even stipulated protective orders require 18 good cause showing
How later courts described this case
- even stipulated protective orders require 18 good cause showing
Written by the judges who cited it.
The opinion
1 David Martinez, Bar No. 193183
DMartinez@RobinsKaplan.com
2 Daniel Allender, Bar No. 264651
DAllender@RobinsKaplan.com
3 Luis D. Gomez, Bar No. 347877
LGomez@RobinsKaplan.com
4 ROBINS KAPLAN LLP
2121 Avenue of the Stars, Suite 2800
5 Los Angeles, CA 90067
Telephone: 310.552.0130
6 Facsimile: 310.229.5800
7 Attorneys for Plaintiffs
Jorge Ernesto Ramirez Ceballos;
8 Fernando Guardado Rosales;
Jose Rosario Cisneros Gutierrez; and
9 Luis Antonio Plasencia Martinez
10
UNITED STATES DISTRICT COURT
11
CENTRAL DISTRICT OF CALIFORNIA
12
13 Jorge Ernesto Ramirez Ceballos; Case No. 2:23-cv-10911-CBM-MAR
Fernando Guardado Rosales;
14 Jose Rosario Cisneros Gutierrez; and [Assigned to the Honorable Judge
Luis Antonio Plasencia Martinez Consuelo B. Marshall]
15
Plaintiffs, Referred to: Hon. Margo A. Rocconi
16
v. DISCOVERY MATTER
17
Banda Maguey Corporation, dba STIPULATED PROTECTIVE ORDER
18 Banda Maguey USA, Inc.; Miguel
Angel Vidal Pulido; Samuel Vidal
19 Pulido; and DOES 1 through 10, [Action filed: December 31, 2023]
inclusive,
20
Defendants.
21
22 Miguel Angel Vidal Pulido,
Counterclaimant,
23
v.
24
Jorge Ernesto Ramirez Ceballos;
25
Fernando Guardado Rosales; Jose
Rosario Cisneros Gutierrez; Luis
26
Antonio Plasencia Martinez; and
ROES 1-10, inclusive,
27
Counterdefendants.
1 1. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public
4 disclosure and from use for any purpose other than pursuing this litigation may
5 be warranted. Accordingly, the parties hereby stipulate to and petition the
6 Court to enter the following Stipulated Protective Order. The parties
7 acknowledge that this Order does not confer blanket protections on all
8 disclosures or responses to discovery and that the protection it affords from
9 public disclosure and use extends only to the limited information or items that
10 are entitled to confidential treatment under the applicable legal principles.
11 2. GOOD CAUSE STATEMENT
12 This action is likely to involve trade secrets, customer and pricing lists and
13 other valuable research, development, commercial, financial, technical and/or
14 proprietary information for which special protection from public disclosure and
15 from use for any purpose other than prosecution of this action is warranted.
16 Such confidential and proprietary materials and information consist of, among
17 other things, confidential business or financial information, information
18 regarding confidential business practices, or other confidential research,
19 development, or commercial information (including information implicating
20 privacy rights of third parties), information otherwise generally unavailable to
21 the public, or which may be privileged or otherwise protected from disclosure
22 under state or federal statutes, court rules, case decisions, or common law.
23 Accordingly, to expedite the flow of information, to facilitate the prompt
24 resolution of disputes over confidentiality of discovery materials, to adequately
25 protect information the parties are entitled to keep confidential, to ensure that
26 the parties are permitted reasonable necessary uses of such material in
27 preparation for and in the conduct of trial, to address their handling at the end
1 information is justified in this matter. It is the intent of the parties that
2 information will not be designated as confidential for tactical reasons and that
3 nothing be so designated without a good faith belief that it has been maintained
4 in a confidential, non-public manner, and there is good cause why it should not
5 be part of the public record of this case.
6 3. ACKNOWLEDGEMENT OF UNDER SEAL FILING PROCEDURE
7 The parties further acknowledge, as set forth in Section 14.3, below, that
8 this Stipulated Protective Order does not entitle them to file confidential
9 information under seal; Local Civil Rule 79-5 sets forth the procedures that must
10 be followed and the standards that will be applied when a party seeks
11 permission from the court to file material under seal. There is a strong
12 presumption that the public has a right of access to judicial proceedings and
13 records in civil cases. In connection with non-dispositive motions, good cause
14 must be shown to support a filing under seal. See Kamakana v. City and County
15 of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp.,
16 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,
17 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
18 good cause showing), and a specific showing of good cause or compelling
19 reasons with proper evidentiary support and legal justification, must be made
20 with respect to Protected Material that a party seeks to file under seal. The
21 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL
22 does not— without the submission of competent evidence by declaration,
23 establishing that the material sought to be filed under seal qualifies as
24 confidential, privileged, or otherwise protectable—constitute good cause.
25 Further, if a party requests sealing related to a dispositive motion or trial,
26 then compelling reasons, not only good cause, for the sealing must be shown,
27 and the relief sought shall be narrowly tailored to serve the specific interest to
1 Cir. 2010). For each item or type of information, document, or thing sought to
2 be filed or introduced under seal, the party seeking protection must articulate
3 compelling reasons, supported by specific facts and legal justification, for the
4 requested sealing order. Again, competent evidence supporting the application
5 to file documents under seal must be provided by declaration.
6 Any document that is not confidential, privileged, or otherwise protectable
7 in its entirety will not be filed under seal if the confidential portions can be
8 redacted. If documents can be redacted, then a redacted version for public
9 viewing, omitting only the confidential, privileged, or otherwise protectable
10 portions of the document, shall be filed. Any application that seeks to file
11 documents under seal in their entirety should include an explanation of why
12 redaction is not feasible.
13 4. DEFINITIONS
14 4.1 Action: this pending federal lawsuit.
15 4.2 Challenging Party: a Party or Non-Party that challenges the
16 designation of information or items under this Order.
17 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
18 how it is generated, stored or maintained) or tangible things that qualify for
19 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
20 the Good Cause Statement.
21 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
22 their support staff).
23 4.5 Designating Party: a Party or Non-Party that designates information
24 or items that it produces in disclosures or in responses to discovery as
25 “CONFIDENTIAL.”
26 4.6 Disclosure or Discovery Material: all items or information, regardless
27 of the medium or manner in which it is generated, stored, or maintained
1 (including, among other things, testimony, transcripts, and tangible things), that
2 are produced or generated in disclosures or responses to discovery.
3 4.7 Expert: a person with specialized knowledge or experience in a
4 matter pertinent to the litigation who has been retained by a Party or its counsel
5 to serve as an expert witness or as a consultant in this Action.
6 4.8 House Counsel: attorneys who are employees of a party to this
7 Action. House Counsel does not include Outside Counsel of Record or any other
8 outside counsel.
9 4.9 Non-Party: any natural person, partnership, corporation, association
10 or other legal entity not named as a Party to this action.
11 4.10 Outside Counsel of Record: attorneys who are not employees of a
12 party to this Action but are retained to represent a party to this Action and have
13 appeared in this Action on behalf of that party or are affiliated with a law firm
14 that has appeared on behalf of that party, and includes support staff.
15 4.11 Party: any party to this Action, including all of its officers, directors,
16 employees, consultants, retained experts, and Outside Counsel of Record (and
17 their support staffs).
18 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 Discovery Material in this Action.
20 4.13 Professional Vendors: persons or entities that provide litigation
21 support services (e.g., photocopying, videotaping, translating, preparing exhibits
22 or demonstrations, and organizing, storing, or retrieving data in any form or
23 medium) and their employees and subcontractors.
24 4.14 Protected Material: any Disclosure or Discovery Material that is
25 designated as “CONFIDENTIAL.”
26 4.15 Receiving Party: a Party that receives Disclosure or Discovery
27 Material from a Producing Party.
1 5. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the
8 trial judge and other applicable authorities. This Order does not govern the use
9 of Protected Material at trial.
10 6. DURATION
11 Once a case proceeds to trial, information that was designated as
12 CONFIDENTIAL or maintained pursuant to this protective order used or
13 introduced as an exhibit at trial becomes public and will be presumptively
14 available to all members of the public, including the press, unless compelling
15 reasons supported by specific factual findings to proceed otherwise are made to
16 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
17 (distinguishing “good cause” showing for sealing documents produced in
18 discovery from “compelling reasons” standard when merits-related documents
19 are part of court record). Accordingly, with respect to information used or
20 introduced as an exhibit at trial, the terms of this protective order do not extend
21 beyond the commencement of the trial. With respect to information that was
22 designated as CONFIDENTIAL or maintained pursuant to this protective order
23 that is not used or introduced as an exhibit at trial, after final disposition of this
24 litigation, the confidentiality obligations imposed by this Order shall remain in
25 effect until a Designating Party agrees otherwise in writing or a court order
26 otherwise directs. Final disposition shall be deemed to be the later of (1)
27 dismissal of all claims and defenses in this Action, with or without prejudice; and
1 rehearings, remands, trials, or reviews of this Action, including the time limits
2 for filing any motions or applications for extension of time pursuant to
3 applicable law.
4 7. DESIGNATING PROTECTED MATERIAL
5 7.1 Exercise of Restraint and Care in Designating Material for Protection.
6 Each Party or Non-Party that designates information or items for protection
7 under this Order must take care to limit any such designation to specific
8 material that qualifies under the appropriate standards. The Designating Party
9 must designate for protection only those parts of material, documents, items or
10 oral or written communications that qualify so that other portions of the
11 material, documents, items or communications for which protection is not
12 warranted are not swept unjustifiably within the ambit of this Order.
13 Mass, indiscriminate or routinized designations are prohibited.
14 Designations that are shown to be clearly unjustified or that have been made for
15 an improper purpose (e.g., to unnecessarily encumber the case development
16 process or to impose unnecessary expenses and burdens on other parties) may
17 expose the Designating Party to sanctions.
18 If it comes to a Designating Party’s attention that information or items that
19 it designated for protection do not qualify for protection, that Designating Party
20 must promptly notify all other Parties that it is withdrawing the inapplicable
21 designation.
22 7.2 Manner and Timing of Designations. Except as otherwise provided in
23 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery
24 Material that qualifies for protection under this Order must be clearly so
25 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
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 of the material on a page qualifies
4 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
7 inspection need not designate them for protection until after the inspecting
8 Party has indicated which documents it would like copied and produced.
9 During the inspection and before the designation, all of the material made
10 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting
11 Party has identified the documents it wants copied and produced, the Producing
12 Party must determine which documents, or portions thereof, qualify for
13 protection under this Order. Then, before producing the specified documents,
14 the Producing Party must affix the “CONFIDENTIAL legend” to each page that
15 contains Protected Material. If only a portion of the material on a page qualifies
16 for protection, the Producing Party also must clearly identify the protected
17 portion(s) (e.g., by making appropriate markings in the margins).
18 (b) for testimony given in depositions that the Designating Party
19 identifies the Disclosure or Discovery Material on the record, before the close of
20 the deposition all protected testimony.
21 (c) for information produced in some form other than
22 documentary and for any other tangible items, that the Producing Party affix in
23 a prominent place on the exterior of the container or containers in which the
24 information is stored the legend “CONFIDENTIAL.” If only a portion or portions
25 of the information warrants protection, the Producing Party, to the extent
26 practicable, shall identify the protected portion(s).
27 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
failure to designate qualified information or items does not, standing alone,
1 waive the Designating Party’s right to secure protection under this Order for
2 such material. Upon timely correction of a designation, the Receiving Party must
3 make reasonable efforts to assure that the material is treated in accordance
4 with the provisions of this Order.
5 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
6 8.1 Timing of Challenges. Any Party or Non-Party may challenge a
7 designation of confidentiality at any time that is consistent with the Court’s
8 Scheduling Order.
9 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
10 resolution process under Local Rule 37-1 et seq.
11 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
12 joint stipulation pursuant to Local Rule 37-2.
13 8.4 The burden of persuasion in any such challenge proceeding shall be
14 on the Designating Party. Frivolous challenges, and those made for an improper
15 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
16 parties) may expose the Challenging Party to sanctions. Unless the Designating
17 Party has waived or withdrawn the confidentiality designation, all parties shall
18 continue to afford the material in question the level of protection to which it is
19 entitled under the Producing Party’s designation until the Court rules on the
20 challenge.
21 9. ACCESS TO AND USE OF PROTECTED MATERIAL
22 9.1 Basic Principles. A Receiving Party may use Protected Material that is
23 disclosed or produced by another Party or by a Non-Party in connection with
24 this Action only for prosecuting, defending or attempting to settle this Action.
25 Such Protected Material may be disclosed only to the categories of persons and
26 under the conditions described in this Order. When the Action has been
27 terminated, a Receiving Party must comply with the provisions of section 15
1 Protected Material must be stored and maintained by a Receiving Party at a
2 location and in a secure manner that ensures that access is limited to the
3 persons authorized under this Order.
4 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
5 otherwise ordered by the court or permitted in writing by the Designating Party,
6 a Receiving Party may disclose any information or item designated
7 “CONFIDENTIAL” only to:
8 (a) the Receiving Party’s Outside Counsel of Record in this Action,
9 as well as employees of said Outside Counsel of Record to whom it is reasonably
10 necessary to disclose the information for this Action;
11 (b) the officers, directors, and employees (including House
12 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for
13 this Action;
14 (c) Experts (as defined in this Order) of the Receiving Party to
15 whom disclosure is reasonably necessary for this Action and who have signed
16 the “Acknowledgment and Agreement to Be Bound” (Exhibit A)
17 (d) the court and its personnel;
18 (e) court reporters and their staff;
19 (f) professional jury or trial consultants, mock jurors, and
20 Professional Vendors to whom disclosure is reasonably necessary for this Action
21 and who have signed the “Acknowledgment and Agreement to Be Bound”
22 (Exhibit A);
23 (g) the author or recipient of a document containing the
24 information or a custodian or other person who otherwise possessed or knew
25 the information.
26 (h) during their depositions, witnesses, and attorneys for
27 witnesses, in the Action to whom disclosure is reasonably necessary provided:
1 Exhibit A hereto; and (2) they will not be permitted to keep any confidential
2 information unless they sign the “Acknowledgment and Agreement to Be
3 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered
4 by the court. Pages of transcribed deposition testimony or exhibits to
5 depositions that reveal Protected Material may be separately bound by the
6 court reporter and may not be disclosed to anyone except as permitted under
7 this Stipulated Protective Order; and
8 (i) any mediators or settlement officers and their supporting
9 personnel, mutually agreed upon by any of the parties engaged in settlement
10 discussions.
11
10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
12 OTHER LITIGATION
13 If a Party is served with a subpoena or a court order issued in other
14 litigation that compels disclosure of any information or items designated in this
15 Action as “CONFIDENTIAL,” that Party must:
16 (a) promptly notify in writing the Designating Party. Such
17 notification shall include a copy of the subpoena or court order;
18 (b) promptly notify in writing the party who caused the subpoena
19 or order to issue in the other litigation that some or all of the material covered
20 by the subpoena or order is subject to this Protective Order. Such notification
21 shall include a copy of this Stipulated Protective Order; and
22 (c) cooperate with respect to all reasonable procedures sought to
23 be pursued by the Designating Party whose Protected Material may be affected.
24 If the Designating Party timely seeks a protective order, the Party served with
25 the subpoena or court order shall not produce any information designated in
26 this action as “CONFIDENTIAL” before a determination by the court from which
27 the subpoena or order issued, unless the Party has obtained the Designating
1 seeking protection in that court of its confidential material and nothing in these
2 provisions should be construed as authorizing or encouraging a Receiving Party
3 in this Action to disobey a lawful directive from another court.
4
11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN
5 THIS LITIGATION
6 (a) The terms of this Order are applicable to information produced
7 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
8 information produced by Non-Parties in connection with this litigation is
9 protected by the remedies and relief provided by this Order. Nothing in these
10 provisions should be construed as prohibiting a Non-Party from seeking
11 additional protections.
12 (b) In the event that a Party is required, by a valid discovery
13 request, to produce a Non-Party’s confidential information in its possession, and
14 the Party is subject to an agreement with the Non-Party not to produce the
15 Non-Party’s confidential information, then the Party shall:
16 promptly notify in writing the Requesting Party and the Non- Party that some or
17 all of the information requested is subject to a confidentiality agreement with a
18 Non-Party;
19 (1) promptly notify in writing the Requesting Party and the Non-
20 Party that some or all of the information requested is subject to a
21 confidentiality agreement with a Non-Party;
22 (2) promptly provide the Non-Party with a copy of the Stipulated
23 Protective Order in this Action, the relevant discovery request(s), and a
24 reasonably specific description of the information requested; and
25 (3) make the information requested available for inspection by the
26 Non-Party, if requested.
27 (c) If the Non-Party fails to seek a protective order from this court
1 Receiving Party may produce the Non-Party’s confidential information
2 responsive to the discovery request. If the Non-Party timely seeks a protective
3 order, the Receiving Party shall not produce any information in its possession or
4 control that is subject to the confidentiality agreement with the Non-Party
5 before a determination by the court. Absent a court order to the contrary, the
6 Non-Party shall bear the burden and expense of seeking protection in this court
7 of its Protected Material.
8 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
9 If a Receiving Party learns that, by inadvertence or otherwise, it has
10 disclosed Protected Material to any person or in any circumstance not
11 authorized under this Stipulated Protective Order, the Receiving Party must
12 immediately (a) notify in writing the Designating Party of the unauthorized
13 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
14 Protected Material, (c) inform the person or persons to whom unauthorized
15 disclosures were made of all the terms of this Order, and (d) request such
16 person or persons to execute the “Acknowledgment an Agreement to Be
17 Bound” attached hereto as Exhibit A.
18
13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
19 PROTECTED MATERIAL
20 When a Producing Party gives notice to Receiving Parties that certain
21 inadvertently produced material is subject to a claim of privilege or other
22 protection, the obligations of the Receiving Parties are those set forth in Federal
23 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
24 whatever procedure may be established in an e-discovery order that provides
25 for production without prior privilege review. Pursuant to Federal Rule of
26 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect
27 of disclosure of a communication or information covered by the attorney-client
1 privilege or work product protection, the parties may incorporate their
2 agreement in the stipulated protective order submitted to the court.
3 14. MISCELLANEOUS
4 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
5 person to seek its modification by the Court in the future.
6 14.2 Right to Assert Other Objections. By stipulating to the entry of this
7 Protective Order, no Party waives any right it otherwise would have to object to
8 disclosing or producing any information or item on any ground not addressed in
9 this Stipulated Protective Order. Similarly, no Party waives any right to object on
10 any ground to use in evidence of any of the material covered by this Protective
11 Order.
12 14.3 Filing Protected Material. A Party that seeks to file under seal any
13 Protected Material must comply with Local Civil Rule 79-5. Protected Material
14 may only be filed under seal pursuant to a court order authorizing the sealing of
15 the specific Protected Material. If a Party’s request to file Protected Material
16 under seal is denied by the court, then the Receiving Party may file the
17 information in the public record unless otherwise instructed by the court.
18 15. FINAL DISPOSITION
19 After the final disposition of this Action, as defined in paragraph 6, within
20 60 days of a written request by the Designating Party, each Receiving Party must
21 return all Protected Material to the Producing Party or destroy such material. As
22 used in this subdivision, “all Protected Material” includes all copies, abstracts,
23 compilations, summaries, and any other format reproducing or capturing any of
24 the Protected Material. Whether the Protected Material is returned or
25 destroyed, the Receiving Party must submit a written certification to the
26 Producing Party (and, if not the same person or entity, to the Designating Party)
27 by the 60-day deadline that (1) identifies (by category, where appropriate) all
1 Receiving Party has not retained any copies, abstracts, compilations, summaries
|| or any other format reproducing or capturing any of the Protected Material.
Notwithstanding this provision, Counsel are entitled to retain an archival copy of
4|| all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
5 || memoranda, correspondence, deposition and trial exhibits, expert reports,
|| attorney work product, and consultant and expert work product, even if such
|| materials contain Protected Material. Any such archival copies that contain or
constitute Protected Material remain subject to this Protective Order as set
9|| forth in Section 6 (DURATION).
10 16. VIOLATION
11 Any violation of this Order may be punished by appropriate measures
12 || including, without limitation, contempt proceedings and/or monetary sanctions.
13
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: December 16, 2024 ROBINS KAPLAN LLP
16
17 By:__/s/ David Martinez
David Martinez
18
19
DATED:
20 Attorneys for Defendants
21
37 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
23
|| DATED: _ 1/8/2025
MARGO A. ROCCONI
25 United States Magistrate Judge
26
27
28
1 EXHIBIT A
2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of
6 perjury that I have read in its entirety and understand the Stipulated Protective
7 Order that was issued by the United States District Court for the Central District
8 of California on _________ [date] in the case of ___________ [insert formal
9 case name and the numbers and initials assigned to it by the court]. I agree to
10 comply with and to be bound by all the terms of this Stipulated Protective Order
11 and I understand and acknowledge that failure to so comply could expose me to
12 sanctions and punishment in the nature of contempt. I solemnly promise that I
13 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
15 with the provisions of this Order.
16 I further agree to submit to the jurisdiction of the United States District
17 Court for the Central District of California for the purpose of enforcing the terms
18 of this Stipulated Protective Order, even if such enforcement proceedings occur
19 after termination of this action. I hereby appoint _______________________
20 [print or type full name] of ________________________________________
21 [print or type full address and telephone number] as my California agent for
22 service of process in connection with this action or any proceedings related to
23 enforcement of this Stipulated Protective Order.
24 Date: ______________________________________
25 City and State where signed: _________________________________
26
27 Printed name: _______________________________