Material must be stored and maintained by a Receiving Party at a
25 || location and in a secure manner that ensures that access is limited to the persons
26 || authorized under this Order.
27 | ///
28° ///
8.
1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
2 || ordered by the court or permitted in writing by the Designating Party, a Receiving Party
3 || may disclose any information or item designated “CONFIDENTIAL” only to:
4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
5 || well as employees of said Outside Counsel of Record to whom it is reasonably
6 || necessary to disclose the information for this Action;
7 (b) the officers, directors, and employees (including House Counsel) of
8 || the Receiving Party to whom disclosure is reasonably necessary for this Action;
9 (c) Experts (as defined in this Order) of the Receiving Party to whom
10 || disclosure is reasonably necessary for this Action and who have signed the
11 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (d) the Court and its personnel;
13 (e) court reporters and their staff;
14 (f) professional jury or trial consultants, mock jurors, and Professional
15 || Vendors to whom disclosure is reasonably necessary for this Action and who have
16 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (g) the author or recipient of a document containing the information or a
18 || custodian or other person who otherwise possessed or knew the information;
19 (h) during their depositions, witnesses ,and attorneys for witnesses, in the
20 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party
21 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
22 || not be permitted to keep any confidential information unless they sign the
23 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
24 || by the Designating Party or ordered by the court. Pages of transcribed deposition
25 || testimony or exhibits to depositions that reveal Protected Material may be separately
26 || bound by the court reporter and may not be disclosed to anyone except as permitted
27 || under this Stipulated Protective Order; and
28° ///
9.
(i) any mediator or settlement officer, and their supporting personnel,
2 || mutually agreed upon by any of the parties engaged in settlement discussions.
3 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
4 OTHER LITIGATION
5 If a Party is served with a subpoena or a court order issued in other litigation that
6 || compels disclosure of any information or items designated in this Action as
7 || “CONFIDENTIAL,” that Party must:
8 (a) promptly notify in writing the Designating Party. Such notification will
9 || include a copy of the subpoena or court order;
10 (b) promptly notify in writing the party who caused the subpoena or order
11 || to issue in the other litigation that some or all of the material covered by the subpoena
12 || or order is subject to this Protective Order. Such notification will include a copy of this
13 || Stipulated Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to be
15 || pursued by the Designating Party whose Protected Material may be affected.
16 If the Designating Party timely seeks a protective order, the Party served with the
17 || subpoena or court order will not produce any information designated in this action as
18 || “CONFIDENTIAL” before a determination by the court from which the subpoena or
19 || order issued, unless the Party has obtained the Designating Party’s permission. The
20 || Designating Party will bear the burden and expense of seeking protection in that court
21 || of its confidential material and nothing in these provisions should be construed as
22 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
23 || from another court.
24 || 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
25 IN THIS LITIGATION
26 (a) The terms of this Order are applicable to information produced by a
27 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
28 © produced by Non-Parties in connection with this litigation is protected by the remedies
10.
1 || and relief provided by this Order. Nothing in these provisions should be construed as
2 || prohibiting a Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to
4 || produce a Non-Party’s confidential information in its possession, and the Party is
5 || subject to an agreement with the Non-Party not to produce the Non-Party’s confidential
6 || information, then the Party will:
7 (1) promptly notify in writing the Requesting Party and the Non-
8 || Party that some or all of the information requested is subject to a confidentiality
9 || agreement with a Non-Party;
10 (2) promptly provide the Non-Party with a copy of the Stipulated
11 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
12 || specific description of the information requested; and
13 (3) make the information requested available for inspection by the
14 || Non-Party, if requested.
15 (c) If the Non-Party fails to seek a protective order from this court within
16 || 14 days of receiving the notice and accompanying information, the Receiving Party may
17 || produce the Non-Party’s confidential information responsive to the discovery request.
18 || If the Non-Party timely seeks a protective order, the Receiving Party will not produce
19 || any information in its possession or control that is subject to the confidentiality
20 || agreement with the Non-Party before a determination by the court. Absent a court
21 || order to the contrary, the Non-Party will bear the burden and expense of seeking
22 || protection in this court of its Protected Material.
23 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
25 || Protected Material to any person or in any circumstance not authorized under this
26 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
27 || the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
28 all unauthorized copies of the Protected Material, (c) inform the person or persons to
11.
1 || whom unauthorized disclosures were made of all the terms of this Order, and (d) request
2 || such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
3 || that is attached hereto as Exhibit A.
4] 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL
6 When a Producing Party gives notice to Receiving Parties that certain
7 || inadvertently produced material is subject to a claim of privilege or other protection,
8 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
9 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
10 || may be established in an e-discovery order that provides for production without prior
11 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
12 || parties reach an agreement on the effect of disclosure of a communication or
13 || information covered by the attorney-client privilege or work product protection, the
14 || parties may incorporate their agreement in the stipulated protective order submitted to
15 || the court.
16 |} 12. MISCELLANEOUS
17 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
18 || person to seek its modification by the Court in the future.
19 12.2 Right to Assert Other Objections. By stipulating to the entry of this
20 || Protective Order no Party waives any right it otherwise would have to object to
21 || disclosing or producing any information or item on any ground not addressed in this
22 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
23 || ground to use in evidence of any of the material covered by this Protective Order.
24 12.3 Filing Protected Material. A Party that seeks to file under seal any
25 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may
26 || only be filed under seal pursuant to a court order authorizing the sealing of the specific
27 || Protected Material at issue. If a Party's request to file Protected Material under seal is
28° ///
12.
1 || denied by the court, then the Receiving Party may file the information in the public
2 || record unless otherwise instructed by the court.
3 || 13. FINAL DISPOSITION
4 After the final disposition of this Action, as defined in paragraph 4, within 60
5 || days of a written request by the Designating Party, each Receiving Party must return all
6 || Protected Material to the Producing Party or destroy such material. As used in this
7 || subdivision, “all Protected Material” includes all copies, abstracts, compilations,
8 || summaries, and any other format reproducing or capturing any of the Protected
9 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party
10 || must submit a written certification to the Producing Party (and, if not the same person
11 || or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
12 || category, where appropriate) all the Protected Material that was returned or destroyed
13 || and (2) affirms that the Receiving Party has not retained any copies, abstracts,
14 || compilations, summaries or any other format reproducing or capturing any of the
15 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
16 || archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
17 || legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
18 || work product, and consultant and expert work product, even if such materials contain
19 || Protected Material. Any such archival copies that contain or constitute Protected
20 || Material remain subject to this Protective Order as set forth in Section 4 (DURATION).
21 || 14. Any willful violation of this Order may be punished by any and all appropriate
22 || measures including, without limitation, contempt proceedings and/or monetary
23 | ///
24 | ///
25 | ///
26 | ///
27 | ///
///
13.
1 || sanctions, evidentiary sanctions, reference to disciplinary authorities, or other
2 || appropriate action at the discretion of the Court.
3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
4
5 || Dated: June 15, 2021
6 /s/ Anthony K. McClaren
Anthony K. McClaren
7 Tariq I. Boulad
PERLEBERG MCCLAREN LLP
8 Attorneys for Plaintiff
9 JOHN MARTINEZ
10 || Dated: June 15, 2021
11
12 /s/ Kara A. Cole
Jon C. Yonemitsu
13 Kara A. Cole
LITTLER MENDELSON, P.C.
14 Attorneys for Defendant
5 TROJAN BATTERY COMPANY, LLC
16 FILER ATTESTATION
17 Pursuant to Local Rule 5-4.3.4(a)(2) I hereby attest that all other signatories
18 || listed, and on whose behalf the filing is submitted, concur in the filing’s content and
19 || have authorized the filing.
20 || Dated: June 15, 2021
21 /s/ Kara A. Cole
Kara A. Cole
22
23 || FOR GOOD CAUSE SHOWN, IT IS SOORDERED.
24 || DATED: _ June 16, 2021
25
96 |) —___/s/Sagar
Honorable Alka Sagar
27 || United States Magistrate Judge
28
14,
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [print or type full name], of
4 [print or type full address], declare under penalty
5 || of perjury that I have read in its entirety and understand the Stipulated Protective Order
6 || that was issued by the United States District Court for the Central District of California
7 || on [date] in the case of John Martinez v. Trojan Battery Company, LLC,
8 || Case No. 2:21-CV-00436-DSF-AS. I agree to comply with and to be bound by all the
9 || terms of this Stipulated Protective Order and I understand and acknowledge that failure
10 || to so comply could expose me to sanctions and punishment in the nature of contempt. I
11 || solemnly promise that I will not disclose in any manner any information or item that is
12 || subject to this Stipulated Protective Order to any person or entity except in strict
13 || compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court for
15 || the Central District of California for the purpose of enforcing the terms of this Stipulated
16 || Protective Order, even if such enforcement proceedings occur after termination of this
17 || action. I hereby appoint [print or type full name] of
18 [print or type full address and
19 || telephone number] as my California agent for service of process in connection with
20 || this action or any proceedings related to enforcement of this Stipulated Protective Order.
21 || Date:
22 || City and State where signed:
23 || Printed name:
24
25 || Signature:
26
27
28
15.