even stipulated protective orders 16 require good cause showing
How later courts described this case
- even stipulated protective orders 16 require good cause showing
Written by the judges who cited it.
The opinion
1
UNITED STATES DISTRICT COURT
2
CENTRAL DISTRICT OF CALIFORNIA
3
4 GS HOLISTIC, LLC,
Case No.: 2:24-cv-08060 CV
5
Plaintiff(s), (SSCx)
6
v. [DISCOVERY MATTER]
7
ONE STOP VAPE, et al. STIPULATED PROTECTIVE
8 ORDER1
9 Defendant(s).
10
11
12
1. INTRODUCTION
13
1.1 Purposes and Limitations. Discovery in this action is likely to
14
involve production of confidential, proprietary, or private information for
15
which special protection from public disclosure and from use for any
16
17 purpose other than prosecuting this litigation may be warranted.
18 Accordingly, the parties hereby stipulate to and petition the court to enter
19 the following Stipulated Protective Order. The parties acknowledge that
20 this Order does not confer blanket protections on all disclosures or
21 responses to discovery and that the protection it affords from public
22 disclosure and use extends only to the limited information or items that
23 are entitled to confidential treatment under the applicable legal
24 principles.
25
26
27
1 This Stipulated Protective Order is substantially based on the model
protective order provided under Magistrate Judge Stephanie S.
1 1.2 Good Cause Statement.
2 This action is likely to involve trade secrets, and other valuable
3 development, commercial, financial, technical and/or proprietary
4 information for which special protection from public disclosure and from
5 use for any purpose other than prosecution of this action is warranted. The
6 Plaintiff contends that disclosure of trade secrets, technical and/or
7 proprietary information, including design specifications, and counterfeit
8
identification criteria, will result in significant and irreparable harm such
9
as a loss of ability to enforce intellectual property rights and irreparable
10
harm to good and brand reputation as a result thereof. Such confidential
11
and proprietary materials and information consist of, among other things,
12
business or financial information, information regarding product
13
development and manufacturing, counterfeit identification guides, or
14
other commercial information (including information implicating privacy
15
rights of third parties), information otherwise generally unavailable to the
16
public, or which may be privileged or otherwise protected from disclosure
17
under state or federal statutes, court rules, case decisions, or common law.
18
Accordingly, to expedite the flow of information, to facilitate the prompt
19
resolution of disputes over confidentiality of discovery materials, to
20
adequately protect information the parties are entitled to keep
21
22 confidential, to ensure that the parties are permitted reasonable necessary
23 uses of such material in preparation for and in the conduct of trial, to
24 address their handling at the end of the litigation, and serve the ends of
25 justice, a protective order for such information is justified in this matter.
26 It is the intent of the parties that information will not be designated as
27 confidential for tactical reasons and that nothing be so designated without
1 manner, and there is good cause why it should not be part of the public
2 record of this case.
3 1.3 Acknowledgment of Procedure for Filing Under Seal. The
4 parties further acknowledge, as set forth in Section 12.3, below, that this
5 Stipulated Protective Order does not entitle them to file confidential
6 information under seal; Local Rule 79-5 sets forth the procedures that
7 must be followed and the standards that will be applied when a party
8
seeks permission from the court to file material under seal.
9
There is a strong presumption that the public has a right of access
10
to judicial proceedings and records in civil cases. In connection with non-
11
dispositive motions, good cause must be shown to support a filing under
12
seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176
13
(9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307
14
F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., Inc.,
15
187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
16
require good cause showing), and a specific showing of good cause or
17
compelling reasons with proper evidentiary support and legal
18
justification, must be made with respect to Protected Material that a
19
party seeks to file under seal. The parties’ mere designation of Disclosure
20
or Discovery Material as CONFIDENTIAL does not—without the
21
22 submission of competent evidence by declaration, establishing that the
23 material sought to be filed under seal qualifies as confidential, privileged,
24 or otherwise protectable—constitute good cause.
25 Further, if a party requests sealing related to a dispositive motion
26 or trial, then compelling reasons, not only good cause, for the sealing must
27 be shown, and the relief sought shall be narrowly tailored to serve the
1 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of information,
2 document, or thing sought to be filed or introduced under seal in
3 connection with a dispositive motion or trial, the party seeking protection
4 must articulate compelling reasons, supported by specific facts and legal
5 justification, for the requested sealing order. Again, competent evidence
6 supporting the application to file documents under seal must be provided
7 by declaration.
8
Any document that is not confidential, privileged, or otherwise
9
protectable in its entirety will not be filed under seal if the confidential
10
portions can be redacted. If documents can be redacted, then a redacted
11
version for public viewing, omitting only the confidential, privileged, or
12
otherwise protectable portions of the document, shall be filed. Any
13
application that seeks to file documents under seal in their entirety
14
should include an explanation of why redaction is not feasible.
15
16
2. DEFINITIONS
17
18 2.1 Action: this pending federal lawsuit.
19 2.2 Challenging Party: a Party or Non-Party that challenges the
20 designation of information or items under this Order.
21 2.3 “CONFIDENTIAL” Information or Items: information
22 (regardless of how it is generated, stored or maintained) or tangible
23 things that qualify for protection under Rule 26(c) of the Federal Rules of
24 Civil Procedure, and as specified above in the Good Cause Statement.
25 2.4 Counsel: Outside Counsel of Record and House Counsel (as
26 well as their support staff).
27
2.5 Designating Party: a Party or Non-Party that designates
1 information or items that it produces in disclosures or in responses to
2 discovery as “CONFIDENTIAL.”
3 2.6 Disclosure or Discovery Material: all items or information,
4 regardless of the medium or manner in which it is generated, stored, or
5 maintained (including, among other things, testimony, transcripts, and
6 tangible things), that are produced or generated in disclosures or
7 responses to discovery in this matter.
8
2.7 Expert: a person with specialized knowledge or experience in a
9
matter pertinent to the litigation who has been retained by a Party or its
10
counsel to serve as an expert witness or as a consultant in this Action.
11
2.8 Final Disposition: the later of (1) dismissal of all claims and
12
defenses in this Action, with or without prejudice; and (2) final judgment
13
herein after the completion and exhaustion of all appeals, rehearings,
14
remands, trials, or reviews of this Action, including the time limits for
15
filing any motions or applications for extension of time pursuant to
16
applicable law.
17
2.9 In-House Counsel: attorneys who are employees of a party to
18
this Action. In-House Counsel does not include Outside Counsel of Record
19
or any other outside counsel.
20
2.10 Non-Party: any natural person, partnership, corporation,
21
22 association, or other legal entity not named as a Party to this action.
23 2.11 Outside Counsel of Record: attorneys who are not employees of
24 a party to this Action but are retained to represent or advise a party to
25 this Action and have appeared in this Action on behalf of that party or are
26 affiliated with a law firm which has appeared on behalf of that party, and
27 includes support staff.
1 directors, employees, consultants, retained experts, and Outside Counsel
2 of Record (and their support staffs).
3 2.13 Producing Party: a Party or Non-Party that produces
4 Disclosure or Discovery Material in this Action.
5 2.14 Professional Vendors: persons or entities that provide
6 litigation- support services (e.g., photocopying, videotaping, translating,
7 preparing exhibits or demonstrations, and organizing, storing, or
8
retrieving data in any form or medium) and their employees and
9
subcontractors.
10
2.15 Protected Material: any Disclosure or Discovery Material that
11
is designated as “CONFIDENTIAL”
12
2.16 Receiving Party: a Party that receives Disclosure or Discovery
13
Material from a Producing Party.
14
15
3. SCOPE
16
The protections conferred by this Stipulation and Order cover not
17
18 only Protected Material (as defined above), but also (1) any information
19 copied or extracted from Protected Material; (2) all copies, excerpts,
20 summaries, or compilations of Protected Material; and (3) any testimony,
21 conversations, or presentations by Parties or their Counsel that might
22 reveal Protected Material.
23 Any use of Protected Material at trial shall be governed by the
24 orders of the trial judge. This Stipulated Protective Order does not
25 govern the use of Protected Material at trial.
26
27
1 4. TRIAL AND DURATION
2 The terms of this Stipulated Protective Order apply through Final
3 Disposition of the Action.
4
Once a case proceeds to trial, information that was designated as
5
CONFIDENTIAL or maintained pursuant to this Stipulated Protective
6
Order and used or introduced as an exhibit at trial becomes public and
7
will be presumptively available to all members of the public, including
8
the press, unless compelling reasons supported by specific factual
9
findings to proceed otherwise are made to the trial judge in advance of
10
the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good
11
cause” showing for sealing documents produced in discovery from
12
“compelling reasons” standard when merits-related documents are part
13
14 of court record). Accordingly, for such materials, the terms of this
15 Stipulated Protective Order do not extend beyond the commencement of
16 the trial.
17 Even after Final Disposition of this litigation, the confidentiality
18 obligations imposed by this Stipulated Protective Order shall remain in
19 effect until a Designating Party agrees otherwise in writing or a court
20 order otherwise directs.
21
22 5. DESIGNATING PROTECTED MATERIAL
23
5.1 Exercise of Restraint and Care in Designating Material for
24
Protection. Each Party or Non-Party that designates information or items
25
for protection under this Order must take care to limit any such
26
designation to specific material that qualifies under the appropriate
27
1 those parts of material, documents, items, or oral or written
2 communications that qualify so that other portions of the material,
3 documents, items, or communications for which protection is not
4 warranted are not swept unjustifiably within the ambit of this Order.
5 Mass, indiscriminate, or routinized designations are prohibited.
6 Designations that are shown to be clearly unjustified or that have been
7 made for an improper purpose (e.g., to unnecessarily encumber the case
8
development process or to impose unnecessary expenses and burdens on
9
other parties) may expose the Designating Party to sanctions.
10
If it comes to a Designating Party’s attention that information or
11
items that it designated for protection do not qualify for protection, that
12
Designating Party must promptly notify all other Parties that it is
13
withdrawing the inapplicable designation.
14
5.2 Manner and Timing of Designations. Except as otherwise
15
provided in this Stipulated Protective Order (see, e.g., second paragraph of
16
section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or
17
18 Discovery Material that qualifies for protection under this Stipulated
19 Protective Order must be clearly so designated before the material is
20 disclosed or produced.
21 Designation in conformity with this Stipulated Protective Order
22 requires:
23 (a) for information in documentary form (e.g., paper or electronic
24 documents, but excluding transcripts of depositions or other pretrial or
25 trial proceedings), that the Producing Party affix at a minimum, the
26
legend “CONFIDENTIAL” to each page that contains protected material.
27
If only a portion or portions of the material on a page qualifies for
1 protection, the Producing Party also must clearly identify the protected
2 portion(s) (e.g., by making appropriate 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
5 inspecting Party has indicated which documents it would like copied and
6 produced. During the inspection and before the designation, all of the
7 material made available for inspection shall be deemed
8
CONFIDENTIAL. After the inspecting Party has identified the
9
documents it wants copied and produced, the Producing Party must
10
determine which documents, or portions thereof, qualify for protection
11
under this Stipulated Protective Order. Then, before producing the
12
specified documents, the Producing Party must affix the
13
“CONFIDENTIAL” legend to each page that contains Protected Material.
14
If only a portion or portions of the material on a page qualifies for
15
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
18
identify the Disclosure or Discovery Material on the record, before the
19
close of the deposition all protected testimony.
20
(c) for information produced in some form other than
21
22 documentary and for any other tangible items, that the Producing Party
23 affix in a prominent place on the exterior of the container or containers in
24 which the information is stored the “CONFIDENTIAL” legend. If only a
25 portion or portions of the information warrants protection, the Producing
26 Party, to the extent practicable, shall identify the protected portion(s).
27
5.3 Inadvertent Failures to Designate. If timely corrected, an
1 inadvertent failure to designate qualified information or items does not,
2 standing alone, waive the Designating Party’s right to secure protection
3 under this Order for such material. Upon timely correction of a
4 designation, the Receiving Party must make reasonable efforts to assure
5 that the material is treated in accordance with the provisions of this
6 Stipulated Protective Order.
7
8
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
9
6.1 Timing of Challenges. Any Party or Non-Party may challenge
10
a designation of confidentiality at any time that is consistent with the
11
court’s Scheduling Order.
12
6.2 Meet and Confer. The Challenging Party shall initiate the
13
dispute resolution process under Local Rule 37.1 et seq. and with Section
14
2 of Judge Christensen’s Civil Procedures titled “Brief Pre-Discovery
15
Motion Conference.”2
16
6.3 The burden of persuasion in any such challenge proceeding
17
18 shall be on the Designating Party. Frivolous challenges, and those made
19 for an improper purpose (e.g., to harass or impose unnecessary expenses
20 and burdens on other parties) may expose the Challenging Party to
21 sanctions. Unless the Designating Party has waived or withdrawn the
22 confidentiality designation, all parties shall continue to afford the
23 material in question the level of protection to which it is entitled under
24 the Producing Party’s designation until the court rules on the challenge.
25
26
27
2 Judge Christensen’s Procedures are available at
1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected
3 Material that is disclosed or produced by another Party or by a Non-Party
4
in connection with this Action only for prosecuting, defending, or
5
attempting to settle this Action. Such Protected Material may be
6
disclosed only to the categories of persons and under the conditions
7
described in this Order. When the Action reaches a Final Disposition, a
8
Receiving Party must comply with the provisions of section 13 below.
9
Protected Material must be stored and maintained by a Receiving
10
Party at a location and in a secure manner that ensures that access is
11
limited to the persons authorized under this Stipulated Protective Order.
12
7.2 Disclosure of “CONFIDENTIAL” Information or Items.
13
Unless otherwise ordered by the court or permitted in writing by the
14
Designating Party, a Receiving Party may disclose any information or
15
item designated “CONFIDENTIAL” only:
16
(a) to the Receiving Party’s Outside Counsel of Record in this
17
18 Action, as well as employees of said Outside Counsel of Record to whom
19 it is reasonably necessary to disclose the information for this Action;
20 (b) to the officers, directors, and employees (including House
21 Counsel) of the Receiving Party to whom disclosure is reasonably
22 necessary for this Action;
23 (c) to Experts (as defined in this Order) of the Receiving Party to
24 whom disclosure is reasonably necessary for this Action and who have
25 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
26 (d) to the court and its personnel;
27
(e) to court reporters and their staff;
1 (f) to professional jury or trial consultants, mock jurors, and
2 Professional Vendors to whom disclosure is reasonably necessary for this
3 Action and who have signed the “Acknowledgment and Agreement to Be
4 Bound” (Exhibit A);
5 (g) to the author or recipient of a document containing the
6 information or a custodian or other person who otherwise possessed or
7 knew the information;
8
(h) during their depositions, to witnesses, and attorneys for
9
witnesses, in the Action to whom disclosure is reasonably necessary,
10
provided: (1) the deposing party requests that the witness sign the
11
“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
12
witness will not be permitted to keep any confidential information unless
13
they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
14
unless otherwise agreed by the Designating Party or ordered by the court.
15
Pages of transcribed deposition testimony or exhibits to depositions that
16
reveal Protected Material may be separately bound by the court reporter
17
and may not be disclosed to anyone except as permitted under this
18
Stipulated Protective Order; and
19
(i) to any mediator or settlement officer, and their supporting
20
personnel, mutually agreed upon by any of the parties engaged in
21
22 settlement discussions.
23
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
24
PRODUCED IN OTHER LITIGATION
25
26 If a Party is served with a subpoena or a court order issued in other
27 litigation that compels disclosure of any information or items designated
1 (a) promptly notify in writing the Designating Party. Such
2 notification shall include a copy of the subpoena or court order;
3 (b) promptly notify in writing the party who caused the subpoena
4 or order to issue in the other litigation that some or all of the material
5 covered by the subpoena or order is subject to this Protective Order. Such
6 notification shall include a copy of this Stipulated Protective Order; and
7 (c) cooperate with respect to all reasonable procedures sought to
8
be pursued by the Designating Party whose Protected Material may be
9
affected.
10
If the Designating Party timely seeks a protective order, the
11
Party served with the subpoena or court order shall not produce any
12
information designated in this action as “CONFIDENTIAL” before a
13
determination by the court from which the subpoena or order issued,
14
unless the Party has obtained the Designating Party’s permission. The
15
Designating Party shall bear the burden and expense of seeking
16
protection in that court of its confidential material and nothing in these
17
provisions should be construed as authorizing or encouraging a Receiving
18
Party in this Action to disobey a lawful directive from another court.
19
20
21 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
22 PRODUCED IN THIS LITIGATION
23 9.1 Application. The terms of this Stipulated Protective Order are
24 applicable to information produced by a Non-Party in this Action and
25 designated as “CONFIDENTIAL.” Such information produced by Non-
26 Parties in connection with this litigation is protected by the remedies and
27 relief provided by this Order. Nothing in these provisions should be
1 9.2 Notification. In the event that a Party is required, by a valid
2 discovery request, to produce a Non-Party’s confidential information in its
3 possession, and the Party is subject to an agreement with the Non-Party
4 not to produce the Non-Party’s confidential information, then the Party
5 shall:
6 (a) promptly notify in writing the Requesting Party and the Non-
7 Party that some or all of the information requested is subject to a
8
confidentiality agreement with a Non-Party;
9
(b) make the information requested available for inspection by
10
the Non-Party, if requested.
11
9.3 Conditions of Production. If the Non-Party fails to seek a
12
protective order from this court within 14 days of receiving the notice and
13
accompanying information, the Receiving Party may produce the Non-
14
Party’s confidential information responsive to the discovery request. If the
15
Non-Party timely seeks a protective order, the Receiving Party shall not
16
produce any information in its possession or control that is subject to the
17
confidentiality agreement with the Non-Party before a determination by
18
the court. Absent a court order to the contrary, the Non-Party shall bear
19
the burden and expense of seeking protection in this court of its Protected
20
Material.
21
22
23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
24 MATERIAL
25 If a Receiving Party learns that, by inadvertence or otherwise, it
26
has disclosed Protected Material to any person or in any circumstance not
27
authorized under this Stipulated Protective Order, the Receiving Party
1 must immediately (a) notify in writing the Designating Party of the
2 unauthorized disclosures, (b) use its best efforts to retrieve all
3 unauthorized copies of the Protected Material, (c) inform the person or
4 persons to whom unauthorized disclosures were made of all the terms of
5 this Order, and (d) request such person or persons to execute the
6 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
7
8
11. INADVERTENT PRODUCTION OF PRIVILEGED OR
9
OTHERWISE PROTECTED MATERIAL
10
When a Producing Party gives notice to Receiving Parties that
11
certain inadvertently produced material is subject to a claim of privilege
12
or other protection, the obligations of the Receiving Parties are those set
13
14 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
15 provision is not intended to modify whatever procedure may be
16 established in an e-discovery order that provides for production without
17 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
18 Rules of Evidence, insofar as the parties reach an agreement on the effect
19 of disclosure of a communication or information covered by the attorney-
20 client privilege or work product protection, the parties may incorporate
21 their agreement in the stipulated protective order submitted to the court.
22
23
12. MISCELLANEOUS
24
12.1 Right to Further Relief. Nothing in this Stipulated Protective
25
Order abridges the right of any person to seek its modification by the
26
court in the future.
27
1 of this Stipulated Protective Order no Party waives any right it otherwise
2 would have to object to disclosing or producing any information or item
3 on any ground not addressed in this Stipulated Protective Order.
4 Similarly, no Party waives any right to object on any ground to use in
5 evidence of any of the material covered by this Stipulated Protective
6 Order.
7 12.3 Filing Protected Material. A Party that seeks to file under
8
seal any Protected Material must comply with Local Rule 79-5. Protected
9
Material may only be filed under seal pursuant to a court order
10
authorizing the sealing of the specific Protected Material at issue. If a
11
Party's request to file Protected Material under seal is denied by the
12
court, then the Receiving Party may file the information in the public
13
record unless otherwise instructed by the court.
14
15
13. FINAL DISPOSITION
16
After the Final Disposition of this Action, as defined in paragraph
17
18 4, within 60 days of a written request by the Designating Party, each
19 Receiving Party must return all Protected Material to the Producing
20 Party or destroy such material. As used in this subdivision, “all Protected
21 Material” includes all copies, abstracts, compilations, summaries, and
22 any other format reproducing or capturing any of the Protected Material.
23 Whether the Protected Material is returned or destroyed, the Receiving
24 Party must submit a written certification to the Producing Party (and, if
25 not the same person or entity, to the Designating Party) by the 60 day
26 deadline that (1) identifies (by category, where appropriate) all the
27
Protected Material that was returned or destroyed and (2) affirms that
1 the Receiving Party has not retained any copies, abstracts, compilations,
2 summaries or any other format reproducing or capturing any of the
3 Protected Material. Notwithstanding this provision, Counsel is entitled
4 to retain an archival copy of all pleadings, motion papers, trial,
5 deposition, and hearing transcripts, legal memoranda, correspondence,
6 deposition and trial exhibits, expert reports, attorney work product, and
7 consultant and expert work product, even if such materials contain
8
Protected Material. Any such archival copies that contain or constitute
9
Protected Material remain subject to this Protective Order as set forth in
10
Section 4.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
1 || 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished
3 || by any and all appropriate measures including, without limitation,
4 || contempt proceedings and/or monetary sanctions.
5
6 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
| DATED: May 20, 2025 __/s/ David L. Perry II
9 David L. Perry II, Esquire
10 Tomas Carlos Leon, Esquire
Attorneys for Plaintiff
1]
12
3 DATED: May 20, 2025 /s/ Marcus F. Chaney
14 Marcus F. Chaney
Attorney(s) for Defendant(s)
15
16
|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
|| DATED: May 22, 2025
“0 STEPHANIE 8S. CHRISTENSEN
21 United States Magistrate Judge
22
23
24
25
26
27
28
1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3
I, ________________________________ [print or type full name],
4
of ________________________________________________________ [print
5
or type full address], declare under penalty of perjury that I have read
6
in its entirety and understand the Stipulated Protective Order that was
7
issued by the United States District Court for the Central District of
8
California on May ___, 2025 in the case of GS Holistic, LLC v. One Stop
9
Vape, Case No.: 2:24-cv-08060 CV (SSCx). I agree to comply with and
10
to be bound by all the terms of this Stipulated Protective Order and I
11
understand and acknowledge that failure to so comply could expose me
12
to sanctions and punishment in the nature of contempt. I solemnly
13
14 promise that I will not disclose in any manner any information or item
15 that is subject to this Stipulated Protective Order to any person or entity
16 except in strict compliance with the provisions of this Order.
17 I further agree to submit to the jurisdiction of the United States
18 District Court for the Central District of California for the purpose of
19 enforcing the terms of this Stipulated Protective Order, even if such
20 enforcement proceedings occur after termination of this action. I hereby
21 appoint ___________________________________________________
22 [print or type full name] of
23
__________________________________________________________________
24
[print or type full address and telephone number] as
25
26
27
1 my California agent for service of process in connection with this action
2 or any proceedings related to enforcement of this Stipulated Protective
3 Order.
4
5 Date: ___________________________
6 City and State where sworn and
7 signed: ___________________________
8
Printed name: ___________________________
9
Signature: ___________________________
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27