Sascha B. Koch v. City of Los Angeles

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UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

10 SASCHA B. KOCH, individual,

Case No. 2:23-cv-07714-CAS-PD

Plaintiff,

12 STIPULATED PROTECTIVE

V. ORDER

4 CITY OF LOS ANGELES, et al. (PD Version)

15 Defendant. CO Check if submitted without material

modifications to PD form

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18 |] 1. INTRODUCTION

19 1.1 PURPOSES AND LIMITATIONS

20 Discovery in this action is likely to involve production of confidentiz

21 || proprietary, or private information for which special protection from public □□□□□□□□□

22 || and from use for any purpose other than prosecuting this litigation may be warrante

23 || Accordingly, the parties hereby stipulate to and petition the Court to enter the followir

24 || Stipulated Protective Order. The parties acknowledge that this Order does not conf

25 || blanket protections on all disclosures or responses to discovery and that the protectic

26 || it affords from public disclosure and use extends only to the limited information «

27 || items that are entitled to confidential treatment under the applicable legal principle

28 || The parties further acknowledge, as set forth in Section 12.3, below, that this □□□□□□□□□

1 Protective Order does not entitle them to file confidential information under seal; Civil

2 Local Rule 79-5 sets forth the procedures that must be followed and the standards that

3 will be applied when a party seeks permission from the court to file material under seal.

4 1.2 GOOD CAUSE STATEMENT

5 This action involves the City of Los Angeles (the “City”) and members of the

6 City’s Los Angeles Police Department (“LAPD”) including Laura Brinkman, Joshua

7 Towe and Manuel Vargas (collectively “Defendants”). The nature of the incident that

8 gives rise to Plaintiff’s suit and Plaintiff’s claims and allegations, will result in

9 discovery production that includes: police reports and evidence; investigation reports

10 and evidence; peace officer personnel materials; information implicating the privacy

11 rights of third parties (i.e., bystander witnesses, emergency personnel information);

12 and other private and confidential materials for which require special protection from

13 public disclosure.

14 Specifically, Plaintiff is seeking materials and information that Defendant(s)

15 maintain as confidential such as personnel files of the police and/or sworn officers

16 involved in this incident, Internal Affairs materials and information, video recordings,

17 audio recordings, photographs, and information and other administrative materials

18 and information currently in the possession of Defendants and which Defendants

19 believe need special protection from public disclosure and from use for any purpose

20 other than prosecuting this litigation. Plaintiff may also seek official information

21 contained in the personnel files of the police and/or sworn officers involved in the

22 subject incident, which Defendants maintain as strictly confidential and which

23 Defendants believe need special protection from public disclosure and from use for

24 any purpose other than prosecuting this litigation.

25 Defendants assert that the confidentiality of the materials and information

26 sought by Plaintiff is recognized by California and federal law, as evidenced inter alia

27 by California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D.

1 not publicly released the materials and information referenced above except under

2 protective order or pursuant to a court order, if at all. The personnel materials and

3 information are of the type that has been used to initiate disciplinary action against

4 the City’s respective employees, and has been used as evidence in disciplinary

5 proceedings, where the employee conduct was considered to be contrary to policy.

6 Defendants contend that absent a protective order delineating the

7 responsibilities of nondisclosure on the part of the parties hereto, there is a specific

8 risk of unnecessary and undue disclosure by one or more of the many attorneys,

9 secretaries, law clerks, paralegals and expert witnesses involved in this case, as well

10 as the corollary risk of embarrassment, harassment and professional and legal harm

11 on the part of the City’s employees referenced in the materials and information.

12 Defendants also contend that the unfettered disclosure of the materials and

13 information, absent a protective order, would allow the media to share this

14 information with potential jurors in the area, impacting the rights of Defendants herein

15 to receive a fair trial.

16 Accordingly, to expedite the flow of information, to facilitate the prompt

17 resolution of disputes over confidentiality of discovery materials, to adequately

18 protect information the parties are entitled to keep confidential, to ensure that the

19 parties are permitted reasonable necessary uses of such material in preparation for and

20 in the conduct of trial, to address their handling at the end of the litigation, and serve

21 the ends of justice, a protective order for such information is justified in this matter.

22 It is the intent of the parties that information will not be designated as confidential for

23 tactical reasons and that nothing be so designated without a good faith belief that it

24 has been maintained in a confidential, non-public manner, and there is good cause

25 why it should not be part of the public record of this case.

26 Plaintiff agrees that there is Good Cause for a Protective Order so as to preserve

27 the respective interests of the parties while streamlining the process of resolving any

1 The parties therefore stipulate that there is Good Cause for, and hereby jointly

2 request that the honorable Court issue a Protective Order regarding confidential

3 documents consistent with the terms and provisions of this Stipulation. However, the

4 entry of a Protective Order by the Court pursuant to this Stipulation shall not be

5 construed as any ruling by the Court on the aforementioned legal statements or

6 privilege claims in this section, no shall this section be construed as part of any such

7 Court Order.

8 2. DEFINITIONS

9 2.1 Action: Sasha Koch v. City of Los Angeles, et al. (Case No. CV-19-

10 05762-JLS-ADSx)

11 2.2 Challenging Party: a Party or Non-Party that challenges the designation

12 of information or items under this Order.

13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

14 how it is generated, stored or maintained) or tangible things that qualify for protection

15 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

16 Statement

17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

18 support staff).

19 2.5 Designating Party: a Party or Non-Party that designates information or

20 items that it produces in disclosures or in responses to discovery as

21 “CONFIDENTIAL.”

22 2.6 Disclosure or Discovery Material: all items or information, regardless of

23 the medium or manner in which it is generated, stored, or maintained (including, among

24 other things, testimony, transcripts, and tangible things), that are produced or generated

25 in disclosures or responses to discovery in this matter.

26 2.7 Expert: a person with specialized knowledge or experience in a matter

27 pertinent to the litigation who has been retained by a Party or its counsel to serve as an

1 2.8 House Counsel: attorneys who are employees of a party to this Action.

2 House Counsel does not include Outside Counsel of Record or any other outside

3 counsel.

4 2.9 Non-Party: any natural person, partnership, corporation, association, or

5 other legal entity not named as a Party to this action.

6 2.10 Outside Counsel of Record: attorneys who are not employees of a party

7 to this Action but are retained to represent or advise a party to this Action and have

8 appeared in this Action on behalf of that party or are affiliated with a law firm which

9 has appeared on behalf of that party, and includes support staff.

10 2.11 Party: any party to this Action, including all of its officers, directors,

11 employees, consultants, retained experts, and Outside Counsel of Record (and their

12 support staffs).

13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

14 Discovery Material in this Action.

15 2.13 Professional Vendors: persons or entities that provide litigation support

16 services (e.g., photocopying, videotaping, translating, preparing exhibits or

17 demonstrations, and organizing, storing, or retrieving data in any form or medium) and

18 their employees and subcontractors.

19 2.14 Protected Material: any Disclosure or Discovery Material that is

20 designated as “CONFIDENTIAL.”

21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

22 from a Producing Party.

23 3. SCOPE

24 The protections conferred by this Stipulation and Order cover not only Protected

25 Material (as defined above), but also (1) any information copied or extracted from

26 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

27 Material; and (3) any testimony, conversations, or presentations by Parties or their

1 Any use of Protected Material at trial will be governed by the orders of the trial

2 judge. This Order does not govern the use of Protected Material at trial. Likewise, the

3 mere existence of this stipulation and Order shall not serve as a basis to preclude the

4 admission of any protected materials as evidence at the time of trial.

5 4. DURATION

6 4.1 Except for information specified in section 4.2, the confidentiality

7 obligations imposed by this Order will remain in effect until a Designating Party agrees

8 otherwise in writing or a court order otherwise directs. Final disposition will be deemed

9 to be the later of (1) dismissal of all claims and defenses in this Action, with or without

10 prejudice; and (2) final judgement herein after the completion and exhaustion of all

11 appeals, rehearings, remands, trials, or reviews of this Action, including the time limits

12 for filing any motions or applications for extension of time pursuant to applicable law.

13 4.2 [POSSIBLE PARAGRAPH] Once the case proceeds to trial, all of the

14 information that was designated as CONFIDENTIAL or maintained pursuant to under

15 this protective order that is authorized for use at trial by stipulation, order or is otherwise

16 admitted as an exhibit will becomes public and will be presumptively available to all

17 members of the public, including the press, unless compelling reasons supported by

18 specific factual findings to proceed otherwise are made to the trial judge in advance of

19 the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th

20 Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in

21 discovery from “compelling reasons” standard when merits-related documents are part

22 of court record). Accordingly, the terms of this protective order do not extend beyond

23 the commencement of the trial for the items that become public record. However, for

24 items that do not become public record through the course of trial, the protective order

25 extends after final disposition of this litigation. For items that do not become part of the

26 public record, the confidentiality obligations imposed by this Order will remain in

27 effect until Section 4.1 is satisfied.

1 5. DESIGNATING PROTECTED MATERIAL

2 5.1 Exercise of Restraint and Care in Designating Material for Protection.

3 Each Party or Non-Party that designates information or items for protection under this

4 Order must take care to limit any such designation to specific material that qualifies

5 under the appropriate standards. The Designating Party must designate for protection

6 only those parts of material, documents, items, or oral or written communications that

7 qualify so that other portions of the material, documents, items, or communications for

8 which protection is not warranted are not swept unjustifiably within the ambit of this

9 Order.

10 Mass, indiscriminate, or routinized designations are prohibited. Designations

11 that are shown to be clearly unjustified or that have been made for an improper purpose

12 (e.g., to unnecessarily encumber the case development process or to impose

13 unnecessary expenses and burdens on other parties) may expose the Designating Party

14 to sanctions.

15 If it comes to a Designating Party’s attention that information or items that it

16 designated for protection do not qualify for protection, that Designating Party must

17 promptly notify all other Parties that it is withdrawing the inapplicable designation.

18 5.2 Manner and Timing of Designations. Except as otherwise provided in this

19 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated

20 or ordered, Disclosure or Discovery Material that qualifies for protection under this

21 Order must be clearly so designated before the material is disclosed or produced.

22 Designation in conformity with this Order requires:

23 (a) for information in documentary form (e.g., paper or electronic documents,

24 but excluding transcripts of depositions or other pretrial or trial proceedings), that the

25 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

26 “CONFIDENTIAL legend”), to each page that contains protected material. If only a

27 portion or portions of the material on a page qualifies for protection, the Producing

1 Party also must clearly identify the protected portion(s) (e.g., by making appropriate

2 markings in the margins).

3 A Party or Non-Party that makes original documents available for

4 inspection need not designate them for protection until after the inspecting Party has

5 indicated which documents it would like copied and produced. During the inspection

6 and before the designation, all of the material made available for inspection will be

7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the document(s)

8 it wants copied and produced, the Producing Party must determine which documents,

9 or portions thereof, qualify for protection under this Order. Then, before producing the

10 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to

11 each page that contains Protected Material. If only a portion or portions of the material

12 on a page qualifies for protection, the Producing Party also must clearly identify the

13 protected portion(s) (e.g., by making appropriate markings in the margins).

14 (b) for testimony given in depositions that the Designating Party identify the

15 Disclosure or Discovery Material on the record, before the close of the deposition all

16 protected testimony.

17 (c) for information produced in some form other than documentary and for any

18 other tangible items, that the Producing Party affix in a prominent place on the exterior

19 of the container or containers in which the information is stored the legend

20 “CONFIDENTIAL.” If only a portion or portions of the information warrants

21 protection, the Producing Party, to the extent practicable, will identify the protected

22 portion(s).

23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

24 failure to designate qualified information or items does not, standing alone, waive the

25 Designating Party’s right to secure protection under this Order for such material. Upon

26 timely correction of a designation, the Receiving Party must make reasonable efforts to

27 assure that the material is treated in accordance with the provisions of this Order

1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

3 designation of confidentiality at any time that is consistent with the Court’s Scheduling

4 Order.

5 6.2 Meet and Confer. The Challenging Party will initiate the dispute

6 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 et

7 seq.

8 6.3 The burden of persuasion in any such challenge proceeding will be on the

9 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

10 to harass or impose unnecessary expenses and burdens on other parties) may expose

11 the Challenging Party to sanctions. Unless the Designating Party has waived or

12 withdrawn the confidentiality designation, all parties will continue to afford the

13 material in question the level of protection to which it is entitled under the Producing

14 Party’s designation until the Court rules on the challenge.

15 7. ACCESS TO AND USE OF PROTECTED MATERIAL

16 7.1 Basic Principles. A Receiving Party may use Protected Material that is

17 disclosed or produced by another Party or by a Non-Party in connection with this Action

18 only for prosecuting, defending, or attempting to settle this Action. Such Protected

19 Material may be disclosed only to the categories of persons and under the conditions

20 described in this Order. When the Action has been terminated, a Receiving Party must

21 comply with the provisions of section 13 below (FINAL DISPOSITION).

22 Protected Material must be stored and maintained by a Receiving Party at a

23 location and in a secure manner that ensures that access is limited to the persons

24 authorized under this Order.

25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

26 ordered by the court or permitted in writing by the Designating Party, a Receiving Party

27 may disclose any information or item designated “CONFIDENTIAL” only to:

1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well

2 as employees of said Outside Counsel of Record to whom it is reasonably necessary to

3 disclose the information for this Action;

4 (b) the officers, directors, and employees (including House Counsel) of the

5 Receiving Party to whom disclosure is reasonably necessary for this Action;

6 (c) Experts (as defined in this Order) of the Receiving Party to whom

7 disclosure is reasonably necessary for this Action and who have signed the

8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

9 (d) the Court and its personnel;

10 (e) court reporters and their staff;

11 (f) professional jury or trial consultants, mock jurors, and Professional

12 Vendors to whom disclosure is reasonably necessary for this Action and who have

13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

14 (g) the author or recipient of a document containing the information or a

15 custodian or other person who otherwise possessed or knew the information;

16 (h) during their depositions, witnesses ,and attorneys for witnesses, in the

17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

18 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will

19 not be permitted to keep any confidential information unless they sign the

20 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed

21 by the Designating Party or ordered by the court. Pages of transcribed deposition

22 testimony or exhibits to depositions that reveal Protected Material may be separately

23 bound by the court reporter and may not be disclosed to anyone except as permitted

24 under this Stipulated Protective Order; and

25 (i) any mediator or settlement officer, and their supporting personnel,

26 mutually agreed upon by any of the parties engaged in settlement discussions.

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1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

2 IN OTHER LITIGATION

3 If a Party is served with a subpoena or a court order issued in other litigation that

4 compels disclosure of any information or items designated in this Action as

5 “CONFIDENTIAL,” that Party must:

6 (a) promptly notify in writing the Designating Party. Such notification will

7 include a copy of the subpoena or court order;

8 (b) promptly notify in writing the party who caused the subpoena or order to

9 issue in the other litigation that some or all of the material covered by the subpoena or

10 order is subject to this Protective Order. Such notification will include a copy of this

11 Stipulated Protective Order; and

12 (c) cooperate with respect to all reasonable procedures sought to be pursued

13 by the Designating Party whose Protected Material may be affected.

14 If the Designating Party timely seeks a protective order, the Party served with

15 the subpoena or court order will not produce any information designated in this action

16 as “CONFIDENTIAL” before a determination by the court from which the subpoena

17 or order issued, unless the Party has obtained the Designating Party’s permission. The

18 Designating Party will bear the burden and expense of seeking protection in that court

19 of its confidential material and nothing in these provisions should be construed as

20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

21 directive from another court.

22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

23 PRODUCED IN THIS LITIGATION

24 (a) The terms of this Order are applicable to information produced by a Non-

25 Party in this Action and designated as “CONFIDENTIAL.” Such information produced

26 by Non-Parties in connection with this litigation is protected by the remedies and relief

27 provided by this Order. Nothing in these provisions should be construed as prohibiting

1 (b) In the event that a Party is required, by a valid discovery request, to

2 produce a Non-Party’s confidential information in its possession, and the Party is

3 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential

4 information, then the Party will:

5 (1) promptly notify in writing the Requesting Party and the Non-Party that

6 some or all of the information requested is subject to a confidentiality agreement with

7 a Non-Party;

8 (2) promptly provide the Non-Party with a copy of the Stipulated

9 Protective Order in this Action, the relevant discovery request(s), and a reasonably

10 specific description of the information requested; and

11 (3) make the information requested available for inspection by the Non-

12 Party, if requested.

13 (c) If the Non-Party fails to seek a protective order from this court within 14

14 days of receiving the notice and accompanying information, the Receiving Party may

15 produce the Non-Party’s confidential information responsive to the discovery request.

16 If the Non-Party timely seeks a protective order, the Receiving Party will not produce

17 any information in its possession or control that is subject to the confidentiality

18 agreement with the Non-Party before a determination by the court. Absent a court

19 order to the contrary, the Non-Party will bear the burden and expense of seeking

20 protection in this court of its Protected Material.

21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

23 Protected Material to any person or in any circumstance not authorized under this

24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

25 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

26 all unauthorized copies of the Protected Material, (c) inform the person or persons to

27 whom unauthorized disclosures were made of all the terms of this Order, and (d) request

1 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

2 that is attached hereto as Exhibit A.

3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

4 PROTECTED MATERIAL

5 When a Producing Party gives notice to Receiving Parties that certain

6 inadvertently produced material is subject to a claim of privilege or other protection,

7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

9 may be established in an e-discovery order that provides for production without prior

10 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

11 parties reach an agreement on the effect of disclosure of a communication or

12 information covered by the attorney-client privilege or work product protection, the

13 parties may incorporate their agreement in the stipulated protective order submitted to

14 the court.

15 12. MISCELLANEOUS

16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

17 person to seek its modification by the Court in the future.

18 12.2 Right to Assert Other Objections. By stipulating to the entry of this

19 Protective Order no Party waives any right it otherwise would have to object to

20 disclosing or producing any information or item on any ground not addressed in this

21 Stipulated Protective Order. Similarly, no Party waives any right to object on any

22 ground to use in evidence of any of the material covered by this Protective Order.

23 12.3 Filing Protected Material. A Party that seeks to file under seal any

24 Protected Material must comply with Civil Local Rule 79-5. Protected Material may

25 only be filed under seal pursuant to a court order authorizing the sealing of the specific

26 Protected Material at issue. If a Party's request to file Protected Material under seal is

27 denied by the court, then the Receiving Party may file the information in the public

1 13. FINAL DISPOSITION

2 After the final disposition of this Action, as defined in paragraph 4, within 60

3 days of a written request by the Designating Party, each Receiving Party must return

4 all Protected Material to the Producing Party or destroy such material. As used in this

5 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

6 summaries, and any other format reproducing or capturing any of the Protected

7 Material. Whether the Protected Material is returned or destroyed, the Receiving Party

8 must submit a written certification to the Producing Party (and, if not the same person

9 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by

10 category, where appropriate) all the Protected Material that was returned or destroyed

11 and (2) affirms that the Receiving Party has not retained any copies, abstracts,

12 compilations, summaries or any other format reproducing or capturing any of the

13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

14 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,

15 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney

16 work product, and consultant and expert work product, even if such materials contain

17 Protected Material. Any such archival copies that contain or constitute Protected

18 Material remain subject to this Protective Order as set forth in Section 4 (DURATION).

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1 || 14. Any willful violation of this Order may be punished by civil or criminal □□□□□□□

2 || proceedings, financial or evidentiary sanctions, reference to disciplinary authorities, «

3 || other appropriate action at the discretion of the Court.

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5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: October 09, 2024 CAMERON JONES LLP

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g By: /s/ Indira J. Cameron Banks

INDIRA J CAMERON-BANKS, ESQ.

9 Attorneys for Plaintiff SASCHA B. KOCH

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11 || Dated: October 9, 2024 HYDEE FELDSTEIN SOTO, City Attorney

D DENISE C. MILLS, Chief Deputy City Attorney

KATHLEEN KENEALY, Chief Assistant City Attorney

13 CORY M. BRENTE, Senior Assistant City Attorney

14 oo

By: Is) Rebecca C.. Punter

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REBECCA E. HUNTER, Deputy City Attorney

16 Attorneys for Defendants, CITY OF LOS ANGELES,

7 LAURA BRINKMAN, JOSHUA TOWE, and MANUE

VARGAS

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30 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

Fhalanas A, □□□

|| DATED:_October 9, 2024 ond.

HON. PATRICIA DONAHUE

3 United States Magistrate Judge

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

4 I, _____________________________ [full name], of _________________ [full

5 address], declare under penalty of perjury that I have read in its entirety and understand

6 the Stipulated Protective Order that was issued by the United States District Court for

7 the Central District of California on [date] in the case of Sasha Koch v. City of Los

8 Angeles, et al. (Case No: CV-19-05762-JLS-ADSx). I agree to comply with and to be

9 bound by all the terms of this Stipulated Protective Order and I understand and

10 acknowledge that failure to so comply could expose me to sanctions and punishment in

11 the nature of contempt. I solemnly promise that I will not disclose in any manner any

12 information or item that is subject to this Stipulated Protective Order to any person or

13 entity except in strict 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

16 Stipulated Protective Order, even if such enforcement proceedings occur after

17 termination of this action. I hereby appoint __________________________ [full

18 name] of _______________________________________ [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

21 Order.

22 Date: ______________________________________

23 City and State where signed: _________________________________

24 Printed name: _______________________________

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26 Signature: __________________________________

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