distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record
Written by the judges who cited it.
The opinion
2
aVbiunrckewnti tCz@onPtrBerBaGs,B ESs.qC. OBMar No. : 3401 32
vcontreras@PBBGBS.COM
3 PETERSON BRADFORD BURKWITZ
GREGORIO BURKWITZ & SU, LLP
4 100 North First Street, Suite 300
Burbank, California 91502,
5 T: 818.562.5800
F: 818.562.5810
6
Attorneys for Defendants,
7 COUNTY OF LOS ANGELES, JEANNETE ARZATE, ANTHONY OKELOLA,
and ESPERANZA LOPEZ
8
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
LUIS ENRIQUE AGUILERA Case No.: 2:23-cv-00875-FMO-MAR
12 ANGELES, an individual; ROSA Assigned to the Honorable: Fernando M.
EMELIA CEBALLOS LOPEZ, an Olguin
13 individual; Y.A., a minor, by and through Magistrate Judge: Margo A. Rocconi
her guardian ad litem, LUIS [Room 6D]
14 AGUILERA; and Q.A.., a minor, by and
through her guardian ad litem, LUIS STIPULATED PROTECTIVE
15 AGUILERA ORDER1
16 Plaintiffs,
17 vs.
18 COUNTY OF LOS ANGELES;
JEANETTE ARZATE, an individual;
19 ANTHONY OKELOLA, an individual;
E. LOPEZ, an individual; ERIKA
20 BARRALES, an individual; NORMA
DISON, an individual; LISETTE SOLIS,
21 an individual; MARICELA OCHOA, an
individual; CITY OF LOS ANGELES,
22 LOS ANGELES POLICE
DEPARTMENT (LAPD), a public entity,
23 LAPD OFFICER RAMIREZ,
Hollenbeck Division, serial number
24 31010; LAPD OFFICER BRAVO,
Hollenbeck Division, serial number
25 36154; and DOES 1-20 inclusive,
26 Defendants.
27
1 This Stipulated Protective Order is substantially based on the model protective order provided
28
under Magistrate Judge Margo A. Rocconi’s Procedures.
2
1.1. PURPOSES AND LIMITATIONS
3
Discovery in this action is likely to involve production of confidential,
4
5 proprietary, or private information for which special protection from public
6
disclosure and from use for any purpose other than prosecuting this litigation may
7
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
8
9 enter the following Stipulated Protective Order. The parties acknowledge that this
10
Order does not confer blanket protections on all disclosures or responses to
11
12 discovery and that the protection it affords from public disclosure and use extends
13 only to the limited information or items that are entitled to confidential treatment
14
under the applicable legal principles. The parties further acknowledge, as set forth in
15
16 Section 12.3, below, that this Stipulated Protective Order does not entitle them to
17 file confidential information under seal; Civil Local Rule 79-5 sets forth the
18
procedures that must be followed and the standards that will be applied when a party
19
20 seeks permission from the court to file material under seal.
21 1.2. GOOD CAUSE STATEMENT
22
Plaintiffs Y.A., and Q.A., are former dependents of the Superior Court of the
23
24 State of California, County of Los Angeles, and the subject of Los Angeles County
25
Superior Court Juvenile Case Nos. 21CCJPOO619A and 21CCJPOO619B
26
(“Juvenile Dependency Court”). Information regarding dependents and information
27
28 contained in their case files of the juvenile court are highly confidential, private and
2
827, California Rules of Court 5.552, and other applicable statutes, regulations and
3
laws. Moreover, the Plaintiffs juvenile dependency court records contains highly
4
5 confidential information of mandated reporters reporting suspected abuse or neglect.
6
Penal Code §§ 11166, 11166.2, 11166.05, and 11167.5. Further, as to release of
7
Plaintiffs juvenile dependency court records, it was ordered by the Court to be
8
9 subject to a protective order. See Dkt. 58.
10
Between 2021 and 2023, the City of Los Angeles and the Los Angeles Police
11
12 Department investigated allegations of child sexual abuse perpetrated against
13 Plaintiffs Y.A., and Q.A. as well as two of their siblings. The investigation included
14
interviews of victims who were abused as children and information about the alleged
15
16 perpetrator of the crimes who is a non-party and whose privacy rights are also
17 implicated. As such, there may be voluminous sensitive materials including police
18
reports, recorded interviews depicting graphic sexual abuse of minors, and other law
19
20 enforcement records, which may be protected pursuant to Government Code §
21 6254(f), Penal Code §§ 832.5, 832.7, 832.8 and 11105, and Evidence Code § 1040.
22
Further, it is possible the parties in this action may seek confidential information
23
24 relating to individual police officers and as such their privacy rights are also
25
implicated pursuant to Evidence Code § 1043, and Pitchess v. Superior Court (1974)
26
11 Cal.3d 531, 535. See also Green v. Baca, 226 F.R.D. 624, 653 (C.D. Cal. 2005)
27
28 and A. Farber and Partners, Inc., 234 F.R.D. 186, 189-90 (C.D. Cal. 2006). Federal
2
States District Court for the Northern District of California, 511 F.2d 192, 198 (9th
3
Cir.1975), aff’d, 426 U.S. 394 (1976); Sanchez v. City of Santa Ana, 936 F.2d 1027,
4
5 1033 (9th Cir. 1990), cert. denied, 502 U.S. 957 (1991). It is the position of the City
6
of Los Angeles and the Los Angeles Police Department that the release of such
7
records cannot be considered absent a protective order and, in some cases, a court
8
9 order.
10
2. DEFINITIONS
11
12 2.1 Action: Case No.: 2:23-cv-00875-FMO-MAR
13
2.2 Challenging Party: a Party or Non-Party that challenges the designation
14
of information or items under this Order.
15
16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
17
how it is generated, stored or maintained) or tangible things that qualify for
18
protection under Federal Rule of Civil Procedure 26(c), and as specified above in the
19
20 Good Cause Statement.
21
2.4 Counsel: Attorneys of record in the action and their affiliated attorneys,
22
paralegals, clerical, and secretarial staff employed by such attorneys who are actively
23
24 involved in the action, and retained by a party, and are not employees of any party.
25
In-House counsel to the undersigned Parties and the paralegal, clerical, and
26
secretarial staff employed by such counsel. Provided, however that each non-lawyer
27
28 given access to Confidential Materials shall be advised that such Materials are being
2
Order and that they may not be disclosed other than pursuant to its terms; Outside
3
Counsel of Record and House Counsel (as well as their support staff).
4
5 2.5 Designating Party: a Party or Non-Party that designates information or
6
items that it produces in disclosures or in responses to discovery as
7
“CONFIDENTIAL.”
8
9 2.6 Disclosure or Discovery Material: all items or information, regardless
10
of the medium or manner in which it is generated, stored, or maintained (including,
11
12 among other things, testimony, transcripts, and tangible things), that are produced or
13 generated in disclosures or responses to discovery in this matter.
14
2.7 Expert: a person with specialized knowledge or experience in a matter
15
16 pertinent to the litigation who has been retained by a Party or its counsel to serve as
17 an expert witness or as a consultant in this Action.
18
2.8 House Counsel: attorneys who are employees of a party to this Action.
19
20 House Counsel does not include Outside Counsel of Record or any other outside
21
counsel.
22
2.9 Non-Party: any natural person, partnership, corporation, association, or
23
24 other legal entity not named as a Party to this action.
25
2.10 Outside Counsel of Record: attorneys who are not employees of a party
26
to this Action but are retained to represent or advise a party to this Action and have
27
28 appeared in this Action on behalf of that party or are affiliated with a law firm which
2
2.11 Party: any party to this Action, including all of its officers, directors,
3
employees, consultants, retained experts, and Outside Counsel of Record (and their
4
5 support staff).
6
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
7
Discovery Material in this Action.
8
9 2.13 Professional Vendors: persons or entities that provide litigation support
10
services (e.g., photocopying, videotaping, translating, preparing exhibits or
11
12 demonstrations, and organizing, storing, or retrieving data in any form or medium)
13 and their employees and subcontractors.
14
2.14 Protected Material: any Disclosure or Discovery Material that is
15
16 designated as “CONFIDENTIAL.”
17 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
18
from a Producing Party.
19
20 3. SCOPE
21
The protections conferred by this Stipulation and Order cover not only
22
Protected Material (as defined above), but also (1) any information copied or
23
24 extracted from Protected Material; (2) all copies, excerpts, summaries, or
25
compilations of Protected Material; and (3) any testimony, conversations, or
26
presentations by Parties or their Counsel that might reveal Protected Material.
27
28
2
trial judge. This Order does not govern the use of Protected Material at trial.
3
4. DURATION
4
5
Once a case proceeds to a trial, all of the information that was designated as
6
confidential or maintained pursuant to this protective order becomes public and will
7
8 be presumptively available to all members of the public, including the press, unless
9
compelling reasons supported by specific factual findings to proceed otherwise are
10
made to the trial judge in advance of the trial. See Kamakana v. City and County of
11
12 Honolulu, 447 F.3d 1172, 1180–81 (9th Cir. 2006) (distinguishing “good cause”
13
showing for sealing documents produced in discovery from “compelling reasons”
14
standard when merits-related documents are part of court record). Accordingly, the
15
16 terms of this protective order do not extend beyond the commencement of the trial.
17
5. DESIGNATING PROTECTED MATERIAL
18
19 5.1 Exercise of Restraint and Care in Designating Material for Protection.
20
Each Party or Non-Party that designates information or items for protection
21
under this Order must take care to limit any such designation to specific material that
22
23 qualifies under the appropriate standards. The Designating Party must designate for
24
protection only those parts of material, documents, items, or oral or written
25
communications that qualify so that other portions of the material, documents, items,
26
27 or communications for which protection is not warranted are not swept unjustifiably
28
2
Mass, indiscriminate, or routinized designations are prohibited. Designations
3
that are shown to be clearly unjustified or that have been made for an improper
4
5 purpose (e.g., to unnecessarily encumber the case development process or to impose
6
unnecessary expenses and burdens on other parties) may expose the Designating
7
Party to sanctions.
8
9 If it comes to a Designating Party’s attention that information or items that it
10
designated for protection do not qualify for protection, that Designating Party must
11
12 promptly notify all other Parties that it is withdrawing the inapplicable designation.
13 5.2 Manner and Timing of Designations. Except as otherwise provided in
14
this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
15
16 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
17 under this Order must be clearly so designated before the material is disclosed or
18
produced.
19
20 Designation in conformity with this Order requires:
21
(a) for information in documentary form (e.g., paper or electronic
22
documents, but excluding transcripts of depositions or other pretrial or trial
23
24 proceedings), that the Producing Party affix, at a minimum, the legend
25
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
26
contains protected material. If only a portion or portions of the material on a page
27
28 qualifies for protection, the Producing Party also must clearly identify the protected
2
A Party or Non-Party that makes original documents available for inspection
3
need not designate them for protection until after the inspecting Party has indicated
4
5 which documents it would like copied and produced. During the inspection and
6
before the designation, all of the material made available for inspection shall be
7
deemed “CONFIDENTIAL.” After the inspecting Party has identified the
8
9 documents it wants copied and produced, the Producing Party must determine which
10
documents, or portions thereof, qualify for protection under this Order. Then, before
11
12 producing the specified documents, the Producing Party must affix the
13 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
14
portion or portions of the material on a page qualifies for protection, the Producing
15
16 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
17 markings in the margins).
18
(b) for testimony given in depositions that the Designating Party identify
19
20 the Disclosure or Discovery Material on the record, before the close of the deposition
21 all protected testimony.
22
(c) for information produced in some form other than documentary and for
23
24 any other tangible items, that the Producing Party affix in a prominent place on the
25
exterior of the container or containers in which the information is stored the legend
26
“CONFIDENTIAL.” If only a portion or portions of the information warrants
27
28 protection, the Producing Party, to the extent practicable, shall identify the protected
2
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
3
failure to designate qualified information or items does not, standing alone, waive
4
5 the Designating Party’s right to secure protection under this Order for such material.
6
Upon timely correction of a designation, the Receiving Party must make reasonable
7
efforts to assure that the material is treated in accordance with the provisions of this
8
9 Order.
10
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
11
12 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
13
designation of confidentiality at any time that is consistent with the Court’s
14
Scheduling Order.
15
16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
17
resolution process under Local Rule 37.1 et seq.
18
6.3 The burden of persuasion in any such challenge proceeding shall be on
19
20 the Designating Party. Frivolous challenges, and those made for an improper purpose
21
(e.g., to harass or impose unnecessary expenses and burdens on other parties) may
22
expose the Challenging Party to sanctions. Unless the Designating Party has waived
23
24 or withdrawn the confidentiality designation, all parties shall continue to afford the
25
material in question the level of protection to which it is entitled under the Producing
26
Party’s designation until the Court rules on the challenge.
27
28 ///
2
7.1 Basic Principles. A Receiving Party may use Protected Material that is
3
4 disclosed or produced by another Party or by a Non-Party in connection with this
5
Action only for prosecuting, defending, or attempting to settle this Action. Such
6
Protected Material may be disclosed only to the categories of persons and under the
7
8 conditions described in this Order. When the Action has been terminated, a
9
Receiving Party must comply with the provisions of section 13 below (FINAL
10
DISPOSITION).
11
12 Protected Material must be stored and maintained by a Receiving Party at a
13
location and in a secure manner that ensures that access is limited to the persons
14
authorized under this Order.
15
16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
17
otherwise ordered by the court or permitted in writing by the Designating Party, a
18
Receiving Party may disclose any information or item designated
19
20 “CONFIDENTIAL” only to:
21
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well
22
as employees of said Outside Counsel of Record to whom it is reasonably necessary
23
24 to disclose the information for this Action;
25
(b) the officers, directors, and employees (including House Counsel) of the
26
Receiving Party to whom disclosure is reasonably necessary for this Action;
27
28 (c) Experts (as defined in this Order) of the Receiving Party to whom
2
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
3
(d) the court and its personnel;
4
5 (e) court reporters and their staff;
6
(f) professional jury or trial consultants, mock jurors, and Professional
7
Vendors to whom disclosure is reasonably necessary for this Action and who have
8
9 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
10
(g) the author or recipient of a document containing the information or a
11
12 custodian or other person who otherwise possessed or knew the information;
13 (h) during their depositions, witnesses ,and attorneys for witnesses, in the
14
Action to whom disclosure is reasonably necessary provided: (1) the deposing party
15
16 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
17 not be permitted to keep any confidential information unless they sign the
18
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
19
20 agreed by the Designating Party or ordered by the court. Pages of transcribed
21 deposition testimony or exhibits to depositions that reveal Protected Material may
22
be separately bound by the court reporter and may not be disclosed to anyone except
23
24 as permitted 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.
27
28
2
IN OTHER LITIGATION.
3
4 If a Party is served with a subpoena or a court order issued in other litigation
5
that compels disclosure of any information or items designated in this Action as
6
“CONFIDENTIAL,” that Party must:
7
8 (a) promptly notify in writing the Designating Party. Such notification shall
9
include a copy of the subpoena or court order;
10
11 (b) promptly notify in writing the party who caused the subpoena or order
12 to issue in the other litigation that some or all of the material covered by the subpoena
13
or order is subject to this Protective Order. Such notification shall include a copy of
14
15 this Stipulated Protective Order; and
16
(c) cooperate with respect to all reasonable procedures sought to be pursued
17
by the Designating Party whose Protected Material may be affected.
18
19 If the Designating Party timely seeks a protective order, the Party served
20
with the subpoena or court order shall not produce any information designated in this
21
action as “CONFIDENTIAL” before a determination by the court from which the
22
23 subpoena or order issued, unless the Party has obtained the Designating Party’s
24
permission. The Designating Party shall bear the burden and expense of seeking
25
protection in that court of its confidential material and nothing in these provisions
26
27 should be construed as authorizing or encouraging a Receiving Party in this Action
28
to disobey a lawful directive from another court.
2
BE PRODUCED IN THIS LITIGATION
3
4 (a) The terms of this Order are applicable to information produced by a
5
Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
6
produced by Non-Parties in connection with this litigation is protected by the
7
8 remedies and relief provided by this Order. Nothing in these provisions should be
9
construed as prohibiting a Non-Party from seeking additional protections.
10
(b) In the event that a Party is required, by a valid discovery request, to
11
12 produce a Non-Party’s confidential information in its possession, and the Party is
13
subject to an agreement with the Non-Party not to produce the Non-Party’s
14
confidential information, then the Party shall:
15
16
(1) promptly notify in writing the Requesting Party and the Non-Party
17
that some or all of the information requested is subject to a confidentiality agreement
18
19 with a Non-Party;
20
(2) promptly provide the Non-Party with a copy of the Stipulated
21
Protective Order in this Action, the relevant discovery request(s), and a reasonably
22
23 specific description of the information requested; and
24
(3) make the information requested available for inspection by the
25
Non-Party, if requested.
26
27 (c) If the Non-Party fails to seek a protective order from this court within
28
14 days of receiving the notice and accompanying information, the Receiving Party
2
request. If the Non-Party timely seeks a protective order, the Receiving Party shall
3
not produce any information in its possession or control that is subject to the
4
5 confidentiality agreement with the Non-Party before a determination by the court.
6
Absent a court order to the contrary, the Non-Party shall bear the burden and expense
7
of seeking protection in this court of its Protected Material.
8
9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
10
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
11
12 Protected Material to any person or in any circumstance not authorized under this
13
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
14
writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
15
16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
17
persons to whom unauthorized disclosures were made of all the terms of this Order,
18
and (d) request such person or persons to execute the “Acknowledgment and
19
20 Agreement to Be Bound” that is attached hereto as Exhibit A.
21
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
22
23 PROTECTED MATERIAL
24
When a Producing Party gives notice to Receiving Parties that certain
25
inadvertently produced material is subject to a claim of privilege or other protection,
26
27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
28
2
may be established in an e-discovery order that provides for production without prior
3
privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
4
5 parties reach an agreement on the effect of disclosure of a communication or
6
information covered by the attorney-client privilege or work product protection, the
7
parties may incorporate their agreement in the stipulated protective order submitted
8
9 to the court.
10
12. MISCELLANEOUS
11
12 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
13
person to seek its modification by the Court in the future.
14
12.2 Right to Assert Other Objections. By stipulating to the entry of this
15
16 Protective Order no Party waives any right it otherwise would have to object to
17
disclosing or producing any information or item on any ground not addressed in this
18
Stipulated Protective Order. Similarly, no Party waives any right to object on any
19
20 ground to use in evidence of any of the material covered by this Protective Order.
21
12.3 Filing Protected Material. A Party that seeks to file under seal any
22
Protected Material must comply with Civil Local Rule 79-5. Protected Material may
23
24 only be filed under seal pursuant to a court order authorizing the sealing of the
25
specific Protected Material at issue. If a Party's request to file Protected Material
26
under seal is denied by the court, then the Receiving Party may file the information
27
28 in the public record unless otherwise instructed by the court.
2
After the final disposition of this Action, as defined in paragraph 4, within 60
3
4 days of a written request by the Designating Party, each Receiving Party must return
5
all Protected Material to the Producing Party or destroy such material. As used in
6
this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
7
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
10
Party must submit a written certification to the Producing Party (and, if not the same
11
12 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
13
(by category, where appropriate) all the Protected Material that was returned or
14
destroyed and (2)affirms that the Receiving Party has not retained any copies,
15
16 abstracts, compilations, summaries or any other format reproducing or capturing any
17
of the Protected Material. Notwithstanding this provision, Counsel are entitled to
18
retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
19
20 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
21
reports, attorney work product, and consultant and expert work product, even if such
22
materials contain Protected Material. Any such archival copies that contain or
23
24 constitute Protected Material remain subject to this Protective Order as set forth in
25
Section 4 (DURATION). This provision shall not apply to the parties who are
26
entitled to the juvenile case file as defined in Welfare and Institution Code §
27
28 827(a)(1)(A-T).
1/114. Any violation of this Order may be punished by any and all appropriate
2
measures including, without limitation, contempt proceedings and/or monetary
3
4 || Sanctions.
> || IT SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
7 DATED: March 13, 2025 /s/ Robert Powell
3 Attorneys for Plaintiffs
9
0 DATED: March 13, 2025 /s/ Vincent Contreras
“4 Attorneys for Defendants, County of Los Angeles
49 and its social workers
8 20 13
DATED: March 13, 2025 /s/ Sasha Lazarevich
8 45 Attorneys for Defendants City of Los Angeles and
3 16 its police officers
a
“18
3 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED
99 || DATED: 3/25/2025
21
22
23 || Honorable Margo A. Rocconi
24 || United States Magistrate Judge
25
26
27
28
18
QRTTPTT ATED PROTRCTIVE ORDER
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, ________________________ [print or type full
4 name], of _________________ [print or type full address], declare under
5 penalty of perjury under the laws of the United States of America that I have read
6 in its entirety and understand the Stipulated Protective Order that was issued by the
7 United States District Court for the Central District of California on [date] in the
8 case of Luis Enrique Aguilera Angeles et al v. County of Los Angeles, et al Case
9 No.: 2:23-cv-00875-FMO-MAR. I agree to comply with and to be bound by all the
10 terms of this Stipulated Protective Order and I understand and acknowledge that
11 failure to so comply could expose me to sanctions and punishment in the nature of
12 contempt. I solemnly promise that I will not disclose in any manner any information
13 or item that is subject to this Stipulated Protective Order to any person or entity
14 except in strict compliance with the provisions of this Order. I further agree to
15 submit to the jurisdiction of the United States District Court for the Central District
16 of California for the purpose of enforcing the terms of this Stipulated Protective
17 Order, even if such enforcement proceedings occur after termination of this action.
18 I hereby appoint ________________________ [print or type full name] of
19 _________ [print or type full address and telephone number] as my California
20 agent for service of process in connection with this action or any proceedings
21 related to enforcement of this Stipulated Protective Order.
22 Date: __________________________
23 City and State where sworn and signed: _____________________________
24 Printed name: ____________________________________
25 Signature: ________________________________
26
27
28